This Privacy Notice describes how Moitea Oy (”Kong Cha”) processes personal data of its consumer-customers, and contact persons of companies, other organisations and stakeholders. Kong Cha is a data controller in its activities. In data protection related issues, you may contact the following addresses:
Moitea Oy (Kong Cha)
Business ID: 3124851-9
Vesipirtintie 4 A 11, 02330 Espoo
In the general section, we tell about the personal data processing activities at Kong Cha and about your rights regarding to your own personal data. Information relating to specific services, you may check easily and fast, how we process your personal data in connection with the services that you use. We process your personal data responsibly and want to be worthy of your trust. You can yourself influence how your personal data is processed. Your personal data is collected for making an agreement or for other dealings, for example, when you register to our service as an user, give us the consent to send you marketing communications, use our web or mobile services, you participate in marketing campaigns or questionnaires, give us feedback, or you are in other ways in contact with us. We process your personal data to perform the agreement between you and us, to deliver our services, marketing and customer communications, and to conduct customer service. Moreover, we target marketing and communications tailored to suit you. In the future, we want to create better experiences, and the collected information helps us better understand our customers.
1. Where do we collect personal data from?
We collect personal data of you, when
- You register as a user of our services
- You give us a permission to send you marketing and communications
- You participate in our marketing campaign or a marketing research or preferences study organised by us
- You give us feedback, or leave us a request to contact you, or you are in any way in contact with us
- You participate into an event organised by us
- You are our business customer or other stakeholder’s contact person, or you are in contact with us as a representative of an organisation; or
- You share, publish, comment, or send a message in Kong Cha’s social media channels. We also conduct social media monitoring in a general level to understand better our customers and to create a better understanding of what is discussed about Kong Cha or our industry.
2. Personal Data that We Collect
The personal data that we process and collect vary by what services you use, and how you use them. You can influence yourself, what kind of personal data we collect of you. Some of the personal data we collect directly from you, for example, when you come to our webite or you participate into our campaign. Part of the personal data we collect of you via web cookies and other corresponding techiques when you use our service. This way we learn, for example, how our services are being used, and how can we offer you a better service experience. We collect the following personal data of you depending on the service you use:
Name and Contact Information: We collect first name, last name, email address, and other same kind of contact information.
Demographic Information: We collect other descriptive personal data like age and/or date of birth, language, and country.
Identifier Information: We collect login information of electronic services like username and password, and other similar information for identification and security.
Campaign Information: When you participate in our marketing campaign, like a lottery or other competition, we collect the information that are associated with it, and the information relating to the participation of that campaign.
Marketing and Preferences Research Information: When we conduct marketing or preference research, we collect information through which we learn how to develop our services, business, and products.
Photos and Videos Recordings: We may take photos or video recordings in Kong Cha events. If we record you specifically, and not e.g. a crowd, we will ask for your consent to publish the photo or video recording. You can yourself influence, what information we collect. You may use most of our services without giving us the aforementioned information. The usage of certain service, like participating in a campaign, processing a reclamation, or purchasing products or services from the web service requires giving personal data. If you decide not to give us your personal data, we may not be able to offer you all the offers or contents, or give you as targeted and personalised service as when we when we get to use your information.
3. Cookies and other similar techologies
4. How and Why we use your personal data
We process your information for business purposes, for example, to deliver the products you have ordered, to provide the service you have purchased, or to perform another agreement. We will also process your information if the processing is necessary to achieve the legitimate interests of Kong Cha. In some situations, we may also ask you for consent to the processing of your information. We combine the information we collect to provide you with the best possible service. We process your information for the following purposes, such as:
Network and Mobile Services: We process your information in order for you to use our online services and mobile application. Your information allows us to identify you, provide our electronic services and fulfil the contract, such as delivering an order.
Customer Service and Communication: We process your information to provide customer service, such as responding to feedback or complaints you provide, implementing customer communications, and resolving disagreements.
Direct marketing and marketing Opinion Surveys: We process your information to market our products and services. We may also process your information in marketing and opinion surveys so that we can better understand our customers and thus provide better services.
Targeting of Communications and Marketing and Services: We process your information to target our communications and marketing. In this way, we can provide you with the most relevant information about our products and services. Content targeting is based on the customer's own interests or what we have learned from the customer's stored information. Such information is, for example, which campaign you have participated in and how you have done business on our online services. Based on this information, we form the groups to which we target our marketing, and therefore we do not specifically target marketing to a specific individual.
Analysis, Statistics and Development of Business, Products and Services: We process data for analytical, statistical and reporting purposes, as well as to develop our business, products and services and to improve the user experience. We process information as described above based on the performance of the agreement or the legitimate interests of Kong Cha. We may also ask you for your consent to the processing of your data for certain purposes. For example, our direct marketing to consumers is always based on prior consent, which you can revoke at any time. A legitimate interest means an interest that is legitimate and the realisation of which is important for the operation of the Kong Cha. Kong Cha can act on the basis of a legitimate interest, when there is a relevant and appropriate relationship between the user of the service, ie the data subject and the Kong Cha. In assessing the legitimate interest, the interests of the data subject and the Kong Cha are weighed, such as the realisation of fundamental rights, the nature of the data collected, the purposes for which they are used, and data security. The data subject has the right to object to processing on the basis of a legitimate interest.
5. How long do we store your data?
We will not retain your information for longer than is necessary to fulfil the purposes described in this Privacy Statement and to comply with any other mandatory legislation, such as accounting legislation. The retention period of your data is also affected by the context in which and for what purpose your data was collected. Please note that notwithstanding the criteria above, we may have an obligation under mandatory law to process certain information about you for a longer period of time, in which case we will only process information to comply with that law. We may also make an exception for retention periods when a legal claim is made against Kong Cha or when matters relating to such a claim is pending. In addition, notwithstanding the foregoing, we may process information anonymised for, such as, analytical and statistical purposes and for the development of our business, products and services.
6. When and how we share information with others
Your information will be processed within Moitea Oy. We may disclose your personal data to authorities, for example, if we are required by law to disclose the information. In addition, we may disclose your information in connection with the possible acquisition or other transaction to the buyer of the business or any other relevant entity related to the transaction. We may disclose personal data to third parties in order to fulfil the agreement. Such parties include, for example, our partners providing payment intermediation or transportation services in our online stores or outlets, who may act as data controllers for the personal data required for payment intermediation and transportation. The partners used by a particular online store are identified in that online store. We encourage you to review the privacy policies of such third parties. We use services provided by third parties to process personal data, but in that case we will not, as a general rule, disclose your information to them in such a way that they may use it for purposes other than those specified by Kong Cha. We use subcontractors and service providers to process your information, such as for technical maintenance or to carry out campaigns and direct marketing, and we oblige them, through appropriate contractual arrangements, to ensure an adequate level of security to protect your personal data and otherwise comply with applicable data protection data laws. The subcontractors and service providers we use will only use your information to fulfil the purposes defined by Kong Cha described above. We will not disclose your information to them so that they may use it for other purposes.
7. Data Subject Rights
Kong Cha complies with current data protection laws in the European Union, which, when applicable, include the following rights:
You are free to request access to a record of your processing (as defined in the law), and you have the right to access to a copy of your personal data, request a correction and, in certain circumstances, deletion of your personal data,
You are entitled to request restriction, and object to the processing, of your personal information which has as its basis our legitimate interests,
You have the right to file a complaint with a data protection authority.
The Finnish Data Protection Authority is the authority in Finland that oversees how we as a company comply with relevant data protection legislation.
If processing of personal data is based on your consent, you are entitled to withdraw your consent for future processing of your personal information at any time.
You are entitled to request that we provide your personal information to another organisation responsible for processing your personal data (controller) in cases where our right to process your personal data is based either on your consent or performance of an agreement with you.
You will have reasonable access to your personal information at no extra cost, if you request this via email@example.com. If we cannot provide you with this within a reasonable time frame, we will provide you with a date for when the information can be provided. If such access is denied, we will explain to you why access has been denied.
Information on your right to object under article 21 of the EU General Data Protection Regulation (GDPR)
i. Right to object to processing which is based on our legitimate interests.
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on article 6 (1) f) GDPR (processing for the purposes of safeguarding legitimate interests); this includes any profiling based on those provisions within the meaning of article 4 (4) GDPR. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for the establishment, exercise or defence of legal claims.
If you choose to refrain from receiving interest-based advertising, it does not mean that you will no longer see advertisements on our web sites without the advertisements displayed will not be appropriate for you and therefore, are perceived as less relevant. See more under the section ”Data subject rights” below.
ii. Right to object to the processing of data for marketing purposes. In certain cases, we process your personal data for direct marketing purposes. You have the right to object at any time to processing of personal data concerning yourself for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, we will no longer processes your personal data for such purposes. There are no formal requirements for lodging an objection; where possible it should be made by [insert link to webpage for objection, or relevant email].
Note: if you ask Espresso House not to contact you by email at a certain email address, Espresso House will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.
8. Security of your information
To help protect the privacy of data and personally identifiable information you transmit through use of our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis.
We restrict access to your personal data to those employees who need to know this information to provide services to you or to administer our systems. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
9. Data Storage and Retention
Personal data handled by Kong Cha is stored and processed in Finland. We take steps to ensure that the information we collect in accordance with this Privacy Notice is dealt with in accordance with the provisions of this Notice and in accordance with applicable laws where the information is available.
If we were to transfer your personal data to third countries, i.e. Countries outside the EU / EEA, we will enter into agreements and take other measures in accordance with applicable legal requirements.
Kong Cha retains personal data for as long as necessary to be able to provide you with our services, and to fulfil the purposes set out in section 5 above. Different types of data may be stored different amounts of time, due to certain criteria.
The criteria that determines how long we store your personal data may be:
How long is the personal data needed for us to be able to provide you with products and services? This includes, among other things, maintaining and improving the products and services, protecting our systems, and administering necessary business and accounting information. This is the general rule underlying the calculation of most storage periods.
Is the personal data considered sensitive? In these cases, the storage period is usually shorter.
Have you, as a data subject, consented to a longer storage period? In these cases, we store the information longer, with your consent.
Do we have legal, contractual or other similar obligations to store the data? Examples of this may include mandatory legislation on retention of information, such as for accounting reasons, government orders to store data which is relevant for surveys or data that must be retained for resolving a possible dispute.
For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at firstname.lastname@example.org
Aggregated data: Aggregated data is collected and processed to monitor and evaluate user trends on the website. This means that information about your actions on our website is collected and then anonymised in a way that means we cannot link the information back to you any longer. We use this anonymous information about how our users use our website and services for statistics, service improvement and product development. This data will be completely anonymous and does not constitute personal data. It may therefore be stored a longer time than your personal information.
Anonymisation means that data which was once personal information is stripped away of anything that may connect it to an individual, as well as being severed from anything that in the future might make it possible to reconnect this data to an individual. This de-personalisation treatment of data is one step further than the process of pseudonymisation, which means keeping certain information apart, to make it harder to identify an individual using this data.
Third Party Links: This Privacy Notice does not apply to any personal data that you provide to another user through the website or through any other means. Any third party links you click on via our website may be subject to these third parties’ privacy policies, terms or other rules. Please make sure you read the respective privacy information for each third party whose links you click in, to keep yourself up to date about the processing of your personal data.
Children: Kong Cha does not knowingly collect personal data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal data through our website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Notice by instructing their children never to provide personal data through the website without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to us through the website, please email us at email@example.com, and we will endeavor to delete that information from our databases.
11. Changes and Updates to the Privacy Notice
We will update our Privacy Notice when needed to reflect customer feedback, and changes to the Service. When the Notice is updated, the latest update date is shown at the top of the Notice and the changes are described on the Change History page. If there are major changes in the Notice or how Kong Cha uses your personal information, you will be notified via web or email before the changes come into force to the extent required by law. Please read this Privacy Notice from time to time to keep you informed about how Kong Cha protects your personal information and privacy.