Privacy Policy

1. Background

We care about your privacy. It is very important to us that you, as a customer, trust us to protect your privacy.

The purpose of this policy ("Privacy Policy") is to make you aware that Ekolla Oy ("Smooth Sunday", "we", "our") processes your personal data in a lawful, appropriate and secure manner. The Privacy Policy describes how Smooth Sunday processes your personal data and what rights you have in accordance with the provisions of the EU General Data Protection Regulation (EU) 2016/679 and its implementing rules and supplementary provisions on data protection ("Privacy Rules").

The Privacy Policy applies (i) when Ekolla offers you products and services when you purchase and order on our website smoothsunday.com ("smoothsunday.com"), (ii) when you otherwise communicate with us via the smoothsunday.com website, social media, email or telephone and (iii) if you have a valid contract (order) with us.

2. Definitions

In this Privacy Policy, the term "personal information" refers to information that refers to an identified or identifiable natural person, e.g., name, address, social security number, date of birth, payment card number, email address, telephone number, purchase history, and IP address.

This Privacy Policy describes how we process your personal data. The term "processing" means, for example, that we register, store, transmit and otherwise use your personal data as described in this Privacy Policy.

3. Data Controller

Company: Ekolla Oy

Business ID: 3182445-9

Address: Sykeraitti 7, 40630 Jyväskylä

Ekolla Oy is responsible for the processing of your personal data as the controller.

4. Why do we process your personal data?

Smooth Sunday processes your personal data for various purposes. In summary, the processing takes place in order to:

  • To deliver goods and services and otherwise fulfill the purchase agreement entered into with you in connection with a purchase or order,
  • Enables general customer relationship management and customer service, e.g. when you contact our customer service by email or telephone,
  • To improve the services and products we offer,
  • To provide personalized services tailored to individual users,
  • To market services and display advertisements on our own services and on the smoothsunday.com website, which is supported by advertising;
  • Provide information about events, send newsletters and send offers by post, email, telephone,
  • To provide you with information and otherwise communicate with you via social media;
  • Prevent fraud and manage risk, and
  • Comply with applicable legislation.

For those of you who have a valid contract (subscription) with Smooth Sunday, in addition to the above, Smooth Sunday  also processes your personal data in order to:

  • Manage your account,
  • Offer special offers, and
  • To contact you and provide you with personalized offers that we think are right for you, as well as invitations to events that we think you would like to attend - all via post, email and text message.

We only collect personal information that is necessary for the purposes described in this Privacy Policy. The personal information we collect about you depends, among other things, on which of our products or services you have requested, ordered or purchased, or how you have contacted us.

When you are asked to provide personal information, e.g. when making a purchase or if you become a member of a customer club, you can choose not to do so. In the event that you choose not to provide information that is necessary to use a particular product or service, this may mean that you will not be able to complete your purchase or order or that we will not be able to fulfill our obligations to you.

In some cases, we collect your personal data from other sources, such as updating address information from the population register through an authorized supplier. In addition, advertising networks, measurement tools or third parties are used to help us or them understand user behavior and preferences. For example, an advertiser may provide us with information about what happened after you clicked on an ad so that we can measure the effectiveness of the ad and become more relevant to you as a customer. We collect this personal data by using cookies (small text files stored on your device) at smoothsunday.com. We do this to make smoothsunday.com and our online services work as well as possible and to give you a good customer experience with tailored content. Read more about the use of cookies in section 9.

5. What personal data is processed and on what legal basis?

In connection with a purchase, order and certain marketing

The personal data we process when making a purchase or order on the smoothsunday.com website is:

  1. first and last name,
  2. billing and delivery address,
  3. telephone number,
  4. e-mail address,
  5. personal identification number,
  6. account and payment information,
  7. purchase history,
  8. IP address and information about how you use the smoothsunday.com website, for example, which products and/or services you have been interested in, search and click history, and your order history and purchasing habits.

The processing of personal data is necessary for Smooth Sunday to be able to offer the sale and delivery of products and services and thus fulfill the purchase contract with you.

Personal data may also be used for subsequent up-selling by offering you benefits such as discounts, general and personal offers, invitations to events, gifts or other direct marketing that we believe you may be interested in and that are useful to you. This processing is based on our legitimate business interest in providing you as a customer with advantageous offers and a better customer and shopping experience. In this assessment, we have reviewed the balance of interests, taking into account that the processing does not involve any sensitive personal data and that we have a clear business interest in being able to market our products and services to you as a customer in an effective manner.

WITH YOUR CONSENT OR FOR ACTIVE SUBSCRIPTION

The personal data we process with your consent or based on an active subscription are:

  1. first and last name
  2. billing and shipping address
  3. telephone number
  4. e-mail address
  5. personal identification number
  6. membership number and membership level
  7. Which newsletters have you been involved with and which of our events have you subscribed to and/or attended?
  8. Password
  9. IP address
  10. Information about how you use the smoothsunday.com website, for example, which products and/or services you have been interested in, your search and click history, and your order history and purchasing habits.

The processing of personal data takes place with your consent or because the processing is necessary for Smooth Sunday to be able to administer your membership and fulfill the customer club membership agreement with you.

Smooth Sunday processes your personal identification number to securely identify your identity or personal data. We always minimize the use of your personal identification number as much as possible.

When you are logged into your membership account on the smoothsunday.com website, we can see your preferences. We can see which products and services you are interested in, what types of products you buy, and which products you put in your shopping cart but then remove from the shopping cart. We store and use this information to fulfill the contract we have with you, which means, among other things, that we send you personalized offers based on your preferences. For more information about how your personal data is processed in connection with your membership, please see the customer club membership terms and conditions.

IN CONNECTION WITH CUSTOMER SERVICE, SERVICE AND RISK MANAGEMENT

The personal data we process when you contact us is:

  1. first and last name
  2. billing and shipping address
  3. communication with you
  4. telephone number
  5. e-mail address
  6. personal identification number
  7. account and payment information
  8. information from customer survey
  9. membership number and membership level, if you are a customer club member, and
  10. IP address and information about how you use the smoothsunday.com website, for example, which products and/or services you have been interested in, your search and click history, and your order history and purchasing habits.

The processing of personal data is necessary for Smooth Sunday to be able to provide good service through our customer service and investigate complaints, thereby satisfying our legitimate interest in providing customer service and improving and developing our business. Furthermore, the processing of personal data to prevent misuse of the services, to prevent illegal logins and to prevent crimes against our business is a legitimate interest. In addition, it is an interest to keep our services up to date, which is why we need to analyze the use of the services so that we can make improvements for you as a customer.

If you contact us by email, post or other means, we may record this communication and the comprehensive information you provide in the message and use it to respond to or process your request.

COMPLIANCE WITH LEGAL REQUIREMENTS

Some of the personal data processed by Smooth Sunday is used to comply with legal obligations in accordance with the requirements of laws, judgments or government decisions. Such requirements may refer, for example, to requirements regarding product liability and product safety, such as developing communication and information to the public and customers regarding the return of products, for example if a defective or dangerous product is suspected. This may also be required by the Accounting Act (1999:1078) or the Money Laundering Act (2017:630). Personal data processed in order for Smooth Sunday to comply with its legal obligations generally include:

  1. first and last name
  2. telephone number
  3. payment history
  4. e-mail address
  5. personal identification number
  6. communication with you
  7. Information about any purchases, e.g. which product you have purchased and any complaints about the product.

6. Social media

Ekolla uses Facebook and Instagram as channels to contact customers and to market and inform about our services. In this regard, Smooth Sunday is responsible for the publication of personal data and information that contains personal data and what you do as a user on social media, for example in the form of comments, photos and movie clips. Smooth Sunday does not in any way accept that offensive content is published on social media. Smooth Sunday asks our users to report inappropriate content to us so that we can ensure that such content does not appear. Smooth Sunday can therefore also remove content that we deem necessary from the social media content

7. How long will your personal data be stored?

We will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected, for example as long as you have a valid contract (order) with us, and for 3 years after termination of the contract. In the list below, we indicate the period for which personal data is retained and the criteria used to determine the retention period.

 

Processing and purpose of processing: Process orders and purchases

Personal data: Name, email address, shipping address, billing address, payment method, order and subscription information (products ordered, order frequency, order number, etc.)

Source: Directly from the registrant and our order management system

Legal basis: contract (terms of use)

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Account creation

Personal data: Name, email address, shipping address, billing address, phone number, payment method, order and subscription information (products ordered, order frequency, order number, etc.)

Source: Directly from the registrant and our order management system

Legal basis: contract (terms of use)

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Provide customer service

Personal data: Name, email address, shipping address, billing address, phone number, payment method, order and subscription information (products ordered, order frequency, order number, etc.)

Source: Directly from the registrant and our order management system

Legal basis: contract (terms of use)

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Comply with applicable laws, such as for accounting purposes

Personal data: Name, shipping address, billing address, email address, phone number, payment method, order and subscription information (products ordered, order frequency, order number, etc.)

Source: Directly from the registrant and our order management system

Legal basis: Legal obligation (Accounting Act)

Storage period: 10 years according to law

 

Processing and purpose of processing: Personal communication and marketing via email and text message

Personal information: Name, shipping address, billing address, email address, phone number, demographic information (e.g. age), order and subscription information (products ordered, order frequency, order number, etc.), information about cookies (e.g. which products you use, clicked on)

Source: Directly from the data subject, our order management system, and first and third party analytics technology (cookies, etc.)

Legal basis: Legitimate interest

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Receiving newsletters

Personal information: Email address

Source: Directly from the registrant

Legal basis: Consent

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Develop, improve and analyze our business, processes and services

Personal data: Name, email address, shipping address, billing address, payment method, order and subscription information (ordered products, order frequency, order history, etc.), information about cookies (for example, which products you have clicked on)

Source: Directly from the data subject, our order management system, and first and third party analytics technology (cookies, etc.)

Legal basis: Legitimate interest

Retention period: Data will be retained as long as you have a valid contract (order) with us, as well as 3 years after termination of the contract.

 

Processing and purpose of processing: Collect product reviews

Personal information: Name, order and subscription information (order history, etc.), your reviews

Source: Directly from the registrant and our order management system

Legal basis: Consent

Retention period: Data is retained until you actively request deletion of the product review or for a maximum of 10 years.

8. Cookies

We use cookies on the smoothsunday.com website. You can find more information about how we handle cookies in our cookie policy.

9. Your rights

You have the right to obtain information about the processing of your personal data by us. Below is a summary of the rights you can exercise by contacting us. You can find our contact details at the end of this privacy policy.

Right to access information

You have the right to request information about the processing of your personal data free of charge. You also have the right to receive a copy of the personal data we process. This request must be submitted to us in writing and must clarify what information you want to receive. We will respond to your request without delay. If we are unable to fulfill your request to obtain the information that your request concerns, we will provide you with reasons for this. A copy of your personal data will be sent to your population registration address, unless otherwise agreed in writing. In order to protect your identity, we may ask you for additional information in connection with your request.

Right to rectification

Smooth Sunday is primarily responsible for the accuracy of the personal data we process, as the controller. If you inform us that the personal data you have provided is no longer accurate, we will correct it as soon as possible, if that is the case.

Right to erasure of data

You have the right to request that Ekolla erase your personal data without undue delay. Personal data must be erased in the following cases:

  1. if the personal data is no longer needed for the purpose for which it was collected,
  2. if you have withdrawn your consent and the processing is based solely on consent as the legal basis,
  3. if the processing is for direct marketing purposes and you object to the processing of your personal data for this purpose,
  4. if you object to the processing of personal data, which takes place after weighing the interests and your interests outweigh ours,
  5. if your personal data has not been processed in accordance with data protection rules or
  6. if deletion is necessary to comply with a legal obligation.

There may be obligations that prevent us from erasing all of your personal data immediately. These obligations arise from applicable law, e.g. accounting. If certain personal data cannot be erased due to applicable law, we will ensure that the personal data can only be used to fulfill such legal obligations and not for any other purpose.

Right to restriction

You have the right to request that Smooth Sunday temporarily restrict the processing of your personal data. Such restriction may be requested in the following cases:

  1. you believe that the personal data we hold about you is inaccurate and you have requested its correction,
  2. when the processing of your personal data is not in accordance with the rules of the data protection regulations, but you still do not want your personal data to be erased but instead restricted and
  3. when we no longer need your personal data for the purposes of the processing, but you need it to assert a legal claim, exercise or defend your rights.

If you have objected to the processing of your personal data, the use of your personal data may be restricted for the duration of the investigation. When restricting your personal data, Smooth Sunday will only store your personal data and obtain your consent in connection with further processing.

Right to data portability

You have the right to request, where we process your personal data with your consent or to fulfil a contractual obligation with you, that we provide you with all personal data we hold about you and which are processed by automated means in a machine-readable format, such as an Excel or CSV file. If technically feasible, you also have the right to request that we transfer your personal data to another data controller.

Right to object

You have the right to object to the processing of your personal data if the processing is based on a legitimate business interest and after weighing the benefits. In these cases, Smooth Sunday will ask you to specify which processing you object to. If you object to a processing, we will only continue the processing if there are legitimate reasons for the processing that outweigh your interests.

10. Consent to the processing of personal data

If you have given your consent, Smooth Sunday will occasionally send you newsletters and marketing that we believe you may be interested in, via email and/or text message, depending on the type of delivery you have requested from us.

When you consent to Smooth Sunday sending you newsletters and marketing via email, you will always receive an email with a link asking you to confirm that you want to receive mailings from us. We do this to ensure as much as possible that you are making an informed choice and that you are requesting mailings from us.

You decide whether you want to give your consent to the planned processing and when you want to withdraw your consent to such processing. If you want to withdraw your consent, please contact us as set out below or by following the link in the mailing.

Read more about what giving your consent means in section 6 above.

11. Profiling

Smooth Sunday analyzes your purchase history, purchasing behavior and behavior on the smoothsunday.com website in order to learn more about you as a customer and our customers in general and to be able to improve our offers (this is so-called "profiling"). For the same purpose, we may also process your personal wishes or preferences that you have provided to us, e.g. information that you are interested in a certain product group. We do this by analyzing what purchases you have made in the past and what products you have viewed or added to your shopping cart on the smoothsunday.com website or based on what you clicked on in our newsletters or other marketing. Based on this information, we offer you our tailored marketing and offers.

Ekolla bases the processing of personal data for profiling purposes on our legitimate interest in sending you offers and information that we believe will be of interest to you in accordance with data protection regulations. As a basis, we have reviewed the balance of interests, taking into account that the processing does not involve any sensitive personal data and that we have a clear business interest in being able to market our products and services to you as a customer in an effective manner.

You can object to the processing of your personal data for profiling purposes at any time. You can do this by contacting hello@smoothsunday.com Once we have received your message, we will stop processing your personal data for profiling purposes.

12. To whom do we transfer your personal data?

We use selected third parties to provide our services and products. This means that we share some of the personal data collected about you with them, for example, with partners such as card and communication service providers, system service providers for functions, case management and CRM systems, or service providers that provide address information, printing and distribution. Smooth Sunday takes technical and organizational measures when sharing or transferring your personal data to ensure that your personal data is processed securely. These selected third parties will only process your personal data in accordance with this Privacy Policy and to fulfill one or more of the purposes stated in this Privacy Policy. Smooth Sunday is responsible to you for the correct and lawful processing of your personal data by these third parties.

Regarding personal data shared with third parties that serve cookies on the smoothsunday.com website, we refer to our cookie policy, which you can find in the link in section 9 above.

Smooth Sunday may be required to disclose your personal data upon request in accordance with the law and government decisions. Such disclosure may be made, for example, to the police or the Finnish Tax Agency.

If Smooth Sunday undergoes changes in its operations or ownership, your personal data may also be shared with third parties. If Smooth Sunday sells all or part of its business or assets, Smooth Sunday may provide your personal data to a potential buyer or its advisor.

Smooth Sunday does not sell your personal information to third parties unless we have first received your consent.

13. How do we protect your personal data?

To protect your privacy, detect, prevent and limit the risk of hacker attacks, etc., Smooth Sunday implements a number of technical and organizational security measures. When sensitive personal data such as credit card numbers and passwords, etc. are transmitted over the Internet, this personal data is protected by one-way encryption. Smooth Sunday also implements measures to protect your personal data from unauthorized access, misuse, disclosure, alteration and destruction. Smooth Sunday ensures that access to your personal data is only granted to personnel who need it to perform their duties and that they treat your personal data confidentially.

14. Supervision and compliance

If you are in any way dissatisfied with how we process your personal data, or if you believe that your personal data has been processed in breach of data protection rules, you can contact us. You can also lodge a complaint with a supervisory authority. You can find more information on how to do this at www.tietosuoja.fi. We ensure that all new employees are provided with this privacy policy so that we can best protect your personal data.

 

The contact details of the Finnish authority are:

www.dataprotection.fi

Office of the Data Protection Commissioner

Postal address: P.O. Box 800, 00521 HELSINKI

Visiting address: Ratapihantie 9, 00520 HELSINKI

Tel: 029 566 6700 (switchboard)

Email: tietosuoja@om.fi

15. Third Party Terms

Smooth Sunday services may in some cases be subject to third-party terms and conditions. Smooth Sunday is not responsible for the use of your personal data by third parties, as they are solely responsible for your personal data and are responsible for the processing of your personal data. Therefore, it is important that you, as a customer, consider and read the terms and conditions from third parties, including those relating to the use of our payment service on the smoothsunday.com website and the service through which you choose the delivery of the product you ordered from us, in which case the credit institution and transport services will process your personal data in accordance with their own terms and conditions. The same applies if the smoothsunday.com website has a link to other websites. We also use so-called third-party cookies on the smoothsunday.com website, which you can read more about in our cookie policy, which you can find in the link in section 9 above.


16. Changing the Privacy Policy

Smooth Sunday reserves the right to amend this Privacy Policy when we deem it necessary to comply with applicable law. Such amendments are primarily required if there are changes in the law, as a result of statements from the supervisory authority or other bodies that issue statements in connection with data protection regulations. In addition, this Privacy Policy will be updated as necessary due to changes in our products and services.

When we update this Privacy Policy, the date of the last update will change at the top of the Privacy Policy and the changes will be described at the bottom under the "Change History" section. If there are material changes to the Privacy Policy or how we use your personal information, you will be notified to the extent required by law on the smoothsunday.com website or by email before the changes become effective.

17. Contact us

If you have any questions about this Privacy Policy or regarding the processing of your personal data, would like to make a request in accordance with the Privacy Policy, or would like to report a violation of this Privacy Policy, etc., you can contact us.

Ekolla Oy (3182445-9)
Sykeraitti 7, 40630 Jyväskylä
hello@smoothsunday.com