AFORE DATA SECURITY STATEMENT

1. PRIVACY

1.1 What personal information do we collect and why?
The collection and processing of personal information at Afore is based on either your consent, ful-filling a contract between you and Afore, Afore’s legitimate interest (direct marketing, duties related to the client relationship or performance of services) or to fulfill a legal obligation of Afore. In gen-eral, the processed personal data is collected directly from the registered. We do not collect infor-mation through observation.
We may collect and process personal information such as name, e-mail address and phone num-ber of customers’, potential customers’, suppliers’ or other stakeholders’ contact persons. This in-formation is used to conduct a successful business relationship (e.g. facilitate our business, sup-port sales activities, manage deliveries, provide maintenance services, invoicing, contacting cus-tomers for contract management and marketing purposes and maintaining customer relationships).

1.2 How do we protect your information?
Afore is committed to respecting individual rights and organizations’ obligations under the Finnish Personal Data Act and the EU’s General Data Protection Regulation (GDPR). We have imple-mented appropriate processes to secure all data from accidental or malicious manipulation, loss, destruction and unauthorized access. We will monitor the access to our data and report any leaks and misuse within timelines defined by law. We will not store any more information than what is needed. The security and privacy aspects are factored in the design phase of any process where we may collect personal information. Our processes are under constant risk-assessment.
Afore only stores personal data as long as it is necessary for the purpose it was collected for or as long as required under applicable laws (e.g. the Finnish Accounting Act, Act on Detecting and Pre-venting Money Laundering and Financing of Terrorism). Normally, personal data related to custom-ers is retained for seven years after the end of the customer relationship. When the personal data is no longer necessary, we will delete it.

1.3 How do we disclose or transfer your data?
Generally, Afore does not transfer or disclose any personal data it collects to third parties. How-ever, we may from time to time disclose, transfer or allow access to personal data within compa-nies belonging to the same group of companies as Afore, AEM Holdings Ltd.
We do not transfer personal data outside the EU or the EEA, apart from disclosing needed contact information inside the companies in same group. All transfers and disclosures are done only on need-to-know basis and always in accordance with applicable data protection laws. If personal data is transferred outside of the EU or the EEA, we will ensure that sufficient level of data protec-tion is maintained through appropriate safety measures, e.g. by using European Commission’s standard contractual clauses.

1.4 What rights do you have?
You have certain rights concerning your personal data granted under the applicable data protection legislation. Afore is committed to implementing these rights and responding to requests made un-der these rights. You may make use of your rights described herein (with the exception of the com-plaint to a supervisory authority) by contacting Afore via the contact details given below.
• You have the right to y request a copy of your personal data and right to access the per-sonal data processed by us.
• You have the right to request that any incorrect, outdated or unnecessary personal data of you is corrected, completed or deleted.
• You have the right to object processing on grounds relating to your particular situation
• You have the right to request the transfer of your personal data to another system
• You have the right to request the erasure of your personal data (right to be forgotten)
• You have the right to request to restrict the processing of your personal data
In addition, where any of your personal data is processed based on consent (including marketing), you may at any time withdraw your consent.
In some situations, we may have justified reasons to refuse your request to use the aforemen-tioned rights. In these situations, we will respond to you and justify the grounds for such refusal without undue delay, and in any case within the deadlines set in the applicable law.
In case you consider that we have not followed the applicable data protection legislation or this se-curity statement in processing your personal data, or you are otherwise not content with how we have realized your rights, you have the right to lodge a complaint to the competent data protection authority. List of the contact details of all data protection authorities in the EEA can be found at the European Commission’s website. The Finnish data protection authority is the Data Protection Om-budsman (www.tietosuoja.fi).

2. SECURITY
Afore is committed to protect its business, customers and other stakeholders from physical and cyberattacks. Security risks are constantly evaluated. We protect ourselves from cyberattacks and misuse with appropriate antivirus software, firewalls and analytics for server activity among other means. We have implemented various processes for internal data-protection and our personnel is educated for data security. For continuity of business, we have implemented appropriate mirroring and back-ups. Our servers are located in secure places with restricted access. For security rea-sons, the details of all systems are left out of this statement.

3. COOKIES
Our website may use cookies and we may use external services like Leadfeeder to collect infor-mation about the visitors to our website based on IP-addresses. A cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser.
A cookie contains limited non-personal data, usually a unique identifier, the name of the website and potentially your IP-address. This enables a website to recognize you as you move around the web-site and/or each time you revisit.
The information we collect through the use of cookies is collected solely to analyze the interest to-wards our products for sales and marketing purposes. Such information cannot be linked to a per-son by Afore and we will not store any personal information as a result. However, please be noted that under certain jurisdiction IP-addresses are considered to be personal data, wherefore collec-tion of your IP-address could be considered as processing personal data.
You can easily disable, refuse cookies from the cookie banner. Please note that if you choose to disable cookies, our services and website may not function properly and certain services may not be available anymore. Each browser is different when it comes to managing cookies, so check the “Help” or “Settings” menu of your browser to learn how to change your cookie preferences.

4. CONTACT DETAILS
Afore is the data controller of your personal data. Afore’s contact details are as follows:
Afore Oy (business ID 1019967-4)
Address: Vakiotie 5, FI-21420 Lieto Finland
Tel. +358 2 2746 040
Email: (info@afore.fi)
We reserve the right to modify this Privacy Statement when necessary. Modified statements will be published on this page and we recommend that you visit this section frequently so that you remain aware of the most recent changes. If you have any questions about Afore’s privacy or security measures or Afore’s processing of personal data otherwise, do not hesitate to contact us.

5. TERMS OF USE
These terms of use govern the use of the website located at https://www.afore.fi/. The website is provided by Afore Oy and/or its service providers. By proceeding to use the website, you agree to be bound by these terms, in their current form and as they may be amended by us from time to time. If you do not accept these terms, you must discontinue your use of the website immediately.
Afore takes reasonable precautions to ensure that information included in the website is accurate, but does not guarantee its accuracy. You should take appropriate steps to verify information dis-played on the website before relying on it. Downloading material from the website is done at your own risk and any materials provided via the website are provided on a “as is” basis.
While Afore takes specific interest into ensuring data security in its processes (including this web-site), we do not fully guarantee that the website will be free from all bugs and viruses. You are re-sponsible for configuring your own security settings, and you should use your own virus and mal-ware protection systems.
Neither Afore nor any of its directors, employees or other representatives will be liable for loss or damage arising out of or in connection with the use of this website. This is a comprehensive limita-tion of liability that applies to all damages of any kind including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to prop-erty and claims of third parties.
Notwithstanding the foregoing, none of the exclusions and limitations in the clause are intended to limit any rights you may have as a consumer under local law or other statutory rights which may not be excluded nor in any way to exclude or limit Afore’s liability to you for death or personal injury resulting from Afore’s negligence or that of Afore’s employees or agents.
Unless indicated to the contrary, all materials on this website including design, text, graphics and photographs are the copyright of Afore. Afore is the owner of the trademarks appearing on this website and all associated trade names, logos and devices unless indicated to the contrary. All other trademarks, logos and names appearing on this website are the property of their respective owners, as indicated. Nothing in these terms is intended to mean or meant to transfer, assign nor grant any of those rights to you. No permission is given by their respective owners for the use of any of them and such use may constitute an infringement of the owner’s rights. You must not re-produce or use images, trademarks or names displayed on the website other than for your per-sonal use without written permission of the owner.
Our website may from time to time contain links to third party website or content linked to such sites. Afore assumes no responsibility for any such third party content or links. Inclusion of any third party links or linked content to the website should not be interpreted as Afore’s endorsement of those linked website. Afore will not be liable for any loss or damage that may arise from your use of such links or linked third party contents.