Attracs and its subsidiaries (Attracs) respects your privacy. This Privacy Statement outlines your rights to privacy and our commitment to safeguarding your personal data.
Attracs as a European corporation, with legal entities, business processes, management structures and technical systems that cross borders. Attracs delivers software and services to private and public businesses (Customers) in Europe. Attracs’s head office is located in Kokkola and the Attracs is subject to European privacy legislation, including the General Data Protection Regulation (GDPR).
All major decisions regarding privacy in Attracs are made at a corporate level supervised by the Data Protection Officer (DPO).
This Privacy Statement is available on our Attracs.com home page and at the bottom of every Attracs website.
This Privacy Statement applies to all business processes in Attracs and to all Attracs websites, domains, mobile solutions, cloud services and communities as well as Attracs branded websites (Attracs Sites). Service specific appendices will be found in the Terms of Service, data processing agreements or equivalent information for the specific service in question.
The Privacy Statement provides information about data processing carried out by Attracs when Attracs determines the purpose and means of the processing (Attracs act as data controller). It also provides information on data processing Attracs do on behalf of our Customers based on their instructions (the Customer as data controller and Attracs as data processor).
Personal data is information that can identify you as a person, such as an email address, street address or phone number etc. Processing your personal data is necessary for us to serve our Customers. Please do not use Attracs Sites or our services if you do not agree with how we process personal data according to this Privacy Statement.
Attracs process personal data about job seekers and contact persons or software users tied to our Customers. In addition we process personal data about persons representing potential Customers (leads) that approach us via Attracs Sites or other channels. Our statement in these regards is to be found in the data controller section.
We also process data on behalf of our Customers of which the Customer controls. Our statement in these regards is to be found in the data processor section.
In this Privacy Statement data subjects may also be referred to as persons or you.
To manage our Customer relations in general and to meet our Customer commitments, Attracs needs information about you in your role as Customer contact person or user of a service. The purposes of processing this personal data are:
The legal ground for processing personal data according to the above-listed purposes in letter a) to i) is mainly because Attracs has a legitimate interest in processing your personal data from a business perspective in a manner that we believe do not conflict with your privacy rights or freedoms. The legal ground for processing personal data according to the purpose listed in letter j) is your consent.
Attracs process personal data about Leads for marketing purposes. In order to provide targeted and relevant content to potential Customers, Attracs builds an interest profile based on your movement, choices and actions on Attracs Sites as well as your response to marketing content per email. The legal grounds for such processing is mainly your consent.
You can read more about how we create such profiles, how you can adjust the profile as well as withdraw your consent in the sections below.
If you are a jobseeker, we process personal data in order to evaluate your potential to become a Attracs employee. The legal grounds for such processing is your consent.
In order to monitor access to our premises, we process personal data about visitors. The processing is based on our legitimate interest to protect our business secrets, employees, premises and you as a visitor. You will be informed of your rights in this context when you register in our electronic visitor system.
In general, Attracs collects personal data directly from you or other persons linked to our Customer. These persons may be a manager or colleague. If the Customer you work for purchases Attracs products or services via a Attracs partner company, we may collect information about you from the partner company.
In some cases, we may also collect information about you from other sources. These sources may be third-party data aggregators, Attracs’s marketing partners, public sources or third-party social networks. Attracs will be able to combine personal data about you obtained from one source with data obtained from another source. This gives us a complete picture of you, which also gives us the possibility of serving you in a more relevant way with a greater degree of personalisation.
Attracs uses different digital tracking technologies to collect information about your movements on Attracs Sites and when interacting with us.
Pixel tags are scripts that executes when a user lands on a website or opens an email. The pixel itself is not visible and can only be seen in the HTML of the site or email. It calls an application on a server that will cause a third party cookie to be downloaded to your computer or registers that the email has been opened.
If you would like to know more about cookies and how they work, please visit www.allaboutcookies.org.
Google Analytics: This cookie allows us to see information on user website activities including, but not limited to page views, source and time spent on a website. The information is depersonalized and is displayed as numbers, meaning it cannot be traced back to individuals. This will help to protect your privacy. Using Google Analytics we can see what content is popular on our websites, and strive to give you more of the things you enjoy reading and watching.
Google Analytics Remarketing: Places cookies on your computer which means that after you leave our website, Google can show you advertisements about Attracs that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
Google AdWords: By using Google AdWords code, we are able to see which pages helped lead to contact form submissions. This allows us to make better use of our paid search budget. This information is not personally identifiable.
Google Adwords Remarketing: Places cookies on your computer which means that after you leave our website Google can show you advertisements about Attracs that you might be interested in, based on your previous behaviour on our website. This information is not personally identifiable.
You can prevent the information generated by the Google cookie about your use of our Sites from being collected and processed by Google in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser. This Add-on is available at http://tools.google.com/dlpage/gaoptout.
Facebook Remarketing: the Facebook pixel tag places cookies on your computer which can send an alert back to Facebook telling Facebook that you have checked out the website. We then assume that you have an interest for Attracs and the content on this site. When visiting Facebook, you will then be exposed to information or adds with similar content. Please use your privacy settings on Facebook to limit exposure to marketing of this kind.
The type of personal data that Attracs process about you may be:
Basic contact details such as name, address, telephone number and email.
Employment information such as employer, title, position including preferences and interests in professional context
Feedback, comments or questions about Attracs or concerning our products and services
Photos or video of you recorded at our premises
Content you have uploaded such as photos and video
Unique user information such as login ID, username, password and security questions
Financial information such as credit card information
Traffic information as provided by your web browser such as browser type, device, language and the address of the website from which you arrived and other traffic information such as IP address
Clickstream behaviour and movement on Attracs Sites and in our products and services
Email behaviour such as which emails from Attracs you open when and how
Other personal data contained in your profile that you have freely given away on third party social networks such as LinkedIn etc.
As data controller, Attracs does not process sensitive personal data about you.
Attracs may also share your personal data with external third parties in the following contexts:
If you make a post, comment or similar on Attracs user communities or other forums on Attracs Sites, such information can be read and used by anyone with access to such forums and used for purposes over which neither Attracs nor you have control. Attracs is not responsible for any information you submit on such forums or Attracs Sites. Attracs will not post any comment, testimonial or similar made by you without your prior consent.
Attracs may share your personal information with our partners in the event this is legitimate from a business perspective and according to applicable privacy legislation. For example, if you purchase a product or service on behalf of your employer that Attracs provides through one of our certified partners. In this regard, Attracs and our partner may share personal data in order to be able to provide the product or service to the Customer.
The police and other authorities may demand the handover of personal information from Attracs. In these cases, Attracs will only hand over the data if there is a court order etc. to do so.
In connection with mergers, acquisitions or divestiture of all or parts of Attracs’s business, the acquiring entity, as well as its consultants, will obtain access to data managed by the Attracs entity/entities involved and this may in some cases include personal data. In such cases, external parties will enter into a NDA with Attracs.
You have the right to opt-out of receiving marketing communications from Attracs and may do so by either:
(a) Following the instructions for opt-out in the relevant marketing communication,
(b) Change preferences under the relevant edit account section if you have an account with Attracs
(c) Contacting us via e-mail on firstname.lastname@example.org
(d) By using Attracs’s subscription manager
Please note that even if you opt-out from receiving marketing communications, you may still receive administrative communications from Attracs, such as order confirmations and notifications necessary to manage your account or the services provided to Customers.
You have the right to access your personal data by requesting an overview of the personal data we process about you and you may have a right to data portability. You also have the right to request that Attracs corrects inaccuracies in your personal data. If you have an account with Attracs for a Attracs Site, this can usually be done through the appropriate "your account" or "your profile" sections on the applicable Attracs Site or service.
Further, you have a right to request deletion of personal data, and to restrict or object to our processing of your personal data according to this Privacy Statement or other service specific terms.
Please use email@example.com to file all requests as mentioned in this section.
Finally, you also have a right to file a complaint with the data protection authorities with regards to our processing of your personal data.
Attracs takes the trust you and our Customers place in us very seriously. Attracs is committed to preventing unauthorized access, disclosure or other deviant processing of personal data. Attracs shall ensure the confidentiality of personal data we process, maintain the personal data integrity and secure its availability according to applicable privacy legislation.
As part of our commitments, we utilize reasonable and appropriate organizational, technical and physical procedures and measures to safeguard the information we collect and process, taking into account the type of personal data and risk posed to you and our Customers upon breach. Since root causes for privacy breaches are most likely to be found internally, we believe that building a strong corporate culture where respect for and awareness around privacy among our employees are fundamental to ensure lawful processing and protection of your data The following measures are of particular importance in this regard:
Data Protection Officer acting as advisor and controller in privacy matters
eLearning privacy courses that are mandatory for all employees
Data processing agreements with subcontractors that process data on behalf of Attracs
Personal data is transferred and stored in secure and redundant operating environments that are only accessible to Attracs employees and subcontractors on a need-to-know basis
Two factor identification required to login to a Attracs network
Software users are required to verify their identity (e.g. login ID and password) before they can access or make changes to their account.
Premises protected by access control and video surveillance systems
Attracs will only retain your personal data for as long as necessary for the stated purpose, while also taking into account our need to answer queries or resolve problems and to comply with legal requirements under applicable laws.
This means that Attracs may retain your personal data for a reasonable period after you and our Customer’s last interaction with us. When the personal data that we collected is no longer required we erase it. We may process data for statistical purposes, but in such cases, data will be pseudonymised or anonymised.
Attracs provides many different services to our Customers. Most of our services involves processing of the Customers’ data, hereunder their personal data. The purposes of processing is determined by our Customers not by Attracs. Making the Customer the data controller. Attracs do in such cases act as data processor and process the data on behalf of and according to instructions given by the Customer. The relation between the Customer as data controller and Attracs as data processor shall be regulated by a data processing agreement.
When the Customer act as data controller the Customer shall, according to applicable privacy legislation, ensure the legal grounds for processing the personal data. Further, the Customer shall assess and establish ownership to the risks posed to data subjects by processing their personal data. Another important aspect of the Customer’s duty as data controller is to comply with the information duty towards data subjects.
Attracs is a natural part of the Customers duties as data controller, in the sense that Attracs’s services constitutes parts of the processing of personal data that the Customer must ensure are compliant with applicable privacy legislation. Thus, when Attracs processes personal data on behalf of its Customers, we must do so in accordance with privacy legislation applicable for data processors.
In short, the Customer and Attracs are obligated to cooperate to ensure privacy for data subjects. Attracs shall provide the information necessary for the Customer to be compliant with applicable privacy legislation.
Attracs uses subcontractors to process personal data and may export your or our Customers data outside the EU in this regard. These subcontractors are typically vendors of cloud services or other IT hosting services.
When using subcontractors, Attracs will enter into a data processing agreement (DPA) with subcontractors in order to safeguard your privacy rights and to fulfil our obligations towards our Customers. When subcontractors are located outside the EU, Attracs ensures legal grounds for such international transfers on behalf of you or our Customers, hereunder by relying on Privacy Shield (US) or using the EU Model Clauses.
Attracs relies on some strategic external third parties to support our business processes and to provide our cloud services. These third parties include but are not limited to:
More information on Attracs’s subcontractors is provided in the service specific terms or in a dedicated data processing agreement. In any case, you are always welcome to request an overview and more detailed information on Attracs’s subcontractors, hereunder documentation of legal grounds for international transfers mentioned above.
If we modify our Privacy Statement, we will post the revised statement here, with an updated revision date. We encourage you to review the Statement regularly. If we make significant changes to our Statement that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website and/or social media pages prior to the changes taking effect.
The last update of this Privacy Statement was May 9th, 2018.
We value your opinion. If you have any comments or questions about our Privacy Statement, any unresolved privacy or data use concerns that we have not addressed satisfactorily, or concerning a possible breach of your privacy, please send them to firstname.lastname@example.org.
You can also send it in writing to Attracs Oy, Tietosuojavastaava, Tervahovintie 2-4, 67600 Kokkola, Finland.
We will handle your requests or complaints confidentially. Our representative will contact you to address your concerns and outline the options regarding how these may be resolved. We aim to ensure that complaints are resolved in a timely and appropriate manner.