Privacy Policy

AddNow Oy (“AddNow”, “we”, “us”) provides the website https://www.addnow.app/ (“Website”) and a digital connection making platform (“Platform”) for consumers and businesses for the purpose of creating, sharing, and viewing contacts with each other. The Website and the AddNow Platform are hereinafter referred to jointly as the “Services”.

Our Privacy Statement explains, for example, the types of personal data we process concerning the users and visitors of the Services and the contact persons of our business partners. This Privacy Statement also explains how we process your personal data and how you may use your rights as a data subject (e.g. right to object, right of access).

In this Privacy Statement, the word “you” or “User” may refer to any of the aforementioned individuals.

This Privacy Statement may be updated from time to time to reflect changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce your rights under this Privacy Statement without providing a notice thereof.

CONTROLLER’S CONTACT DETAILS

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the email contact@addnow.app with attn “Privacy”, so we can reply to you more quickly.

Name of the controller: AddNow Oy

Company ID: 3251043-5

Address: Kanavakatu 1 A 4008, 00160 Helsinki, Finland

E-mail address: contact@addnow.app

Attn: Privacy

PERSONAL DATA PROCESSED AND DATA SOURCES

The categories of personal data we collect depend on the Services you use, and the requirements of applicable law. The personal data collected and processed by us can be divided into three general categories: User data, contact data, and analytics data.

User Data

User Data is personal data collected directly from you or social media service providers. We may collect User Data from you in various ways, including when you register for or use the Services or communicate with us.

User Data that is necessary to use the Services

The following personal data collected and processed by us is necessary for the proper performance of the contract between the User and us and compliance with our legal obligations.

When the User registers for the Services and creates a user account, the User needs to provide us with the following information:

• Name
• Email address
• Username
• Password

Suppose you register or log in to the Services with a social media account (Facebook, Google, or Twitter). In that case, the social media service provider in question shares personal information about you, such as your profile picture and your social media handle/username.

User Data you give us voluntarily

We also collect and process the following User Data in case you provide it to us voluntarily:

Additional Account Information:

• Profile information (such as profile photo, description, and interests)
• Username or tag and password
• Your messages and other content you submit when you use the Service (such as chat logs and support tickets)
• Data you provide in connection with surveys, promotions, and other events
• The in-app information like which users you follow on the Services
• Links to the user's different social media profiles
• Other data you choose to give us
• In future, our payment service providers will collect your payment details in connection with any purchases you make through us or the app store regarding our application.

Other voluntary information provided by the User, such as:

• User’s marketing opt-ins and opt-outs
• Information the User provides in correspondence with us

Contact Data

We also collect and process specific Contact Data of the contact persons of our business partners. Contact Data is collected directly from you or the organisation you represent. Contact Data includes:

• Names
• Email addresses, phone numbers and other contact details
• The organisation the user represents and their title
• Correspondence between AddNow’s representatives and the User

Analytics data (Device and usage Data)

Although we do not usually use Device and Usage Data to identify you as an individual, you can sometimes be recognised from it alone or when combined or linked with User Data. In such situations, Device and Usage Data can also be considered personal data under applicable laws, and we will treat such data as personal data.

We automatically collect the following Device and Usage Data when you visit or interact with the Services:

Device Information

We collect the following information relating to the technical device you use when using the Services:

• Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
• Your IP address and mobile device identifiers (such as your device or advertising ID)
• Data we collect with cookies and similar technologies (see more below)
• Approximate location data (as derived from IP address)
• Data about your use of the Service, such as usage data, purchases made and your interactions with other users inside the Service
• Country
• Screen resolution
• Advertising identifier of your device

Usage Information

We collect information on your use of the Services, such as:

• Data about your account and service usage, including in most cases an automatically created internal account ID

• Time spent on the Services

• Interaction with the Services

• The URL of the website you visited before and after visiting the Services

• The time and date of your visits to the Services

• The sections of the Services you visited

• The Users or products you searched for while using the Services

You may also have the option to create an AddNow ID using your email address or other contact information.

Data we collect from our partners.

We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement the information we have about you, such as:

• Data we receive if you link a third-party tool with the Service (such as Facebook, LinkedIn or WhatsApp)
• Demographic data (such as to determine the coarse location of your IP address)
• Data to fight fraud (such as refund abuse in the application or click fraud in advertising)
• Data from platforms that the services run on or data from payment service providers (such as payment verification data)
• Data for advertising and analytics purposes (such as surveys), so we can provide you with a better Service.
• Data that you have made available to us from a third-party service (such as Facebook, LinkedIn or WhatsApp) via your privacy settings

WHO CAN SEE YOUR DATA

Apart from AddNow, your data can be accessed by others in the following situations:

Other users.

Social features are a core component of our application. Other users may, for example, see your profile data, in-app activities and read the messages you have posted.

Our service providers.

AddNow has vendors who help us to provide the Service. These vendors process your data only at and according to AddNow’s instructions to provide the Service and perform tasks such as hosting, support, advertising, analytics, and fraud prevention.

Other companies and public authorities.

To verify payments (with payment providers such as PayPal) and combat fraud and illegal activity, we may process and disclose data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our users, or others.

Advertising and Social Media partners.

The Service includes features from our partners, such as social media interaction tools, functionalities through application programming interfaces (APIs) or software development kits (SDKs) and in-app advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

These partners may access data regarding your activities and your device (such as your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share data we have collected about you with third-party advertising partners. These advertising partners may use this data (and similar data collected from other services) for purposes of delivering targeted advertisements to you when you visit third-party services within their networks. These partners may operate under their own privacy policies. This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising.”

PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA

We use your data for a variety of business purposes, such as:

To make the service work

AddNow processes the personal data of the User to be able to offer the Services to the Users primarily under the contract between the User and AddNow.

To perform the contract, we process data necessary to

• Create accounts and allow you to use our Service
• Operate the Service
• Verify and confirm payments
• Provide and deliver products and services you request
• Send you Service-related communications

To make the Service more suitable for our users

To provide a great service to our users, we have a legitimate interest in collecting and processing necessary data to

• Update and develop user profiles
• Develop and improve the Service and user experience
• Manage our relationship with you
• Provide social features as part of the Service
• Customize your Service experience
• Respond to your comments and questions and provide user support
• Provide you AddNow offers in the Service as well as in other websites and services (including by email)
• Send you related information, such as updates, security alerts, and support messages
• Enable you to communicate with other players

For claims handling and legal obligations

AddNow may process personal data in relation to claims handling, debt collection and legal processes. We may also process data to prevent fraud, misuse of our services, and data, system, and network security.

We process data to enable us to administer and fulfil our obligations under the law. This includes data processed to comply with our bookkeeping obligations and provide information to relevant authorities such as tax authorities.

For communication and personalized advertisements.

AddNow may process your personal data to contact you regarding the Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Services to you.

To show you personalized advertisements in the Service and elsewhere (including email) we have a legitimate interest in processing necessary data to

• Track the content you access in connection with the Service and your online behaviour
• Deliver, target, and improve our advertising and the Service

To keep the Service safe and fair

To keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyse and monitor the use of the Service and its social features
• Moderate communication either automatically or manually
• Act against fraudulent or misbehaving users

For quality improvement and trend analysis

We may also process information about your use of the Services to improve the quality of the Services e.g., by analysing any trends in the use of the Services. To ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

To analyse, profile, and segment.

In all of the above cases and purposes, we may analyse, profile and segment all collected data.

Legal grounds for the processing

We process the personal data of a registered User to perform our contractual obligations towards the User. We also process personal data to comply with our legal obligations. Furthermore, we process the User’s data to pursue our legitimate interest in running, maintaining, and developing our business and creating and maintaining customer and other business relationships. When choosing to use your data based on our legitimate interests, we weigh our interests against your right to privacy and, e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymised or non-personally identifiable data when possible.

In some parts of the Services, you may be requested to grant your consent to process personal data. In this event, you may withdraw your consent at any time.

With your consent.

With your consent, we may process your data for additional purposes

TRANSFER TO COUNTRIES OUTSIDE EUROPE

AddNow stores your data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, our service providers and we may transfer your data to or access it in jurisdictions outside the European Economic Area or the User’s domicile.

INTERNATIONAL DATA TRANSFERS

We will take steps to ensure that your data receives an adequate level of protection in the jurisdictions in which they are processed. If we transfer personal data to recipients in third countries (countries outside the EU or European Economic Area), you can infer this from the information on data processing by our service providers described in this privacy notice. By adopting adequacy decisions, the European Commission has determined whether such a third country provides an adequate level of data protection. The exact list of countries with an adequacy decision can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. If an adequate level of protection has not been determined by the European Commission for a third country, we will ensure that the adequate level of data protection is provided through other measures, such as binding internal data protection rules, standard contractual clauses, certification mechanisms or recognized codes of conduct.

RECIPIENTS

We only share your personal data within the organisation of AddNow if and as far as reasonably necessary for the purposes of this Privacy Statement.

We do not share your personal data with third parties outside of AddNow’s organisation unless one of the following circumstances applies:

For the purposes set out in this Privacy Statement and to authorised service providers

We may provide your personal data to our affiliates or to authorised service providers who perform services for us (including data storage, accounting, sales, marketing, and payment service providers) to process it for us.

When third parties process data on behalf of AddNow, AddNow has taken the appropriate contractual and organisational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Services, the processing is typically based on their policies and standards.

For legal reasons and legal processes

We may share your personal data with third parties outside AddNow if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (I) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of AddNow, you or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons

If AddNow is involved in a merger, acquisition, or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give you notice when your personal data are transferred or become subject to a different privacy statement if your personal data is concerned.

With your explicit consent

We may share your personal data with third parties outside AddNow when we have your explicit consent to do so. You have the right to always withdraw this consent.

YOUR RIGHTS

Opt-out of marketing emails and other direct marketing.

You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications, or by changing your in-app settings. The updated settings may not be effective immediately. Note that you may continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy.

Push Notifications

We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest-Based Ads" (Android).

You can also opt-out of personalized in-app offers through the options provided in the application settings (where applicable).

Access the personal data we hold about you.

If you request, we will provide you with a copy of your personal data in an electronic format.

Your other rights

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent.

We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may also contact your local data protection authority within the European Economic Area, Switzerland, or UK for unresolved complaints.

If you wish to exercise any of your data subject rights described above, please use the support options described in “Contact Us” above. We will respond to all requests in accordance with applicable laws.

Right to restriction of processing

You may request us to restrict the processing of personal data, for example, when your data erasure, rectification, or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may, however, lead to fewer possibilities to use the Services.

How to use your rights

The abovementioned rights may be used by sending a letter or an e-mail to us at the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.

To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as requesting you provide us with a purchase receipt or other account information, asking you to link your email address with your application account (for example through AddNow ID), or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.

You have the right not to receive discriminatory treatment as a result of your exercise of these rights.

DIRECT MARKETING

We will only contact you for the purposes of direct marketing if you have voluntarily given your consent to marketing communications. You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us at the addresses indicated above, by using the unsubscribe possibility offered in connection with any direct marketing messages or via your User settings on the Platform.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements, and prevent fraud. Cookies and similar technologies allow us and our partners to store their preferences and track your activities within the Service. Note that our partners may operate under their own privacy policies.

We and our partners collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We do so to

• Detect and prevent fraud.
• Allow users to use the Service on one device and pick up seamlessly where they left off on another device.
• Analytics, personalization and attribution.
• Limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or
• Provide personalized advertising on each device that is inferred from the browsing patterns on all the devices.

You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

INFORMATION SECURITY

HOW DO WE PROTECT YOUR DATA

Security Safeguards

To help ensure a secure and safe user experience, we are continuously developing and implementing administrative, technical, and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration. Measures include, for example, encryption, pseudonymisation, firewalls, secure facilities, and proper access systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience, and ability to restore the data. In addition, we regularly test the Services, systems, and other assets for security vulnerabilities.

Should, despite the security measures, a security breach occur that is likely to have adverse to transmit those data to a third party independently effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

Data retention

We retain your data for as long as your account is active or as needed to provide you with the Service. We may for example periodically de-identify unused accounts, and we may regularly review and de-identify unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data storage period

AddNow does not store your personal data longer than is legally permitted and necessary for the purposes of this Privacy Statement. The storage period depends on the nature of the information and on the purposes of the processing. The maximum period may therefore vary per use.

Most User Data relating to a user’s user account with the Services will be deleted after a period of 2 months has elapsed after the User has deleted its user account with the Services. Contact Data will be stored if we have an ongoing business relationship with the organisation the User in question represents. Thereafter, a part of the Contact Data or personal data relating to a User’s user account with the Services may be stored only if such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes.

We will store Analytics Data relating to non-registered Users of the Services for ten years.

LODGING A COMPLAINT

If you consider our personal data processing to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).