Privacy Policy

LAST UPDATED: MARCH 25, 2013

Analyse² Privacy Policy

1. DEFINITIONS

“Analyse²” means Analyse Solutions Finland Ltd. and Analyse Systems Finland Ltd. and its affiliates in the United States (“US”).

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”).

“Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life.

2. INTRODUCTION

Analyse² (“we,” “us”) creates custom-made assortment solutions for retailers and suppliers. Our unique software combines product attributes and consumer trends to help companies in the consumer goods business build the optimal assortment. Analyse² is based in Finland with offices in Brazil, Mexico, and the United States.

We are committed to protecting the personal data of our employees and customers and to complying with applicable data protection laws. As an element of our ongoing efforts to strengthen the protection of personal data, this privacy policy explains how we process personal data and the principles that we uphold with respect to personal data transferred from the European Economic Area (“EEA”).

3. SCOPE

This Privacy Policy applies to all personal data processed by Analyse2, regardless of the format in which such data are processed.

3.1 THE PERSONAL DATA WE COLLECT

(a) Site Visitor Data and Automatically Collected Data

On our website www.analyse2.com/en (the “Site”) we may collect the following personal data from visitors to the Site:

  • First Name;
  • Last Name;
  • Job Title;
  • Company;
  • Address;
  • Mobile Phone; 
  • Email;
  • City; and
  • Country

The software in use on the Site may automatically collect the following information that in certain circumstances may constitute personal data (“Automatically Collected Data”):

  • The logging technology used on the Site automatically collects the URL of the site from which you came and the site to which you are going when you leave the Site.  We also collect the Internet protocol (IP) address of the device you use to access the Service, information about the operating system of your device, as well as the name of your Internet service provider.
  • We may place a “cookie” on the hard drive of the device that you use to access the Site.  Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling us to recognize your browser for purposes such as saving your preferences and directing relevant content to you.  Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, accepting them individually, and deleting saved cookies from your hard drive.  We would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Site. 
  • Google Analytics is an element of the Site.  By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the Internet Protocol address, and the type of operating system used in the devices used to access the Site.  By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.  The site also uses Snoobi, a technology that collects and stores data such as the website that referred you to the Site, the search engine used to find the Site, search terms used in finding the Site, and the geographic location of a visitor to the Site.

(b) Human Resources Data

On the Site we may collect the following personal data from candidates for employment with Analyse²:

  • Name;
  • Email;
  • Telephone number;
  • Personal data accessible through links provided by applicants, as applicable, to online career profiles; and
  • Personal data contained in resumes/curriculum vitae submitted through the Site.

Throughout an employee’s career with Analyse² we may collect various categories of personal data as required by the law and our human resources processes and benefits administration. 

(c) Data Collected by Our Software

The software we use in providing our services to our customers may collect the following categories of data that in certain circumstances may constitute personal data:

  • Name;
  • E-mail address;
  • User account ID;
  • Password;
  • Corporation;
  • Data visibility and data access permission level;
  • Individual user statistics;
  • IP address; and
  • Type of browser and operating system used in the devices used to access the Site.

3.2 THE PURPOSES FOR WHICH WE USE THE DATA

3.2.1 Site Visitor Data

We use the site visitor data for the following purposes:

  • To communicate with visitors to the Site;
  • To prevent and investigate fraud and other misuses;
  • To protect our rights and/or our property;
  • To operate and improve our products and services;
  • To manage the Site;
  • To provide features available on the Site;
  • To develop, improve, and protect the Site;
  • For market research;
  • To audit and analyze the Site; and
  • To ensure the technical functionality and security of the Site.

3.2.2 Human Resources Data

We use the human resources data for the following purposes:

  • To carry out and support our human resources functions and activities;
  • To carry out our obligations under employments contracts and employment and benefits laws;
  • To administer employee participation in benefits, compensation and human resources plans and programs;
  • To manage employee performance;
  • To implement compliance and discipline procedures, and investigate and report on employee compliance and discipline; and
  • To comply with our legal obligations, carry out investigations and for internal administrative and analytics purposes.

We process sensitive personal data about our employees to the extent necessary or appropriate for compliance with relevant legal or contractual obligations, including managing attendance and employee records.

3.2.3 Data Collected by Our Software

We use the data collected by our software for the following purposes:

  • Developing new products and services and improving our existing products and services;
  • Digital marketing (online, mobile, social media);
  • Sales organization and efficiency;
  • Sales force effectiveness; and
  • Key Account Management.

4. HOW WE DISCLOSE DATA

4.1 Site Visitor Data

We may disclose site visitor data to:

  • Service providers, such as payment processors and data analytics service providers;
  • Public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

4.2 Automatically Collected Data

We may disclose Automatically Collected Data to:

  • Service providers, such as data analytics companies;
  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

4.3. Human Resources Data

We may disclose Human Resources Data to:

  • Service providers, such as recruiting companies and benefits administrators;
  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

4.4. Data Collected by Our Software

We may disclose data collected by our software to:

  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or other corporate reorganization, in accordance with this Privacy Policy.

5. DATA SECURITY AND DATA INTEGRITY

We take reasonable measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction. These measures include, but are not limited to access control measures, availability control measures, input control measures, transfer control measures, employee control measures, and data separation control measures. Please be reminded, however, that we cannot guarantee that personal data are always secure because data security measures in use from time to time may be vulnerable. 

6. THE EU-US SAFE HARBOR

The European Union (“EU”) Data Protection Directive (95/46/EC) (the “Directive”) prohibits the transfer of personal data from the EU to countries that do not meet the so-called adequacy standard for the protection of personal data set out in the Directive. Currently the US is not considered to meet the adequacy standard set out in the Directive.

In order to enable the transfer of personal data to the US, the US Department of Commerce in consultation with the European Commission agreed on a "safe harbor" framework (“Safe Harbor”). For more information about the Safe Harbor, please refer to the U.S. Department of Commerce website at http://www.export.gov/safeharbor.

Analyse² complies with Safe Harbor and has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Analyse²´s certification, please visit http://www.export.gov/safeharbor/. Our policies and procedures are intended to ensure that personal data are kept confidential and only collected, processed or used in compliance with this Privacy Policy.

6.1. NOTICE

When we collect personal data directly from individual natural persons to whom the personal data relate (“Data Subjects”) in the EU, we will inform them about the purposes for which we use their personal data. We will also inform the Data Subjects of the types of third parties, if any, to which the personal data may be disclosed and the choices and means for limiting the use and disclosure of their personal data. One of the ways in which we provide such information is by means of this Privacy Policy.

If we do not collect personal data directly from a Data Subject but receive them from our affiliates or customers in the EU, we will use such personal data in accordance with the notices such entities provided and the consents or choices made by the data subjects.

6.2 CHOICE

We will give Data Subjects the opportunity to choose (opt out) whether their personal data will be disclosed to a third party or used for a purpose incompatible with the purpose for which they were originally collected or subsequently authorized by the Data Subject. We will provide affirmative or explicit (opt in) choice for sensitive personal data, if the sensitive personal data are to be disclosed to a third party or used for a purpose other than the original purpose or the purpose authorized subsequently by the Data Subject. If you would like to exercise your choices, please contact us via e-mail at privacy@analyse2.com or write us at 697 High St., #242, Westwood, MA 02090.

6.3 ONWARD TRANSFER

We will apply the notice and choice principles if we disclose personal data to a third party. If we transfer personal data to a third party that is acting as an agent, we make sure that the third party subscribes to the Safe Harbor Privacy principles or is subject to the Directive or another so-called adequacy finding. Alternatively, we enter into a written agreement with such third party requiring that the third party provide at least the same level of data protection as is required by the Safe Harbor Privacy Principles.

6.4 ACCESS

We grant Data Subjects access to personal data about them. Data Subjects will have the right to correct, amend or delete the personal data where they are inaccurate, except where the burden of expense of providing access would be disproportionate to the risks to the Data Subject’s privacy in the case in question, or where the rights of persons other than the Data Subject would be violated. In order to exercise your access rights, you may contact us at privacy@analyse2.com.

6.5 SECURITY

We take reasonable measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We have implemented technical and organizational measures which comprise physical access control, system access control, logical access control, disclosure control, input control, job control, availability control and separation control. However, as data security measures in use from time to time may be vulnerable, we cannot guarantee the security of personal data.

6.6 DATA INTEGRITY

We take reasonable steps to ensure that personal data are reliable for their intended use, accurate, complete and current. When we are notified that any data, including employee personal data, are inaccurate, incomplete or not current, we will correct, complete or update the respective data within a reasonable time.

6.7 ENFORCEMENT

We will conduct compliance reviews of our relevant privacy practices to verify adherence to this Privacy Policy. Any employee that we determine is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.

7. DISPUTE RESOLUTION

Should you have any questions regarding this Privacy Policy or the protection of the personal data we hold about you, please contact us at privacy@analyse2.com or at the following address:

Analyse2, Inc.

697 High St., #242, Westwood, MA 02090

USA

We will conduct a reasonable investigation of and will attempt to resolve any complaints in accordance with the principles contained in this Privacy Policy. For complaints that cannot be resolved between us and the complainant, Analyse² agrees to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Privacy Principles.

8. CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time. If this Privacy Policy changes, the revised Privacy Policy will be posted at the “Privacy Policy” link on Analyse² websites. In the event that the change is significant or material, Analyse² will notify you by adequate means on the homepage. We recommend checking the Privacy Policy regularly.

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Hevosenkenkä 3, 02600 Espoo, Finland
Tel: +358 10 423 3040
Helpdesk: +358 10 423 3044

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