This privacy policy describes how we collect and use your personal data.

Unless otherwise specified, you are not obligated to provide us with your personal data. However, if you choose not to provide your personal data, we may not be able to provide you with our products or services.

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1. Controller

Groke Technologies Oy

Lemminkäisenkatu 14-18 B
20520 Turku, Finland

Contact information in privacy related matters:

Groke Technologies Oy / Marja-Liisa Laihonen
Lemminkäisenkatu 14-18 B
20520 Turku, Finland
+358 40 848 5591
marja-liisa.laihonen@groke-tech.com

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2. Personal data collected

We collect your personal data and other information when you contact us, order or use our services and/or products or otherwise interact with us. Personal data collected by us may include the following:

• Information collected from our business partners’ contact person(s)
  - Name
  - E-mail address
  - Phone number

• Information collected from job applicants
  - Name
  - E-mail address
  - Phone number
  - Address
  - Any other information voluntarily provided by the job applicant, for example on the provided CV or application

• Information collected from the users of our website, our services and users of Tribe
  - Name
  - E-mail address
  - Phone number
  - Company related information (current position, duration of employment, length of service on a vessel etc.)
  - Cause of registration
  - Information related to the use of our website or services (such as information collected through the use of cookies, IP-address, time of access, browser or application used, content viewed on the website etc.)

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3. Purposes and grounds for collecting and processing personal data

We collect and process your personal data for the following purposes:

• In regard to our business partners, customers and other parties using our services, to provide you with our products and services, manage the customer relationship and to fulfil the agreement between you and us

• In regard to job applicants, to contact, interview, evaluate and hire new employees

• To develop and improve our services

• When you have given your consent, to provide you with our newsletter

In addition to the aforementioned, we may also process your personal data when so required by law or when you have given your specific consent.

4. Sharing of your personal data and transfers of personal data

We do not share, sell, or disclose your personal data to third parties outside of the situations described below:

• We may share your personal data with our partners for the purposes of an audit or in order to acquire financing (such recipients consisting of banks, financial institutions and/or auditing organizations)

• We may share your personal data with our business partners and third-party service providers providing for example outsourced IT-services

• We may disclose personal data in connection with third parties in connection with a prospective sale, acquisition, merger, or other reorganization of our business

• We may share or disclose your personal data with third parties if you have given your consent for us to do so

• We may share or disclose your personal data to authorities or other similar third parties when so obligated by mandatory law

In all aforementioned situations we will ensure that your personal data is processed and disclosed in accordance with applicable data protection legislation.

We frequently use and share personal data with the following third-party service providers:

• Eficode Oy
• Elisa Oyj (web)
• Google Cloud (web)
• If Vahinkovakuutus Oyj (web)
• Mehiläinen Oy (web)
• PricewaterhouseCoopers Oy
• Tietokeskus Finland Oy
• Turun Tilikeskus Oy
• Zoner Oy

We do not generally transfer personal data collected in EU / EEA to countries outside of the EU / EEA. However, there may be cases where your personal data is processed or collected outside of the EU / EEA (such as with Tribe users located in Japan or other countries outside of EU / EEA). If processing your personal data requires for the personal data to be transferred to countries outside of the EEA, we shall ensure that measures providing adequate protection are in effect (such as European Commission’s Standard Contractual Clauses).

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5. Your rights

You have the following rights regarding personal data processed by us:

Right to access

You have the right to access and obtain a copy of your personal data processed by us and to know what of your personal data we are processing.

Right to rectification

You have the right to request us to rectify any of your personal data processed by us, if said data is incorrect or incomplete.

Right to erasure and the right to restrict processing

You have the right to request the erasure of your personal data processed by us or for restriction of said processing. If you submit a request for erasure or restriction of processing, we shall process the request, and either erase the personal data, restrict the processing, or provide you with qualified grounds for refusal of the request.

Please note, that we as the controller may have a right or obligation based on mandatory law to not erase specific personal data. Such obligations may, for example, be based on the Bookkeeping Act.

Right to object

You have the right to request that we stop processing your personal data. Please note that there may be legal obligations that prevent us from complying.

However, you always have the right to forbid processing of your personal data for direct marketing purposes.

Right to withdraw consent

If the processing of your personal data is based solely on your consent, you have the right to withdraw said consent at any time. You can withdraw your consent generally through the service you have given the consent in, but in case this is not possible, you may withdraw the consent by contacting us as described below.

Right to data portability

You have the right to request your personal data processed by us in a machine-readable format.

Using your rights

You may exercise your right by either managing your choices and settings through our services or the website or by contacting us:

Groke Technologies Oy
Lemminkäisenkatu 14-18 B
20520 Turku
+358 40 848 5591
info@groke-tech.com

Right to lodge a complaint with the data protection authority

If you feel that our processing is not compliant with relevant data protection legislation or you are not otherwise satisfied with our processing, you may lodge a complaint with your local data protection authority.

The Finnish data protection authority’s contact information can be found at www.tietosuoja.fi/fi/index/yhteystiedot.html

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6. Data retention

We only hold and process your personal data for the duration necessary to fulfil the purposes of processing described in this privacy policy. Please note, however, that mandatory legislation, such as the Bookkeeping Act, may obligate us to hold or process your personal data for periods up to 10 years.

• Personal data related to our business partners and customers is generally kept for the time defined in the Bookkeeping Act

• Personal data of job applicants is kept for 6 months from the receipt of said data, unless the applicant has given their consent for a longer period

• Personal data of users of Tribe is kept for as long as the user in question is using the service and for up to 1 year after they have unregistered or stopped using the service. However, the user may request the deletion of their data sooner if they have ceased to use the service.
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7. Automated decision-making and profiling

We do not generally use your personal data for automated decision-making or profiling. However, the personal data of Tribe -users may be used to send customized or targeted Tribe-newsletters.

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8. Cookies

We may use cookies, web beacons and other similar methods to improve and provide our services and website. The cookies used may also be from third parties.

You have the option to disable the use of non-mandatory cookies through your browser settings or by selecting your cookie-preferences on our website. Please note, that if you disable some or all non-mandatory cookies, our services or website may lose some functionalities.

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9. Changes to this privacy policy

We may update this privacy policy to meet the requirements of changed legislation or changes in our business or data protection practices. In case of any material changes, we shall notice said change at the beginning of this privacy policy and our website. We recommend that you periodically re-visit this privacy policy and our website for possible changes.