1. Controller
AitoHR Oy, Business ID 2959860-8.
Privacy and data subject requests: contact@aitohr.fi.
2. Who this notice covers
This notice applies to people who subscribe to the Kirjado newsletter using the website form.
3. Data processed and its source
We obtain the data directly from you through the subscription form. We process:
- your email address
- your optional name
- your optional reader or author choice
- your optional interests or professional roles
- the time of consent and the source page
- technical data needed to deliver the newsletter and manage the subscription.
4. Purposes of processing
We use the data to:
- send the Kirjado newsletter and manage subscriptions
- understand subscriber interests
- plan, improve and, where useful, segment newsletter content
- demonstrate consent and handle privacy requests.
We do not sell the data or use it for personal sales contacts.
5. Legal basis and withdrawing consent
The legal basis is your consent. You may withdraw it at any time using the unsubscribe link in a newsletter or by emailing contact@aitohr.fi. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6. Required and optional data
An email address is needed to deliver the newsletter. All other form data is optional. We cannot send the newsletter without an email address and consent.
7. Recipients and processors
Data is processed by authorised AitoHR Oy personnel and by service providers acting on its behalf for website forms, data transfer and automation, website operation, email and newsletter delivery. The form uses Make for data transfer.
Service providers may process data only under AitoHR Oy’s instructions and applicable data protection law. We do not disclose data to third parties for their own marketing.
8. Transfers outside the EEA
Some service providers may process data outside the European Economic Area. Transfers rely on a European Commission adequacy decision or another lawful safeguard, such as standard contractual clauses, with supplementary measures where needed.
9. Retention
Subscriber data is retained while the subscription and consent remain valid. When you unsubscribe, your data is removed from the active mailing list without undue delay. Limited records of consent and withdrawal may be retained as needed to demonstrate legal compliance or handle legal claims.
10. Automated decision-making and profiling
Optional interest and role choices may be used to plan content or group subscribers. We do not use the data for automated decisions that produce legal or similarly significant effects concerning you.
11. Your rights
Subject to applicable data protection law, you have the right to:
- obtain confirmation of whether we process your data and access it
- request correction of inaccurate or incomplete data
- request deletion of your data
- request restriction of processing
- receive data you provided in a portable format where applicable
- withdraw your consent at any time.
To exercise your rights, email contact@aitohr.fi. We may request additional information to verify your identity.
12. Security
We protect data using appropriate technical and organisational measures. Access is limited to people and providers who need it for their duties. However, no online service can guarantee absolute security.
13. Right to lodge a complaint
If you believe your data is processed unlawfully, you may lodge a complaint with a supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman: tietosuoja.fi.
14. Changes to this notice
We update this notice when our processing or service providers change. The current version and update date are published on this page. If the purpose of processing changes materially, we will request fresh consent where required.