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Eficode Privacy Policy 1. Introduction The companies within the Eficode Group (“Eficode”, “we”, “us”, or “our”), at the direction of the top management, respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share, and protect personal data across our group. It also describes your data protection rights and how you can exercise them under applicable data protection laws, including: The EU General Data Protection Regulation (GDPR) The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 This policy applies to all websites, services, and operations of Eficode and its subsidiaries. In the event you and Eficode enter into a written agreement on providing services and the agreement includes specific terms or a Data Processing Agreement (DPA), the personal data processing is agreed upon in more detail in that document and it shall prevail over this Policy. 2. Data controllers and representatives The data controller responsible for your personal data will be the Eficode Group company you have a direct relationship with. The Eficode Group companies include the following; Country Eficode Group company Business ID Finland Eficode Group Oy 3330243-5 Finland Eficode Oy 1971814-3 Sweden Eficode AB 556976-1959 Denmark Eficode A/S 30987225 Norway Eficode A/S 914 758 440 Germany Eficode Germany GmbH 12297 Netherlands Eficode B.V. 72383836 Switzerland Eficode Switzerland AG 537802 Poland Eficode Poland Sp. Z.o.o. 0000821709 United Kingdom Eficode UK Limited 05643578 USA Eficode USA, Inc. 4177603 The Eficode Group has a dedicated Data Protection Officer (DPO) that is responsible for overseeing the data processing and data protection activities throughout the group. The Eficode DPO can be contacted at: dataprotection@eficode.com. 3. Scope This Privacy Policy applies to: Visitors to our websites and digital platforms Customers, business partners, and suppliers Job applicants and employees (for applicants, see Section 9) Event attendees, marketing contacts, and research participants Users of Eficode’s customer systems (e.g. Eficode ROOT, Service Desks) 4. Personal data we collect We collect personal data directly from you, automatically through our digital systems, or occasionally from trusted partners. 4.1 Categories of data Depending on your relationship with us, we may collect: Category Examples Purpose / Use Identification data Name, job title, organisation Contract management, communication Contact data Email, phone, address Service provision, billing, customer service Technical data IP address, device data, cookies Website operation, analytics, security Professional data Role, qualifications, CV, LinkedIn Recruitment, contract management Financial data Bank details, payment info Payments, accounting, compliance Research & event data Demographics, responses, feedback UX studies, event management Marketing data Newsletter preferences, click data Marketing communications and analytics We do not knowingly collect data of children under 18 years of age. 5. How we use personal data We use your data only for legitimate business purposes. These include: Providing, operating, and improving our products and services Managing contracts and fulfilling orders Communicating with you about our services, events, or support Conducting recruitment and HR management Complying with legal and tax obligations Running analytics and maintaining security of our systems Marketing and business development (only with consent or legitimate interest) We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects. 6. Lawful basis for processing We process personal data under the following lawful bases: Contract: when processing is necessary to perform a contract or to take steps before entering into one. Legitimate interest: for business operations such as customer management, marketing, and network security. Consent: when required, e.g., for marketing subscriptions, research participation, or data sharing with partners. Legal obligation: to comply with tax, accounting, or employment laws. 7. Data retention We retain personal data only for as long as necessary for the purpose collected or to comply with applicable legal obligations. Data type Typical retention period Customer & business partner data Duration of relationship + 6 years Accounting & tax data Up to 10 years Job applicant data 2 years (renewable with consent) Marketing contacts 3 years, extended by each interaction UX/research data 2 years, extendable for active studies Event data 3 years or until consent withdrawn Data stored for compliance reasons (e.g., accounting, taxation) cannot be deleted until legal obligations expire. As Eficode operates in multiple countries, some retention periods may differ depending on the data controller and legal obligations. 8. Data protection and security Eficode implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or alteration. These include encryption, access controls, and secure storage. Eficode is certified to ISO27001 and ISO27701 Information Security Standards, and all service providers acting as processors are subject to written data protection agreements. Further details on our security practices, documents and policies are available via our Trust Centre. 9. Recruitment and job applicants The companies within the Eficode Group process applicant data for recruitment and hiring purposes. We collect: Identification and contact information Employment and education history CVs, cover letters, references, and interview notes (If applicable) right-to-work documents, credit or criminal checks, and health or diversity information Special category data is only processed where required by law or with your explicit consent (e.g., for equality monitoring or workplace adjustments). Retention for unsuccessful applicants: 6 months to 2 years, depending on the Eficode entity and applicable local laws. The retention time may be extended with the data subject’s consent. 10. Marketing and communications We may send you marketing communications about Eficode products or services if: You have provided consent; or You are an existing customer and we rely on legitimate interest. You may opt out at any time by using the form provided below. 11. Data sharing and international transfers We share personal data only when necessary and with adequate safeguards. We may share your data with: Eficode Group companies for internal operations, shared IT systems, infrastructure and business applications Subcontractors, service providers, and cloud vendors bound by contractual safeguards Partners or event sponsors (only with consent of the data subject) Regulators, authorities, or courts where legally required Eficode does not sell personal data. International transfers In certain instances, for example when necessary to use certain tools or applications, personal data may be transferred outside the EU/EEA or the UK. Where this occurs, we ensure one of the following mechanisms applies: Adequacy decision by the European Commission or UK Secretary of State Standard Contractual Clauses (EU SCCs) or UK International Data Transfer Agreement (IDTA) Binding Corporate Rules or other recognised safeguard Eficode does not rely on the EU–US Data Privacy Framework alone for compliance. Sub-processors Eficode uses certain trusted third-party service providers (“sub-processors”) to assist in operating our services. These partners process personal data only as necessary to provide their specific functions and are contractually required to protect it in line with applicable privacy legislation and this Privacy Policy. The current list of sub-processors and their purposes is available on our Trust Center, which we update as needed. 12. Data subject rights Under the applicable privacy legislation, you have the following rights: Access – Obtain confirmation and a copy of your data. Rectification – Correct inaccurate or incomplete information. Erasure (“right to be forgotten”) – Request deletion where legally possible. Restriction – Limit how your data is used. Portability – Receive your data in a portable format. Objection – Object to processing based on legitimate interest or direct marketing. Withdraw consent – At any time, for processing based on consent. Requests can be made by emailing dataprotection@eficode.com. We respond within one month as required by law. 13. Cookies and tracking Eficode uses cookies and other similar technologies on its websites for better user experience and content targeting. Cookies are small text files that are placed in the user’s device when the user is visiting Eficode’s website. By connecting information based on cookies and the user’s possible submission of form(s), Eficode creates a personal profile of the user, which helps Eficode offer personalized information and content in different channels. The use of cookies also enables Eficode to remember the user’s preferences and actions, as well as lets Eficode monitor and analyze the usability of the website. Types of cookies: Essential cookies – Required for website functionality Analytics cookies – Measure website usage and performance Advertising cookies – Customise ads and prevent repetition Eficode always asks the user’s permission to collect cookie information when they access the Eficode website for the first time with a specific device. Most browsers accept cookies automatically, but the user can always edit their internet browser settings and remove cookies. Users can avoid cookies by changing the settings of the internet browser. 14. Data Protection Authorities Eficode operates in multiple jurisdictions. You may contact your local authority if you have privacy concerns about Eficode’s data processing activities. The contact details of the data protection authorities are found from the table below. Country Data Protection Authority Contact Information Finland Tietosuojavaltuutettu https://tietosuoja.fi tietosuoja@om.fi Sweden Integritetsskyddsmyndigheten (IMY) https://www.imy.se/en/ imy@imy.se Denmark Datatilsynet https://www.datatilsynet.dk/english dt@datatilsynet.dk Norway Datatilsynet https://www.datatilsynet.no/en Germany BayLfD https://www.datenschutz-bayern.de/ poststelle@datenschutz-bayern.de Netherlands Autoriteit Persoonsgegevens https://autoriteitpersoonsgegevens.nl/en Switzerland FDPIC https://www.edoeb.admin.ch/edoeb/en/home info@edoeb.admin.ch Poland UODO https://uodo.gov.pl/en kancelaria@uodo.gov.pl United Kingdom Information Commissioner’s Office https://ico.org.uk/ 15. Updates to this Policy We may update this Privacy Policy periodically to reflect legislative or operational changes. The latest version is always available on our website. Material changes will be communicated via email or website notification.