PURPOSE OF THIS DOCUMENT
The purpose of Interactive Ads Ai Oy Data Protection Policy is to describe how Interactive Ads approaches protecting our customers and users data and privacy, and how we’re complying with GDPR & the national data protection policies & laws.
DEFINITIONS OF KEY TERMS
Data Privacy Officer (DPO)
An expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR.

Data Controller (DC)
The entity that determines the purposes, conditions and means of the processing of personal data.

Data Processor (DP)
The entity that processes data on behalf of the Data Controller.

Data Subject (DS)
A natural person whose personal data is processed by a controller or processor.

Processing
Any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc.

Personal Data
Any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person.

Right to Access
Also known as Subject Access Right, it entitles the data subject to have access to and information about the personal data that a controller has concerning them.

Pseydonymisation
The processing of personal data such that it can no longer be attributed to a single data subject without the use of additional data, so long as said additional data stays separate to ensure non-attribution.

Profiling
Any automated processing of personal data intended to evaluate, analyse, or predict data subject behaviour.

PRINCIPLES OF DATA PROCESSING
See Interactive Ads ‘Privacy Policy’ for detailed documentation on Personal Data we’re gathering & the Personal Data gathering purposes.

Interactive Ads will never disclose nor sell the gathered personal data for third parties without an explicit consent from all of the data subjects being affected. Personal Data processing activities within Interactive Ads can be broken down into 2 separate categories as follows:

1 Processing performed by Interactive Ads
Interactive Ads authorised personnel will be processing the personal data gathered solely for the purpose of helping our customers do better marketing in a more cost effective manner, and within the boundaries of implementing the contracts between Interactive Ads and our customer companies.

Interactive Ads can perform automated machine learning powered analysis on the gathered data, in order to gain better understanding of the users of our platform and to better connect them with possibly interesting companies using our services.

Interactive Ads will never use the gathered data for anything else except for activities driven by the purpose of advancing our customers marketing process & it’s efficiency directly or indirectly.

2 Processing performed by Interactive Ads customer companies
Interactive Ads customer companies processors participating in the processing activities are always explicitly specified in a separate attachment provided for the data subjects in beforehand in conjunction with this document & Interactive Ads official Privacy Policy.

Interactive Ads customers shall only be performing data processing activities for the following purposes:

1.  Gathering & nurturing companies own lead & customer database for more efficient marketing activities
2. Discovering their gathered leads from the database based on given criteria
3. Educate, help and engage potential website visitors and customers.
Interactive Ads will sign a separate contract with every individual data processor where the processor agrees to honor the privacy of our data subjects and to obey this data privacy policy document + any possible additional national data privacy code of conducts available at the time of signing the contract.

All data subjects have a legal Right to Access and Right to be Forgotten as per GDPR. Due to this data subjects are able to request a record of all data Interactive Ads has about them via email, or can request an erasure of stored data regarding them. In order to fulfil this request the requester has to be able to identify themselves via the same email address they’re requesting the data about.

KEY REQUIREMENTS AND CONTROL PROCEDURES
All parties involved in the data processing activities either as Interactive’s personnel or Interactive’s customers are required to sign a contract binding them to comply with this Data Protection Policy & Interactive Ads Privacy Policy. All in beforehand undisclosed processing, unlawful processing, or processing that does not obey Interactive’s Privacy Policy & Data Protection Policy are forbidden.

All customer facing communication with Interactive Ads servers are protected via (HTTPS) encrypted connections to prevent accidental disclosure of confidential data by our users when using eg. a public wi-fi access point.

All production servers are being hardened and maintained according to industry’s best security practises to minimise the chance of accidental data breaches and incidents. Data is regularly, redundantly and automatically being backed up into multi-location storage solutions for incident recovery situations. Backups are being stored for a maximum duration of 12 months from their creation date.

Interactive Ads data is protected by an Access Control List (ACL) layer integrated into our web application that makes sure only authorised personnel are allowed to process certain personal data objects belonging to their company. All data processing activities are being automatically logged for later auditing purposes to ensure processing to be always lawful.

All data is being physically processed and stored within the borders of EU nations (Finland, Ireland, Germany, Netherlands), and will not be transfer-red outside of EU without a prior consent and notice of all data subjects being affected.

Interactive’s DPO ensures and monitors that all data processing activities of Interactive Ads data is only being performed by authorised parties and in compliance with this policy, our Privacy Policy, and the related laws and regulations.

Interactive’s DPO co-operates regularly with the local supervising data privacy authority to ensure compliance with the latest laws and regulations, and to ensure safety and privacy of our users.

General Information
Registrar
Interactive Ads Ai Oy
Business ID: 2922046-1

Contact Person
Mikael da Costa
CEO
Mikael@leadoo.com

Purpose of this Document
The purpose of Interactive Ads’s Privacy Policy is to specify exactly what information Interactive Ads is collecting from it’s users and how + why that data is being processed.

Users of Interactive Ads platform are required to grant Interactive Ads consent for the data gathering & processing activities specified in this document, due to the nature of lead generation software services Interactive Ads is providing.

Unfortunately without consent to proceed the users will be unable to utilise Interactive Ads’s services.

Interactive Ads will always log the granted consent (per email address being used by our visitors) for later auditing purposes.

You can at any time withdraw your data processing consent by contacting our Data Protection Officer via the contact details provided in this document. In such occasion please make sure you’re contacting us via the same email address you originally granted the consent with.

Please refer to our ‘Data Protection Policy’ + it’s appendix for more information about how Interactive Ads will be protecting your privacy, and who will be authorised to perform processing activities on the data related to you within our system. These documents are required to always be presented to you together, and you’ll be required to read through them before granting Interactive Ads consent for processing your data.

Interactive Ads honours it’s users privacy and never discloses nor sells the gathered information for 3rd parties.

What data do we collect & how is it utilised?
Personal data gathered varies slightly depending on the use case with which the data was collected from you. If you interacted with our customers’ chatbots, the following information can be collected from you:

1. Full name
2. Email address
3. Phone number
4. Answers to chatbot questions
5. Company name
6. Source of your lead (can be the HTTP referrer, or an ID of a specific page where you applied through)

If you register to our platform or connect with us by any other digital means, the data collected from you can slightly differ from the most popular use case specified above. The collection of personal data can be manually extended by the Company processing your data, in a form of labels and categories.

You will always be presented with our ‘Privacy Policy’, ‘Data Protection Policy’ and the terms of our service, and will be required to grant Interactive Ads a consent for data gathering & processing, before any personal data will be collected and stored.

Personal data gathered will only be processed by the following parties:

1. Interactive Ads’s authorised personnel or direct contractors
2. Interactive Ads’s customer company’s authorised personnel

Interactive Ads platform requires every user processing the data to authenticate with their personal user credentials. Users will be further authorised via Interactive Ads platform’s members functionality that ensures that they will only be granted option to process data they’re explicitly authorised to.

Personal data can be processed for the following purposes:

1. By Interactive Ads AI to analyse the users of our service for providing more valuable functionality to companies utilising our platform to generate more leads
2. By Interactive Ads AIs customer company that originally collected the information from you, to communicate with you
3. By Interactive Ads AI, for giving companies using our services insights into their analytics

4. By Interactive Ads AI that originally collected the information from you, to communicate with you

Personal data is always company specific, and won’t be accessible by any other Interactive Ads customer company but the one that was associated when you voluntarily granted the consent for data gathering purposes and initially submitted the data into our system.

Interactive Ads will pseudonymise (make the data unidentifiable) if it’s used in more general or wide statistical purposes, to make sure your privacy won’t be threatened by such process.

Your personal data will be automatically erased or pseudonymised when the company that originally gathered the data is either no longer using our tools, or doesn’t need that particular piece of data in order to either measure or improve their lead generation process.

How & Where is the Data Stored?
All personal data is stored electronically, and will be physically stored within EU nations.

Our most commonly utilised data centre locations are in Finland, Netherlands, Germany, and Ireland.

All data processing is handled through industry best practise procedures and encrypted connections (TLS/HTTPS, SSH), more about this in the ‘Data Protection Policy’ document.

No data storing or processing happens outside of EU borders, without a prior consent of the data subjects.

Rights of the Data Subject
You have a legal right to either withdraw your data processing consent, or to object the processing of your personal data, at any time.

If you decide to not grant consent for processing your personal data, you unfortunately won’t be able to further utilise Interactive Ads’s services.

You can withdraw your earlier data processing consent by informing Interactive Ads’s Data Protection Officer (DPO) via the same email address you originally granted the consent with. You will receive an email confirmation after your data has been erased from our active system.

Interactive Ads honours your legal rights and privacy, and will inform you in beforehand via email if/when the contents of this document change.

If you have any questions regarding data processing at Interactive Ads Oy, please don’t hesitate to contact us.

If you for some reason feel like your privacy has not been handled appropriately or lawfully, you can either contact Interactive Ads’s DPO, or directly file a complaint to the local supervising authority for further inspection.

General Terms and Conditions (03/2020)

After the offer has been accepted, these general terms and conditions will become part of the cooperation between the Parties. The Parties may deviate from these terms and conditions by written agreement between the Parties in a way specified in these terms and conditions.

Definitions:

These products, information and services available through leadoo.com and interactiveads.ai (“Service” or “Services”) are provided by Interactive Ads Ai Oy, business ID 2922046-1 (“Interactive Ads” or “Leadoo”).

The term “Partner” refers to the party that has accepted the offer and whose details have been defined in The Contract.

The term “Parties” refers to Leadoo and the Partner.

The term “Service” refers to the service package ordered by the Customer, the contents of which have been defined in The Contract.

1. Binding force and contents of the order

The order confirmation is binding. The Partner’s contact person has entered into cooperation with the representative of Leadoo in accordance with the offer and these terms and conditions.

This Contract as a whole (hereinafter referred also to as “Contract”) consists of a written offer, this document’s order confirmation and the general terms and conditions of this document. In addition, written conversations conducted between the Parties via email are considered to be part of the Contract. Oral conversations are not considered to be part of the Contract. Any supplements or changes made to the terms of the Contract must be approved by both Parties, notwithstanding changes to the general terms which are handled according to paragraph 11. Email conversations are considered to be written conversations.

2. Content of the cooperation

Through cooperation, Leadoo offers the Partner the services listed in The Contract. The features of the services are listed in The Contract. Leadoo and the Partner may agree on more specific features of the services in writing, e.g. via email.

3. Deployment of the service

The Partner’s contact person must agree on the deployment of the service with Leadoo’s contact person via email (support@leadoo.com) at least five (5) business days before the deployment of the service, so that Leadoo can take care of the necessary arrangements.

4. Compensation and fees

The Partner is obligated to pay the fees specified in The Contract to Leadoo. All prices quoted exclude VAT, and the valid VAT rate will be added to the prices.

The due date of the Service’s deployment fee is 14 days after the deployment of the Service, or on an individually agreed date.

Invoicing will be done separately for each contract period, and always at the start of the contract period.

5. Terminating and canceling the Contract and the Contract’s continuity

The Partner may terminate this Contract by paying the payment obligations defined in The Contract in full for the entire remaining contract period.

Leadoo may terminate this Contract by the end of the agreed and paid contract period by notifying the Partner of this in writing.

Leadoo may terminate this Contract if Leadoo discovers that the Partner has intentionally or with gross negligence misused the Service in violation of its purpose. The Partner must be given the opportunity to rectify their actions before terminating the Contract.

The length of the contract period is defined in The Contract. For the services “Interactive Text”, “Interactive Chat”, “Interactive Embed” and “Interactive Ads Video”, the Contract will be automatically renewed and continue as an indefinite Contract after the contract period, unless the Partner has terminated the Contract by sending an email to support@leadoo.com. The Contract will be renewed for 12 months at a time, unless the Parties agree otherwise in writing. The Contract must be terminated at least 14 days before the start of the new contract period.

6. Parties’ rights and obligations

The Partner is always responsible to Leadoo and to its customers for ensuring that any company using the Leadoo systems is committed to comply with good business ethics. The Partner has no right to transfer the Contract to a third party without Leadoo’s written consent.

7. Communications between the Parties

The parties are obligated to inform each other immediately of any changes that may affect the fulfillment of the obligations related to the production of the Service. This information shall be sent to the contact persons of the Parties via email (support@leadoo.com).

8. Partner’s systems

The Partner is responsible for any equipment, software, data connections and related services required to use and utilize the Service that are not included in the Service defined in this Contract. Leadoo is not responsible for any defects in the Service resulting from disruptions or incompatibilities with the Service in the hardware or software environment or data connections that are the responsibility of the Partner.

9. Changes to the Service

Leadoo has the right to make changes that affect the technology and use of the Service, provided that the content of the Service does not change significantly. Leadoo may replace the Service used to deliver the agreed services with either a new version of the Service or with another system.

Leadoo also has the right to change the services because of a change in legislation, because of an official decision, or because of any other specific reason when the circumstances have changed considerably. The Partner must, at their own expense, take care of such changes in so far as they call for changes to the Partner’s own equipment and systems.

Leadoo aims to inform the Partner of any changes affecting the services within a reasonable time in advance, as well as to take necessary measures to minimize any damages potentially caused to the Partner by these changes. Leadoo is not responsible for any damages caused by the aforementioned measures.

10. Use of name

Leadoo may use your, and the company’s that you are representing, name and logo in its marketing collateral, websites, and promotional materials to identify you as a customer of Leadoo.

11. Changes to these Terms

Leadoo may change these terms at any time, upon notice, and we recommend that you review the terms regularly. The up to date terms can be found on leadoo.com If you do not agree to the new terms for the Service, you should discontinue your use of the Service. None of the changes will apply retroactively and the changes will become effective on the announced date.

12. Indemnity liability and limitation of liability

If a Party breaches the Contract and thus causes any damages to the other Party, the breaching Party is liable to compensate the other Party for any direct damages caused to them by the breach. If a Party discovers that the Contract has been breached, the Party must immediately notify the other Party of the matter. The breaching Party must be given the opportunity to rectify the damages they have caused within a reasonable time before the actualization of the indemnity liability, described in this clause.

The Parties state that an error in the Leadoo system causes Leadoo’s liability to be limited to any direct damages caused to the Partner. Leadoo’s indemnity liability is limited to the total value of the current contract period of the Contract drawn up between the Parties and may in no case exceed this value. Any other parties such as Leadoo’s subsidiaries, officers, directors, employees, agents, partners and licensors shall not be liable for any direct, indirect, incidental, special, consequential or exemplary damages, including, but not limited to, damages for loss of profits, goodwill, use, data, cost of procurement of substitute goods or services or other intangible losses (even if Leadoo has been advised of the possibility of such damages).

However, a Party shall never be held liable for any indirect or unforeseeable damages, such as loss of income, loss of profit, damage to one’s reputation or business interruptions. However, this limitation of liability shall not apply if the damage is caused intentionally or by gross negligence.

Leadoo is not responsible to the Partner’s customers or third parties for the availability or correctness of the services included in this program, nor for their suitability for a particular purpose.

Leadoo’s responsibility for technical services and their functionality is limited to the functionalities of Leadoo’s own information systems. Leadoo cannot guarantee disruption-free access to the services throughout the targeted coverage area of the services, or otherwise guarantee the availability or disruption-free use of the services. Leadoo is not responsible for any restrictions on the use of the service abroad.

Any compensation claims resulting from potential breaches of the Contract must be submitted to the other Party in writing (e.g. via email) within two (2) months from the date on which the Party detected or should have detected any negligence, action or error entitling the Party to compensation.

13. Privacy Policy

The valid and current privacy statement used in this Contract can be found on the leadoo.com website at: https://leadoo.com/pivacy-policy. Leadoo reserves the right to change the privacy statement if the legislation or any factor related to person registers changes.

14. Disclaimers and warranties

YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK AND THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. LEADOO AND ITS AFFILIATES, SUBSIDIARIES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, PARTNERS AND LICENSORS EXPRESSLY DISCLAIM ANY AND ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. LEADOO AND ITS AFFILIATES, SUBSIDIARIES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, PARTNERS AND LICENSORS MAKE NO WARRANTY THAT (I) THE SERVICE WILL MEET YOUR REQUIREMENTS; (II) YOUR USE OF THE SERVICE WILL BE TIMELY, UNINTERRUPTED, SECURE OR ERROR-FREE; (III) ANY INFORMATION OBTAINED BY YOU AS A RESULT OF THE SERVICE WILL BE ACCURATE OR RELIABLE; AND (IV) ANY DEFECTS OR ERRORS IN THE SOFTWARE PROVIDED TO YOU AS PART OF THE SERVICE WILL BE CORRECTED. ANY MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICE IS ACCESSED AT YOUR OWN DISCRETION AND RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR DEVICE OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY SUCH MATERIAL. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM LEADOO OR THROUGH OR FROM THE SERVICE SHALL CREATE ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.

15. Applicable law and settlement of disputes

This Contract is governed by Finnish law. Any disputes shall be settled primarily through negotiation. If the Parties cannot find a satisfactory solution through negotiation, the dispute shall be settled before ordinary court in the Helsinki District Court.

16. Miscellaneous

If any particular term of these terms shall be held invalid, illegal or unenforceable, the remaining terms shall not be affected or impaired.
Partner agrees that Leadoo uses Cookies or other ways of identifying users to deliver its service and conducting marketing. Partner understands that she is solely responsible for all documentation and regulations of GDPR, data protection, cookie consent and personal data regulatories. You own the data, including attachments uploaded by users and the personal data inside the service. Leadoo works as processor of the data. Leadoo takes security and privacy seriously. Leadoo sometimes shares data with third party companies and services that we use. Services that we share some data with include, but not limited to: Google, AWS, DigitalOcean, Facebook, LinkedIn and Pipedrive. For more details see our privacy policy.