Coolbrook Oy Privacy Policy

September 2023

We value the security of the personal data of the employees and other representatives of our customers, suppliers and partners and any other individuals accessing our website or services provided by us.

This Privacy Policy gives an overview of how Coolbrook processes Personal Data (as defined below). It applies not only to all websites and any services provided by Coolbrook thereunder but to any Personal Data collected in connection with the management of our customer and supplier relationships, receiving employment applications, participation in events and promotional campaigns.

Our website may contain links to other websites and other third party services that have their own privacy policies that may apply. We recommend that you read the privacy policies of such websites and services carefully as Coolbrook is not responsible for the data protection policies of third parties or the content or quality of their services. This Privacy Policy does not apply to websites of our partners or other third parties through whom you may interact with Coolbrook.

Other terms related to data protection may be announced in connection with specific operations or services of Coolbrook. Such specific terms supersede this Privacy Policy in the event of conflict.

1 Data controller and contact

Coolbrook Oy is a limited liability company with operating brand ”Coolbrook”, having its registered office located at Pieni Roobertinkatu 9, Helsinki (“we” or ”us” or “Coolbrook”). Coolbrook’s company ID is 2419630-0.

Coolbrook is the data controller of personal data collected by Coolbrook (“Personal Data”).

If you have any questions regarding this Privacy Policy or data protection at Coolbrook, you may reach out to us by sending email to info@coolbrook.com.

2 Legal basis of processing

The legal basis of processing Personal Data may be an agreement, legal obligation, legitimate interest of the controller or consent, or other voluntary approval. The legitimate interests of Coolbrook to process Personal Data are to:

• increase user satisfaction and online platform experience;
• enhance personalised communication;
• support customized services;
• connect with stakeholders; and
• improve and protect the services.

When required by applicable laws, we will request data subject’s consent for processing of Personal Data.

Consent to the processing of Personal Data is obtained using an appropriate method, such as ticking a box indicating your consent, making a choice in the technical settings of the website, or other express statement or action depending on the service or application you use. Such consent is always revocable. You may at any time prohibit the processing of your Personal Data for direct marketing and profiling purposes.

3 What data is processed and where is it obtained from

We collect Personal Data that you voluntarily provide to us. We may also receive data on you from third parties. This information is collected, notably if and when you:

• enter into an agreement with Coolbrook;
• provide an employment application to Coolbrook, directly or through the website;
• subscribe to a newsletter or email alerts;
• fill in a contact form on our website;
• download marketing content; or
• respond to a survey.

The following Personal Data may be collected:

• first and last name, language, contact information, such as address, telephone number and e-mail address;
• date of birth and personal identification number (if allowed by the applicable data protection laws);
• marketing authorizations and prohibitions;
• employer name, business ID and contact person;
• IP address, browser type and source of your visit; and
• website usage information by using cookies (see section 7 below for details).

4 How and why do we use the collected data

4.1 Purpose of processing

As the data controller Coolbrook processes and uses Personal Data for relationship management, delivery and maintenance of the website, personalised marketing, communications, contacts, evaluations and compliance with legal requirements. In addition, the data can be used for statistical or optimisation of business processes and needs-based design of the website, as well as for user satisfaction and market research.

4.2 Transfer of data to subsidiaries or third parties

We may from time to time transfer Personal Data collected by us to other Coolbrook companies in the EU or outside the EU for the purposes set forth herein. Such transfer does not imply any restrictions on applicability of this Privacy Policy and Coolbrook is responsible for ensuring that there is a legal basis for any such transfer.
Coolbrook has the right to transfer Personal Data to a subsidiary or to a third party in connection with reorganization, merger, sale, joint venture, transfer or other transfer of Coolbrook’s business or parts of such, assets or shares, as long as the party to whom we transfer Personal Data agrees to process your Personal Data in accordance with the data processing standards set out in this Privacy Policy.

Coolbrook has also contracted with third party service providers to manage our databases and provide technical and other support for the services. Your Personal Data may be disclosed and transferred to such third-party service providers and other contractors as deemed necessary for the purposes and in accordance with the data processing standards described in this Privacy Policy.

Coolbrook may share non-personal information (such as anonymous data about users, addresses of sites that redirect to our website and addresses used to exit the website, use of services, etc.) with third parties for the purposes of assessing content uses, services, promotions and/or availability of services.

5 How we protect Personal Data (data security)

We are committed to protecting the Personal Data we collect. To protect your data managed by us against manipulations, loss, destruction or against the access of unauthorised persons, we conduct several technical and organisational security measures. Our security measures are continuously improved.

We will retain your Personal Data for only as long as required, and thereafter the data is either made anonymous or permanently deleted. For more specific information on how long we hold your personal data, please contact us (see section 1 for contact details).

6 How to access, update, correct or delete your Personal Data

We take reasonable efforts to ensure that the Personal Data we have about you is as up-to-date, accurate, and complete as necessary for the purposes for which we use that data.

You have the following rights with respect to your Personal Data:

• Right of access to information (Article 15 of the General Data Protection Regulation (EU 2016/679) (“GDPR”));
• Right to rectification (Article 16 of the GDPR);
• Right to erasure (‘right to be forgotten’) (Article 17 of the GDPR);
• Right to restriction of processing (Article 18);
• Right to data portability (Article 20);
• Right to lodge a complaint with a supervisory authority (Article 77);
• Right to withdraw your consent (Article 7); and
• Right to resist particular data processing measures (Article 21 GDPR). 

You have the right to access, and oppose for legitimate reasons, the processing of your Personal Data as well as the right to update, correct or request deletion of your Personal Data collected by us, by contacting us (see section 1 for contact details).

Contact information of the Finnish Office of the Data Protection Ombudsman (the national supervisory authority in Finland) are available at www.tietosuoja.fi.

7 Cookies and third party services

Cookies are small text files that are stored on your browser. Some cookies are activated automatically because the online service needs them to function properly. Cookies can also be used to track use of services and to allow for targeted content and relevant advertising.

We use cookies on our website to make the use of our services easier and technically smoother. Cookies help us obtain information about the number of visitors, the pages visited by visitors, browsers and operating systems. With this information, we can better understand the use of our services and needs of our users so as to develop our services.

Certain technical data will be stored by us, such as the subpages you visited with us, the date and the duration of your visit.

The data is used only for service evaluation, not to analyse individuals visiting our website.

We can store cookies received from your device if they are strictly necessary for the operation of our website. For all other types of cookies we need your permission. For this purpose, we ask for your consent to store other than strictly necessary cookies. Our website may use third party services to display advertisements based on your recent visit to the site (remarketing), website analytics and social media plugins.

8 Changes to the Privacy Policy

This Privacy Policy is subject to changes from time to time. We therefore recommend that you regularly review this document.

In case of any questions, please contact us (see section 1 for contact details).