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Contents Privacy Policy Latest update: 30th of September, 2026 Your privacy is important to us, and we are committed to protecting the personal information that you may provide to us. This privacy policy explains what information we may collect about you, if you browse our website and use the freely accessible service, or if you would like to learn more about our services, future development or other similar matters, and in connection you provide us with your contact details. This privacy policy is prepared by Vainu. io Software Oy with business ID 2557864-2 (“Vainu“) regarding the collection of data related to websites www.vainu.com and vainu.io (and any of its sub-sites), blogs, events arranged by Vainu. io Software Oy or its subsidiaries, and to other marketing purposes. All subsidiaries of Vainu Corporation also apply the principles and policies described herein. The purpose of this policy is to provide information to i) website visitors and ii) subscribers of newsletters, blogs and other materials iii) prospective customers about what information may be collected and how the information is used. By using our website and/or if you submit your personal data to Vainu, your personal data may be processed as explained in this data privacy policy. This privacy policy also explains your rights concerning the personal data that we process in connection with the above-mentioned activities. By using our website, you may be asked to provide us with your e-mail address if you are interested in our service, so that we may be in contact with you. By contacting you, we may provide you with more information about our service, provide you with instructions about trying our service in a demo session, answer any questions that you may have or in general provide you with relevant updates concerning the development of our service and other interesting details about current updates. If you would just like to receive relevant updates, you may subscribe for our newsletter and blog updates, and ask for a demo session later, if you and/or your organization think that Vainu’s service would be useful to your organization. After you have provided us with your contact details, you may at any time change your mind and use the unsubscribe button at the bottom of each email that you receive from us. After this, you will not receive any more relevant updates from Vainu. Vainu will only use your contact details in accordance with this Privacy Policy, which may be found in full below. We will not use your e-mail address for direct marketing purposes without your explicit consent, or sell your contact details to any third parties. 1. Controller Vainu. io Software Oy Siltasaarenkatu 8-10 00530 Helsinki Finland 2. Contact Information https://www.vainu.com/about-us/ Siltasaarenkatu 8-10, 00530 Helsinki Finland Data Privacy Officer: Sami Kekäläinen Siltasaarenkatu 8-10 00530 Helsinki Finland dpo@vainu.io 3. Personal data, purpose and legal basis of processing Data subjects are the users of Vainu’s website and the subscribers of newsletters and/or other materials through Vainu’s website, product presentation or by other identifiable means. Personal data Purpose of processing Legal basis Basic information provided by the individual, such as name, title, position, profession, country Contact information, such as phone, email address Allowing you to contact us via chat and forms on our websites Sending monthly newsletters, daily blog notifications and other materials on our website Consent Our legitimate interest to carry out our business and to improve our products and services Chat or meeting discussions Individuals’ own activity (submission of reviews, information on received/opened e-mails from Vainu) Professional interests, information of experiences with Vainu, contact preferences Improving and developing our services and products Statistical analyses Development and reporting related to the business operations Operational management, administration, analysis, categorization and development of the personal data Registration to the events of Vainu and providing information regarding the events Direct marketing Fulfill the obligations based on the law and orders of the authorities Legitimate interest to carry out our business and to improve our products and services Consent Legitimate interest to market products and services to business customers Legal obligation Direct marketing bans Respecting the customer's wish regarding direct marketing Our legal obligation to comply with the prohibition on direct marketing Information about the communication connection and terminal device, such as IP address, device ID or other device-specific identifier, and cookie information (please see section 5. “Use of Cookies and related technology”) Targeting advertising on our online services Consent Processing of personal data will be limited to what is justifiable to provide our website users with an improved experience when browsing at our website, and to what is deemed necessary for Vainu in carrying out its business and improving its services, provided that these interests are not outweighed by the data subjects rights and interests. 4. Regular sources of Personal Data Vainu collects personal data primarily from the data subjects themselves, from Vainu’s customer database and through cookies. 5. Use of cookies and related technology Cookies are small text files that can be used by websites to make a user's experience more efficient. With the cookies, Vainu can collect information about usage of the internet and online service in general. With this information, we can improve our website and the services, such as offering services targeted more accurately to data subject’s liking, e.g. by saving your favorites and by identifying you every time you return to our site. We can store cookies on your device if they are strictly necessary for the operation of the site. For all other types of cookies, we need your consent. You can manage and disable cookies in the Cookie Declaration on our website. Please note that disabling cookies can prevent you from using some content/services on our website. Vainu uses different types of cookies depending on the life span and origin. Session cookies are temporarily stored on your device and deleted when you shut down your browser. Permanent cookies will remain on your device for a certain period or until you choose to remove them. We may use first-party cookies that are placed on your device by us and collect information that we use. Third-party cookies are provided by other than us and are used, for example, to collect information for advertising and tailor-made content as well as for web statistics. We use cookies for the following purposes: Necessary cookies are needed for our website and all functions to work, e.g. to be able to have a chat function. Preference cookies are used for improved functionality and personalization, e.g. language and the region you are in. Statistic cookies help us see anonymous information on where the visitors come from and what parts of our website are used most so we can improve the website and its performance. Marketing cookies are used to display relevant and engaging ads, usually on third party websites, by collecting information about your activities on our website. Vainu may use other technologies or third-party analytical software to collect and use certain non-personal data that does not enable Vainu to identify the person. Vainu may use such non-personal data for purposes of analyzing usage of the websites and services, and managing, providing, and further developing the websites and services. Non-personal data may include general, aggregated or demographic information. It will not be linked to any personal information, through cookies or other means, without the person’s consent. This type of anonymous, aggregated profiling and session data may include information that the person has provided to Vainu through the use of the websites, services or products, or taking a part in surveys, polls, etc. However, it will not be tied to any personal information, without the person’s consent. 6. Transfers and handling of Information The data that Vainu collects may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers (e.g. if our service provider or supplier is located outside EEA). The information may also be disclosed to a third party during a negotiation of any merger or acquisition and the receiving party has undertaken to follow non-disclosure liabilities with respect to the disclosed information. Only necessary personal data is shared with these third parties. Vainu will only disclose personal data based on a contract to third parties operating outside EU/EAA, which have taken steps to ensure that adequate data protection arrangements are in place in accordance with the data protection regulation. These may include, but are not limited to, Data Protection Agreements, adequacy decision or standard contractual clauses provided by the European Commission. Personal Data may be disclosed to authorities in cases required by the mandatory local legislation or court order. Data may also be disclosed if the disclosure is permitted by applicable law, regulation or agreement or consented by the data subject. 7. Retention of Personal Data Personal data will be stored only as long as and only to the extent that is necessary in relation to the initial and compatible purposes of processing. When such requirements no longer exist, personal data will be deleted. The requirements is deemed to exist during the period that the data subject receives emails or other materials from Vainu based on consent. If the data subject has unsubscribed from receiving any communication from Vainu and there is no other legal basis for processing, personal data will be stored for a limited amount of time, should the data subject wish to re-subscribe to receive information from Vainu. Vainu will keep up-to-date internal policies regarding the erasure of such personal data. In any event, the personal data is stored in accordance with possible applicable lawful storing period. Vainu evaluates the need to store personal data regularly. In addition, Vainu performs all possible reasonable measures to ensure that any inaccurate, incorrect or outdated personal data will be deleted or corrected without delay. 8. Data Security The information security of personal data and processing and confidentiality, integrity, and usability are ensured with appropriate technical and administrative measures in accordance with Vainu's information security principles. The vast majority of Vainu’s personal data is in electronic form. In case there are physical documents containing personal data, such documentation is destroyed immediately. The servers used by Vainu are protected by appropriate firewalls and technical security. All databases and information systems are accessible only with individual and personal login information (username and password) granted by Vainu. The rights to access the database are restricted so that the information can only be viewed and processed by persons who are legally admitted and required to do so. The employees of Vainu have bound themselves to comply with professional secrecy and concealment regarding the information they receive during the processing of personal information. Privacy and security guidelines have been communicated to employees and Vainu shall strictly enforce privacy safeguards within the company. 9. Rights of the Data Subject Information and access to personal data Data subject has right to receive information; what data is being collected, the purposes of the processing for which the personal data are intended as well as the legal basis for the processing and the recipients or categories of recipients of the personal data, if any. Right of access by the data subject Data subject has the right to obtain confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data. If a request is made by the data subject, Vainu will provide a copy of the personal data undergoing processing.. Right to rectification Data subject shall have the right to rectify inaccurate personal data concerning him or her. Taking into account the purposes of the processing, data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. In case there are changes in personal data, the data subject must notify such changes to Vainu. In addition, Vainu is responsible for ratifying data it recognizes to be erroneous itself without delay. Data used for direct marketing Data subject has the right to object to direct marketing at any time and free of charge. Right to withdraw consent Data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. For example, the data subject can unsubscribe from receiving newsletters by using the unsubscribe link at the bottom of each email that is sent to data subjects and following the simple instructions on the unsubscription page. Right to erasure Data subject has the right to request the erasure of personal data, if the legal basis for the processing of personal data has ceased. Despite the request for erasure, the data may not be erased if Vainu is obliged to process personal data for the establishment, exercise or defense of legal claims. Right to data portability Data subjects have the right to receive personal data concerning him or her, in a structured, commonly used and machine-readable format and to transmit the data to another controller, in case technically appropriate and not disproportionate for Vainu. Right to lodge a complaint to the supervisory authority You may also lodge a complaint to the supervisory authority if you consider that the processing of personal data violates the relevant data protection legislation in force. The national supervisory authority in Finland is Data Protection Ombudsman (tietosuoja@om.fi). 10. Contact information and changes to the Privacy Policy All requests concerning the exercise of data subjects’ rights may be submitted primarily to the following address privacy@vainu.io or to the Data Privacy Officer dpo@vainu.io. Vainu has the right to change or update this privacy policy at any time. We recommend that you read the privacy policy from time to time.