# Privacy policy - A creative & digital agency

> Privacy policy and data protection practices for Ahooy Creative Oy, detailing how visitor data and cookies are managed.

## Contact Information
**Data Controller:**
Ahooy Creative Oy (Business ID: 1800528-0)
Kauppakatu 12
70100 Kuopio, Finland

**Contact Person:**
Hanna Kivijärvi
hanna.kivijarvi@ahooy.fi

**Last Updated:** 11 June 2025

## Legal Basis and Purpose of Processing
The purpose of this register is to ensure the security of the company’s website. The collected data is used in the event of technical issues or investigations of security breaches.

*   **Legitimate Interest:** The controller must process personal data to perform business-related tasks. A balancing test has determined that legitimate interest is a suitable legal basis, as the processing does not cause serious harm to the rights and freedoms of the individuals.
*   **Consent:** Used for cookies and similar tracking technologies. Consent is given through a website banner and can be withdrawn via the “cookie settings” section.

## Content of the Register
The personal data register contains the following information obtained from website visits:
*   IP address
*   Time of website visit
*   Pages visited by the user
*   Viewing durations
*   Visitor’s browser type

## Data Retention and Disclosure
*   **Retention:** The data is not routinely deleted.
*   **Disclosure:** Data is used only by the company and authorized external service providers (such as website hosting personnel). Data is not disclosed to partners except in cases involving data breaches.
*   **International Transfers:** Data is not regularly transferred outside the EU or EEA. If non-EU/EEA service providers are used, Standard Contractual Clauses (SCCs) or the EU–U.S. Data Privacy Framework (DPF) are employed as legal bases, alongside additional safeguards like pseudonymization or Transfer Impact Assessments (TIA).

## Data Security
*   Access is restricted to designated employees and authorized contractors.
*   Users have personal usernames, passwords, and signed confidentiality agreements.
*   The system is protected by a firewall to block external access attempts.
*   Processing complies with data protection legislation and good data handling practices.

## Cookie Policy
Cookies are small text files stored on the user’s device to improve the visitor experience and analyze site functionality.
*   **Usage:** Data may be used for targeting communication, marketing optimization, and linking to information provided via web forms.
*   **Identification:** Visitors cannot be identified solely based on cookies.
*   **Management:** Users can disable cookies via the website banner or browser settings. Disabling cookies may affect site functionality.

## Rights of the Data Subject
Data subjects have the following rights, which can be exercised by contacting the controller from an identifiable email address:

### Right of Access and Portability
*   You have the right to access your stored personal data.
*   Note: When legitimate interest is the legal basis, the right to data portability does not apply.

### Right to Rectification
*   Inaccurate, unnecessary, or outdated data will be corrected or deleted without undue delay.
*   Requests must specify the data to be corrected and the reason.
*   If a request is denied, a written explanation will be provided, which can be submitted to the Data Protection Ombudsman.

### Right to Restriction and Deletion
*   You may request a restriction of processing or the deletion of your data ("Right to be forgotten").
*   If you are a contact person for a company or organization, your data cannot be deleted during that active period.

### Right to Object
*   You have the right to object to the use of your data for direct marketing and promotional purposes.
*   You may request anonymization of data where applicable.

## Right to Lodge a Complaint
If you believe your data has been processed in violation of regulations, you may file a complaint with a supervisory authority.

**Finnish Supervisory Authority:**
Office of the Data Protection Ombudsman
P.O. Box 800, Ratapihantie 9, 00521 Helsinki, Finland
Phone: +358 29 56 66700
Email: tietosuoja@om.fi
Website: www.tietosuoja.fi