Privacy Policy

Last updated February 19, 2024

Contents

1. DEFINITIONS

2. CONTACT DETAILS

3. PERSONAL INFORMATION WE COLLECT

3.1. Necessary information needed to use the Valmista -platform

3.2. Information you choose to give us

3.3. Information Automatically Collected by Using the Valmista Platform and our Payment Services

3.4. Personal Information We Collect from Third Parties

4. HOW WE USE INFORMATION WE COLLECT

4.1. Provide, Improve, and Develop the Valmista Platform

4.2. Create and Maintain a Trusted and Safer Environment

4.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing

4.4. Provide Payment services

5. SHARING & DISCLOSURE

5.1. Sharing With Your Consent or at Your Direction

5.2. Sharing Between Members

5.3. Information You Publish

5.4. Service Providers

5.5. Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights

5.6. Service Providers

5.7. Business Transfers

5.8. Third party services and features

5.9. Co-operation partners

6. OTHER IMPORTANT INFORMATION

6.1. Valmista uses industry-standard physical, technical and publication

6.2. Responsibility of account information

7. STORAGE PERIOD

8. YOUR RIGHTS

8.1. Your access and control of your data

8.2. Information received from third-parties

8.3. Right to withdraw consent

8.4. Data erasure

8.5. How to use your rights

9. SECURITY

10. CHANGES TO THIS PRIVACY POLICY

10.1. Changes

10.2. Contact details

1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

2. CONTACT DETAILS

TOTEMI INVESTMENT OY Kahilanniementie 5 53130 Lappeenranta Finland VAT / business id 3092683-2 info@valmista.com

Valmista has appointed a data protection officer who you can reach through the above contact details.

3. PERSONAL INFORMATION WE COLLECT

3.1 Necessary information needed to use the Valmista -platform

For providing the Valmista services, we need certain information for being able to provide the service. Valmista collects personal information about you when you use the Valmista -platform. Also we gather details about the device you're using, like what kind it is and what operating system it has, but this can vary depending on your device and its settings. At Valmista, we prioritize your privacy and transparent communication. Rest assured, all personal data is collected with the utmost respect for your privacy and in accordance with relevant data protection regulations. The collected information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, social media profiles, date of birth, and profile photo, some of which will depend on the features you use.

3.2 Information you choose to give us

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.

• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. These may also include personal information, for example your experience, education, etc relevant information.

• Your offering, including the services to be provided, prices and other defining information.

• Information related to identification for verifying profile. Such as documents proving your identification. These are not publicly visible for users of Valmista.

• Payment information that you decide to give us for enabling payments.

• Geolocation and location information

3.3 Information Automatically Collected by Using the Valmista Platform and our Payment Services

When you use the Valmista Platform and Payment Services, we automatically collect personal information. This information may include

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the Valmista if you enable this through your settings or device permissions.

• Usage Information. Such as the pages or content you view, searches for Listings, requests you have made, and other actions on the Valmista Platform.

• Log Data and Device Information. Such as details about how you’ve used the Valmista Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Valmista Platform. We may collect this information even if you haven’t created an Valmista account or logged in.

• Cookies are used for optimizing and to continuously improving the website for you, we use tracking technologies from selected partners. With your consent we use optional tracking technologies (f ex pixels or similar) for the purpose of analysis, marketing and the integration of external content. In addition, you may also receive advertising on third-party-websites. Valmista and our third-party partners operate in accordance with GDPR. Examples of the cookies:

  • Essential Cookies are necessary for basic website functions like logging in and payments.
  • Performance Cookies help understand how you use the site, but don't collect your personal info. These help to improve the website operation.
  • Functionality Cookies collect info about your device and settings (like language) to give you a better, personalized experience on the site.
  • Targeting/Advertising Cookies are for showing you ads that match your interests. They track your preferences to show relevant ads.

• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details, depending on the payment method chosen to use

3.4 Personal Information We Collect from Third Parties

We collect personal information from other sources, such as:

• Third-Party Services. If you link, connect, or login to the Valmista Platform with a third-party service (e.g. Google, Facebook, Linkedin), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

4. HOW WE USE INFORMATION WE COLLECT

4.1 Provide, Improve, and Develop the Valmista Platform

Such as to:

• enable you to access the Valmista Platform and make payments,
• enable you to communicate with other Members,
• process your request,
• perform analytics, debug and conduct research,
• provide customer service, training,
• send you messages, updates, security alerts, and account notifications,
• personalize and customize your experience based on your interactions with the Valmista Platform, your search and requests history, your profile information and preferences, and other content you submit, and

4.2 Create and Maintain a Trusted and Safer Environment

Including to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• verify or authenticate information provided by you,
• comply with law, respond to legal requests, prevent harm, and protect our rights (see also section 5.5),
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Valmista Platform, your profile information and other content you submit to Valmista, and information obtained from third parties. In limited cases, automated processes, which analyses your account and activities on the Valmista platform as well as information in relation to activities on and off the Valmista platform that can be associated with you, could restrict or suspend access to the Valmista Platform if such processes detect activity that may pose a safety or other risk to Valmista, our community, or third parties.

4.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing

For example to:

• show or send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Valmista or its third-party partners,
• analyse characteristics and preferences to send you promotional messages, marketing, advertising, and other - information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

4.4 Provide Payment services

Personal information is used to enable, or authorize third parties to use, Payment Services such as to:

• detect and prevent money laundering, fraud, abuse, and security incidents,
• conduct security investigations and risk assessments,
• comply with legal obligations (such as anti-money laundering regulations),
• enforce the Payment Terms and other payment policies,
• with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences, and
• provide and improve Payment Services.

5. SHARING & DISCLOSURE

5.1 Sharing With Your Consent or at Your Direction

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Valmista account or participating in promotional activities (f ex advertisement) by Valmista partners or third parties.

Where permissible under applicable law, we may use certain information about you such as your email address, de-identify it, and share it with social media platforms to generate leads, drive traffic to Valmista, or otherwise promote our products and services.

5.2 Sharing Between Members

To help facilitate requests or other interactions between Members, we may need to share certain information such as:

• When a request is made. When a request is confirmed, additional information is shared to assist with coordinating the requests, like profile photo and phone number. When you as a Provider have a confirmed request, certain information is shared with the Customer to coordinate the request, such as your profile, full name, phone number, and Listing address.

5.3 Information You Publish

You can make certain information publicly visible to others, such as:

• Your public profile page, which includes your profile photo, first name (or initials where applicable), description, and city.
• Listing pages that include information such as the Services or experiences approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings, and other public feedback.
• Content in a community or discussion forum, blog, or social media post. We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.

Information you share publicly on the Valmista Platform may be indexed through third-party search engines.

5.4 Service Providers

Providers may use third-party services to help manage or deliver their services. Providers may use features on the Valmista Platform to share information about the Customer with such third-party service providers.

5.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to.

5.6 Service Providers

We share personal information with affiliated and unaffiliated service providers to help us run our business and for their compliance purposes, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Valmista Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or similar claims. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

5.7 Business Transfers

If Valmista undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5.8 Third party services and features

When you use services or features available through the Valmista (such as using a third-party buttons to Facebook, Google or LinkedIn), these third parties may collect or share information about you, including personal information. The practices of third parties regarding the processing of your data are governed by their own privacy policies.

5.9 Co-operation partners

We share personal data with our business partners when they have participated in a campaign or marketing activity or advertising organised by Valmista or its partners, or when they provide services or products directly or indirectly through Valmista (e.g. through an affiliate program).

6. OTHER IMPORTANT INFORMATION

6.1 Valmista uses industry-standard physical, technical and publication

We use a variety of security measures, including encryption and authentication, to protect and maintain the security and integrity of your personal information, to prevent unauthorized access and use, and to prevent damage or misuse. Although we strive to protect your personal information, we cannot guarantee complete security. You must take care of your own conduct and information, and you must strive to keep your personal information safe and confidential by sharing it only in secure contexts

6.2 Responsibility of account information

You retain responsibility for your own Valmista-account and data, and you must ensure the security of your account by choosing a strong password and ensuring that no one else has access to your account or personal information. If you suspect that the security of your account is at risk, you should notify us immediately.

7. STORAGE PERIOD

Valmista does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Valmista or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum storage period may therefore vary per use, sensitive information being stored shortest time reasonably possible. When your personal data is not needed any more as the purposes described in this document, those are removed or anonymised appropriately.

8. YOUR RIGHTS

When you provide us with your information, or you use Valmista services, you agree to our use of it as described in this policy. We’re committed to handling your data responsibly.

8.1 Your access and control of your data

You can access and update some of your personal information through your Valmsita user Account. Note that you have right and are responsible for keeping your personal information up to date. You can request a copy of your personal data by contacting us.

8.2 Information received from third-parties

If you have connected your Valmista Account to a third-party service, like Facebook, Google or LinkedIn, you can change your settings and unlink from that service in your Valmista account.

8.3 Right to withdraw consent

In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent means you cannot further use Valmista- services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.4 Data erasure

You can request the deletion of your personal data, and we will delete your data, unless we have a legitim reason not to do so.

8.5 How to use your rights

If you believe your data is being mishandled, please contact Valmista by email (see contact details in chapter 2 or 10) with your information (email, full name, address, phone number). We may reject or charge requests that are manifestly unfounded, unreasonably repetitive or excessive.

You have a right to file a complaint to local data protection authority.

9. SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Valmista platform, systems, and other assets for security vulnerabilities. Furthermore, access to personal data by employees of Valmista is restricted and access is subject to what is necessary for purposes of the employee’s work assignments. Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the users, we will inform the relevant users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

10. CHANGES TO THIS PRIVACY POLICY

10.1 Changes

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will publish the revised Privacy Policy and update the “Last Updated” in the Valmista -platform. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Valmista Platform will be subject to the revised Privacy Policy.

10.2 Contact details

If you have any questions about this privacy policy, or about how we use your data, you can contact us in the email address info@valmista.com .