Effective from 1 January 2026<\/em><\/p>\n\n\n\n Unless otherwise agreed, these terms and conditions apply to all media sales agreements concerning Alma Media Group’s products and services (including concepts produced by content marketing).<\/p>\n\n\n\n Alma Media Group’s products and services hereinafter refer to all Finnish products and services that operate and appear in print and electronic format and that are owned and represented by Alma Media Corporation and its Group companies (collectively ”Alma” and each separately the ”Publisher”). Such products and services include printed magazines, digital editions, websites and online services, mobile sites and services, applications, newsletters, direct email marketing and other Alma media outlets (”Media”). These terms and conditions do not concern distribution or reader advertisements. With regard to Alma’s online marketplaces, i.e. classified advertising taking place online (e.g. etuovi.com, vuokraovi.com, nettiauto.com, autotalli.com, jobly.fi, urakkamaailma.fi, toimitilat.kauppalehti.fi), these terms and conditions apply to advertisements other than the actual marketplace advertisements. With regard to programmatic advertising, these terms and conditions apply to the extent that the terms and conditions of the marketplace or the market practice do not require otherwise (however, the terms and conditions specified in sections 1, 3, 14\u201324, 25\u201326 and 28\u201330 always apply to agreements made through programmatic buying).<\/p>\n\n\n\n These terms and conditions apply when Alma sells advertising and announcement space and solutions in its Media for advertisements, announcements, images, videos, contact information and other advertising material (”Material”) submitted by advertisers, advertising agencies, media agencies or other advertising service companies or their representatives (”Client”). If an advertisement is submitted on behalf of the advertiser by an advertising or media agency, other advertising service company or a representative of the advertiser, such intermediary is responsible for compliance with all aspects of the agreed terms and conditions as well as these terms and conditions in the same manner as for its own obligations (including responsibility for the content of the Material and for the advertising fee with full liability for any credit losses, i.e. del credere responsibility). The resale of Alma’s advertising and announcement space and solutions is prohibited unless specifically agreed with Alma. With regard to the content of and fees related to joint Material submitted by two or more Clients, the responsibility lies with the Client who placed the order. These terms and conditions also apply to content marketing arrangements where Alma produces the content.<\/p>\n\n\n\n These terms and conditions apply to the publication of individual advertisements as well as campaigns. A campaign refers to a package consisting of advertisements booked at the same time to advertise the same product or service in one or several Media of Alma. Separate campaigns by the same Client shall be regarded as a single campaign if the break between the campaigns is no more than seven (7) days and the same Material and\/or target group has been used. By way of exception, a content marketing campaign shall be regarded as a single campaign even if the Material to be published changes, provided that the campaign is booked at the same time and the same product or service is advertised in one or several Media of Alma.<\/p>\n\n\n\n An agreement to publish the Material submitted by the Client or created for the Client is established once the Client places an order with the Publisher, either in writing or verbally. The Publisher shall seek to send the Client a separate order confirmation for each order. However, the order is binding upon the Client even without confirmation. The order confirmation does not need to be signed or returned, unless otherwise agreed. The Material will be published in the Media specified in the order confirmation or otherwise agreed, in accordance with these terms and conditions and the Publisher’s implementation practices and the special terms and conditions applicable to the Medium in question, as they stand at any given time.<\/p>\n\n\n\n Any terms and conditions of an individual media sales agreement that deviate from these terms and conditions must be agreed in writing. In the event of conflicting terms and conditions, the terms and conditions of the agreement between the parties and\/or the order confirmation shall have first priority (where both exist, the document with the later date shall apply), medium-specific terms and conditions and instructions shall have second priority, and these terms and conditions shall have the lowest priority.<\/p>\n\n\n\n The prices (excl. VAT) for publishing in the Media are specified in any applicable order confirmation, agreement or offer, as well as on the website of the Medium concerned. Prices are also available from the media sales department of each Medium. In the event of conflicting prices, the prices in the agreement between the parties and\/or the order confirmation shall have first priority (where both exist, the document with the later date shall apply), the prices in the offer shall have second priority, and the general price list on the medium-specific website shall have the lowest priority. Special advertising solutions, additional elements and their effect on the price shall always be agreed separately.<\/p>\n\n\n\n The Publisher has the right to amend its price lists at any time. Amendments shall be communicated on the medium-specific websites and in media sales bulletins, where possible. Price increases also apply to advertising bookings made by the Client and unconfirmed offers made by the Publisher in connection therewith, unless the Publisher has separately notified the Client that its offer is binding. The Client has the right to cancel or shorten the entire advertising booking or a part thereof free of charge within six (6) days from the date on which the Client was notified in writing of the price increase.<\/p>\n\n\n\n The prices announced are exclusive of VAT. The Publisher will add to the prices the VAT applicable at any given time, as well as any other taxes and fees relating to publishing operations and advertising and announcement revenues as required by the authorities. These will be specified as separate items on the invoice. The Publisher also has the right to charge a fee for paper invoices.<\/p>\n\n\n\n Cost increases arising from laws, regulations or measures by the authorities will be added to the prices correspondingly from the date on which they come into effect. Such increases also apply to previously placed orders that have not yet been invoiced.<\/p>\n\n\n\n If the advertising copy or other Material requires a larger size than that specified in the order, the advertisement will be published in the size required by the copy or Material and invoiced accordingly. If the advertising copy or other Material requires a smaller size than that specified in the order, the fee charged for the advertisement will be based on the space reserved.<\/p>\n\n\n\n In addition to the stated advertising price, any advertisement production work outside the scope of the agreement will be charged in accordance with a separate price list. Changes made contrary to a draft or advertising copy will be charged based on the time spent on the changes. If the Publisher amends an advertisement in a manner that affects its price, the Publisher must obtain the Client’s approval before making the amendment or, if the Client cannot be reached, notify the Client of the amendment no later than three (3) days after the publication of the advertisement.<\/p>\n\n\n\n The production costs for content marketing articles, videos, photography or podcasts shall always be agreed separately. Production costs do not include any travel costs.<\/p>\n\n\n\n Invoicing shall take place no later than at the end of the campaign. The term of payment for established account clients is fourteen (14) days from the invoice date. Complaints concerning invoices must be submitted within eight (8) days of the invoice date. Late payment interest shall be charged on overdue payments in accordance with the law. In addition, the Publisher is entitled to charge the Client for any collection costs related to overdue payments.<\/p>\n\n\n\n For media sales on credit, the Publisher requires corporate customers to provide their Business ID and private Clients to use strong electronic identification. Credit histories will be checked for all new Clients. If requested, the Client must provide the Publisher with collateral. Payment defaults will be handled on a case-by-case basis. In the event of payment defaults, the Publisher has the right to decline to publish the Material without the Client being entitled to any refund.<\/p>\n\n\n\n Cash clients must pay the amount to a bank account specified by the Publisher no later than three (3) days before the publication date. Proof of payment must be submitted to the Publisher by email or other agreed means.<\/p>\n\n\n\n The Publisher reserves the right to amend the terms of payment.<\/p>\n\n\n\n Alma grants discounts on various grounds. Discounts are mutually exclusive, unless otherwise agreed between the parties. The order in which multiple discounts may be applied varies by Medium.<\/p>\n\n\n\n An agreement entitling the Client to a discount must be concluded before the commencement of advertising covered by the agreement. Advertising carried out prior to the conclusion of the discount agreement shall not be included in the agreement total and the discount shall not be applied to such advertising. The agreement must specify the Media to which it applies.<\/p>\n\n\n\n The agreement total includes advertising in all Media specified in the agreement (excluding marketplace visibility), any fees for additional work, content marketing assignments, and net invoicing relating to the Media specified in the agreement submitted through an advertising or media agency. Performance-based advertising, programmatic advertising or data services shall not be included in the agreement total, unless otherwise agreed. The net agreement total refers to the total invoiced amount exclusive of VAT, taking into account all discounts, media agency reimbursements and commissions relating to programmatic buying (if programmatic buying is agreed to be included in the agreement total).<\/p>\n\n\n\n The agreement total determines the discount percentage, which in turn determines the final price payable by the Client. The discount percentage shall not be applied to all purchases that accumulate the agreement total.<\/p>\n\n\n\n The agreement total and discount tables are Client-specific and do not apply to other companies within the Client’s group of companies. However, they may be applied to companies in which the Client holds a majority interest (more than fifty per cent), provided that such companies are specified in the agreement concluded with the Client. Discounts are calculated separately for print and electronic Media in accordance with separate tables.<\/p>\n\n\n\n The discount only applies to advertisements submitted or conveyed through the Media specified in the agreement. If the Client fails to comply with the terms and conditions of the agreement, the Publisher reserves the right to recover the discount granted. Media sales discounts never apply to content marketing productions, reader advertisements or actual marketplace visibility. Furthermore, discounts are not granted for fees for additional services, performance-based advertising, programmatic advertising or data services.<\/p>\n\n\n\n The Publisher grants a discount of 10\u201335% on advertising intended to promote the awareness of a cause or ideology, or the related awareness of the advertiser or a person’s public image (ideological and societal advertising), including election advertising. Media agency or direct client discounts are also taken into account. Advertising must not contain sponsored logos. The discount does not apply to business, recruitment, real estate or similar administrative advertisements placed by societal entities.<\/p>\n\n\n\n Societal advertising:<\/p>\n\n\n\n Media agency discounts calculated on gross prices may be granted to media agencies that have concluded an agreement with Alma. In such cases, the media agency is responsible for the content of the Material and for the advertising fee. Other operational and qualitative criteria for the discount:<\/p>\n\n\n\n Advertising space must be reserved before the publication date. Eeach Medium has its own reservation schedule for print adverttising. For digital campaigns, a preliminary reservation is valid for 14 days, after which the inventory is released automatically if the reservation has not been confirmed. If a reservation is made less than five (5) days before the start of the campaign, the Publisher will no longer accept preliminary reservations and the reservation must be made as a confirmed booking.<\/p>\n\n\n\n For content marketing reservations, the reservation schedule for advertising space follows either the digital campaign or print campaign schedule, depending on the publication channel. Confirmation must be made no later than five (5) business days before publication so that any released space can be offered elsewhere. Content to be delivered in final form or for editing must be submitted five (5) business days before publication. If the Publisher produces the content, the order must be placed fourteen (14) days before the desired publication date.<\/p>\n\n\n\n A Programmatic Guaranteed campaign is reserved using Alma’s Deal ID and the reservation is always binding. The purchase and billing of Programmatic Guaranteed campaigns are conducted through programmatic buying systems. Alma reserves the right to separately invoice for any ad impressions reserved for the Programmatic Guaranteed campaign that remain unpurchased. Any post-campaign invoicing is based on reports from Alma’s advertising management systems.<\/p>\n\n\n\n Cancellations of confirmed print campaigns must be made no later than the reservation date of the publication. Cancellations of specific placement advertisements must be made at least fourteen (14) days before the publication date. Cancellations of insert reservations must be made at least twenty-one (21) days before the publication date.<\/p>\n\n\n\n Cancellations made after the last possible cancellation date will incur a charge of 50% of the net price. In a force majeure situation, cancellations must always be made in writing; in such cases, the costs incurred by preparatory work will be invoiced.<\/p>\n\n\n\n If customer-specific special terms have been agreed for specific placement reservations, a cancellation of the campaign will incur a charge of 100% of the net price.<\/p>\n\n\n\n The above cancellation terms apply to the distribution of content marketing campaigns. If the Client cancels, the production cost will be invoiced in full and the Client will receive the content for its own use in accordance with these terms and conditions.<\/p>\n\n\n\n The Publisher reserves the right to relocate or cancel a campaign, advertising space or advertising impression without liability for compensation if warranted by special circumstances. The Publisher will notify the Client of such changes without delay and shall seek to provide new equivalent advertising space or impressions in place of those altered or cancelled.<\/p>\n\n\n\n All Material for print campaigns must be submitted in accordance with the medium-specific material submission schedule and instructions. All Material for digital campaigns must be submitted no later than two (2) business days before the start of the campaign and, for special solutions, no later than five (5) business days before the start of the campaign, in accordance with the medium-specific material instructions.<\/p>\n\n\n\n If Material is not submitted in accordance with the instructions, is delayed, is technically non-functional, is questionable in terms of content, or is too similar in appearance to the editorial content of the Medium, the Publisher cannot guarantee that the advertisement will be published or that the campaign will begin at the desired time. In such cases, the campaign visibility will be reduced proportionately to the delay in the delivery of the Material.<\/p>\n\n\n\n If the Publisher does not have Material meeting the instructions at the required time but nevertheless decides to publish the advertisement, the Publisher shall not be liable for any deficiencies in the appearance of the advertisement. In such cases, the Publisher may also place the advertisement in a location other than that agreed.<\/p>\n\n\n\n The Publisher shall not be liable for any damage arising from the omission of an erroneous advertisement or from the publication of an advertisement on a date other than the agreed publication date due to deficient Material.<\/p>\n\n\n\n The Publisher cannot guarantee that a report can be generated for a digital campaign if the Material is submitted late or in deficient form.<\/p>\n\n\n\n In the situations described above, invoicing will be at 100% even if the visibility of the advertisement or campaign is limited, the appearance is deficient or the advertisement is placed in a location other than that agreed. If the Material is submitted after the announced material submission deadline, a late submission surcharge in accordance with the medium-specific price list will be charged. In addition, the costs of any correction work relating to the Material will be charged. If the Publisher is required to make amendments or corrections to the submitted Material, the work will be charged in accordance with the medium-specific price list.<\/p>\n\n\n\n If the Material causes technical problems during a digital campaign in one or more of Alma’s Media, the Publisher has the right to replace it with a GIF version or remove the advertisement entirely from the Medium.<\/p>\n\n\n\n The Client has the right, upon request, to receive a proof of a print advertisement being produced, provided that the Material has been submitted within the material submission schedule.<\/p>\n\n\n\n Media visibility shall be valid for the agreed period but no longer than one (1) calendar year. A content marketing article published online shall also remain accessible online for one (1) calendar year from its publication date, unless otherwise agreed.<\/p>\n\n\n\n Digital advertisements shall be placed in their designated positions by 10:00 a.m. on the first day of the media period, unless otherwise agreed. Weekly online campaigns run from Monday to Sunday, unless otherwise agreed.<\/p>\n\n\n\n When making a reservation for a digital campaign, the number of advertisements to be included in the campaign and the desired rotation schedule must be specified. The Publisher will carry out one change per campaign free of charge.<\/p>\n\n\n\n Alma sells impression-based, time-based and click-based digital campaigns. Campaigns are verified using Alma’s advertising management systems or analytics.<\/p>\n\n\n\n Display guarantee for impression-based campaigns: If the total number of impressions for the campaign is lower than 95% of the number of impressions purchased, either the campaign will be continued until the required number of impressions is reached or the missing impressions will be credited to the Client as advertising impressions in their next campaign. If the number of impressions falls less than five (5) per cent below the target, no compensation for missing impressions will be made. If the Client’s Material is submitted late, Alma shall not be liable for the fulfilment of the display guarantee.<\/p>\n\n\n\n If the Client wishes to remove or relocate a campaign during the campaign period due to, for example, current news content, the Publisher shall primarily seek to move the campaign to another section of the Medium in question, subject to availability. Moving the campaign to another section is free of charge, but the display guarantee for the digital campaign will cease to apply and the campaign will be moved to a section with available space. If the Client wishes to remove the campaign entirely from the relevant Medium during the campaign period, the Publisher will charge 100% of the campaign value in accordance with the cancellation terms.<\/p>\n\n\n\n For campaigns purchased as packages, Alma does not guarantee visibility in all Media specified in the package. Campaigns purchased directly for a specific target medium take precedence over campaigns purchased as packages, and package advertisements will be published in those target media within the package where space is available.<\/p>\n\n\n\n The Client grants the Publisher the right to use and, if necessary, make changes to the Material in order to publish it in the Media specified in the order confirmation or otherwise agreed. Material submitted to the Publisher by the Client will not be returned. If the Material is produced using a third-party tool (by the Client, its representative or the Publisher), the Material will not be delivered to the Client but will remain in the relevant system.<\/p>\n\n\n\n The Publisher holds the right of ownership and all rights to the Media it publishes and any part thereof. These rights include, among other things, copyright to software and to databases compiled from the Clients’ Material. The Client’s advertisements will become part of the Publisher’s databases without separate compensation. The advertisements may, as part of such databases, be published when the databases are published. For the avoidance of doubt, the Publisher always has the right to use the Material as part of those media contents in which the Material has been published or displayed (so-called archive use). Unless the Client has notified the Publisher otherwise in writing at the latest at the time of delivery of the Material to the Publisher, the Publisher also has the right, following the first publication or display, to transfer the Material to a storage platform of its choice and to use it in demonstration, training and research compilations as well as on its own internet and extranet pages. The Publisher does not have the right to use the Material for commercial purposes in other media.<\/p>\n\n\n\n The Publisher grants the Client the rights of use described below in relation to Material produced by the Publisher for the Client. The Publisher holds the right of ownership and copyright to Material it produces for the Client, such as the original advertisement, and the Client is not entitled to transfer the rights received from the Publisher to a third party or otherwise exploit the Material produced by the Publisher in comparable products or services of third parties without the Publisher’s prior written consent. The Client has the right to publish Material produced by Alma for the Client in Alma’s media channels, the Client’s social media and the Client’s own websites. Unless otherwise agreed, the Client does not have the right to publish Material produced by the Publisher for the Client in other commercial channels. Publication of the Material for marketing purposes elsewhere requires the Publisher’s prior consent, in which case a surcharge of +50% will be added to the production price.<\/p>\n\n\n\n The Client may use, for the purpose of use described above, any photograph or video published in connection with an article that has been photographed or produced by the Publisher. Unpublished photographs or videos taken or produced by the Publisher are subject to a fee, and if the Client wishes to acquire the right to use them, this must be agreed before the date of photography or production. If a stock image has been used in the Material, the Publisher has no right to further transfer the rights to such image, and the Publisher accepts no responsibility for any use of the image outside the Publisher’s media.<\/p>\n\n\n\n The Client is not entitled to use the brands of Alma’s Media in its own marketing unless specifically agreed with Alma.<\/p>\n\n\n\n The Client is responsible for ensuring that the Material submitted to the Publisher does not violate applicable laws, orders issued by authorities and advertising self-regulatory bodies, instructions provided by the Publisher, these terms and conditions, other contractual terms and conditions or good practice. The Client undertakes to take account of restrictions concerning, among other things, political advertising, advertising targeting minors, and advertising for the following categories: alcohol, tobacco, gambling, pharmaceuticals, counterfeit goods and pirated products. In respect of firearms, only advertisements for safety-enhancing parts or equivalent products are considered to comply with good practice.<\/p>\n\n\n\n The Client must notify the Publisher if its advertisement constitutes a political advertisement or advertising campaign within the meaning of Regulation (EU) 2024\/900 on the transparency and targeting of political advertising, and must provide the information required by the Regulation in the manner and form required by the Publisher. The Client is also responsible for including the mandatory information required by the Regulation in the advertisement. The Client is responsible for the completeness, accuracy and currency of the information provided and undertakes to notify the Publisher of any changes and to correct any identified errors or omissions without delay.<\/p>\n\n\n\n The Publisher has the right, without any obligation to refund payments or pay other compensation, to refuse to display an advertisement or to discontinue its display if the information provided by the Client is, in the Publisher’s interpretation, in conflict with the above-mentioned requirements or is incorrect, or if any identified errors or omissions cannot be rectified without undue delay.<\/p>\n\n\n\n The Client is responsible for securing the rights of ownership and\/or rights of use in the Material it submits, and for ensuring that the display of the Material does not infringe the copyright, patent or other intellectual property rights or any other rights of any person. The Client is responsible for all costs arising from the acquisition or exercise of the aforementioned rights (including Teosto fees). The Client is liable for all damages and related claims arising from the infringement or absence of copyright, patent, other intellectual property rights or other rights in connection with the Material it submits. The Publisher must bring such claims to the attention of the Client, after which the Client shall bear sole responsibility for responding to such claims and their consequences.<\/p>\n\n\n\n The Client is responsible for ensuring that the Material it submits, the systems it uses or the advertising tags it uses do not cause technical damage or disruption to the network, Alma, other clients or the users of the Media. The Client is obliged to compensate for any damage caused by the Material it submits, its systems or its advertising tags. The Publisher has the right to take necessary measures and use electronic tools of its choice to ensure that the Material complies with the Material instructions and does not contain prohibited content or functionalities.<\/p>\n\n\n\n What is stated in this section regarding the Client’s liability in respect of Material submitted by the Client also applies to Material produced by the Publisher for the Client, if the Client has used the Material in breach of these terms and conditions.<\/p>\n\n\n\n The Publisher shall not be liable to the Client or any third party for any costs or damage incurred by the Client or a third party as a result of a breach of the terms and conditions set out in this section. For the avoidance of doubt, the Publisher is responsible for ensuring that it has the right to grant the Client a licence to use the Material it has produced for the Client, in accordance with section 14.<\/p>\n\n\n\n The Publisher reserves the right to decline to approve the Client’s advertisement if the Client, the Material or the campaign fails to meet the requirements applicable to the advertising space. The Media may have certain client-specific restrictions.<\/p>\n\n\n\n The Publisher has the right to amend the range, content, operation and descriptions of the services it offers. The Client is not entitled to compensation on the grounds described herein.<\/p>\n\n\n\n The Publisher is entitled to place advertisements by competing companies in the same section of a Medium without prior notice. Due to the confidential nature of client relationships and the limited availability of advertising space, the Publisher cannot provide advance information about competitors’ campaigns. No refunds will be made in the event of overlapping campaigns.<\/p>\n\n\n\n The privacy and user experience of the users of the Media are of paramount importance to Alma. In this context, the Client is also responsible for the systems it uses and for the activities of its representatives and subcontractors as if they were its own. The Client must ensure that its cooperation partners are aware of and comply with the restrictions set out in these terms and conditions.<\/p>\n\n\n\n The parties undertake to comply, in all cooperation involving the processing of personal data \u2013 including in connection with advertisements, target pages of advertisements and the use of advertising targeting technologies \u2013 with applicable EU and national legislation on the processing of personal data and privacy protection, such as the General Data Protection Regulation (EU) 2016\/679 (”Data Protection Legislation”), as well as the self-regulatory principles of IAB Europe applicable from time to time, such as the Transparency and Consent Framework, and to take the necessary measures to implement such principles. The Publisher will request consent from the users of the Media 1) for the use of cookies and other similar technologies, and, to the extent possible, also for the cookies used by the Client’s advertising systems, in the Publisher’s Media, and 2) for the purposes of use approved by the Publisher.<\/p>\n\n\n\n Unless expressly otherwise agreed, the terms and conditions of this section 18.1 apply to all agreements between Alma and the Client to the extent that they involve the processing of personal data by Alma on behalf of the Client acting as data controller, or the processing of personal data by the Client on behalf of Alma acting as data controller. The data controller is the party that determines the purposes and means of the processing of personal data. The data processor is the party that processes personal data on behalf of the data controller. Depending on the nature of the cooperation, a party may simultaneously be the data controller in respect of certain data and the data processor in respect of certain other data.<\/p>\n\n\n\n The subject matter, nature and purpose of the processing of personal data, as well as the types of personal data and the categories of data subjects, shall be described in the agreement between the parties or in written instructions issued by the data controller before the processing of personal data commences. Unless otherwise agreed, in relation to digital advertising the purpose of processing is to target the Client’s advertising campaign in Alma’s Media. If the Client and the Publisher have agreed that the Publisher will model personal data submitted by the Client using personal data held by the Publisher, the purpose of processing is the modelling of personal data. The duration of processing is limited to the storage period necessary for the agreed campaign or modelling.<\/p>\n\n\n\n Unless otherwise agreed, controllership is determined based on the origin of the personal data. To the extent that the data categories used for targeting or submitted to the Publisher for modelling consist of data relating to the use of the Client’s digital services or data from the Client’s customer or marketing register (including group identifiers submitted by the Client), the Client acts as the data controller. The categories of data subjects are then users, customers and potential customers of the Client’s digital services. Alma acts as the data controller to the extent that the data relates to the use of Alma’s digital services (including advertising impressions) or originates from Alma’s customer or marketing register, including advertising target groups formed on that basis. The category of data subjects then consists of users, customers and potential customers of Alma’s digital services. In addition, third-party data may be used in advertising. In such cases, the party whose advertising benefits from the data is responsible for the compliance of the third-party data and the related agreements.<\/p>\n\n\n\n The Client does not have the right to use browser fingerprinting or similar tracking technologies when advertising in the Publisher’s network. Without the data controller’s prior written consent, the data processor is not entitled to use cookies or other similar technologies to collect, for any purpose, data concerning the media, their users or users’ terminal devices from the data controller’s media (including, without limitation, for the purpose of determining users’ interests or targeting digital advertising to such terminal devices other than in connection with the agreed campaign). Without a separate agreement and compensation, data collected from Alma’s Media may not be used for advertising targeting outside Alma’s Media. However, the Client is entitled to use cookies and other similar technologies to measure the results of its campaign (advertising impressions, reach and conversion). Even in such cases, data collected from the campaign may not be disclosed to third parties, such as ad exchange service providers, or combined with any other data. The Publisher has the right to carry out audits of cookie practices in the Media within the Publisher’s network. If an audit reveals that the Client (or its cooperation partner and\/or any third party otherwise authorised by the Client) is acting in breach of these terms and conditions, the Publisher will notify the Client, whereupon the Client must immediately rectify its practices. In addition, the Publisher has the right, in the manner described below, to immediately discontinue the campaign in connection with which these terms and conditions have been breached, as well as all other campaigns of the Client in any Medium, and to terminate all agreements between the Client and Publishers within the Alma Group without liability for compensation.<\/p>\n\n\n\n The data controller is responsible for having a lawful basis for the processing of the personal data it collects and for having the right to transfer such personal data to the data processor for processing. If the Publisher and the Client have agreed on the modelling of personal data submitted by the Client, the Client is responsible for ensuring that the data can be combined in the manner required by the modelling (the Client must have a lawful basis for processing in relation to the modelling and must ensure that data subjects are informed in accordance with the Data Protection Legislation). The data controller is also responsible for complying with the obligations imposed on data controllers under the Data Protection Legislation and ensuring that the written instructions given to the data processor comply with the Data Protection Legislation. The parties undertake not to transfer to the other party for processing any information considered sensitive (special categories of personal data within the meaning of Article 9 of the General Data Protection Regulation).<\/p>\n\n\n\n The data processor undertakes to:<\/p>\n\n\n\n The Publisher has the right to charge for the implementation of the measures described in points (f)\u2013(g) and (j)\u2013(l) above in accordance with the then-current price list.<\/p>\n\n\n\n The data controller hereby grants the data processor general advance authorisation to engage another data processor. The data processor is responsible for the work of the subprocessors it engages as if it were its own. The data controller has the right to object to the use of a specific subprocessor, in which case the data processor shall take commercially reasonable measures to replace that subprocessor. If such a change cannot be made, the parties shall have the right to terminate the cooperation without liability for compensation. Termination of the agreement does not release the Client from its payment obligation in respect of actions taken prior to termination. Alma’s subprocessors are listed in Appendix 1 to these terms and conditions.<\/p>\n\n\n\n The data controller accepts that the implementation of the agreed measures may require the transfer of personal data outside the EU\/EEA area. The data processor undertakes to ensure that any transfer outside the EU\/EEA area is effected using legal transfer mechanisms as described in the Data Protection Legislation, such as the European Commission’s standard contractual clauses.<\/p>\n\n\n\n If either party breaches the terms and conditions set out herein, the other party has the right to immediately discontinue the campaign in connection with which the breach occurred, as well as all other campaigns of the Client in any Medium, and to terminate all agreements between the Client and Publishers within the Alma Group without liability for compensation. If the termination is caused by the Client, the Client is obliged to pay the full price for the campaign.<\/p>\n\n\n\n Each party is liable to the other party for direct damages (including administrative fines imposed by authorities, compensation paid to data subjects and reasonable legal costs) that arise directly from that party having processed personal data in breach of these terms and conditions or the obligations under the Data Protection Legislation. Neither party shall be liable for loss of profit or other indirect damages.<\/p>\n\n\n\n The Client undertakes, upon the conclusion of a campaign, to remove any retargeting advertising tags referring to Alma’s systems that have been used in the campaign. If the removal of the advertising tags is delayed due to a reason attributable to the Client, the Client shall pay the Publisher a delay penalty of EUR 10,000 for each commenced week of delay.<\/p>\n\n\n\n The terms and conditions of this section 18.1 shall remain in force for as long as the data processor processes personal data of data subjects on behalf of the data controller.<\/p>\n\n\n\n This section 18.2 sets out the terms and conditions for the disclosure of personal data controlled by the Publisher for the purposes of selected Clients’ campaigns or other purposes of processing. Unless expressly otherwise agreed, the terms of this section apply where the Client specifically acquires target groups from Alma either directly or through programmatic advertising. The agreement on the disclosure of target groups is formed when the Client makes a purchase either directly or through its media buying system (DSP). To the extent that the cooperation requires the disclosure of personal data from the Publisher to the Client, each party acts as an independent data controller and is independently responsible for the lawfulness of its operations and for the existence of a lawful basis for processing.<\/p>\n\n\n\n Data used in the campaign: The Publisher grants the Client, i.e. the advertiser or a media or advertising agency or other cooperation partner carrying out the advertiser’s media buying, access to target group data relating to the users of the Publisher’s digital services. A target group, or segment, describes a group assessed to consist of users with certain interest areas. Users are identified by an identifier linked to an individual or to a device or browser used by that individual, which cannot as such be linked to any specific person. In addition to behavioural data from the Publisher’s websites, demographic data provided by the user and\/or statistically modelled demographic data may be combined with the identifier. In modelling, the Publisher uses its own data to model audiences equivalent to the Client’s personal data groups and makes these available to the Client for use in advertising. The target group data described above is hereinafter referred to as ”Alma Target Groups”.<\/p>\n\n\n\n Purpose of processing: The Client, i.e. the advertiser or a media or advertising agency or other partner carrying out the advertiser’s media buying, may use Alma Target Groups in order to combine the identifiers associated with the Alma Target Groups with the advertiser’s data, such as the identifiers of visitors to the advertiser’s website, for the purpose of targeting advertising to specific users within the Publisher’s network or on other websites through its media buying systems. Alma Target Groups may be used for targeted advertising in other networks only where this has been expressly agreed. Alma Target Groups may not be stored in other systems, such as the advertiser’s customer register. Alma Target Groups may not be used for any other purpose (e.g. further modelling) or disclosed further.<\/p>\n\n\n\n Duration of processing: A campaign or other agreed processing shall be carried out during a separately agreed period. Alma Target Groups used in a campaign or other agreed processing must be deleted immediately upon fulfilment of the agreed purpose of processing.<\/p>\n\n\n\n Other terms: The parties also agree that:<\/p>\n\n\n\n If the Publisher agrees on the disclosure of Alma Target Groups directly with the advertiser, the advertiser shall ensure that any media or advertising agency or other partner acting on its behalf carrying out its media buying is aware of the terms and restrictions relating to the use of Alma Target Groups as set out herein. The advertiser shall enter into a separate agreement on the processing of personal data with the media or advertising agency or other partner carrying out its media buying, and shall require that such party uses Alma Target Groups only for the purposes described in this section 18.2.<\/p>\n\n\n\n If the Publisher agrees on the disclosure of an Alma Target Group with a media or advertising agency or other partner acting on the advertiser’s behalf carrying out the advertiser’s media buying, such party shall ensure that the advertiser is aware of the terms and restrictions relating to the use of Alma Target Groups as set out herein. A media or advertising agency or other partner carrying out media buying does not acquire any independent rights to Alma Target Groups.<\/p>\n\n\n\n Any use of Alma’s data service and the integration of the Client’s and the Publisher’s identifiers within its framework, as well as the associated data protection roles and obligations, shall always be agreed separately in writing. In the event of any conflict between the data service agreement and these terms and conditions, the data service agreement shall take precedence.<\/p>\n\n\n\n Campaign results and data concerning advertisements seen and clicked by users in the Media are stored in Alma’s systems. Alma has the right to use such results and data for the development of its operations, marketing and sales activities.<\/p>\n\n\n\n The Publisher has the right to temporarily take a digital service offline for maintenance, upkeep or other similar reasons. The Publisher shall not be liable for any damage caused by service interruptions.<\/p>\n\n\n\n The Publisher shall not be liable for errors in digital or other Material submitted by the Client or for errors arising from the transfer of such Material.<\/p>\n\n\n\n The Publisher shall be liable for errors and delays in the publication of an advertisement only in respect of error-free Material received in accordance with the material submission schedule. The Publisher’s maximum liability for an approved advertisement not being published, a delay in publication or an error occurring during publication is the price of the advertisement. A minor deviation from the advertising copy, printing quality or proof shall not be considered an error. The Publisher’s maximum liability for Material submitted to other media is limited to its production value.<\/p>\n\n\n\n Under no circumstances shall the Publisher be liable for any indirect damages that may be incurred by the Client or third parties. The Publisher’s total liability for any damage caused to the Client is always limited to the price of the purchased campaign (or other form of cooperation). In respect of section 18 (processing of personal data), the Publisher’s total liability is limited to the amount paid by the Client to the Publisher for media sales cooperation during the preceding twelve (12) months.<\/p>\n\n\n\n Complaints concerning erroneous advertisements must be submitted within eight (8) days of publication in the newspaper or magazine or of the end of the digital campaign. Complaints concerning invoicing errors must be submitted no later than eight (8) days from the invoicing date. All other claims for damages must be submitted within three (3) months of the date on which the Client became or should have become aware of the damage.<\/p>\n\n\n\n Cooperation is carried out subject to force majeure, meaning that all unforeseeable circumstances beyond the Publisher’s reasonable control and independent of the Publisher, such as strikes, technical disruptions, delays caused by subcontractors and other similar circumstances, are outside the Publisher’s liability for compensation.<\/p>\n\n\n\n The terms and conditions of the cooperation other than those published by the Publisher, including prices deviating from the general price list and applicable discounts, are confidential for the duration of the agreement and for two (2) years thereafter. Neither party may disclose information about the content of the agreement to third parties. The parties also undertake to keep confidential all information received from the other party that is marked as confidential or that should otherwise be understood to be confidential in view of its nature (including personal data received from the other party). In respect of trade secrets, the confidentiality obligation remains in force for the period specified by the Trade Secrets Act.<\/p>\n\n\n\n The confidentiality obligation shall not, however, apply to information that:<\/p>\n\n\n\n1. Application of terms and conditions<\/h2>\n\n\n\n
2. Establishment of an agreement<\/h2>\n\n\n\n
3. Deviating and conflicting terms and conditions<\/h2>\n\n\n\n
4. Prices<\/h2>\n\n\n\n
5. Terms of payment<\/h2>\n\n\n\n
6. Discounts<\/h2>\n\n\n\n
General terms and conditions for discounts<\/h3>\n\n\n\n
Societal and ideological advertising<\/h3>\n\n\n\n
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Advertising and media agency discount<\/h3>\n\n\n\n
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7. Reservations and confirmation<\/h2>\n\n\n\n
8. Cancellation of campaigns<\/h2>\n\n\n\n
Cancellation terms for print campaigns in Kauppalehti<\/h3>\n\n\n\n
Cancellation charge<\/th> Advertisement cancellation<\/th> Specific placement ad cancellation<\/th> Insert cancellation<\/th><\/tr><\/thead> No charge<\/td> More than 2 business days before publication<\/td> 10 business days before publication<\/td> 3 weeks before publication<\/td><\/tr> 50% charge<\/td> 2 business days before publication<\/td> Less than 10 business days before publication<\/td> Less than 3 weeks before publication<\/td><\/tr> 100% charge<\/td> The day before publication<\/td> Less than 5 business days before publication<\/td> \u2013<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n Cancellation terms for print campaigns in Talousel\u00e4m\u00e4, Tekniikka&Talous, Arvopaperi, Tivi and Mikrobitti<\/h3>\n\n\n\n
Cancellation charge<\/strong><\/th> Advertisement cancellation<\/strong><\/th> Specific placement ad cancellation<\/strong><\/th> Insert cancellation<\/strong><\/th><\/tr><\/thead> No charge<\/td> Before the reservation date<\/td> 5 business days before the reservation date<\/td> 3 weeks before publication<\/td><\/tr> 50% charge<\/td> \u2013<\/td> \u2013<\/td> Less than 3 weeks before publication<\/td><\/tr> 100% charge<\/td> After the reservation date<\/td> Less than 5 business days before the reservation date<\/td> \u2013<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n Cancellation terms for print campaigns in Iltalehti<\/h3>\n\n\n\n
Cancellation charge<\/strong><\/th> Advertisement cancellation<\/strong><\/th> Large edition cancellation<\/strong><\/th> Midsummer edition cancellation<\/strong><\/th> Special magazine cancellation<\/strong><\/th><\/tr><\/thead> No charge<\/td> More than 2 business days before publication<\/td> More than 3 business days before publication<\/td> 5 business days before publication<\/td> 10 business days before publication<\/td><\/tr> 50% charge<\/td> 2 business days before publication<\/td> 3 business days before publication<\/td> Less than 5 business days before publication<\/td> Less than 10 business days before publication<\/td><\/tr> 100% charge<\/td> The day before publication<\/td> Less than 3 business days before publication<\/td> Less than 3 business days before publication<\/td> Less than 5 business days before publication<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n Cancellation terms for confirmed digital campaigns<\/h3>\n\n\n\n
Cancellation charge<\/strong><\/th> Digital campaign cancellation<\/strong><\/th><\/tr><\/thead> 25% charge<\/td> 6\u201310 business days before campaign start<\/td><\/tr> 50% charge<\/td> 4\u20135 business days before campaign start<\/td><\/tr> 100% charge<\/td> 3 business days before campaign start or later<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n 9. Material submission<\/h2>\n\n\n\n
10. Campaign duration<\/h2>\n\n\n\n
11. Verification of and display guarantee for digital campaigns<\/h2>\n\n\n\n
12. Changes to advertising space<\/h2>\n\n\n\n
13. Modification and return of Material<\/h2>\n\n\n\n
14. Intellectual property rights<\/h2>\n\n\n\n
15. Liability for the content of advertisements<\/h2>\n\n\n\n
16. Publisher’s rights<\/h2>\n\n\n\n
17. Competing advertisements in Media<\/h2>\n\n\n\n
18. Terms and conditions applicable to the processing of personal data<\/h2>\n\n\n\n
18.1. Processing of personal data on behalf of the other party<\/h3>\n\n\n\n
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18.2. Disclosure of target groups from the Publisher to the Client<\/h3>\n\n\n\n
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19. Storage of campaign data and results<\/h2>\n\n\n\n
20. Liability for errors and complaints<\/h2>\n\n\n\n
21. Force majeure<\/h2>\n\n\n\n
22. Confidentiality<\/h2>\n\n\n\n