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GDPR and Privacy Policy

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Data Protection and Privacy Policy

Introduction
We want to have confidence with our customers and are therefore committed to safeguarding your privacy. Your personal information must be safe with us, and this privacy policy explains why and how Znapio collects and uses personal information. Use of our apps, websites, support services and social media is subject to the terms and conditions of this Privacy Policy. 

What personal information do we process and why?
Znapio processes personal information that is needed in order to deliver the Znapio solution with the agreed functionality. Personal information can be name, mobile number, position and GPS position to attach submitted photos and reports to the right seller, store, campaign, etc. 

All of the following data recorded on the register may be processed:

• First name and surname
• Contact information (postal address, telephone number and email address)
• The start and end dates of customer contacts and/or relevant contacts, and method how of these started or ended
• Direct marketing permits and bans
• Data on the use of digital services and content (e.g. ordering of newsletters), metadata concerning the data subject’s browser and sent to the controller’s server (e.g. IP address, browser program, browser version, page from which the data subject visited our website), as well as cookies sent to the data subject’s browser and cookie-related data 
• Information related to marketing or sales promotions, such as marketing measures targeted at the data subject, and participation in such marketing (e.g. participation in promotional prize draws and competitions, and events) data related to the management and maintenance of customer contacts and other related contacts (e.g. data on the purchase and cancellation of payable products and services, data on free-of-charge-product and service orders, delivery information, feedback, complaints, as well as recordings of customer service interactions such as telephone calls, emails, and chat and text messages)
• Matters of interest indicated by the data subject 
• The language used
• Data on changes made to the data listed above 
• Data generated by analyzing service use or other data provided by the customer, e.g. possible subjects of interest.

In addition to the above-mentioned data, the following register data on a product and/or service purchaser may be processed:

• Customer code
• Invoicing and debt-collection data

The personal details used for managing and analyzing customer contacts and other relevant contacts, service production and personalization, business development and planning, and marketing and customer communications. 

We receive personal information directly from the user when creating a user profile or by receiving lists from the user's employer. When creating a user profile directly or indirectly from the employer, there is at the same time a consent given from the user that we process personal information.

Users of the service may withdraw their consent at any time by contacting Znapio. 

Protection of register and access
Processing of personal information about our users is an integrated part of our business. Znapio will share information with subcontractors and partners where necessary.

The data included on the digital register is protected by firewalls, encryption, passwords and other technical means generally accepted in the sector. Manually maintained material is located on premises subject to controlled access.

Only pre-identified employees working for and assigned by the controller, or working for companies acting on behalf of the controller, have access to data on the register, on the basis of user rights issued by the controller.

Znapio uses various IT services and IT systems in our business. In some of these, personal data is stored and handled. Our categories of service providers and partners are:

• Hosting /infrastructure / storage
• SMS gateway
• Analytical tools
• Suppliers of customer support tools
• Marketing and email providers
• Internal communication tools. 

Some of these systems are installed locally with us, and only our employees have access to the data. However, some systems are cloud solutions or installed at the supplier, which means that we transfer personal data to the supplier. In these cases, the supplier is responsible and handles the data on our behalf and in accordance with our instructions. 

Data controller contact info
Znapio by the general manager in BeMobile/More Mobile Relations is the person responsible for the treatment of the company's processing of personal information. If you have any questions about our privacy statement or about our use of personal information, please contact us at support@znapio.com or by mail at:

BeMobile AS, Schweigaardsgate 34 C, 0191 Oslo
More Mobile Relations Oy, Erottajankatu 9 A 6 Helsinki

Right of access, restriction of processing and rectification
According to the Personal Data Act, data subjects have the right of access to information, to check on what data pertaining to them has been recorded in the register. Upon the request of the data subject, we will make any necessary rectifications and additions to the personal data or, with regard to the purpose of processing the data, erase any erroneous, unnecessary, incomplete or outdated data. To check and update data, contact the above-mentioned person in charge of register-related matters.

Data subjects have the right to object to the processing and handover of data concerning them direct advertising, distance selling and other direct marketing, as well as market survey and opinion-polling purposes.

As a user of Znapio service, you have the right to gain access to your personal data and use of these, which includes the following:

• To gain access to your own personal information, what we have stored about you
• Removing all the personal data we have stored on you
• That incorrect, incomplete or information is corrected, deleted or supplemented
• Being able to dispute our processing of data
• To be able to withdraw the consent you have given
• The right to data portability. To the extent it is relevant, to be able to transfer data that we have collected under consent to another solution

If you have any questions regarding our processing of your personal information, please contact us via the contact details below. Requests must be answered within 30 days.

If you wish to complain about our processing of your personal data, you can address a request to the Norwegian or Finnish Data Protection Authority.

Regular data sources
Personal data on the data subject is gathered from the data subject themselves, from various services used by the data subject (e.g. Znapio network and mobile services, and Znapio social media channels) as well as various marketing measures in relation to activities such as promotional prize draws, competitions and events. In addition, personal data can be collected and updated from public authorities and companies providing services that involve personal data. 

Handover and transfer of data
The controller will not hand over the Customer’s personal data to third parties. 

Storage location and times
Znapio stores your personal information as long as it is required for the purpose. If you are a user of Znapio then your contact information will be retained as long as you choose to be a customer or as long as your employer wants to keep data in the solution. If a user is deleted in the system then all personal information will be anonymized. All data on our local systems is stored within the EU (Belgium) on Google Cloud. 

Cookies
At www.znapio.com, we use cookies to optimize and develop the sites. The information is stored anonymously. In addition to our privacy policy, this policy also applies to our cookies. 

Znapio uses cookies and other methods to gather statistics on visitor traffic. A cookie is a small text file sent to the customer’s browser, which usually contains an anonymous identifier. Cookies will not damage your terminal.  

Znapio uses cookies to gather visitor statistics and detailed data on the use of our website. We use such data to help us present issues and themes of interest to our customers. Znapio may also use data gathered using cookies and other methods to target content at customers. Znapio does not forward the personal data of its customers or website users to third-party advertising networks. The customer has the option of blocking cookies by changing the browser settings. 

Supervisory authority
Znapio is belonging in Norway and Finland and it is the Norwegian/Finnish Data Protection Authority that supervises that privacy law has been followed up. If you have any questions about privacy and Znapio, you can contact the Norwegian/Finnish Data Protection Authority directly. You can find more information on their website: https://www.datatilsynet.no or https://www.tietosuoja.fi/en

Amending the privacy policy
Znapio continuously develops its business operations and therefore reserves the right to make changes to this privacy policy. Changes may also be made on the grounds of legislative amendments.