- Alma Media > Tietosuoja > Data Privacy 2019
Privacy at Alma Media
Privacy notice
We at Alma Media Group (“Alma”) value your privacy and strive to provide you with a safe and secure user experience. At the same time, we want to understand your needs and interests and create content that interests you. By collecting data from various sources and using it innovatively, we can provide added value to both our service users and our advertising customers. In this privacy notice, we explain in more detail how the companies belonging to the Alma Media Group collect and use personal data.
We provide services primarily through our business areas. Alma’s business areas are: Alma News Media, Alma Marketplaces and Alma Career. The companies belonging to each business area are considered as joint controllers together with Alma Media Oyj (1944757-4).
The companies belonging to the Alma Media Group are:
- Alma Media Oyj (1944757-4)
- Alma Media Finland Oy (business ID 0869288-1)
- Etua Oy (business ID 2167036-1)
- Netwheels Oy (business ID 1578348-2)
- Alma Career Oy (business ID 1482646-0)
When you use any website, product or service provided by one of the above-mentioned companies, the above-listed companies belonging to the same business area are joint controllers of your data. The products and services of Alma may be found here. More information on the roles of Alma’s different companies can be found in the section “How and when does Alma act as a joint controller” of this privacy notice.
We ask you to familiarize yourself with this privacy notice. The purpose of this privacy notice is to meet the requirements of the EU General Data Protection Regulation and other applicable data protection legislation and to compile Alma’s data protection information.
We follow the industry’s self-regulatory principles. Alma participates in IAB Europe’s self-regulatory principles for transparency and consent (Transparency & Consent Framework) and adheres to its definitions and rules. Alma uses a TCF compliant consent management mechanism (Consent Management Platform, CMP).
Please note that our services may contain links to external sites. Search engines index our web pages, which means that the content of our pages (including any personal data published on them) may appear in search results. We cannot control these sites, and this privacy notice does not apply to these external sites. We recommend using discretion when browsing the internet and reading the privacy policy of each site separately.
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What types of personal data we process?
We have both consumers and businesses as our customers. In addition to processing personal data of consumers customers, we process personal data of potential consumer customers and representatives or employees of our business customers and potential business customers.
The types of personal data we process include personally identifiable data, observed data collected with cookies and other similar techniques, location data, questionnaire and panel data and derived data which is inferred from the data listed above.
In addition, at Alma Insights we process variety of business, personal and real estate data.
We may combine observed data with other personal data relating to you and enrich observed data with the data provided by you. We process personal data only to the extent needed to fulfil the defined purposes of use.
All our operations do not require that we process data that could be used to identify you personally. If we can fulfil our legitimate business purposes by using data that cannot be used to identify you personally, we process data, e.g. in product development, in aggregated and anonymous form.
We typically process the following personal data:
- Basic information, such as forename and last name, address, phone number, email address;
- Demographic information, such as country of residence, marital status, gender, language, income level and information related to property, title or profession, information related to employer;
- Information related to customer relationship, such as requests for quotas made in or with the help of our services, orders and purchases from Alma or from third parties offering services through Alma’s services, different stages and events from purchase process, information and images on ads published and on the target of ad, customer number, information related to billing and debt collection (method of payment, details of means of payment, social security number in credit transactions), contacts and reclamations and recordings of customer service telephone calls, security camera or chatbots. If you use paid services, we may save with your consent encrypted information about your credit card to a trusted third party service in order to enable future payments. We ourselves save only the type of credit card, expiration date and the four last digits of the credit card. If payment is made through internet payment systems, we save generic ID that is used to allocate payments. If payment is made through net bank, we save the reference number and ID of the bank;
- Other information related to the use of services, such as usernames and passwords, screen names, searches and comparisons made through the services, targeted benefits and campaigns, information on whether you have opened newsletters and marketing messages and the following actions you have made, content you have created or related to you (e.g. content and communication produced in social media sites related to the data controller), sign-in services used (e.g. Facebook Connect) and information on which sign-in services the user account is attached to;
- Information related to choices and interests, such as direct marketing consents and opt-outs;
- Comments and reviews given by you in our services provided that those comments and reviews are given under your name or screen name which can be associated with you personally. Please note that if you leave comments or reviews by using outside sign-in services (such as Facebook Connect), your profile information is visible to other users in connection with your comments and reviews. Comments and reviews are not, however, used for any other purposes that to enable the comment and review feature.
Personally identifiable information related to business customers:
- Basic information, such as forename and last name, address, phone number, email address;
- Information related to employer, such as name of the employer, business-ID, area of operations and contact details;
- Information related to tasks and position, such as area of responsibility and board membership;
- Information related to customer relationship, such as orders, products and services of the company offered through Alma’s services and use and manage rights related to the services, billing information, contacts and reclamations;
- Information related to the use of the services, such as user names and passwords, information on whether you have opened newsletters and marketing messages and the following actions you have made;
- Information related to choices and interests, such as direct marketing consents and opt-outs, information on interests.
Information related to potential customers:
We typically process the following information about our potential customers, such as persons likely to be interested in our services and persons who have previously been our customers: name, contact details, age, gender, mother tongue, title or profession and other information, such as segment that the data subject belongs to. We also process the following data of the representative of our potential business customer: information related to the tasks of the person, such as title or area of responsibility within the company.
Information observed via cookies and other similar techniques:
We automatically collect information about how you use Alma’s websites and mobile applications (e.g., visit information such as page address, duration and timing of visit, and which areas of the page you visit (e.g., news/home country), information about the article read, such as article title, subject words, article length and publication date, information related to the use of service features, such as saved articles and interests, search conditions, such as the number of searches made by the user (e.g. In addition, we collect technical information about your terminal device (including IP address, device ID, physical location, browser, operator and operating system type, and associated URLs). The data is automatically collected in server logs or by means of mobile identifiers or applications placed on the user’s terminal device or by means of a JSON object. For more information, see the section below entitled “What are cookies and how are they used?”
Location data:
Location data is defined by using applicable geo and Internet positioning methods. Location data is collected and used primarily when you use application or site of Alma which you have given a consent to provide location based services such as local weather information or location based advertising. Some applications may locate the user’s device also when the user is not actively using the application. This does not, however, mean that Alma would continuously monitor your location but Alma only saves information on certain predefined locations by using so called beacons. Certain services enable you to save important locations, such as home, work, school or stores, to a map. In this case, information is based on information you provide us instead of locating your device.
Questionnaire and panel information:
We may conduct individual questionnaires on our websites or invite you to take part in a more permanent research panel. Typically, the answers are nameless, but we collect different sociodemographic information on the respondent to gain some background information on the answers. We may combine information given by you in questionnaires and data observed via cookies in statistical modelling and broaden the information to apply to a more wider group.
Derived data:
We use the information described above in mathematical models. For example, we target advertising by using a model that assumes that people with similar social-demographic background act similarly.
Business, real estate and personal information:
Through Business Information, Real Estate Information and Personal Data sections of Alma Insights we process and disclose to our customers the following information:
- Business information, such as the position and authority of the person in charge in different companies and organisations, date of birth or social security number of the person in charge (social security number requires a legal purpose of use and a permission from the information provider), contact details, domicile, nationality;
- Real estate information, such as ownership information on real estates (e.g. name, date of birth or social security number, address) and resident information of apartments (e.g. name, apartment number, date of birth, move-in date);
- Personal data, such as name, address, mother tongue, information on trusteeship, information on payment defaults, bans of business operations, debt restructurings, prenuptial agreements, gifts;
- Information on decisionmaker database, such as name, title, company and company’s background information which the person represents (e.g. area of operations, employee amount, net revenue amount), the operative and/or procurement area of responsibility and contact details (visiting and postal address, email address, mobile number).
The information on sections 2 and 3 above as well as information on bankrupt and company reorganisation databases are disclosed only to customers that have a legitimate reason to process the information and are given permission by the information provider.
Sensitive information:
Should you choose to provide us with sensitive information, such as your political affiliation on Uusisuomi.fi -service, we process this information based on your consent. Regarding Alma News Media, we may be given information on your trade union membership from you based on your consent or from your trade union when we are offering services at a discount price to members of the trade unions together with these trade unions.
Sensitive information is always used only to offer the specific service in question and information is not disclosed outside the specific service. If you choose to provide sensitive information where such information is not asked, you will do so at your own risk.
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Where do we obtain personal data?
We receive your information through registration, subscription or other contact. We receive the information either directly from you or, for example, from the party responsible for the group order on your behalf. The data may be observed and derived from the use of the services.
Data may be collected and updated from the registers of the controller and other companies belonging to the Alma Media Group.
In addition, we receive information from registers maintained by the authorities, the credit information and customer disruption register, social media related to our operations, and other reliable registers.
Alma Insights services are provided by various data providers, publicly available sources, and our telephone survey work.
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For what purposes do we use personal data and what is the legal basis of processing?
We process your information based on the following regulatory grounds:
Contract: We process the information you provide us to fulfill the contract for the service or product you have ordered. Some services feature personalized content, which we consider to be part of fulfilling the contract. We cannot make an offer or fulfill a contract, such as deliver a newspaper, enable logging into a digital account, or tailor content to your interests, invoice our services, or contact you for contract-related matters without processing personal data. When collecting data, we try to inform you of which data is mandatory for fulfilling the contract and which you can provide if you wish.
Consent: We may process your information based on your consent (if the law requires us to request consent) to send you direct marketing messages using electronic channels, to disclose your contact information for selected partners’ electronic direct marketing actions, or to provide location-based services. We may also request your consent in situations where the purposes of processing change or we need to process sensitive information, such as information on trade union membership. You can withdraw your consent at any time. Withdrawing consent may affect the availability and functionality of the services. Withdrawing consent does not affect the legality of the processing based on consent before its withdrawal. Please also note that not all direct marketing actions require explicit consent. For example, we may send you an email based on an existing customer relationship to market products or services that belong to the same product category or are otherwise similar to the product or service you have already ordered. We may also send you an email to your work email address based on your position without consent in situations where the marketed product or service is related to your work tasks. In such situations, you always have the right to opt out of direct marketing. In addition, we set cookies and process cookie-observed data mainly based on your consent. The processing of cookies is described in more detail below in the section “What are cookies and how are they used?”.
Legitimate interest: We process personal data within Alma for business and customer service analysis and development, product development and reporting, profiling and modeling, and technical distribution of advertising and content. Our goal is to improve customer understanding and create content and services that better suit your interests. For example, in product development and reporting, data is mainly processed at the group level, and individual data subjects cannot be identified from the reports. Advertising allows us to maintain our advertising-funded services and our role in the essential information dissemination in a democratic society.
We process data to prevent and investigate misuse of services and information security. We occasionally have to examine, for example, service log data or phone call recordings to investigate abuses related to our services or to resolve production problem situations in technology or customer service. We use surveillance cameras for security reasons at our service points.
Alma Insights services offer, for example, comprehensive information on the decision-makers of Finnish companies, so that our corporate customers can update their own customer register information or find those people who are likely to be interested in their products and services. The service enables customers to maintain the currency of their own customer or marketing register in accordance with data protection legislation and to carry out marketing measures on the basis of legitimate interest.
In addition, we may use the information for marketing and opinion research, as well as for marketing by telephone or mail, or for marketing targeted on the basis of work tasks or existing customer relationships.
Sales and customer service calls are recorded to protect the rights of the parties related to the transaction. Calls can also be recorded on the basis of legitimate interest in situations where no customer relationship has been established.
The above-mentioned purposes are in accordance with our legitimate interest, and we believe that you can expect the processing based on the relationship between you and the company belonging to Alma or your work tasks or position. We do not process sensitive information based on legitimate interest. Taking into account the above-mentioned purposes, your reasonable expectations, the nature of the data, our efforts to minimize the processing of identifiable information as much as possible, and the fact that you can object to the processing as described below, we believe that the processing is not in conflict with your fundamental rights or freedoms.
Legal obligation: We may be required to retain some of your personal data to comply with accounting or other mandatory legislation during and after the customer relationship. In this case, the processing is based on compliance with a legal obligation.
Alma as a processor: In certain situations, we act as a processor of personal data in accordance with the instructions of another controller. For example, information provided in the systems produced by companies belonging to Alma Career business area, as well as in various contact forms of services produced by Alma Career, is processed mainly on behalf of real estate agents, car dealers, banks and insurance companies acting as controllers. In certain situations, these data may also be processed for Alma Career’s own purposes, for example, to develop our services and to investigate misuse situations.
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What are cookies and how are they used?
We use cookies to make our services better, to show more relevant advertising and to tailor the content of our services and marketing messages. The purposes of using cookies are described in more detail below.
We strive to develop our services by analyzing their use with various tools. We use e.g. Google Analytics to measure the use of our site. We also use Google Analytics advertising features (remarketing, similar audiences service, Google Display network impression reporting, Google Analytics demographics and topics reporting, and Google Analytics User ID identification features). The information stored in the cookies used by Google’s tools (such as pseudonymized IP addresses) is forwarded and stored on Google’s servers in various parts of the world. As a result, this information may be processed on servers located outside the user’s country of residence. With the information it receives, Google evaluates the user’s way of browsing the content of the pages and compiles summary reports on the use of the site. In addition, Google compiles reports on the services offered in connection with the sites and produces statistics on the use of the Internet. Google may also tailor the content of the ads that users see based on their previous browsing history. Google may also transfer information to third parties if required by law, or in cases where a third party processes the information on Google’s behalf. We also use, for example, the Hotjar tool, which allows us to, for example, build so-called heat maps that show which page elements users click, how they move on the pages and how far they average on the pages. With your consent, we can also record your visit, in which case we see what kind of mouse movements you have made on the page. This helps us solve possible usability problems.
Cookies are also used for advertising purposes. We help our advertisers to target advertising in Alma’s services to users who have, for example, visited the advertiser’s online store and viewed a certain product. Similarly, Alma’s ads can be targeted on third-party services outside the Alma network based on the fact that the user has visited our service.
We may combine behavioral information collected by cookies with personally identifiable information, such as name and email address, but most often we background the observed online behavioral information with demographic information (such as age or location). In this way, we can create different target groups of site users. Target groups consist of information that relates to a group that is expected to behave similarly or have similar characteristics, such as sports enthusiasts (target group based on estimated interest), likely car or new home buyers (target group based on estimated intention), people living in the metropolitan area (target group based on estimated or given geographical location or location information) or 20-30 year olds (target group based on estimated or given age). In targeting advertising, we primarily aim to find target groups of interest to advertisers, not to target advertising to you personally.
First-party cookies are set by the site visible in the address bar or at the request of another party on that site. In addition to these, our services use third-party cookies, such as advertising networks, measurement and tracking service providers, advertising technology providers, and social media services. The processing in connection with social media services is always subject to the data processing terms of the social media service provider in question.
We strive, among other things, by various physical, electronic and contractual means, to ensure that unauthorized parties do not have access to your information and that our contractual partners do not use the information in any way other than as required by the cooperation. Third parties are sought to be bound by applicable law. In digital advertising, we strive to work only with advertising technology providers who are committed to complying with IAB Europe’s self-regulatory guidance on transparency and consent (Transparency and Consent Framework).
We use cookies for different purposes:
Essential cookies: These cookies are necessary for the use of the services and their functions, for example, for logging in or remembering the contents of the shopping cart, and are therefore always enabled. These cookies are also used to provide other services, such as enabling video viewing on our site and remembering the user’s language and font choices.
Storing data on the device and/or accessing data on the device: Alma and suppliers may store data on the device, such as cookies and device identifiers, and use the data for purposes presented to the user. The consent given for this enables the setting of non-essential cookies.
Selecting standard ads: To select standard ads, Alma and suppliers may use real-time data on the context when the ad is displayed, including information on the content and device, such as device type and features, browser information (user-agent), URL address and IP address, use the user’s approximate location data, determine how often ads are shown to the user, determine the order in which ads are shown to the user, prevent the ad from appearing in an inappropriate editorial context (which is not brand safe). Alma and suppliers cannot use this data to form a personalized ad profile for the selection of future ads. Note. Approximate means an inaccurate location with a radius of at least 500 meters.
Forming a personalized ad profile: To form a personalized ad profile, Alma and suppliers may collect user data, such as information on user activity, browsing history of sites or applications, interests, demographic factors or location, to form or modify an ad profile for targeted advertising and combine this data with other data previously collected, including data collected across sites and applications, to form or modify an ad profile for targeted advertising.
Selecting personalized ads: To select personalized ads, Alma and suppliers may select personalized ads based on the user’s ad profile or other user data, such as previous activity, interests, browsing history of sites or applications, location or demographic data.
Forming a personalized content profile: To form a personalized content profile, Alma and suppliers may collect user data, such as information on user activity, interests, browsing history of sites or applications, demographic factors or location, to create or modify a content profile for personalized content and combine this data with other data previously collected, including data collected across sites and applications, to create or modify a content profile for content personalization.
Selecting personalized content: To select personalized content, Alma and suppliers may select personalized content based on the content profile or other user data, such as previous activity, interests, browsing history of sites or applications, location or demographic data.
Measuring advertising and its effectiveness: To measure the effectiveness of advertising, Alma and suppliers may measure whether ads were shown to the user and how, and whether the user responded to them and how, compile reports on advertising and its impact and effectiveness, compile reports on users who responded to advertising using data collected from users’ responses to that advertising, compile reports for publishers on the ads displayed on their sites or applications, measure whether the ad is displayed in a suitable (brand safe) editorial context, determine the percentage of the ad that was possible to see and the duration of that possibility and combine this data with other data previously collected, including data collected across sites and applications. Alma and suppliers cannot use data from audience panels or other similar sources as advertising measurement data without a separate legal basis for using market research to create user understanding.
Measuring content and its effectiveness: To measure the effectiveness of content, Alma and suppliers may measure and report on how content was displayed to the user, and how the user responded to the content, compile reports using directly measurable or known data on users who responded to the content. Alma and suppliers cannot measure whether ads and how they (including native advertising) were shown to the user, and whether the user responded to them and how, using data from audience panels or other similar sources as advertising measurement data without a separate legal basis for using market research to create user understanding.
Applying market research to generate audience insights: By using market research to generate audience insights, Alma and the providers may produce aggregated reports for advertisers or their representatives on the audiences reached by their ads, produce aggregated reports for publishers on the audiences that were shown or interacted with the content and/or ads on their websites and apps, and combine other data about the user (offline data) with online behavior data (online data) for market research purposes to generate audience insights, if the providers have indicated that they match and combine other data about the user with online behavior data. Alma and the providers may not measure the effectiveness of ads that were shown to a specific user or that the user interacted with, unless the provider has a separate legal basis for measuring ad effectiveness or measure what content was shown to a specific user and how they interacted with it, unless the provider has a separate legal basis for measuring content effectiveness.
Product development: For product development purposes, Alma and the providers may use data to improve their existing products with new features or to develop new products and create new mathematical models and algorithms using machine learning. Alma and the providers may not carry out any other data processing that is allowed for another purpose based on this purpose.
Security, fraud prevention and debugging: To ensure security, prevent fraud and debug, Alma and the providers may ensure that data is transmitted securely, detect and prevent malicious, fraudulent, invalid, or unlawful activity, and ensure the proper and efficient functioning of systems and processes, including monitoring and enhancing the performance and efficiency of systems and processes that are used for permitted purposes. Alma and the providers may not carry out any other data processing that is allowed for another purpose based on this purpose. Note. The data that is collected and used to ensure security, prevent fraud and debug may include automatically transmitted device-identifying features, precise location data, and data obtained by actively scanning device features for identification purposes.
Technical delivery of ads or content: For the technical delivery of data and to respond to technical requests, Alma and the providers may use the user’s IP address to technically transmit ads over the internet, transfer the user to the advertiser’s website when the user interacts with the ad, use the user’s IP address to technically transmit content over the internet, transfer the user to the advertiser’s website when the user interacts with the content, and use device type and features information for the technical delivery of ads or content, e.g. to deliver the correct size of ad or video file in a format supported by the device. Alma and the providers may not carry out any other data processing that is allowed for another purpose based on this purpose.
Sharing of Alma Media’s target groups: Alma may share target group or modeling data with selected partners. The partner may combine the target group or modeling data with their own data to reach those groups that are likely to be interested in the products or services offered by the partner. An individual person is not directly identifiable from the data. The data is not stored otherwise than temporarily for the implementation of the campaign.
In carrying out the above purposes, Alma and the provider use the following features:
Combining your other data with your online behavior data: Alma and the providers may combine your other data (offline data) with the collected online behavior data (online data) to support one or more purposes or special features.
Connecting different devices to each other: Alma and the providers may directly or based on probability determine that two or more devices belong to the same user, household, or business, and actively scan the device features for probabilistic identification, if the users have given the providers permission to actively scan the device features for identification.
Using automatically transmitted device data for device identification: Alma and the providers may create an identifier based on data that the device automatically transmits, such as IP address or browser information (user-agent) and use the identifier again to identify the device. Alma and the providers cannot create an identifier for the user using data collected by actively scanning certain device features, such as installed fonts and screen resolution, unless the user has specifically given permission to actively scan the device features for identification or use the identifier again to identify the device.
In addition, the following special features based on your consent are in use:
Use of precise location data: Alma and the suppliers may collect and process precise location data to support one or more purposes. Please note that precise location data means that there are no restrictions on the accuracy of the user’s location; the location can be determined within a few meters. The use of location data also requires that you have given your consent to the use of location data through the consent management mechanism (CMP) and the browser/device location permission settings.
Active scanning of device features for identification purposes: Alma and the suppliers may create an identifier using information collected by actively scanning certain device features, such as installed fonts and screen resolution, and use such an identifier to identify the device again.
Alma sets non-essential cookies with your consent and uses the information collected by cookies for the above-mentioned purposes mainly based on your consent. The use of information collected by cookies for security, abuse prevention and error correction, as well as technical distribution of advertising and content, is based on our legitimate interest.
With your consent, we collect information on the use of the online service for audience measurement purposes, such as: the page from which the user has moved to our service, a unique device and/or cookie identifier, the data collection channel (internet browser, mobile browser, application), browser identifier (user agent), IP address, session time. If you do not give your consent to the collection of personal data, personal identifiers will be removed from the measurement data collected for visitor statistics.
Withdrawing or opposing a legitimate interest does not affect the processing done before such action and we may still use the data at an aggregated level for modeling and business development purposes. However, we will not use the information, for example, to target advertising to you personally. Regardless of whether you give or withdraw your consent, we will show you as much advertising as before, but it will not be selected according to your likely interests.
In addition to Alma, third parties set cookies. The third parties are listed in Alma’s cookie settings under the “Partners” tab. Some of these third parties process information collected by cookies based on a legitimate interest. You can view the processing bases, purposes and features and make choices by partner in Alma’s cookie settings.
Some of our services may use so-called social plugins and embedded content. For example, Facebook’s social plugin buttons or content (e.g. Instagram images embedded in articles) may appear in some of our services, but their content comes directly from Facebook or its owned Instagram service. Facebook may collect information about you and track your interaction with the embedded content as if you were visiting its site directly. In addition, if you want to log in to our services using, for example, a Facebook or Google user ID, the service providers will share your personal information with Alma based on the authorization you have given. The use of external login mechanisms requires the setting of cookies by the service providers on your device, and the cookies may also be used for purposes other than login. Read more about Facebook’s privacy policy and Google’s privacy policy.
This privacy notice, together with the information provided in the cookie settings, constitutes Alma’s cookie policy. Consent management is constantly evolving and updates to the cookie settings are possible. Changes will be notified separately.
Please note that not all of Alma’s sites use all of the above-mentioned purposes, in which case some sites will display a simpler cookie information.
For more information on the impact options, please see below.
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How long do we retain personal data?
We store personal data for at least the duration of the customer relationship and for a reasonable time thereafter. The information is stored, for example, on the basis of the customer relationship, mainly for 48 months after the end of the last contract period or subscription period or the last login to the digital account, so that we can send you offers based on your previous order or purchase history or inferred interests, enable easy reactivation of services, use the information to develop our services and respond to possible complaints.
If you have not used any of the business unit’s services (e.g. by logging in to the service) within a reasonable time, we may send you an email asking you to confirm that the customer relationship is still valid. If confirmation is not received within the deadline set in the message, the customer relationship is deemed to have ended. Before transferring the data to be permanently deleted, we may send you a final reminder message. After that, the old profile can no longer be activated.
About three months after the end of the customer relationship defined by the criteria described above, we will prune unnecessary data and typically transfer information about your name, contact details, age, gender, mother tongue, value or profession, and other identification information, such as target group information, to the marketing register. We process the data for marketing purposes as long as you have not refused to receive marketing messages. If you opt out of marketing, and there is no other basis for processing, we will retain information about the prohibition and contact details to ensure compliance with the prohibition.
Please note that if you have produced content for our services, for example by commenting on a Kauppalehti news item or rating a car repair shop in the Autojerry.fi service, according to the terms of use of our services, we may, if we wish, retain the content you produce, as long as we remove the identifiable information related to it. For example, the texts you publish on discussion forums may remain visible in our services despite your request to delete the data, as long as they can no longer be linked to a specific person. Comments deleted from our services are stored in their original form in a protected database for five years from their publication, for the purpose of investigating possible misuse.
Sales and customer service phone calls are typically stored for 12 months and chat conversations for about three months, unless there is a reason for longer storage.
We typically store web behavior data collected by cookies and other similar technologies for about 24 months, as this time is assumed to describe your interests. Target group information derived from the data, which is linked to customer information, can be stored as long as customer information or marketing register information is stored.
We strive to keep the personal data we hold accurate and up to date by deleting unnecessary data and updating outdated data. However, we encourage you to periodically check the timeliness of your data by logging into the personal information sections of the services. You can also influence the retention time of the data yourself through the choices described below, for example by requesting the deletion of your data.
With regard to the deletion of data related to terminated customer relationships, development and testing work is still partly in progress, which is why we may have data for longer periods of time than described in this description. We aim to update our systems as soon as possible.
We comply with legal obligations to retain data. We may have to retain information on the implementation of the contract for more than 10 years after the end of the customer relationship in order to defend ourselves against legal claims. The 10-year retention period also applies to information that we need to demonstrate that we have implemented the requests of the data subjects in accordance with data protection legislation.
We may collect behavioral data in Alma’s digital services and mobile applications using cookies and other similar technologies (e.g. web beacon tags, pixels and tags, and browser local data storage) (hereinafter collectively “cookies”). A cookie is a small file that is stored on your device and that contains an anonymous, numeric identifier that allows us to identify and count the different browsers that visit our site. Mobile applications also use a similar numeric identifier for cookies. Cookies and other similar technologies do not harm your device or files. They cannot be used to spread viruses, nor do they allow us to access the information on your hard drive. In addition to Alma, third parties also set cookies on Alma’s sites or use similar technologies.
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What choices do data subjects have?
We are committed to providing choice and control over privacy and we are constantly developing more user-friendly ways to influence, so that you can manage your own data through your user account. Below we list different ways you can currently influence the collection and processing of your data:
Reviewing, correcting and deleting data: You have the right to review the personal data stored about you. We ask you to verify your identity in order to exercise your rights. However, the right to access may be restricted by law, the privacy of other individuals and the protection of trade secrets.
Upon request, we will correct, supplement or delete personal data that is incorrect, incomplete or outdated for the purpose of processing.
With regard to Alma Insights services, certain personal data is transmitted directly from official sources, in which case any requests for correction, supplementation or deletion of data must be addressed to the respective authority.
If you have an Alma Account, make your own data review or deletion request using the Alma Account self-service.
If you do not have an Alma Account, you can submit a data review or deletion request by filling out the electronic data request form. Please note that the electronic form is intended only for individuals who do not have an Alma Account in use.
Otherwise, you can make your own data review or deletion request by filling out a form. Please fill in the form carefully according to the instructions. The instructions can be found at the end of the form.
Taking into account the nature of the personal data processed, the verification and integrity of the request submitted to Alma is based primarily on the signature on the document. In addition to a handwritten signature, we also accept an electronic signature.
The purpose of the information requested on the form is not to collect more information about the person exercising their data protection rights, but to try to distinguish the person from other, possibly similarly named, individuals. Because the same person may have provided different information when using Alma’s services, the purpose of the information requested on the form is to identify the person with sufficient accuracy in different information systems.
The information requested on the data request form does not have to be provided, but in this case we may not be able to identify the person with sufficient accuracy and we will execute the data request only on the basis of the information provided. If we cannot sufficiently verify that the data relates to the person in question, the data cannot be disclosed.
Please note that we may retain and use your information if it is necessary to comply with legal obligations, resolve disputes or enforce contracts. Information that we need to demonstrate that we have implemented the requests of data subjects in accordance with data protection legislation, we retain for 10 years. These include, for example, the information provided by the data subject on the data request form, as well as the information provided in the related inquiries and responses.
Insofar as Alma is only a processor of your data, i.e. processes it on behalf of and on behalf of another data controller, your request should be addressed to the data controller acting as such.
Data transfer: You can also have your personal data transferred, which we process automatically based on consent or contract, by contacting our customer service.
Right to object and restrict direct marketing and related profiling: You can opt out of the disclosure and processing of your data for direct marketing purposes at any time by clicking on the link at the end of the marketing message or by contacting our customer service. In some applications, you can opt out of in-app marketing from the app settings.
Right to object and restrict processing: You can object to processing based on legitimate interest on grounds relating to your personal situation. For example, in such a situation, the processing will be restricted for the time it takes to assess the grounds for objecting to the processing. Processing may also be restricted, for example, when the data subject disputes the accuracy of the personal data, in which case the processing will be restricted for the time it takes us to verify the accuracy of the data.
Withdrawal of consent: You can withdraw your consent at any time by contacting our customer service or by other means specifically offered. For example, you can withdraw your consent to the use of your mobile device’s location data at any time from the device, browser, or mobile app settings. You can withdraw your direct marketing consent by clicking on the link at the end of the marketing message or by contacting our customer service. You can withdraw your cookie consent from Alma’s cookie settings.
Right to complain: You can file a complaint with the authority if you consider that your data has been processed in violation of this privacy notice and the applicable law.
Regarding cookies and other technologies, as well as the processing of data collected by them, you can influence the following ways:
Alma’s cookie settings: Alma’s cookie settings allow you to manage your choices related to cookies and the use of data collected by them, for example, to give consent, withdraw consent or object to legitimate interest by purpose or partner. You can find the cookie settings mainly at the bottom of each website or in the application settings.
Blocking cookies: You can block the use of cookies by changing your browser settings. Please note that blocking cookies may affect the functionality of our services. In addition, blocking cookies may affect the price you pay for the service in some situations; for example, in Alma Insights services, you can download the same document from the service multiple times during the same usage session, but we only charge for one search. Without cookies, we cannot track these searches and we charge each search separately.
Clearing cookies or mobile identifier: You can clear cookies or the browser’s local data store from the browser settings or reset the mobile identifier from the device settings. By clearing cookies or the mobile identifier regularly, you can change the identifier based on which a profile is formed of you. Clearing cookies does not stop data collection altogether, but rather resets the profile based on previous behavioral data.
Preventing the use of Google Analytics: You can prevent the use of website data in Google Analytics by installing a browser add-on that prevents the use of Google Analytics. This add-on prevents Google Analytics JavaScript running on websites (e.g. ga.js, analytics.js and dc.js) from sharing website visit information with Google Analytics.
Data processing related to mobile applications: The user has several options to influence the data collected by mobile applications. Often, mobile applications offer the opportunity to manage choices related to the processing of location data, notifications sent by the application, and targeted advertising through the application settings. In some applications, the user can also opt out of sending marketing messages and newsletters, as well as collecting usage data for this purpose. In addition to the application settings, the user can also influence the data collected by the applications through the general settings of the mobile device.
Please note that the choices you make are mainly based on cookies and end when you delete all cookies from your browser. Your choices are also browser-specific, so if you use multiple browsers, remember to make choices on each browser separately. The choices on the mobile device are application and device specific.
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Who processes personal data?
The data is processed by those employees of Alma who have the right to process data to perform their duties. In addition, we use subcontractors to process data, in which case we ensure by contractual arrangements that the data is processed in accordance with the applicable legislation. If we transfer data outside the EU/EEA area, we ensure that the transfer takes place in accordance with the legal safeguards, such as the EU model clauses.
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To whom is the data disclosed?
Alma: We may process your personal data within Alma. In addition to the parent company Alma Media Oyj, the companies that belong to Alma Media Group at any given time are listed at the beginning of this privacy notice.
Alma Insights services: Alma Insights services brings together information from various data providers, such as the following information on decision-makers, property owners and other individuals: name, contact details and advocacy information, payment defaults, business prohibitions, debt arrangements, prenuptial agreements and donations. This information is disclosed to Alma Insights services customers in accordance with the service terms of use. The scope of the information disclosed depends on the industry and purpose of use of the data recipient and generally requires the consent of the data provider. Data providers include various authorities.
Decision-makers database information is disclosed for targeted campaign use and for the continuous maintenance of customers’ own customer and marketing registers. Corporate customers are allowed to use decision-maker information according to their area of responsibility to send information related to the work tasks of the registered person. In addition, we may disclose log data related to the use of Alma Insights services to data providers for monitoring compliance with contracts.
Advertising target groups:
Buying and selling advertising space in real time: Buying and selling advertising space typically takes place automatically and in real time using software. Advertiser customers and their partners use the information collected from Alma’s sites to make a purchase decision on advertising space and to measure campaign results (ad impressions, reach and conversion). According to Alma’s sales terms and conditions, information collected from Alma’s network may not be used for any other purposes or combined with other information, but this must always be agreed separately with us.
Providing advertising target group and modeling information for campaigns: Occasionally, we may conduct short-term campaigns with selected partners, where we give the partner access to target group and modeling information, so that the partner can reach the groups that are likely to be interested in the products or services offered by the partner. In this case, the partner may combine the information with their own information. The duration of the campaign is limited and the combination is mainly done in real time or for a short period of time, so that the partner does not enrich their own customer register with the target group information.
Please note that advertising target groups can be used outside of Alma’s network in such a way that the partner processes Alma’s customers’ information as a processor of personal data. For example, Facebook’s custom audiences are created so that your email address or phone number is used to create an encrypted identifier in the browser, which is compared to Facebook’s encrypted identifiers. This way, advertising can be targeted on Facebook to Alma’s customers or to create target groups that resemble Alma’s customers’ profiles. Alma does not receive information on which identifiers sent to Facebook end up in the final target group and which identifiers do not have a match on Facebook. Facebook, on the other hand, does not receive information from Alma about who is behind the identifier. Facebook is committed to using the target group only for Alma’s advertising. You can influence the custom audiences through Facebook.
Authorities: We may disclose your personal information to competent authorities as required by applicable law. These authorities include, for example, tax, police, enforcement and supervisory authorities.
Research and product development: We may disclose your information for scientific or historical research and product development purposes. The information is mainly converted into a form that no longer identifies the subject of the information.
Corporate arrangements: If we sell, merge or otherwise reorganize our business, your personal information may be disclosed to buyers and their advisors.
Direct marketing and opinion and market research: We may disclose your personal information for consent-based and opt-out direct marketing and opinion and market research, unless you have prohibited it. For example, we may disclose the search criteria you have entered in the marketplace, the contact requests related to certain items and your contact information to selected partners, such as the sellers or brokers of the items you are interested in.
Event partners: The current partners of the free events and training services organized by the companies belonging to Alma group regularly receive the contact information of the persons who have registered for the event or training.
In addition, information on the profile of the persons who have registered for the event or training (e.g. job title and workplace) can be disclosed to the speakers and trainers of the events and trainings for content planning purposes.
Consent: We may disclose your information to third parties if you have consented to it.
Collection and legal claims: We may disclose your personal information to third parties if it is necessary to enforce the contract, collect receivables, investigate possible violations or to prepare, present or defend a legal claim.
Service providers offering their services or otherwise present in the marketplaces: In certain situations, the provision of services and compliance with contracts requires the disclosure of your information. If you have ordered a quote (e.g. a loan quote request from a bank when changing your home) or an actual service (e.g. an inspection time for your car) from a third party through our marketplaces, we will provide the necessary information to the service provider, so that they can provide you with the requested quote or perform the ordered service. Partners may also be provided with the name, email address and item information of the registrant who has purchased additional visibility, in order to find out by email with the registrant how the additional visibility product has worked.
Work community in corporate subscriptions: If the use of the service is based on a subscription made by your employer or another company on your behalf, we may share information about your use of the service with your work community’s contract or billing contacts to the extent necessary for billing purposes, for example.
Disclosure of information: The purpose of certain of our services is to allow users to share information with each other and to enable other users to find information. For this reason, some of the information may be inherently public and accessible to anyone on the internet. In many of our services, you can define the publicity of your information and/or decide for yourself what information you provide about yourself.
Priority of contract terms: If we have agreed by contract terms not to disclose information outside the service, we will primarily comply with the contract terms.
Non-disclosable information: The information of the following services is not disclosed outside the service in any situation: Lawyer Register, State Calendar and dictionary services.
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How is data protected?
We protect personal data by using appropriate technical and organizational safeguards. The databases where the register data are stored are protected by firewalls, passwords and other appropriate technical means. The databases and their backups are located in locked premises. Manually processed documents containing information of the registered persons are stored in locked premises in such a way that unauthorized access to them is prevented. We ensure that only those employees and employees of the companies acting on behalf of the controller have access to the data who need it for the performance of their work tasks. Movement in the work premises is monitored by access permits.
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How and when does Alma act as a joint controller?
We provide services primarily through our business areas. Alma’s business areas are: Alma News Media, Alma Marketplaces and Alma Career. The companies belonging to each business area are considered as joint controllers together with Alma Media Oyj (1944757-4).
The companies belonging to the Alma Media Group are:
- Alma Media Oyj (1944757-4)
- Alma Media Finland Oy (business ID 0869288-1)
- Etua Oy (business ID 2167036-1)
- Netwheels Ltd (business ID 1578348-2)
- Alma Career Oy (business ID 1482646-0)
The joint controllers of Alma inform you about the processing of personal data through this privacy notice. You can contact the customer service of the service you use or use some other opportunities offered to you (for example, click on the link at the end of the email message to withdraw your consent or object to electronic direct marketing). More information in the section “How can you contact us?”
In addition, individual Alma companies act as joint controllers when they maintain a page on Facebook. For visitor data on Alma’s Facebook pages, Facebook and Alma are joint controllers. You can get more information about the processing of personal data from Facebook’s privacy notice. We collect information on, for example, likes and visits to our Facebook pages, the visibility of our publications, and the demographic profiles of the people reached by our publications.
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Can this privacy notice be changed?
We constantly develop our services and we can change this privacy policy without prior notice. The changes may be based on case law, legislative changes or guidelines issued by the authorities. We recommend that you regularly review the privacy policy.
This privacy notice was last updated in September 2024, when Alma renewed its company structure and business areas.
Alma’s new business areas are Alma News Media and Alma Marketplaces.
Alma News Media business area includes Finland’s largest digital news media Iltalehti, the leading financial news media Kauppalehti and Alma’s other journalistic news media.
Alma Marketplaces business area includes marketplaces and systems for housing, offices and mobility, comparison services and services for businesses and professionals. The segment’s most well-known services include Etuovi, Nettiauto, Objektvision and Suomenlaki.com.
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How can you contact us?
If you have any questions regarding Alma’s services, we kindly ask you to contact the customer service of the respective service. Alma’s products and services can be found at https://www.almamedia.fi/en/business-services/.
If your contact is specifically related to this privacy notice, we kindly ask you to send feedback by email to: tietosuoja(at)almamedia.fi or send a letter to the address: Alma Media Oyj, Data Protection/Law, Alvar Aallon katu 3 C, 00100 Helsinki. The data protection officer of the Alma Media Group is Matti Venho.
Updated Updated 1 September 2024
How to use your rights?
If you wish to use the rights described above, please note that requests are reviewed on a case by case basis. Please use this form to use your right of access or deletion. We ask you to verify your identity when using your rights. Please note that we may save and use your personal data if it is necessary to fulfil our legal obligations, to solve disputes or enforce contracts.