We at Loyalistic Ltd are committed to protecting the privacy of the users of our services, and we comply with the General Data Protection Regulation of the European Union (2016/679/EU), which will be applied as of 25 May 2018, as well as other Finnish and EU data protection legislation while processing any personally identifiable or other similar user data in the course of providing our services. This Privacy Policy applies to personal data that we collect in our customer and marketing data filing system ("Data Filing System"). This includes both, subscriptions to our Loyalistic internet-based software ("Loyalistic Service") by our customers ("Customer") and processing of data we receive from our websites through the Loyalistic Service ("Websites"). This Privacy Policy explains and governs our data collection, processing and usage practices.

By using the Loyalistic Service or the Websites, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described herein, you should not use the Loyalistic Service or the Websites. Please note that we may periodically update this Privacy Policy. We will use reasonable efforts to inform you of any possible changes and their effects in due time beforehand on our website or otherwise. We recommend that you visit our website occasionally to review any changes. This Privacy Policy was last updated on 17 May 2018.

Data controller:
Loyalistic Ltd (Business ID: 1050694-5)
Laippatie 3
00880 Helsinki
+358 40 6847 468

1 The Loyalistic Service

The Loyalistic Service is an internet-based content marketing tool designed to be utilized by our Customers for lead generation purposes on their websites and online marketing activities. Loyalistic Ltd processes information provided by its Customers as directed and in accordance with agreements with our Customers, and does not control the content on the websites or services of its Customers, or the information collected and processed by our Customers. These are governed exclusively according to their own privacy policies. Our permitted use of information is set out in this Privacy Policy.

2 The Information We Collect

2.1 Sources of Personal Data

When subscribing the Loyalistic Service we ask you to provide certain personal data related to your subscription. We collect this information directly from you, and store it in the Data Filing System for purposes described in this Privacy Policy. This Customer information includes, for example, your name, contact details (such as address, billing address, e-mail and phone number), company name, language and other information that personally identifies you (such as IP-address), submitted or made available by you later in the course of your subscription ("Personal Information").

2.2 Customer Information

We process the following categories of personal data of the representatives of our existing and potential Customers (later also "you"):

2.3 Website usage, log files and cookies

You are free to explore the Websites without providing any information about yourself. However, we collect certain information received automatically through the operation of the Loyalistic Service either directly or on a Website. Such information refers to your computer (or other device) and your use of the Loyalistic Service and visits to a Website, and includes (i) information about your subscription and your interactions with the Loyalistic Service or Website, including advertising, products and services which are displayed, offered or otherwise made available on the Loyalistic Service or a Website; (ii) details pertaining to your use of the Loyalistic Service features and other contributions to the Loyalistic Service or a Website; (iii) technical data, such as the referring website address, access times, your IP address, device identifier, network and computer performance, browser type, language, operating system, and the Loyalistic Service version; and (iv) location information. We may use cookies and similar technologies to collect this information (see Section 8 below). We may store and use this information in accordance with this Privacy Policy.

2.4 Payment information

When you subscribe the Loyalistic Service, we do not store and process your credit card information and other invoicing data provided by you. All processing of credit card information is performed by trusted third parties for the sole purpose of verifying your financial qualifications and collect payment from you. The use of your data by our invoicing service provider is subject to its privacy policies.

2.5 Information Collected by Our Customers

Our Customers can use the tools we provide, as well as tools provided by third parties, to collect information similar to that referred to on Section 2.3 above when you visit their websites running the Loyalistic Service. Loyalistic Ltd does not control its Customers' use of these tools, nor do we control the information they collect or how they use it. These are always subject to our Customers' own privacy policies.

3 How We Use the Information We Collect

3.1 Compliance with Privacy Policy

We use the information collected only to the extent provided for in this Privacy Policy. Our Customers are obligated to comply with this Privacy Policy, and we recommend that as our Customer you refer to this Privacy Policy in your own terms and conditions applicable between you and your client.

3.2 Use of and Basis for Processing Your Personal Data

The basis for processing your personal data is our legitimate interest based on the purposes of use determined below.

If you already are our Customer, the purpose of processing your personal data is to: (i) provide, personalize and improve the Loyalistic Service or Websites, for example by providing customized or localized content and advertising (see Section 8 below); (ii) ensure technical functioning of the Loyalistic Service and Websites, develop new features or services and provide support; (iii) perform research, analyze and compile statistical information about your use of the Loyalistic Service or a Website, including your interaction with content made available therein; (iv) communicate with you for purposes related to the management of Customer or user relationship (including billing, surveys, newsletters etc.); and (v) send you promotional material and other marketing communications relating to our or our Customers' products or services.

The purpose for which the personal data concerning our potential Customers are used is carrying out direct marketing and other sales and marketing measures regarding the Loyalistic Service, i.e. standard marketing procedures such as sending marketing messages by email. The processing of the personal data of our potential Customers has no other impact than targeting of marketing messages.

We do not further process your personal data for other purposes than those described in this data protection record and we will not sell your personal data to any third party.

However, we may share the data (whether personal data or non-personally identifiable) with our subcontractors partners for the above purposes. In case we share the data, we will ensure that personal data is shared and processed only to the extent necessary and only for the intended purpose. Such third parties are also required to maintain the confidentiality of your personal data.

3.3 Access to Personal Data

Loyalistic Ltd's personnel have no general access to personal data included in the Loyalistic Service. Access to such personal data is given exclusively to authorized persons on Loyalistic Ltd's side or its subcontractors, for instance, in connection with the supply of support services relating to the Loyalistic Service. We have ensured that our employees do not process personal data on a wider basis than required for the production of the Service. The Service Provider's personnel have received training on the restrictions relating to the processing of personal data.

4 Transfers of Your Personal Data to Third Parties

4.1 Transfers to Our Business Partners

Your personal data may be transferred to our business partners and subcontractors. The current list of our business partners we transfer data to is located at https://loyalistic.com/en/gdpr/transfers/.

Our business partners may process your personal data only for the purposes defined in this Privacy Policy. We always ensure that our partners do not process the personal data transferred to them for any other purposes.

We may also be required to share your personal data with competent authorities in accordance with legislation concerning the processing of personal data.

4.2 Third Party Services and External Websites

The Loyalistic Service enables you to promote and share your content with social network services (such as Facebook, Twitter etc.). The use of your content and related information (including personal data, if any) on these services is subject to the terms and conditions and privacy policies of the relevant service providers, and we do not have access or control over nor do this Privacy Policy apply to these third party services.

Our Websites may include links to third party websites. Please note that we do not control, and are not responsible for, the content or practices of such websites, which are also subject to their own terms and privacy policies.

5 Transfers to Other Countries

In order to ensure proper functioning of the Loyalistic Service and the Websites, and to facilitate our global operations, we may need to share and transfer your information with companies operating outside Finland (for example if our servers are located in another country). You expressly consent that Loyalistic Ltd has the right to share and transfer your information freely within the EU/EEA for the purposes described in this Privacy Policy.

We transfer your personal data outside the European Union or the European economic area in accordance with data protection legislation. The operators we transfer your data to is located at https://loyalistic.com/en/gdpr/transfers/.

In all situations, we transfer your personal data outside the EU or the European Economic Area only based on one of the lawful grounds mentioned below:

6 Principles for the Retention of Your Personal Data

The personal data of our existing Customers shall be retained for as long as the Customer relationship exists. After the termination of the Customer relationship your personal data shall be retained for a maximum of one year following the termination of the customer relationship.

The personal data of our potential customers shall be retained in the Data Filing System for as long as you hold a position to which our marketed product or service is related, provided that you have not prohibited direct marketing. In such case information on the prohibition of direct marketing can be retained in the Data Filing System. Your personal data may be retained for longer if applicable legislation or our contractual obligations towards third parties require a longer retention period.

7 Security

We employ several security technologies and measures to protect and prevent your personal data stored on our servers from unauthorized access, use and disclosure. Our servers are located in a controlled and secure environment and user credentials are required to access the environment and personal data.

8 Information about Cookies and Similar Technologies

A "cookie" is a small text file that is placed on your computer or other terminal device by a web server when you visit a website. Cookies are used to personalize your browsing experience by helping a website recognize your device when you return to that website. Each cookie is individually assigned to your terminal device and only the server that has placed the cookie is able to read it later on. A cookie does not run programs and it cannot be used to deliver viruses or other malware, or harm your terminal device or data files. An individual user is not identifiable merely through the use of cookies or similar technologies.

We use cookies and other similar technologies to operate, analyze and improve the Loyalistic Service and Websites to better serve our Customers and users, and to provide you with personalized information in accordance with this Privacy Policy. The information we collect by these means is described in Section 2.3 above. If you have provided personal data about yourself, we may combine the information we receive with the help of these techniques with your personal data.

You have the option to manage your cookie preferences through your web browser. You can set your browser to accept, block or delete all or certain cookies. Please note that if you choose to block cookies, this may prevent the proper functioning of the Loyalistic Service or Websites. For more information about cookies and how to block them, please visit for example www.youronlinechoices.com or www.allaboutcookies.org.

9 Your Rights With Respect to Personal Data

You have the right to prohibit us from processing your personal data for purposes of direct advertising, distance selling and other marketing communications, market research and opinion polls (opt-out) by informing us thereof. You may give us channel-specific consents and prohibitions concerning direct marketing (e.g. prohibit marketing messages sent by e-mail but allow marketing messages sent by mail).

In addition, you have the right to, according to applicable data protection legislation, at any time:

You can verify your identity and access your personal data at https://content.loyalistic.com/transparency. If you have any further requests, you should present your request for exercising any of the aforementioned rights in the manner described in the 'Contacts' Section of this data protection record. We may ask you to specify your request in writing and to verify your identity before processing the request. We may refuse to fulfil your request on grounds set out in applicable data protection legislation.

You also have the right to lodge a complaint with the supervisory authority concerned or with the supervisory authority of the EU member state of your habitual residence or place of work, if you consider that we have not processed your personal data in accordance with applicable data protection legislation.

10 Contacts

All requests concerning the use of the rights mentioned above, questions about this Privacy Policy and other contacts should be made to Loyalistic Support to the address You may also contact us through the feedback- or other contact function on our website or application, in person in our offices or in writing:

Loyalistic Ltd
Laippatie 3
00880 Helsinki
+358 40 6847 468

You can verify your identity and access your personal data also online at: https://content.loyalistic.com/transparency.