PRIVACY POLICY 

Effective date: 1.4.2023

We All need Privacy and we commit to keep yours.

For those who want the short and relevant answer, we will always, ALWAYS, respect your privacy, your email address, and the information you give us.

We are not going to sell it, trade it, or abuse any information you submit to us.

We want to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information, tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our Company collects information from all end users of our Internet services (the “Services”), including those who access some of our Services but do not have accounts (“Visitors”) and those who may purchase Products and/or pay a monthly service fee to subscribe to the Service (“Members”). This Policy also explains what we do with the information we collect, and the choices Visitors and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully.

1 – INTRODUCTION

This privacy notice provides you with details of how Jason Staines / Leading Light Oy, Kutomotie 8aB 41, 00380 Helsinki, Finland, email: [email protected] , (referred to as “we”, “us”, “our” in this privacy policy) collects and processes your personal data.

1.1 “You” refers to you as a participant and user of Leading Light website. Our website refers to leadinglight.fi.

1.2 Leading Light Oy is the data controller and are therefore responsible for your personal data.

1.3 The Data Protection Officer (DPO) is Jason Staines, email: [email protected]

1.3 If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Ombudsman of the Finnish Data Protection Authority, the Finnish authority for data protection issues. We will be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

1.4 It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [email protected]

Members may be asked to provide certain personal information when they sign up for our Products or Services including name, address, telephone number. The personal information collected from Members during the registration process (or at any other time) is used primarily to provide a customized experience while using our Products and Services.

2 – WHAT ARE WE DOING WITH YOUR PERSONAL DATA?

2.1 With your consent we will send you emails regarding our products and services. This is both free of charge and premium material (blogs, video clips, workbooks, white papers etc.) and also information about different events (webinars, breakfast seminars etc.)

2.2 When you buy something from our website, as a part of the buying and sales process, we collect personal information that you give us. It makes it possible for us to deliver both the services and products that you bought, as well as to offer you support. We also collect information about you during your time as a Jason Staines customer to be able to send relevant communication to you, this includes you purchase history, how you interact with our website and what offers and events you show interest in by reading emails from us or clicking on links in emails from us.

3 – HOW DO WE USE YOUR PERSONAL DATA?

3.1 Personal data means any information capable of identifying an individual. It does not include anonemised data. We may process certain types of personal data about you as follows:

  • Identity Data may include your first name, last name and professional title.
  • Contact Data may include your billing address, delivery address, email address, telephone numbers and social media.
  • Financial Data may include your bank account and payment card details.
  • Transaction Data may include details about payments between us and other details of purchases made by you.
  • Technical Data may include your login data, IP-addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access our sites.
  • Profile Data may include your username and password, purchases or orders, your interests, preferences and feedback.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and and your communication preferences.

3.2 We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

3.3 We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

4 – HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1 We collect data about you through a variety of different methods including:

  • Direct interactions: You may provide data by filling in forms on our website (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
    • order our products or services;
    • create an account on our site;
    • subscribe to our service or publications;
    • request resources or marketing be sent to you;
    • enter a competition, prize draw, promotion or survey; or
    • give us feedback.
  • Automated technologies or interactions: As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
    • analytics providers such as Google based outside the EU;
    • advertising networks such as Google and Facebook based outside the EU;
    • Contact and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU
    • Identity and Contact Data from publicly available sources such as Fonecta based inside the EU.

5 – WHY DO WE USE YOUR PERSONAL DATA?

5.1 We will only use you personal data when legally permitted. The most common uses of your personal data are:

  • Where we need to perform the contract between us.
  • Where we need to comply with legal or regulatory obligation.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

5.2 You will receive marketing communications from us if you have:

  • requested information from us or purchased goods or services from us; or
  • if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications (for example if you start a subscription of any of our email broadcasts or other email marketing); and
  • in each case, you have not opted out of receiving that marketing.

5.3 When asking for your personal data we will ask for your consent and get your opt-in consent by email before using it for marketing purposes. We also give you the opportunity to reverse your consent. You can reverse your consent anytime by updating your preferences in our preference center alternatively clicking the link “unsubscribe” or “end subscription” which you will find in every email we send you in the form of email marketing. You can also contact us at any time at [email protected] to reverse your consent.

5.4 Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. By opting out you should be aware that your user experience may not work as intended and that Jason Staines may not be able to keep you updated in changes regarding services that you purchased.

5.5 When Visitors or Members send email inquiries to our company, the return email address is used to answer the email inquiry we receive. Our company does not use the return email address for any other purpose and does not share the return email address with any third party. Thanks for reading our privacy policy

6 – SUMMARY OF HOW WE USE YOUR PERSONAL DATA?

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

Purpose Type of data Lawful basis for processing
Provide, manage, develop and maintain our products/services ·        Identity data
·        Contact data
·        Financial data
·        Transaction data
·        Technical data
·        Profile data
·        Usage data
·        Marketing and Communications data		 Performance of a contract with you
Comply with legal obligations ·        Identity data
·        Contact data
·        Financial data
·        Transaction data		 Legal obligation
Deliver relevant content and advertisements to you about our products/services ·        Identity data
·        Contact data
·        Technical data
·        Profile data
·        Usage data
·        Marketing and Communications data		 Legitimate interests
·        Create possibilities to develop our products/services
·        Create possibilities to communicate with our customers in a relevant manner
Data analytics to improve our website, products/services, marketing, customer relationships and experiences ·        Identity data
·        Contact data
·        Technical data
·        Profile data
·        Usage data
·        Marketing and Communications data		 Legitimate interests
·        Create possibilities to define types of customer for our products/services
·        To keep our website and products/services updated and relevant

7 – WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

7.1 We do not sell or rent your personal information to any third party.

7.2 Generally the third-party services we use only collect and use information needed to allow them to deliver the services we hired them for. These parties are:

  • Service providers who provide IT and system administration service.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal insurance and accounting services.
  • Customs, regulations and other authorities based in Finland and other relevant jurisdictions that may legally require reporting of processing activities under certain circumstances.

7.3 We share your personal data within our group of companies and many of our third parties service providers are based outside the European Economic Area (EEA). The third parties service providers processing of your personal data will involve a transfer of data outside the EEA. Countries outside of the EEA do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside the EEA unless the transfer meets certain criteria, see description in section 7.4.

7.4 Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for your personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certificate mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw your personal data out of the EEA. Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.5 We may be obliged to disclose your personal information if our business and / or website is purchased or merged with another company, your information may be transmitted to the new owners so that they can continue to sell and support our products and services.

 

8 – YOUR SAFETY IS IMPORTANT TO US

8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees; agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.3 Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website we encourage you to read the privacy notice of every website you visit.

9 – FOR HOW LONG DO WE SAVE YOUR PERSONAL DATA?

9.1 We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm for unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after the original transaction date.

9.3 In some circumstances you can ask us to delete your data, see contact information in section 13. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice you.

10 – YOUR LEGAL RIGHTS

10.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

Your can see more about these rights at: http://www.tietosuoja.fi/en/

If you wish to exercise any of the rights set out above, please email us at [email protected]

10.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

10.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

10.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11 – CHANGES OF THIS PRIVACY POLICY

We will continually update this privacy policy to mirror any changes in how we treat privacy policy. Changes are being made as we published changes on the website. If we make essential changes we will inform you of these. If you don’t consent to these changes you have the right to terminate your contract with Jason Staines before the new privacy policy is applied.

12 – COOKIES

Jason Staines is using cookies to give a more personified user experience to our users and customers. You can set your browser to refuse all or some cookies, or alert you when websites set or use cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

13 – QUESTIONS AND CONTACT INFORMATION

If you want access to, change something, leave a complaint, adjust or remove any personal information we might have, or if you want more information, please contact us at [email protected] or send us a letter to Leading Light Oy, Kutomotie 8aB 41, 00380 Helsinki, Finland.