Legal
With this Privacy Notice we provide you information about why and how we process your personal data in our business operations. Please note that we process personal data both as a controller and a processor (see Section 3 of this Privacy Notice for more information of our data processing activities as a processor).
We process your personal data for the following purposes as a controller:
- Customer relationships
- Strategic analysis of customer data to develop services and fulfil customer needs
- Direct marketing
- Business partner relationships
- Communications
- Social media
- Cookies
- Recruiting
1) WHAT TERMS ARE USED IN THIS PRIVACY NOTICE?
Controller means the party responsible for processing the personal data of the data subject.
Customer means our customer who uses our robocall service to contact End-Customers. When we process personal data of our Customers, we refer to the personal data of our Customer’s contact persons, as our Customers themselves do not have personal data since they are legal persons. We are a controller of the personal data of our Customers.
Data subject is a term for a human being in accordance with data protection laws.
End-Customer means a customer of our Customer who participates in the robocalls of our service. We are a processor of the End-Customer’s personal data, whereas our Customer is a controller of the End-Customer’s personal data.
Legal basis for processing means the legal ground on which the controller processes the data subject’s personal data. The lawfulness of processing is described in Article 6 of the GDPR.
Personal data means any information concerning the data subject or information by which the data subject can be identified.
Privacy notice means a document drawn up in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (hereinafter ”GDPR”), through which the controller informs data subjects of the ways their personal data is processed.
Processor means the party who processes personal data on behalf of the controller.
Purpose for processing means the reason why the controller processes the data subject’s personal data.
2) OUR CONTACT DETAILS
On-Time Research Solutions Oy (Business ID: 2562657-9)
Kauppakatu 39,
40100 Jyväskylä, Finland
If you have any questions regarding the privacy notice, please contact Ilari Aalto (ilari.aalto@ontime.fi).
3) WHEN DO WE ARE A PROCESSOR?
We are a processor, and our Customers are controllers for the personal data of End-Customers that we process on behalf of our Customers.
We process the personal data of End-Customers on behalf of our Customers when our Customers use our robocall service to contact or be a point of contact for End-Customers.
When we process personal data of End-Customers on behalf of our Customers, we comply with the provisions of our data processing agreement (see Section 5 of our Terms of Service).
4) WHY DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data in accordance with the processing purposes listed below. In the sections on processing purposes, you will find information on what personal data we process and on what legal basis we process your personal data.
a) Customer relationships
Explanation: Personal data is processed to conclude and carry out customer relationships.
Category of data subjects: Customers.
Categories of personal data: Contact details, pictures and videos, and customer relationship data.
Legal basis for processing: Performance of our contractual obligations with the Customers.
b) Strategic analysis of customer data to develop services and fulfill customer needs
Explanation: Personal data is processed to develop our services and better fulfill customer needs.
Category of data subjects: Customers.
Categories of personal data: Contact details and customer relationship data.
Legal basis for processing: Our legitimate interests, according to which we develop our services and better fulfill customer needs. Our interests override those of the Customers, as we need to be able to analyze our data to enhance our services.
NB! You may have a right to object data processing for these purposes (see section concerning your rights).
c) Direct marketing
Explanation: Personal data is processed to market our services.
Category of data subjects: Customers and potential Customers
Categories of personal data: Contact details and customer relationship data.
Legal basis for processing: Our legitimate interests, as we need to market our services in order to carry out business. Our interests override the interests of our Customers and potential Customers since we carry out direct marketing in accordance with applicable laws.
NB! You may have a right to object data processing for these purposes (see section concerning your rights).
d) Business partner relationships
Explanation: Personal data is processed to conclude and carry out business relationships.
Category of data subjects: Business partners (contact persons).
Categories of personal data: Contact details and data related to our relationship.
Legal basis for processing: Performance of our contractual obligations with our business partners.
e) Communications
Explanation: Personal data is processed to carry out communications.
Category of data subjects: People who contact us.
Categories of personal data: Contact details and possible other data disclosed to us by the data subject.
Legal basis for processing: Our legitimate interests, according to which we carry out our communications. Our interests are in line with those of the people who contact us, as they expect us to process their data for communications purposes.
NB! You may have a right to object data processing for these purposes (see section concerning your rights).
f) Social media
Explanation: Personal data is processed in our social media sites and accounts.
Category of data subjects: People who contact us.
Categories of personal data: Contact details and possible other data disclosed to us by the data subject.
Legal basis for processing: Our legitimate interests, according to which we manage our social media. Our interests are in line with those of the people who contact us, as they expect us to process their data for communications purposes.
NB! You may have a right to object data processing for these purposes (see section concerning your rights).
g) Cookies
Explanation: Personal data is processed in cookies of our websites.
Category of data subjects: People visiting our websites.
Categories of personal data: IP addresses.
Legal basis for processing: Consent based on the Act on Electronic Communications Services of Finland (917/2014).
Please have a look at our Cookie Notice for more information about cookies used in our websites.
h) Recruiting
Explanation: Personal data is processed to carry out recruiting.
Category of data subjects: Job applicants.
Categories of personal data: Contact details, CV data, videos and pictures, bank data, and possible other data disclosed to us by the data subject.
Legal basis for processing: Our legitimate interests, according to which we carry out our recruiting. Our interests are in line with those of the job applicants, as they expect us to process their data for recruiting purposes.
NB! You have a right to object data processing for these purposes (see section concerning your rights).
5) FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data from different sources, depending on our purposes for processing personal data.
a) Customer relationships / b) Strategic analysis of customer data to develop services and fulfil customer needs / e) Communications / f) Social media / h) Recruiting
We collect your personal data for these purposes from yourself.
d) Business partner relationships
We collect your personal data for these purposes from yourself, our business partners, and different public sources (e.g. trade register and social media).
c) Direct marketing
We collect our Customers’ personal data for these purposes from the Customers themselves.
We collect our potential Customers’ personal data for these purposes from the potential Customers themselves and different public sources (e.g. trade register and social media).
g) Cookies
We collect your personal data by using cookies.
6) DO WE TRANSFER YOUR PERSONAL DATA?
We may transfer personal data to third parties as a normal course of our business. When personal data is transferred to third parties, we ensure that the transfers are carried out in a secure way and in accordance with adequate data protection agreements.
We may also transfer personal data to third countries. When doing so, we ensure an adequate level of data protection, e.g. by using standard contractual clauses issued by the European Commission, and other similar arrangements.
All personal data may be transferred to data storage and communications services providers. Accounting-related data may be transferred to financial management services providers.
7) HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
The retention period of your personal data depends on the purposes for which we process your personal data. We inspect the necessity of the personal data stored regularly and keep records of the inspections.
a) Customer relationships / d) Business partner relationships
We process and retain personal data for as long as our contractual relationship is in effect.
b) Strategic analysis of customer data to develop services and fulfill customer needs
We process and retain personal data for as long as it is necessary to fulfil the purpose of data processing.
c) Direct marketing
We process and retain personal data for as long as it is relevant or until you prohibit us (i.e. opt-out) from processing your personal data for direct marketing purposes, or when we find out that you no longer wish to receive marketing.
e) Communications
We will process and retain the necessary personal data for three (3) years after the contact.
f) Social media
We will process and retain social media information until individuals remove their information from our social media channels.
g) Cookies
The retention period depends on each cookie used.
h) Recruiting
We will process and retain the necessary personal data for a maximum of twelve (12) months from the receival day of your job application.
8) WHAT DATA PROTECTION RIGHTS DO YOU HAVE?
You may have the right to use the below-listed data protection rights. The contacts concerning the rights shall be submitted to the controller’s contact person. Your rights can be put into action only when you have been satisfactorily identified.
You may also have a right to lodge a complaint to the supervisory authority, if you think that the processing of your personal data infringes the data protection laws.
Right to inspect
The data subject has a right to inspect what data the controller has stored of him/her.
Right to rectify and erasure
The data subject has a right to request the controller to rectify or erase the personal data concerning the data subject on the grounds provided by law.
Right to restriction of processing
The data subject can request the controller to restrict the processing of the personal data concerning the data subject on the grounds provided by law.
Right to data portability
The data subject shall have a right to receive the personal data concerning him/her, which he/she has provided to the controller, in a structured, commonly used, and machine-readable format where the processing is performed automatically and based on consent or a contract.
Right to object
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him/her for such marketing.
Where personal data are processed on the basis of the legitimate interests of the controller, the data subject shall have the right to object the processing of personal data concerning him/her for such purposes in accordance with the law.
Automated individual decision-making, including profiling
The data subject shall have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or similarly significantly affects him/her.
Right to withdraw consent
Where the legal basis for the processing of personal data is the consent of the data subject, the data subject shall have the right to withdraw his/her consent.
9) CAN THIS PRIVACY NOTICE BE AMENDED?
We may unilaterally amend this privacy notice. We update the privacy notice as necessary, for example, when there is a change in legislation. Amendments to this privacy notice will take effect immediately when we post an updated version on our website.
If we make significant changes to the privacy notice, or if there is a significant change in the way it is used, we will notify the data subjects.
Generally
We use a wide range of cookies on our website, some of which are controlled by ourselves (first-party) and some of which are controlled by other organizations (third party). Some of the cookies are considered necessary for us to be able to deliver the website to you and others help us enhance our understanding of how you use our website as well as assist us in our marketing activities.
Under the Act on Electronic Communications Services of Finland (917/2014), we are required to obtain your consent for any use of cookies which is not considered as necessary, as well as provide you with information as to what these cookies do.
About cookies
Cookies on our website are used for a variety of different purposes, but generally speaking their use breaks down into the following categories:
- Necessary cookies, which are cookies required for the operation of our website. They include, for example, cookies that enable you to securely use our website.
- Non-essential cookies, which are cookies used for business purposes which are not considered necessary to deliver the website to you. Such cookies include analytics cookies and marketing cookies.
We use the following non-essential cookies:
- Google Analytics
- Hotjar
- Hubspot
- Facebook
Your choices regarding these cookies
Necessary cookies will be placed in your web browser without your prior consent. These are being used to maintain the functionality of the website. Any non-essential cookies will only be placed in your web browser with your prior consent.
CEO’s foreword
As a new industry, multichannel communication optimization algorithms based on Machine Learning (ML) and call robotics include some aspects to which the standards of other sectors cannot be directly applied. What we do is closely linked to factors associated with privacy, personal data protection, information security and ethical considerations. Often, our operations include a conversation about questions like customer experience and reputation. As pioneers of change, we carry a responsibility for taking these issues into account and thinking about what kind of society we want to build for the future generations.
When it comes to the field of multichannel communication optimization algorithms and call robotics, society has not had time to come up with a comprehensive set of regulations. We are fully aware that, in situations where traditional regulation has not been able to keep up with the latest phenomena, we as individuals as well as a company are responsible for creating rules that will help us build a better future – and for faithfully sticking to those rules.
Here then is a summary of the rules and business principles to which we adhere in everything we do – we call them our Code of Conduct.
We would also like to thank the Data & Marketing Association of Finland (DMA Finland) for their sparring during the drafting process of these principles. With your cooperation, we have had good opportunities to create functional practices and guidelines for our industry regarding call robotics, which are in everyone’s interest. We would also like to thank the Data & Marketing Association of Finland (DMA) for sparring with us during the process of drawing up these principles. Working in cooperation with you, we have a good chance of creating good policies and rules for call robotics industry that will benefit us all.
-Teemu Valkonen, CEO, On-Time
“When it comes to advanced technology, like robotics, regulation is always a little bit behind the curve. You can tell a responsible company from the way it creates ethically sustainable operating models and keeps a close eye on the field based on terms and conditions, limit values, recommendations, and other measures.”
-Jari Perko, CEO, ASML
1. On-Time’s general principles
Proper appreciation for the benefits of multichannel communication optimization algorithms and automated calls
Multichannel communication optimization algorithms and call robotics has a lot to give in many areas of society but, for most people, it is still a bit of an unknown quantity. We want to be advocates of the useful and legitimate applications of multichannel communication optimization algorithms and call robotics call robotics by showing that, properly used, our service will significantly benefit both the operators using it and their customers.
Ethics as a guideline
With regard to the use of our service, we want to stress that ethics must inform every aspect of multichannel communication optimization algorithms and call robotics. The use of multichannel communication optimization algorithms and call robots and personal contacts are subject to the same rules: the communication must be customer-friendly and legal.
For our part, we want to help create an ethical operating model for the industry. We believe that a framework of rules that works and is sufficiently detailed will benefit us, our customers and, first and foremost, the customers and partners of our customers who answer robocalls.
Sustainable multichannel communication optimization algorithms and call robotics
The only sensible way to make sure that the benefits of multichannel communication optimization algorithms and call robotics will be utilized in the future is by having the operators involved in building an operating framework for the industry. What we need is a sustainable operating model instead of easy winnings, and that is what we want to create for Finland.
We want to avoid the problems that call robots have created, for example, in the United States where the majority of calls are various scams or otherwise unethical. We believe that, as a small language region, Finland is well-equipped to efficiently regulate operations in the call robotics industry and ensure that the operations are on a sustainable basis.
2. Use of On-Time’s service
Using the service
We feel strongly that our service should only be used for activities that are in line with our own policies. To ensure this, we have specified in our terms and conditions the purposes for which our automated call robotics and multichannel communication optimization algorithms service can be used. Customers must accept these terms and conditions in order to use the service.
Our service is meant exclusively for:
- the implementation of automated opinion polls, market surveys, customer satisfaction surveys, other surveys, or stakeholder communication by phone.
Our service may not be used for:
- Direct marketing, telemarketing, fundraising, or political advertising (without the recipient’s explicit consent)
- Conveying political messages or messages that are defamatory or discriminatory, constitute an infringement of privacy, or are otherwise illegal
- Conveying messages that paint a misleading picture of a third party
- Conveying messages that cause direct or indirect damage to a service provider or a third party
- An abnormal purpose, which causes the service to be disrupted or interrupted.
Requirements pertaining to the use of the service by customers
Our customers are responsible for using the service in accordance with the Information Society Code (917/2014) and other established laws. In addition, the use of the service must ensure that:
- The call recipients understand that the call is an automated opinion call, market survey, customer satisfaction survey, another survey, or message to stakeholders
- The call recipients are told clearly who or which party is behind the survey, or message and what the purpose of the survey or message is
- The call, including recordings, is tested before using it for an actual survey or actual communication.
Use in breach of the terms and conditions
If a customer is deemed to have used our service in breach of our terms and conditions, the customer’s access right will be canceled with immediate effect and the customer will be fully liable for any consequences to a service provider or third party arising from the use of the service in breach of the terms and conditions.
If the service provider becomes subject to a claim for damages, charge or a temporary or permanent service interruption as a result of the use of the service in breach of the terms and conditions, the customer who has breached the terms and conditions will be liable in full for the damage caused to the service provider. The service provider reserves the right to amend these terms and conditions.
3. Confidentiality of Operations
Confidentiality is the cornerstone of our operations
Our business is extremely data-intensive, which is why strict confidentiality is the basic requirement of our operations in all circumstances. We do not disclose any data provided by our customers to any third parties.
Data security applies to all of our activities
We adhere to a strict data security policy with regard to data processed both in the virtual environment and in the physical world. When processing personal data, we comply with all legal requirements. The system we provide for our customers also enables the legal processing of personal data.
4. On-Time as an employer
People are the core of our business
Even though the technology is an essential part of the service we sell, the most important thing for us is to work with good people. This applies equally to our employees as well as our partners and customers. The atmosphere at our office is one of fairness, equality, and openness. Each of us can – and should – speak their mind.
The right balance between freedom and responsibility
At On-Time, we appreciate the freedom to influence the content of our work. We are also empowered to make decisions regarding our work. In order to use that freedom and power correctly, we must understand and take responsibility for our company’s goals and results.
We share a personal interest in the industry
We feel privileged to work in an industry we are interested in even outside the parameters of work.
We share a strong interest in all things new, especially automation. Our aim to automate operations springs from a desire to focus on factors that can genuinely make a difference in terms of our happiness. The wish to improve drives us forwards – we are a group of people that is creating something entirely new together.
5. Sticking to our principles
Our principles guide us and our customers alike
Because the legislation is yet to catch up with our industry, we take great care in following our moral and ethical principles. Through our own actions, we want to improve the reputation of multichannel communication optimization algorithms and call robotics as an industry and ensure that its future is bright.
Our duty is to tell our customers about the principles to which they agree when using our service. Sticking to the rules is our responsibility as well as that of our customers.
