Swanlake Strategy Privacy Notice

 

1. Controller

Swanlake Strategy Oy (“Swanlake”, “we”, “us”)

Lönnrotinkatu 5 (2nd floor), 00120 Helsinki, Finland

tel. +358 (0)40 801 8555

 

2. Contacts

Got a question about data protection? Drop us a line at petri@swanlakestrategy.com and we’ll get back to you.

 

3. What is this notice for?

We collect certain personal data about our clients, potential clients, partners, individuals who want to hear our news, as well as recruitment candidates.

 

We collect this data so that we can, for example, be able to respond to requests for new business, send newsletters and point of views to our subscribers, and process job applications sent to us via our website. We also use analytics on our website to learn more about how it is used and how we can improve it.

In this Privacy Notice, you’ll find details about the data we collect about you and how we use it to better your experience.

 

4. What data do we collect and how do we use it?

Recruitment candidates

 

If you apply for a job at us, we’ll collect the following information about you (you may have provided this on our website, or we’ve obtained it during the recruitment process):

  • Your name and contact information

  • Professional interests and skills

  • Where you would like to work

  • Link to your LinkedIn profile

  • Cover letter, CV and other files/information that you personally wish to send us

  • Data relevant for processing the application as obtained during discussions, interviews and other communication between us and you

 

We use this data only for the purposes of processing your application and communicating with you during our recruitment process. We do not share your information with anyone else, unless it is expressly required by applicable laws or requests by public authorities.

 

If your application involves one of our group companies, we may share your data with a representative of that company.

Clients, partners and other contacts

 

Are you an existing Swanlake client, have you subscribed to our newsletter, requested a contact regarding new business opportunities or opted to hear more about our trainings? In order to be able to stay in touch with you, we collect and process the following data:

  • Name, title, contact information

  • Information on your organization and your position in it

  • Your request and communication with us and the necessary information and notes concerning such contacts between you and us (such as services ordered and provided, billing information, information on meetings and communication between you and us).

  • Information on newsletter, marketing, event or invitation concerning you

  • Data created based on the above described data we already have.

 

We obtain this data when you send contact requests to us (e.g. subscribing to our newsletter or point of views), by receiving the data from a reliable public source such as public company databases, or in the context of our services to you or your dealings with us (e.g. contact details to communicate with you about our existing client relationship).

 

We use this data for

  • Managing the business relationship between you and Swanlake

  • Processing requests sent to us, providing our services and pursuing the legitimate interests of Swanlakerelated to such request and services

  • Promoting our services, communicating with you and sending newsletters you have subscribed to

  • Analyzing, planning and improving our operations

 

Your data is not shared with any other parties outside of Swanlake companies, unless expressly required by applicable laws or public authorities. We may also share your data to our trusted partners if processing your request or provision of our services requires us to do so.

 

Swanlake has a legitimate interest to process the above listed personal data for the purposes described above. This interest is based on your connection with us and concerns e.g. your position in a company related to us or your direct request to us.

5. Cookies and analytics

 

We use cookies on our website to improve its user experience. Cookies are small text files that a browser saves on your device and they are used, for example, when a service wants to save a your information when moving from one website to another. If you do not want to use cookies, you can change your cookie settings at any time in your browser. Please note that disabling cookies might impact the how our website functions.

 

When you access our website, we ask for your consent to allow us to store the following cookies on your device:

  • Google Analytics – We use Google Analytics to collect information about how users behave on our website. We use the information to compile reports and to help us improve the site. These cookies collect the number of visitors to the website, where visitors have come to the website from and the pages they visited. You can read more about these cookies and how Google safeguard them here.

  • Wix – Wix.com is a Processor for our site-visitors’ data. For more information about Wix’s obligations as a data processor for your customer data, see our Data Processing Agreement

 

6. Transfer of data outside of the EEA

 

Wix as our website platform can store Swnlake site-visitors' data in a number of locations. Site-visitors ́ personal information may be stored in data centers located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law.

 

Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). 

 

The security of sensitive data is of extreme importance to Wix. See all the security certifications received by Wix.com.

 

7. How long do we store your data?

 

Job candidates: We store the data collected in connection with the application process for 3 years from the date of last contact with you. If you wish, we may also store your data for a longer period in order to get in touch about future opportunities.

Our clients, and requests for new business and newsletters: We store the data only as long as is necessary for the respective purpose. Since this period depends on the case at hand, we review the necessity of our data regularly and erase data when it is no longer needed.

8. What are you rights?

You have the right to request access to, erasing and correcting your personal data as held and processed by Swanlake, as well as to send us any other requests based on then applicable data protection laws (e.g. request restriction of processing of the data). Further, you always have the right to prohibit us from sending newsletters or other marketing messages to you. Please send any requests concerning your data to the email addresses set out above in Section 2.

Data protection laws are supervised in Finland by the Finnish Data Protection Ombudsman. If you have questions belonging to the jurisdiction of the Data Protection Ombudsman, or if you wish to lodge a complaint regarding processing of personal data, you may contact the Data Protection Ombudsman’s office as instructed at www.tietosuoja.fi.

9. How do we secure your data?

We consider all personal data we collect to be confidential. Your data can only be accessed by the Swanlake employees when it is necessary for them to perform their work related to your data.

The network and equipment of Swanalke and its partners have been secured by using appropriate measures to protect the personal data against unauthorised access and accidental or unlawful destruction, alteration, disclosure, transfer or other unlawful forms of processing.

10. Changes to this Privacy Notice

We may update this Privacy Notice as we improve our website and operations. The updated notice will be made available on our website.