Terms and Conditions

Terms and Conditions

These Terms and Conditions (the “Terms”) constitute a legal agreement between you and Olonio, Leonkatu 22D, 00540 Helsinki, Finland ("Olonio", "we" or "us") governing the use of our website and our services (collectively “Services”). We license use of our Services to you on the basis of these Terms.


Terms of use

1.1. The provisions set out in these Terms govern your access to and your use of our Services and shall constitute a legally binding agreement between you and us. We may change such terms from time to time and it is your responsibility to periodically review these Terms to stay informed of updates. If you do not agree to such terms, you must not use our Services.

1.2. Subject to you agreeing to abide by these Terms, we hereby grant to you a revocable, non-exclusive and non-transferable licence to use our Services on these Terms.

1.3. We reserve the right to, without any notice, explanation or liability and in our sole discretion, refuse to allow you or suspend your access to our Services at any time, or remove or edit content (including content submitted by you) on our Services.

1.4 We reserve the right to change, modify, suspend or discontinue any portion of the Services, or any other services. You agree that access to or operation of any of the foregoing may from time to time be interrupted or encounter technical difficulties.


Fees and Payments

2.1. All charges for the paid services (“Charges”) are posted on the Services, or otherwise set forth in the Agreement. You agree to pay for paid services according to these Terms. Charges paid by Customer are non-refundable.

2.2. Any Fees due in relation to your Account must be paid by their due date for payment, as notified to you through our Services or otherwise. Failure to make timely payment of the Fees may result in the suspension or termination of your access to your Account and/or our Services or any of the Services.

2.3. Our Fees may be amended from time to time at our discretion. We will provide you reasonably advanced written notice of any amendment of Fees.

2.4. You shall be responsible for any applicable taxes (including any goods and services tax) under these Terms.

2.5. All payments shall be made by using the payment methods specified by us from time to time. You acknowledge and agree that you are subject to the applicable user agreement of any third-party payment methods. We shall not be liable for any failure, disruption or error in connection with your chosen payment method. We reserve the right at any time to modify or discontinue, temporarily or permanently, any payment method without notice to you or giving any reason.

2.6. We must receive payment in full no later than the day on which such payment is required to be paid in immediately available and freely transferable funds, without any restriction, condition, withholding, deduction, set-off or counterclaim whatsoever.

2.7. Unless otherwise notified in writing by us, termination of your Account for any reason whatsoever shall not entitle you to any refund of the Fees.


Rights

3.1. Unless we expressly agree otherwise in the Agreement, all Content, the Services, and all intellectual property rights associated with the Content and Services, are the sole and exclusive property of Olonio. Subject to your full and complete payment of all amounts due to Olonio, and to the extent Olonio provides you with visual, textual, and/or interactive works or materials, in any form, as part of the Services (individually and collectively, the “Olonio Content”),Olonio grants you a non-exclusive, non-transferable, non-sublicensable, revocable, worldwide, limited license to use the Olonio Content solely in connection with your use of the Services.

3.2. You agree not to use, copy, remove, publish, distribute, perform or display any Olonio Content, or any portion thereof, in any other context or website or in connection with any other service. Except for the license granted herein, this is an agreement for services, and you are not granted any licenses under the Agreement. You will not take any actions inconsistent with our ownership of each of our rights in the Content and the Olonio Content.

3.3. In connection with the rights and licenses granted by Olonio under the Agreement,

3.3.1. You may share Olonio Content with Third Parties on Social Media or on blogs or websites or otherwise, provided you have prito obtained express written consent to do so form us.

3.3.2. Olonio may provide you with user Documentation and/or reference manuals, (collectively, the “Documentation”). Olonio is the sole and exclusive owner of all right, title and interest in and to the Documentation and all of the intellectual property rights associated with the Documentation.

3.4. You agree you will not, directly or indirectly:

3.4.1. reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code, object code, or underlying structure, ideas, or algorithms of, or found at or through the Services or any software, Documentation, Olonio Content or data related to the Services (“Content”);

3.4.2. remove any proprietary notices or labels from the Services or any Content; reproduce or copy the Content or the Services or any part thereof;

3.4.3. modify, translate, or create derivative works based on the Services or any Content;

3.4.4. copy, sell, license, sublicense, distribute, pledge, assign, or otherwise transfer or encumber rights to the Services, the Olonio Content, or any Content;

3.4.5. create any derivative product from any of the foregoing;

3.4.6. without our express written permission, introduce software or automated agents or scripts to the Services so as to produce multiple accounts, generate automated searches, requests and queries, or to strip or mine data from the Services;

3.4.7. perform or publish any performance or benchmark tests or analyses relating to the Services or the use thereof;

3.4.8. upload, link to or post any portion of the Content and/or the Olonio Content on a bulletin board, intranet, extranet or website;

3.4.9. use or distribute the Content and/or the Olonio Content in violation of any applicable laws, regulations or export restrictions;

3.4.10. possess or use the Content in any format other than machine-readable format;

3.4.11. use the licenses and rights granted under the Agreement to design, develop or distribute a commercial product or service that competes with the Services;

3.4.12. circumvent or attempt to circumvent any technological measures designed to enforce certain limitations or instructions with respect to your use of the Services;

3.4.13. use the Services to send or store infringing, obscene, threatening, harassing, libellous, or otherwise unlawful or tortious material, including material harmful to children or violative of third party privacy rights; or

3.4.14. allow third parties to gain access to the Services or to otherwise use the Services in any manner other than as expressly permitted in this Agreement.

3.5. Olonio reserves all rights in the Services not explicitly granted herein.

3.6. You acknowledge and agree that the Services, the Content, Olonio names and logos and all related product and service names, design marks and slogans, and all other material comprising the Content or the Services, are the property of Olonio or its affiliates or suppliers (collectively, the “Marks”). Unless stated otherwise, all Marks are protected as the copyright and/ or other intellectual properties are owned by Olonio or by other parties that have licensed their material to Olonio. You are not authorized to use any of the Marks in any advertising, publicity or any other commercial manner without the prior written consent of Olonio. Your use of the Services confers no title or ownership in the Services, the Content or the Marks and is not a sale of any rights in the Services, the Content or the Marks. All ownership rights remain in Olonio or its third-party suppliers, as the case may be.

3.7. You acknowledge and agree that any comments, ideas and/or reports provided to Olonio (“Feedback”) shall be the property of Olonio and you hereby irrevocably transfer and assign to Olonio such Feedback, and all associated intellectual property rights, provided however that you shall be free to use such Feedback in the ordinary conduct of your business.


Uploading Data

4.1. The services invite you to upload your Raw Oura data obtained from Oura Cloud service (collectively, "Data").

4.2. You are fully responsible for your Data uploaded to our services. We will not be responsible, or liable to any third party, for:

4.2.1. the Data or accuracy of any Data or data uploaded by you; or

4.2.2 the loss of any Data or data provided to us by you. You should keep a record of all such Data and data.

4.3. We do not assert any ownership over your Data. You retain full ownership of all of your Data and any intellectual property rights, or other proprietary rights associated with your Data. We are not liable for any statements or representations in your Data provided by you in any area on the Services.

4.4. We have the right, in our sole and absolute discretion, to edit, redact, or otherwise change any Data; to re-categorize any Data to place them in more appropriate locations on the Services; and to pre-screen or delete any Data at any time and for any reason, without notice.


Prohibited Uses

5.1. You may use our Services only for lawful purposes. You may not use our Services:

5.1.1. in any way that breaches any applicable local or international laws or regulations;

5.1.2. in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;

5.1.3. to send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards as set out in our prevailing terms and conditions as amended from time to time; and

5.1.4. to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

5.2. You also agree:

5.3. not to reproduce, duplicate, copy or re-sell any part of our Services in contravention of the provisions of our Terms; and

5.4. not to access without authority, interfere with, damage or disrupt:

5.5. any part of our Services;

5.6. any equipment or network on which our Services is stored;

5.7. any software used in the provision of our Services; or

5.8. any equipment or network or software owned or used by any third party.


Restrictions

Except as expressly set out in this Agreement or as permitted by any applicable law, you undertake:

6.1.1. not to reproduce, copy, modify, adapt, translate, publish, display, communicate, transmit, sell, exploit or use the whole or any part of any Service or any of the contents therein for any commercial or other purposes;

6.1.2. not to disassemble, decompile, reverse-engineer or create derivative works based on the whole or any part of the source code of our Services nor attempt to do any such thing, or to reproduce, display or otherwise provide access to the Services or any of the contents therein, including but not limited to framing, mirroring, linking, spidering, scraping or any other technological means;

6.1.3. not to provide or otherwise make available our Services in whole or in part (including but not limited to program listings, object and source program listings, object code and source code), in any form to any person without prior written consent from us;

6.1.4.to include our copyright notice on all entire and partial copies you make of our Services on any medium;

6.1.5. to comply with all applicable technology control or export laws and regulations; and

6.1.6. not to disrupt, disable, or otherwise impair the proper working of the Services, our Services or our servers, such as through hacking, cyber-attacks (including but not limited to denial-of-service attacks), tampering or reprogramming.


Intellectual property rights

7.1. You acknowledge that all intellectual property rights in our Services anywhere in the world belong to us, that rights in our Services are licensed (not sold) to you, and that you have no rights in, or to, our Services other than the right to use them in accordance with these Terms.

7.2. Any intellectual property rights in content uploaded by you to our Services shall continue to belong to you or their respective owners. You agree that you grant us a royalty-free and non-exclusive licence to use, reproduce, publish and display such intellectual property rights for the purposes of performing the Services, internal administrative purposes and any other purposes set out in these Terms, including for the purpose of improving the Services and our responses to users of the Services.

7.3. You acknowledge that you have no right to have access to our Services in source code form.

7.4. You must not modify the paper or digital copies of any materials you have printed off or downloaded from our Services in any way and you must not use any illustrations or any graphics separately from any accompanying text.

7.5. Our status (and that of any identified contributors) as the authors of content on our Services must always be acknowledged.

7.6. You must not use any part of the content on our Services for commercial purposes not specified on our Services without obtaining a licence to do so from us or our licensors.

7.7. If you print off, copy or download any content on our Services in breach of this Agreement, your right to use our Services will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.


Term and Termination

8.1. These Terms shall remain in full force and effect while you use the Services. Without limiting any other provision of these Terms, we reserve the right to, in our sole discretion and without notice or liability, deny access to and use of the Services (including blocking certain IP addresses), to any person for any reason or for no reason, including without limitation for breach of any representation, warranty, or covenant contained in these Terms or of any applicable law or regulation. We may terminate your use or participation in the Services or delete your account and any content or information that you posted at any time, without warning, in our sole discretion.

8.2. If we terminate or suspend your account for any reason, you are prohibited from registering and creating a new account under your name, a fake or borrowed name, or the name of any third party, even if you may be acting on behalf of the third party.

8.3. In addition to terminating or suspending your account, we reserve the right to take appropriate legal action, including without limitation pursuing civil, criminal, and injunctive redress.


Warranties

9.1. While we make all efforts to maintain the accuracy of the information on our Services, we provide the Services, Services and all Related Content on an “as is” and “as available” basis, unless otherwise specified in writing. We make no representations or warranties of any kind, express or implied, as to the operation of any of the foregoing, unless otherwise specified in writing.

9.2. To the full extent permissible by law, we disclaim all warranties, express or implied, relating to our Services or any Services, including but not limited to implied warranties of merchantability and fitness for a particular purpose. We do not warrant that the Services, our Services, the Related Content, or electronic communications sent by us are Error-Free, or free of viruses or other harmful components.


Medical Disclaimer

10.1. The information provided in the Services is not intended or implied to be a substitute for professional medical advice, diagnosis, or treatment. All content, including text, graphics, images, and information, is for general information purposes only.

10.2. Olonio makes no representation and assumes no responsibility for the accuracy of information contained in or available in the Services.

10.3. You are encouraged to confirm any information obtained with other sources and review all information regarding any medical condition or treatment with your General Practitioner. Please do not disregard professional medical advice or delay seeking medical treatment because of something you have discovered using our Services.

10.4. Olonio does not recommend, endorse, or make any representation about the efficacy, appropriateness or suitability of any recommendation or other information.

10.5. Olonio is not responsible nor liable for any advice, recommendation, or any other information that you obtain from the Services.

10.6. Olonio accepts no responsibility or liability for any adverse consequences resulting directly or indirectly from the use of our in the Services. Contact your doctor immediately if you suspect that you have a medical problem or emergency.

10.7. We are not responsible for your personal actions or choices before, during or after using any of our Services.

10.8. You accept full responsibility for your use, or non-use, of any information provided by us through any means whatsoever. Your use, or non-use, of this information is at your own risk, and you absolve us of any liability or loss that you or any other person, may incur from your or their use or non-use of the Olonio Services, or information provided by Olonio. If you have any concern, please consult a physician or any other medical specialist.


Limitation of Liability

11.1. We are not liable for the completeness, accuracy or correctness of any information uploaded on our Services and any Related Content. You expressly agree that your use of the Services and our Services, is at your sole risk.

11.2. We do not assist with dispute resolution between any you and any Consultant and are not obliged at any time to adjudicate on any such dispute. In the event of any dispute, you are responsible for contacting the relevant Consultant. Without prejudice to the foregoing, we remain entitled at all times to investigate at our discretion any complaint regarding the use of our Services or any suspected unlawful activity and to take any action that we deem appropriate, including to file a report with the appropriate authorities.

11.3. You agree not to use the Services, our Services and the Related Content for any re-sale purposes, and we have no liability to you, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, arising under or in connection with these Terms (including but not limited to the use of, or inability to use, the Services, our Services or any other website or software) for:

11.3.1. loss of profits, sales, business, or revenue;

11.3.2. business interruption;

11.3.3. loss of anticipated savings;

11.3.4. loss or corruption of data or information;

11.3.5. loss of business opportunity, goodwill or reputation; or

11.3.6. any other indirect or consequential loss or damage.

11.4. Nothing in these Terms shall limit or exclude our liability for:

11.4.1. death or personal injury resulting from our negligence;

11.4.2. fraud; and/or

11.4.3. any other matter in respect of which we are prohibited under applicable law from limiting or excluding our liability.

11.5. Our Services is not intended to serve a record-keeping function and we shall not be liable for any loss of data or content.

11.6. These Terms set out the full extent of our obligations and liabilities in respect of the supply of the Services and our Services. Except as expressly stated in these Terms, there are no conditions, warranties, representations or other terms, express or implied, that are binding on us. Any condition, warranty, representation or other term concerning the supply of the Services and our Services which might otherwise be implied into, or incorporated in, these Terms whether by statute, common law or otherwise, is excluded to the fullest extent permitted by law.


Indemnity

You agree to indemnify and hold us, our related corporations, and our respective directors, officers, employees, agents and representatives, independent contractors, licensees, successors and assigns harmless from and against all claims, losses, expenses, damages and costs (including but not limited to direct, incidental, consequential, exemplary and indirect damages), and reasonable legal fees, resulting from or arising out of your act, default or omission, whether in your use of our Services, Services, and/or any websites or software in relation thereto or otherwise, and whether in respect of your breach of these Terms or any laws or regulations or otherwise.


Other important terms

13.1. We may transfer our rights and obligations under these Terms to another organisation, but this will not affect your rights or obligations under these Terms.

13.2. You may only transfer your rights or your obligations under these Terms to another person if we agree in writing.

13.3. No joint venture, partnership or agency or employment relationship has arisen by reason of these Terms.

13.4. These Terms and any document expressly referred to in it constitutes the entire agreement between us regarding their subject matter, and supersedes and extinguishes all previous agreements, promises, assurances, warranties, representations and understandings between us, whether written or oral, relating to that subject matter. You agree that you shall have no remedies in respect of any statement, representation, assurance or warranty (whether made innocently or negligently) that is not set out in these Terms or any document expressly referred to in it. You agree that you shall have no claim for innocent or negligent misrepresentation or negligent misstatement based on any statement in these Terms or any document expressly referred to in it.

13.5. All communications and notices made or given pursuant to this Agreement must be in the English language.

13.6. If we fail to insist that you perform any of your obligations under these Terms, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we do waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.

13.7. Each of the conditions of these Terms operates separately. If any court or competent authority decides that any of them are unlawful or unenforceable, the remaining conditions will remain in full force and effect.

13.8. These Terms, its subject matter and its formation, and any other disputes or claims in connection therewith, are governed by the law of Finland. In the event of any such disputes or claims in connection with these Terms, you agree to first engage in good faith discussions with us to resolve such dispute or claim. If such dispute or claim is not resolved within sixty (60) days, we both irrevocably submit to the exclusive jurisdiction of the courts of Helsinki.

Privacy Policy

This Privacy Policy describes how we, the data controller Olonio, Leonkatu 22D163, 00540 Helsinki, Finland, ("Olonio", "we" or "us") collect, store and process information about individual visitors to this website.


This Privacy Policy only applies to website of Olonio on which this Privacy Policy is stored or from which reference is made to this Privacy Policy by means of a link (hereinafter: "website"). This Privacy Policy does not apply to linked website that are not owned and controlled by Olonio.


Commitment to data protection


In order to make our Privacy Policy both easy to understand and to avoid complex legal jargon, we first need to explore the following definitions.


Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


Personal Data is all information that relates to an identified or identifiable natural person (so-called data subject). This includes, for example, your name, date of birth, e-mail address, postal address or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.


Special category data is personal data that needs more protection because it is sensitive. This may include personal data revealing racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data, or data concerning health. In order to process special category data, we first need to obtain consent.


Consent means any freely given indication of the data subject's wishes for the specific case in an informed and unambiguous manner, in the form of a declaration or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.


In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the Finnish Data Protection Act 2018 (tietosuojalaki), the European General Data Protection Regulation ("GDPR"), and only as described in this Privacy Policy.


However, we reserve the right to put this data to additional uses to the extent permitted or required by law or necessary to support legal or criminal investigations. In this case, we will inform you again about this further data processing to the extent required by law and obtain your consent.


In the next sections we explain when and how we process personal data about you when you visit our website.


Purposes of use of personal data and legal basis

a) Log Files

We only collect and process access data that your internet browser automatically transmits to us for technical reasons in order to provide the website. Depending on the access protocol used, the protocol data record contains general information with the following contents: Your session data (usage behaviour, length of stay, which links were clicked on, etc.), your abbreviated and unabbreviated IP address, your browser version, your operating system, your website-specific settings, your cookie IDs, your pixel IDs. This data does not allow any direct inference to your person and is processed to improve our website offer and to defend against attempted attacks on our web server. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. f) GDPR. We have a legitimate interest in presenting you with a website optimized for your browser and in enabling communication between our server and your device.


b) Hosting

To provide our website, we use the services of systeme.io who process the above-mentioned data and all data to be processed in connection with the operation of this website (log file when visiting the website) on our behalf. Our website is hosted using the services of systeme.io owned and operated by ITACWT Limited, 3 Cruise Park Rise, Tyrrelstown, Dublin 15, Ireland. The legal basis for the data processing is our legitimate interest in providing our web site in accordance with Art. 6 para. 1 f) GDPR.


c) Contact requests

Enquiries via our contact form or e-mail may include your name, address, e-mail address, the subject of your contact and your message. We process and store the personal data provided by solely for the purpose of processing and responding to your enquiry and contacting you. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.


d) Newsletter

When registering for our newsletter, you are required to provide your email address. Insofar as you have given us your consent to data processing when registering for the newsletter, we process and store the personal data provided when registering for the newsletter exclusively for the purpose of providing the newsletter and our services and/or promotions in accordance with the newsletter you have subscribed to. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. a) GDPR. You can revoke your consent at any time with effect for the future. Our newsletter is provided using the services of systeme.io owned and operated by ITACWT Limited, 3 Cruise Park Rise, Tyrrelstown, Dublin 15, Ireland.


e) Services

When ordering our service, it is necessary, among other things, to provide your name, e-mail address and postal address and, if applicable, your payment data. We process and store the personal data provided when you place an order solely for the purpose of providing you with the ordered service. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.


During the Olonio Smart Ring Data Visualization Process it is necessary for us to process Special category data which is part of your Raw Oura data obtained from Oura Cloud service. This may include but is not limited to Measurement data such as heart rate, movement data, and temperature data, Calculated user, sleep and activity data, such as sleep phases (deep, light, REM, awake), activity levels throughout the day, readiness level. In order to provide you with our services you must first obtain your Raw Oura data from Oura Cloud service and then submit your Raw Oura data obtained from Oura Cloud service via our upload function.


In order to process your Special category data, the legal basis of consent in accordance with Art. 9 para. 2 lit. a) GDPR is requested. The processing of your Raw Oura data obtained from Oura Cloud service takes place using OneDrive cloud storage and Power BI both provided by Microsoft Central and Eastern Europe, Konrad-Zuse-Str.1, 85716 Unterschleißheim, Germany. The legal basis for the processing of your Special category data is Art. 9 para. 2 lit. a) GDPR in conjunction with Art. 6 para. 1 lit. b) GDPR. We have further entered into a Data Protection Addendum with Microsoft.


You have the right to withdraw your consent at any time. However, withdrawing your consent would render the provision of our services impossible. If you wish to withdraw your consent, please contact us using info@olonio.com. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent prior to the revocation.


f) Stripe

Payment by credit card and debit card is made via the payment service provider Stripe 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland to which we pass on your mandatory details (e-mail address) provided during the checkout, for payment processing. Your data will only be passed on for the purpose of payment processing with the payment service provider Stripe and only insofar as it is necessary for this purpose. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.


g) iDEAL, Bancontact

If you wish to pay with iDEAL Currence B.V., Gustav Mahlerplein 33-35, Amsterdam, Noord-Holland 1082 MS, NL or have a Bancontact card at a participating bank can pay with Bancontact Payconiq Company NV/SA, Rue d'Arlon 82, 1040-Brussels, Belgium. If you choose iDEAL or Bancontact, you will be redirected to your bank's payment page at the end of the checkout process. Here you can make a transfer of payment as usual. After the transaction is completed, you will be redirected back to the web site of the operator. When choosing these payment methods, we only receive the information about whether the payment was successful or not. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.


h) Microsoft Teams

We may use Microsoft Teams by Microsoft Central and Eastern Europe, Konrad-Zuse-Str.1, 85716 Unterschleißheim, Germany to conduct follow-up calls or customer support services and various types of data are processed when using Microsoft Teams. The scope of the data depends on the information you provide before or during participation. The legal basis for this is our legitimate interest in effective customer communication in accordance with Art. 6 Para. 1 lit. f) GDPR and if applicable to fulfil our contract with you (Art. 6 Para. 1 lit. b) GDPR).


i) Cookies and similar technologies

For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy, which is part of this Privacy Policy.


Transfer of personal data

Olonio will not disclose or otherwise distribute your personal data to third parties unless this is necessary for the performance of our services (legal basis for processing: Art. 6 para. 1 lit. b) GDPR), you have consented to the disclosure (legal basis for processing: Art. 6 para. 1 lit. a) GDPR) or the disclosure of data is permitted by relevant legal provisions.


Olonio is entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors for Olonio pursuant to Art. 4 No. 8 GDPR within the framework of the data protection provisions. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.


The service providers commissioned by Olonio process your data exclusively in accordance with our instructions. Olonio remains responsible for the protection of your data, which is ensured by strict contractual regulations, technical and organizational measures and additional controls by us.


Personal data may also be disclosed to third parties if we are legally obliged to do so e.g., by court order (legal basis for processing: Art. 6 (1) (c) GDPR) or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil Olonio's legitimate interests or in the event a merger, acquisition, or sale of our business (legal basis for processing: Art. 6 (1) (f) GDPR).


Storage and retention

Your personal data will be stored by us only for as long as is necessary to achieve the purposes for which the data was collected or - if statutory retention periods exist that go beyond this point and for the duration of the legally prescribed retention period. We then delete your personal data. Only in a few exceptional cases is your data be stored beyond this period, e.g. if storage is necessary in connection with the enforcement of and defense against legal claims against us.


Olonio is entitled to process your personal data insofar as this is necessary to fulfil legal obligations. For this purpose, Olonio may transfer this data in particular to authorities, law enforcement agencies and courts. In this case, the transfer of your data is required by Art. 6 (1) (c) GDPR for compliance with a legal obligation to which we are subject. Olonio is further entitled to process personal data if and to the extent necessary to detect or prevent misuse of this website or to enforce claims of Olonio, its employees or users, whereby the data processing in these cases is necessary to protect these aforementioned legitimate interests of Olonio pursuant to Art. 6 (1) (f) GDPR. Insofar as the disclosure of health data is necessary for the assertion of claims or the defence against claims, the related data processing is based on Art. 9 (2) f) GDPR.


International transfers

Our main operations are based in Finland and your personal information is generally processed, stored and used within in Finland and other countries in the European Economic Area (EEA). In some instances, your personal information may be processed outside the European Economic Area. If and when this is the case, we take steps to ensure there is an appropriate level of security, so your personal information is protected in the same way as if it was being used within Finland and the EEA.

Where we need to transfer your data outside Finland or the EEA, we will use one of the following safeguards:


- The use of approved standard contractual clauses in contracts for the transfer of personal data to third countries.

- Transfers to a non-EEA country with privacy laws that give the same protection as Finland and the EEA.


Automated decision-making

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place on the part of Olonio.


Direct marketing in the context of a customer relationship

We use the data you provide to fulfil and process our contract and to respond to your enquiries in accordance with Art. 6 (1) (b) GDPR or on the basis of your consent in accordance with Art. 6 (1) (a) GDPR.


Your Rights

You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on the Data Protection Ombudsman's Office website (https://tietosuoja.fi/en/home).- information about the processing of your personal data.


- obtain access to the personal data held about you.

- ask for incorrect, inaccurate or incomplete personal data to be corrected.

- request that personal data be erased when it’s no longer needed or if processing it is unlawful.

- object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation.

- request the restriction of the processing of your personal data in specific cases.

- receive your personal data in a machine-readable format and send it to another controller (‘data portability’).

- request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.

- You also have the right in this case to express your point of view and to contest the decision

- Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form.


The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it.


We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.


We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the Data Protection Ombudsman's Office, their contact details can be found on their website (https://tietosuoja.fi/en/home).


Security and confidentiality

To ensure the security and confidentiality of the personal data we collect on the Website, we use data networks that are protected by, among other things, industry-standard firewalls and password systems. When handling your personal information, we take appropriate technical and organizational measures to protect your information from loss, misuse, unauthorized access, disclosure, alteration or destruction and to ensure its availability.


Personal information and children

Most of the services available on this website are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact. The parent or guardian will be provided with (i) information about the specific type of personal information being collected from the minor, (ii) the purpose for which it will be used, and (iii) the opportunity to object to any further collection, use or storage of such information. We comply with youth protection laws.


Links to other website

The website may contain links to another website. We have no control over the privacy practices or the content of those other website. Therefore, we recommend that you carefully read the respective privacy policies of these other website that you visit.


Changes

This Policy and our commitment to protecting the privacy of your personal data can result in changes to this Policy. Please regularly review this Policy to keep up to date with any changes.


Queries and Complaints

Any comments or queries on this policy should be directed to us using the following contact details.


Olonio,

Leonkatu 22D163,

00540 Helsinki, Finland

info@olonio.com


If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us. You can also make a referral to, or lodge a complaint with, the Data Protection Ombudsman's Office.

Cookies Policy

The following Cookie Policy is applicable to www.olonio.com operated by Olonio, Leonkatu 22D163, 00540 Helsinki, Finland. This cookie policy sits in line with the Finnish Data Protection Act 2018 (tietosuojalaki), the General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications Directive (PECD) and should be read in line with our Privacy Policy. If you have questions or comments, please contact us using info@olonio.com.


For more information about how we process your personal information, notice of your privacy rights and our contact details, please refer to our privacy policy, which forms part of this Cookie Policy.


Functionality and types of cookies

A cookie is a small data record that is stored on your terminal device and contains data such as personal page settings or login information. This data record is either sent to your web browser by the server with which you have established a connection or generated by a script. When you later revisit the same domain, the information stored in the cookie is transmitted to and read by the server.


The most common types of cookies are explained below for your understanding:


Session cookies: while you are active on a website, a session cookie is temporarily stored in the memory of your device, in which a session identifier is stored, for example, to prevent you from having to log in again each time you change pages. Session cookies are deleted when you log out or lose their validity as soon as their session has automatically expired.


Persistent cookies: Persistent cookies store a file on your terminal device for the period of time specified in the expiration date (storage period). Through these cookies, the website remembers your information and settings the next time you visit. This results in faster and more convenient access, as you do not have to set your language preferences for our website again, for example. When the storage period expires, the cookie on your device is automatically deleted.


Third-party cookies: In contrast to first-party cookies, third-party cookies are session or persistent cookies that originate from a provider other than the website operator. They can be used, for example, to collect information for advertising, custom content and web statistics.


Legal basis for the use of cookies

Cookies serve many different purposes, for example, they enable you to navigate our website efficiently, they store your preferred settings and generally improve your visit experience.


Depending on their respective purpose, the cookies used on our website can be divided into two categories: Technically necessary and technically non-necessary cookies.


The classification as technically necessary or technically non-necessary also determines the legal basis on which we use the respective cookie:


Technically necessary cookies

Technically necessary cookies are required for our website to function properly; they enable you to navigate our website efficiently and use its functional features. An example of this is, for example, the reminder of recently performed actions (e.g., entered text) when you return to a page within the same session.


The legal basis for the collection and processing of personal information in the context of the use of technically necessary cookies is the fulfilment of our contractual obligations or the protection of our legitimate interests, which consist in particular in providing you with our website with its essential functions.


Technically non-essential cookies

Technically non-essential cookies are not necessary for the proper functioning of our website, but they enable us to improve the content of our website, compile statistics for internal market analysis purposes, provide you with a more personalized online experience or provide additional features.


Technically non-essential cookies can in turn be divided into the following subcategories:


Performance cookies: these cookies help us understand how visitors interact with our website by providing data about which websites or search terms bring users to our website, how long they typically stay on our website, or how many subpages they view on average. We use this data to improve the content of our website and to compile statistics for internal market analysis purposes about individual use of our website.


Functional cookies: these cookies allow our website to remember the choices you make (for example, your username, language, or the region you live in) to provide you with a more personalized online experience. They also allow you to watch videos and interact with social tools such as blogs, chat rooms and forums.


Targeting/advertising cookies: these cookies are used to provide content that is more relevant to you and your interests (direct marketing). They can be used to provide targeted advertising or to limit the frequency with which you are shown an advertisement. They also help us measure the effectiveness of advertising campaigns. In addition, we may use these cookies to store which websites you have visited.


Analytical cookies: Analytical cookies are used by third parties. These cookies allow third parties to recognise that you have visited our platform. We and our third-party providers may also combine information obtained from these cookies with personal data available from other sources, including data collected about you when you use other websites and data collected about you when you are offline, whether on our platform or data maintained by the third-party provider.


The legal basis for the use of technically non-essential cookies (and the associated collection and processing of personal information) is your consent given voluntarily when you first visit our website as part of our cookie banner.


You can revoke your consent at any time with effect for the future. Your consent to the use of technically non-essential cookies and the associated processing of your personal information is not necessary for the use of our website, i.e., you can also use our website without technically non-essential cookies.


Cookies used on our website:


Cookie

Type

Description

Lifespan

_fbp

Advertisement

This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.

3 months

fr

Advertisement

Facebook sets this cookie to show relevant advertisements to users by tracking user behavior across the web, on sites that have Facebook pixel or Facebook social plugin.

3 months

_ga_C5X0SRXV6E

Analytics

This cookie is installed by Google Analytics.

2 years

_ga

Analytics

The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.

2 years


Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses the analysis cookies described in our Cookie policy to analyze our platform with regard to your usage behavior. The information generated by cookies about your use of our platform will be transmitted to and stored by Google on servers in the United States. However, your IP address is shortened before the usage statistics are analyzed so that no conclusions can be drawn about your person. For this purpose, the code "anonymizeIp" has been added to Google Analytics on our platform to ensure anonymized collection of IP addresses. Google will use the anonymized information obtained through the cookies to evaluate your use of the platform, to compile reports on website activities for the website operators and to provide other services associated with the use of the platform and the internet. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.


Facebook Remarketing

Within our platform, so-called "Facebook pixels" of the social network Facebook, which is operated by Meta Platforms Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"), are used. With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our offer as a target group for the display of advertisements, so-called "Facebook ads". Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our platform. This means that with the help of the Facebook pixel we want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our platform after clicking on a Facebook ad.


You can object to the collection by the Facebook pixel and use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads or declare the objection via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/.


Control cookies

You can set your web browser to display a message whenever a cookie is about to be stored, or you can refuse cookies altogether. You can also delete cookies that have already been set. If you want to restrict or block cookies stored on your device, you can do this via your web browser settings. You can find more information about this in the help function of your web browser.


Please note that setting changes always only affect the respective web browser. If you use different web browsers or change the end device, the settings must be made again.


Further information on data protection

For further information on data protection, please refer to our privacy policy. If you would like more detailed information about our data protection practices, please contact us using info@olonio.com. We will be happy to assist you.