Privacy policy for Growpolis’ customers, potential customers and interest groups

Effective as of June 1st, 2020

+ 1. Controller of the filing system

Controller of these filing systems is the Finnish company Rockyplat Oy / Growpolis (business registration number: 2921163-7) and companies at the time belonging to the Growpolis Group, all together hereinafter referred to as ”Growpolis” or “We” / “Us”.

Our contact details in privacy matters are:

Please do not hesitate to contact us if you have any questions, concerns or ideas related to Growpolis’s personal data procedures.

In addition to being processed in Our filing systems, your Personal Data may be processed in the filing systems of Our service providers offering their products and services to You via the GROWPOLIS platform (“Partners”). In such case the privacy policies of the Partners are also applicable to processing of your Personal Data.

+ 2. Definitions

In the following the most essential terms used in this Privacy Policy are explained:

1.1. ‘Business Customer’ means any representative of a company, association, foundation or public body which has purchased or ordered something from Growpolis or has some other type of other relevant connection with Growpolis.

1.2. ‘Potential Business Customer’ means any representative of a company, association, foundation or public body which is not yet or anymore an active client.

1.3. ‘Interest Groups’ means amongst others representatives of suppliers, the press, entities offering services to Growpolis and other stakeholders.

1.4. ‘Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’).

1.5. ‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

1.6. ‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

+ 3. To what purposes we process your data and based on which grounds?

This Privacy Policy covers processing of Personal Data of Business Customers, Potential Business Customers as well as representatives of different Interest Groups. In the following we explain the differences in each category. One or more roles and purposes may apply simultaneously.

3.1. Business Customers

  • Providing products and services
    Growpolis may use your Personal Data for providing products and services for you, for example when you purchase products and services through Growpolis’s platform, use Our other digital services, subscribe to our newsletters and participate in Our events.
  • Managing, analyzing and improving the customer relationship
    Growpolis may use your Personal Data for managing, analyzing and improving the customer relationship with you and the entity you represent.
  • Communication with you
    Growpolis may use your Personal Data to communicate with you, for example to send you invitations, important alerts and other such notices relating to Our or Our Partners’ products and services, invitations to market research and to ask for your feedback on our products and services.
  • Marketing to you
    Growpolis may contact you to enhance your experience with Growpolis by informing you of new products, services or promotions Growpolis may offer itself or on behalf of its Partners. Growpolis may use your Personal Data to personalize Growpolis’s offering and to provide you with more relevant content. This means for example making recommendations and to display customized content and advertising in Our services (such as websites, applications and marketing e-mails) and in third party services (such as display advertisements).
  • Managing and developing products and services
    Growpolis may use your Personal Data to manage and develop Growpolis’s business operations, including its products and services as well as to manage and develop the business operations, products and services of the chosen Partners.

Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):

a) Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

b) Processing is necessary for the purposes of the legitimate interests pursued by Growpolis or by a third party, such as the Partners.

c) You have given consent to the processing of your Personal Data.

d) Processing is necessary for compliance with a legal obligation to which Growpolis is subject (for example the duty to keep the records based on Accounting Act).

The legitimate interests of Growpolis or third party referred to above may include amongst others the following matters:

  • right to promote the sales of Growpolis’s and Partners’ products and services by way of direct marketing, including Profiling for the purposes of marketing and sales;
  • business development, and
  • investigation of possible malpractice.

3.2. Potential Business Customers

  • Marketing to you
    Growpolis may contact you to promote its or its Partners’ products and services or to invite you to events. Growpolis may use your Personal Data to personalize its offering and to provide you with more relevant content. This means for example making recommendations and to display customized content and advertising in Our services (such as websites, applications and marketing e-mails) and in third party services (such as display advertisements).
  • Communication with you
    Growpolis may use your Personal Data to communicate with you, for example to ask for your feedback on our prior engagement with you.
  • Managing and developing products and services
    Growpolis may use your Personal Data to manage and develop Growpolis’s business operations, including its products and services as well as to manage and develop the business operations, products and services of the chosen Partners.

Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):

a) Processing is necessary for the purposes of the legitimate interests pursued by Growpolis or by a third party, such as the Partners.

b) You have given consent to the processing of your Personal Data.

The legitimate interests of Growpolis referred to above may include amongst others the following matters:

  • right to promote the sales of Growpolis’s products and services by way of direct marketing, including profiling for the purposes of marketing and sales;
  • customer service for potential customers; and
  • business development.

3.3. Interest groups

  • Managing, analyzing and improving the relationship
    Growpolis may use your Personal Data for managing, analyzing and improving the relationship with you and the entity you represent.
  • Communication with you
    Growpolis may use your Personal Data to communicate with you, for example to send you news, alerts and other such notices relating to Our relationship as well as invitations.
  • Managing and developing products and services
    Growpolis may use your Personal Data to manage and develop Growpolis’s business operations, including its products and services as well as to manage and develop the business operations, products and services of the chosen Partners.

Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):

a) Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

b) Processing is necessary for the purposes of the legitimate interests pursued by Growpolis or by a third party, such as the Partners.

c) You have given consent to the processing of your Personal Data.

d) Processing is necessary for compliance with a legal obligation to which the controller is subject (for example the duty to keep the records based on Accounting Act).

The legitimate interests of Growpolis referred to above may include amongst others the following matters:

right to promote the business activities of Growpolis by way of for example press releases, and
business development.


In addition to the above, Growpolis uses your data in which ever role you are if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our agreements or this Privacy Policy.

+ 4. What types of information we may collect about you?

Content of Growpolis’s filing system may include the following types of data and changes made to these data types:

  • first and last names
  • contact data (e-mail address, telephone number and/or postal address, social media account names)
  • title and/or job description of current and previous jobs related to activities with Growpolis
  • name and business information of the entity you work for currently or previously, related to activities with Growpolis
  • language preferences
  • gender
  • data available from social media accounts (such as LinkedIn)
  • when your data was put into the filing system
  • campaigns, promotions and other communication directed to you, as well as their use, including participation in events
  • interests and other information or survey data provided by you
  • direct marketing choices
  • use of your rights related to your Personal Data (such as right of access and right to rectification)
  • information of the use of Growpolis’s digital services as well as digital content created by you
  • automatically collected data (such as IP Address, your device’s operating system, browser type and language)
  • mobile device identifiers (such as your unique device ID and your device name)
  • recordings of customer service telephone conversations as well as e-mail and chat correspondence
  • subscription and purchase history
  • Personal Data contained in documents and information provided by or or behalf of you

+ 5. Which sources we gather your Personal Data from?

Growpolis gathers Personal Data directly from you, for example from:

  • website forms,
  • mobile applications,
  • physical forms in events,
  • telephone conversations, e-mail correspondence and chat services, and
  • other customer service communications.

Growpolis may gather Personal Data from the technical device you use in your communication with Growpolis.

Growpolis may obtain and update the Personal Data in its filing system from the Partners offering services via Growpolis as well as from officials and companies offering personal data services. Growpolis may gather Personal Data from companies’ websites, official company registers, social media and from other public sources.

Growpolis may gather Personal Data from the Business Customer when the representative of the company gives Personal Data of other employees of said company to Growpolis.

+ 6. To whom we may transfer and assign your Personal Data?

Growpolis does not sell, lease or otherwise disclose your Personal Data to third parties outside of the Growpolis Group unless otherwise stated below.

Growpolis shares your Personal Data with authorized third parties that perform services for Growpolis for the purposes described in this Privacy Policy within the limits of the applicable legislation. This may include for example providing services such as the commercial advice services, customer service (including chat services) and software services, managing and analyzing Personal Data, conducting market research as well as planning and execution of diverse campaigns.

Growpolis may share your Personal Data for obtaining payment for products and services including the transfer or sale of delinquent accounts to third parties for collection.

Growpolis takes the responsibility to safeguard your Personal Data seriously. Growpolis does not allow the above described third parties to use your Personal Data for any purpose other than to perform those services, and Growpolis requires them to protect your Personal Data in a way consistent with this Privacy Policy.

Growpolis shares your Personal Data with the chosen Partners offering their services through Growpolis platform. In addition to processing your Personal Data on behalf of Growpolis the Partners may have the need to process your Personal Data independently in their own customer data files, in which case the processing is carried out according to their individual privacy policies. Growpolis urges you to read those privacy policies as well when purchasing products and services from a chosen Partner.

Growpolis may share your Personal Data with potential investors seeking to invest in Growpolis’s customers. Such data may be disclosed only with the customer company’s and its representatives’ consent.

Growpolis may share your Personal Data with carefully considered third parties for joint or independent direct marketing purposes. Sharing of your Personal Data for such purposes may in principle only happen when the planned purposes of the third party are not incompatible with Growpolis’s purposes described in this Privacy Policy. Only the minimum necessary amount of your Personal Data is shared with third parties.

Growpolis may share your Personal Data based on a valid order from a court or other official body with sufficient authority.

Growpolis may share your Personal Data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your Personal Data would be transferred to another entity as a result of such a proceeding.

+ 7. How long do we process your Personal Data?

Growpolis may process your Personal Data for as long as described below for each different sub-group. In addition to the below stated times, Growpolis may always process your Personal Data for e.g. tax or legal purposes or due to an extraordinary long-term commitment for as long as necessary and justified.

7.1. Business Customers

Growpolis may process your Personal Data for as long as the customer relationship between the company you represent and Growpolis exists, and until the end of the calendar year following the 6th year thereafter.

Growpolis may process your Personal Data for as long as you are working at any company which is Growpolis’s customer, and until the end of the calendar year following the 6th year thereafter.

After the above specified timeframe has ended, Growpolis may process part of your Personal Data and consider you a representative of a Potential Business Customer.

7.2. Potential Business Customers

Growpolis may process your Personal Data continuously as Growpolis aims at building a customer relationship with the company you represent. Once the customer relationship has started, the duration of the processing is defined in point 7.1. above. Growpolis updates the Potential Business Customer data file and deletes Personal Data from time to time based on commercial decision making.

7.3. Interest Groups

Growpolis may process your Personal Data for as long as you are a member of any of Growpolis’s Interest Groups such as Our Partners or press representatives. Growpolis may process Personal Data related to a supplier of products or services or a contractual co-operation party until the end of the calendar year following the 6th year after the end of the contractual relationship.

+ 8. How can you exercise the different types of rights you have?

All rights can be exercised personally by contacting Growpolis’s privacy team by using the contact details issued at section 1 above. The team will then give further instructions on how to exercise a specific right. Where Growpolis has reasonable doubts concerning the identity of the person making the request, Growpolis may request the provision of additional information necessary to confirm your identity.

Growpolis will provide information on action taken on a request to you within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

8.1. Right of access to your Personal Data

You have the right to obtain from Growpolis confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, receive information about your personal data.

8.2. Right to rectification

You have the right to obtain from Growpolis without undue delay the rectification of inaccurate Personal Data concerning you.

8.3. Right to erasure (‘right to be forgotten’)

You have the right to obtain from Growpolis the erasure of Personal Data concerning you without undue delay where one of the following grounds applies:

(a) your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) you withdraw consent on which the processing is based and where there is no other legal ground for the processing;

(c) you object to the processing and there are no overriding legitimate grounds for the processing;

(d) your Personal Data have been unlawfully processed;

(e) your Personal Data have to be erased for compliance with a legal obligation in Union or member state law to which Growpolis is subject;

(f) the Personal Data have been collected in relation to the offer of information society services.

However, you do not have the right or erasure if the processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or member state law to which Growpolis is subject; or

(c) for the establishment, exercise or defence of legal claims.

8.4. Right to restriction of processing

You have the right to obtain from Growpolis restriction of processing where one of the following applies:

(a) the accuracy of the Personal Data is contested by you, for a period enabling Growpolis to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of their use instead;

(c) Growpolis no longer needs the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

(d) you have objected to processing pending the verification whether the legitimate grounds of Growpolis override those of you.

8.5. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you which is based on legitimate interests pursued by Growpolis or by a third party, including profiling. Growpolis shall no longer process the Personal Data unless Growpolis demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms for the establishment, exercise or defence of legal claims.

Where Personal Data are processed for direct marketing purposes, you have the right to object at any time to processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Please be aware that you cannot opt out of receiving service messages from Growpolis, including but not limited to security and legal notices. Please also note that the Growpolis platform includes marketing material such as Partners’ presentations.

8.6. Right to data portability

You have the right to receive the Personal Data concerning you, which you have provided to Growpolis, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where:

(a) the processing is based on consent or on a contract; and

(b) the processing is carried out by automated means.

+ 9. Is it mandatory for you to disclose your Personal Data to us?

Where your Personal Data is necessary for Growpolis in order to fulfil its contractual obligations related to a contract with you, disclosing your Personal Data to us is mandatory. For example, you cannot register as a user or make purchases from Growpolis’s online platform without disclosing the necessary Personal Data.

+ 10. How can you withdraw a consent given by you?

You may withdraw possible consent by contacting Growpolis’s privacy team (contact information in section 1) or by using possible electronic means provided by Growpolis.

+ 11. Do we make decisions affecting you based on automated means?

Growpolis does not for the time being make decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affect you.

+ 12. Do we process your Personal Data in order to profile you?

Growpolis may target (and measure the performance of) ads to its websites’ and applications’ visitors and users as well as newsletters recipients based on profiling both on and off of Growpolis’s services for example through a variety of ad networks and exchanges, using the following data, whether separately or combined:

  • data from advertising technologies on and off of Our services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • information provided by you (e.g., contact information);
  • data from your use of Our services (e.g., search history, clicking on an ad or product etc.);
  • information from others (e.g. advertising partners and data aggregators);
  • information inferred from data (e.g., using job titles to infer seniority or names to infer gender).

+ 13. What are our principles for securing your Personal Data?

Growpolis has established electronic and administrative safeguards designed to make the information collected secure.

Only appointed personnel of Growpolis and of organizations operating by Growpolis’s assignment or on behalf of Growpolis are entitled to use the Personal Data filing system. All persons processing the system have a personal right of use granted by Growpolis or its co-operation partner. Different levels of access have been created based on the data a person needs according to his/her job description. Systems are protected with a firewall that prohibits unauthorized access outside of Growpolis.

All personnel of Growpolis and its subcontractors are obliged to keep the information of the Personal Data which they obtain in their work confidential.

Manually processed documents containing Personal Data are protected against unauthorized access.

+ 14. Is your Personal Data transferred to countries outside the European Union?

Growpolis’s services may be provided using resources and servers located in various countries around the world. Therefore Growpolis may transfer your Personal Data outside the country where you use our services, including to countries outside the EU and EEA that do not have laws providing specific protection for Personal Data or that have different legal rules on data protection.

In such cases Growpolis ensures that a legal basis for such a transfer exists and that adequate protection for your Personal Data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

+ 15. How can you exercise your right to lodge a complaint to the supervisory authority?

In case you suspect a breach of data protection legislation, please contact Growpolis’s privacy team first (contact information in section 1). In case the matter is not solved amicably between you and Growpolis, you may contact the Data Protection authority of the country where the Growpolis entity in question operates, currently Finland. Contact information of the competent authority can be found here.

+ 16. Which law do we apply for processing Personal Data?

The processing of Personal Data in Growpolis’s filing system is governed by the European Union’s applicable data protection legislation as well as national laws of countries where Growpolis is established, currently Finland.

+ 17. How can we update this Privacy Policy?

Growpolis may modify this Privacy Policy, and if we make material changes to it, we will provide notice on Our website or by other means, to provide you the opportunity to review the changes before they become effective. Your continued use of Growpolis’s products and services after We publish or send a notice about Our changes to this Privacy Policy means that you have become bound by the updated Privacy Policy.