Attracs Privacy Statement


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.

Scope and acceptance

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.

Whose data we process

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.

Attracs as data controller

Why we process your personal data

About Customer contacts and software users

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:

  1. Execute sales and contract process to Customers
  2. Provide requested offers on products and services to Customers
  3. Perform deliveries in accordance with agreements made with you or Customers
  4. Offer support to users of our products and services
  5. Improve and develop the quality, functionality and user experience of our products, services and Attracs Sites
  6. Detect, mitigate and prevent security threats and perform maintenance and debugging
  7. Prevent abuse of our products and services
  8. Process orders, invoicing, payments and other financial follow-up
  9. Create interest profiles in order to promote relevant products and services
  10. Operate user communities to educate and enable interaction between users and Attracs

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.

About Leads

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.

About jobseekers

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.  

About visitors

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.

How we collect your personal data

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.

We will also use cookies and other tracking technologies when you use Attracs Sites and interact with us per email in order to optimise your experience of Attracs and our sites.   Please see the paragraph describing automatic data collection tools for more information on how these technologies function and your rights in this context.

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.

Automatic data collection tools

Attracs uses different digital tracking technologies to collect information about your movements on Attracs Sites and when interacting with us.

Cookies and pixel tags

Cookies are small text files that contain a string of characters and uniquely identifies a browser. They are sent to a computer by website operators or third parties. Most browsers are initially set up to accept cookies, since this is required by most website owners in order to access their sites. You may be, however, able to change your browser settings to cause your browser to refuse cookies in general, block third party cookies or to indicate when a cookie is being sent.  

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 cookies and technologies

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 cookies

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.

What personal data we process

The type of personal data that Attracs process about you may be:

  • Basic contact details such as name, address, telephone number and email.

  • Demographic Information such as date of birth, age and gender
  • 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.

How we share your personal data

Outside Attracs

Attracs may also share your personal data with external third parties in the following contexts:

Attracs user communities

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.

Business partners

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.

Public Authorities

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.

M&A

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.

Your rights

Right to opt-out of marketing communications

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

© Contacting us via e-mail on privacy@attracs.com

(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.

Basic rights

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 privacy@attracs.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.

Data security and retention

How we keep your personal data secure

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:

Organisational
  • 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

Technical
  • 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.

Physical
  • Premises protected by access control and video surveillance systems

How long we store your personal data

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 as a data processor

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.

Customer and Attracs obligations

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.

Subcontractors and export of personal data

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:

  • Google (US), provider of some of our email, office automation and our cloud services
  • Pipedrive (EU and US), provider of our preferred CRM system
  • Atlassian (NZ and US), provider of user community platforms such as Attracs Jira
  • Microsoft Azure (EU and US), provider of technical platform for our cloud services, some of our email, office automation
  • Amazon (EU and US), provider of technical platform for our cloud services
  • Hetzner (EU), provider of technical platform for our cloud services
  • Teamtailor (US), provider of our recruiting system  
  • Liquid Planner (US), provider of our project management system

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. 


Changes to this Statement

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.

How to contact us

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 privacy@attracs.com.

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.