Privacy Policy – Pauli Saari

This privacy policy provides information on the processing of personal data by www.paulisaari.com, hereafter Pauli Saariwe or us. We want you to feel secure when we are collecting and sharing your data and therefore, we want you to know how we collect, use, share, and keep the information about you and the choices that are available to you as a data subject. As such, this privacy policy is concerned with how we handle the personal data of visitors and customers of Pauli Saari (the Privacy Policy). The Privacy Policy applies to the Pauli Saari website, and the accompanying domains (dolphin-purple-ezb7.squarespace.com;  lifepurpose.eu; and purposeguide.eu), as well as your use of or access to any of our online services. Your use of our website and services (the Services) and any dispute arising over privacy is subject to this Privacy Policy.

We reserve the right to, at all times, and with or without any particular notification, make changes to this Privacy Policy. We might need to do so in the case of new developments, activities, online services, or when the applicable laws are amended. We therefore advise you to regularly check this Privacy Policy to make sure you are up to date on any possible amendments.

1. When does this Privacy Policy apply?

This Privacy Policy is applicable to the processing of personal data of customers and visitors of Pauli Saari. This Privacy Policy is also applicable to all personal data of clients which is stored and/or processed by Pauli Saari on a server within the EU.

When processing personal data of data subjects who are in the EU in connection with our Services, Pauli Saari acts as a data controller. When Pauli Saari determines the purpose and the manner of processing your personal data, Pauli Saari is deemed to be a data controller. We apply a similar approach to protecting your personal data regardless of whether we are acting as a data controller or a data processor.

Pauli Saari is committed to adequately protecting your personal data in accordance with the applicable laws and regulations, regardless of your location and where we process it. Similarly, we are committed to providing the appropriate protection framework when transferring your data outside of the EEA.

2. Which types of personal data do we collect and why?

(1)  To deliver you the website’s functionalities and for their technical and functional management

(i)             What does this purpose encompass?

For any person that accesses and/or uses our website, we process technical data to be able to offer you all our website’s functionalities and to allow our website’s administrators to manage and improve our website’s performance. We process your personal data in order to allow you to save your data (or preferences) to configure your device. To this end, we use cookies on the website to ensure you can retrieve information from our website quickly and easily. Consult our Cookie Policy for more information. 

(ii)           What legal ground justifies the processing of personal data for this purpose?

We process your personal data for this purpose based our legitimate interest. We do so to improve our overall marketing and communication efforts and to inform and update key stakeholders. 

(iii)         Which personal data do we process for this purpose?

For this purpose, we process any personal data that you have entered into our website yourself, or that is generated by the functionalities described under (i), which includes your IP-address and the internet browser you use. We make use of analytical cookies to register the pages you visited on our website, your click- and surf behaviour and the length of your session, yet in a way untraceable to an individual person.

(iv)          How long will we hold on to your personal data?

We will store personal data gathered for this purpose for a maximum of 1 year. After this period, we will permanently delete your personal data from our systems.

(2) To allow you to contact us or connect with us (e.g. on social media)

(i)                  What does this purpose encompass?

Pauli Saari maintains active accounts on several social media platforms. When you contact us via one of these platforms, we process your personal data in order to answer your queries, to respond to the messages or requests, and subsequently to contact you in relation to any campaigns we might run through these platforms from that point onwards.

Additionally, when you click any of the buttons included on our website to be able to contact us, we will refer you to the website or app of the applicable third party, whether this is your email provider or a social media platform. Consult our Cookie Policy for more information.

(ii)                 What legal ground justifies the processing of personal data for this purpose?

We process your personal data based on a legitimate interest. Being able to communicate with (potential) clients is vital to our platform. It can also improve our overall marketing and communication efforts.

(iii)                Which personal data do we process for this purpose?

For this particular purpose, we process via the communication channel which you have chosen to use to connect with us, and we process the personal data you used to connect with us and chose to supply to Pauli Saari. This includes your (user) name, address, email address, gender, and any additional personal data you included in your message. Moreover, if you accessed our social media through one of the buttons on our website, the relevant third party might place cookies on your device. For more information on this, refer to the ‘cookie’ section below.

(iv)                 How long will we hold on to your personal data?

We will store the data collected for this purpose for a maximum of 5 years. After this period, we will permanently delete all this data from our systems.

(3)  For answering your questions and handling of complaints

(i)             What does this purpose encompass?

If you get in touch with us at our address or via a contact form, we will use your personal data in order to reply to and answer your query or to respond to and handle a complaint.

(ii)           What legal ground justifies the processing of personal data for this purpose?

We process your personal data based on your consent and legitimate interest. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal.  In this case, the legitimate interest is constituted by our intent to carefully deal with your complaints and questions. 

(iii)         Which personal data do we process for this purpose?

To the end of this purpose we process your name, email address, your correspondence with Pauli Saari about your question or complaint and all other personal data which are necessary to answer your question or to handle your complaint.

(iv)          How long will we hold on to your personal data?

We will retain your personal data for as long as we need to execute your request or handle the complaint, plus a maximum of 1 month, after which the data will be deleted from our systems. 

(4)  To ensure correct enforcement and respect of your rights included in this Privacy Policy

(i)             What does this purpose encompass?

As a result of the rights you have as a person whose personal data is processed by us, which can be found in Section 6 of this Privacy Policy, we process your personal data in order to execute and administer your requests to us in relation to these rights. For example, if you want to exercise your right to be forgotten, we need to register a minimum amount of data in order to make sure that we do not contact you anymore.

(ii)           What legal ground justifies the processing of personal data for this purpose?Processing of this personal data is based on our legitimate interest. The legitimate interest we have is that we intent to respect your choices and thus, we want to ensure that if you exercise your right to be forgotten, we will never contact you again for any purpose. We also process this data in order to comply with applicable law, which is, in this case, the General Data Protection Regulation with regard to your privacy.

(iii)         Which personal data do we process for this purpose?

For this purpose, we process contact details such as your address and email address, and personal details such as your name.

(iv)          How long will we hold on to your personal data?

Due to the nature of this purpose, we need to store this data for an unlimited period.

(5)  For relationship management and marketing

(i)             What does this purpose encompass?

Pauli Saari uses the information stored in its database to send you newsletters, as well as to provide customer services. We also use your personal data for the development, execution, and analysis of market surveys and marketing strategies. 

(ii)           What legal ground justifies the processing of personal data for this purpose?

We process your personal data regarding newsletters based on your consent. You can withdraw your consent at any time, without this affecting the lawfulness of processing based on consent before withdrawal. Any data regarding customer services is based on our legitimate interest. After you have become our client, we will want to be able to reach our regarding your experiences with our Services in order to improve on them. 

(iii)         Which personal data do we process for this purpose?

For this purpose, we process you contact details such as your address and email address, personal details such as your name and date of birth, contact preferences, payment information, order history, and correspondence with us. 

(iv)          How long will we hold on to your personal data?

Personal data will be retained for a maximum of 10 years after the termination of our relationship. After this term, your personal data will be deleted from our systems. 

(6)  For the conclusion and execution of agreements

(i)            What does this purpose encompass?

When you agree to become a client of Pauli Saari, we enter into a contractual relationship. We process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data in order to deliver and administer your purchased Services, and for the implementation of our programs. Pauli Saari will process your personal data in order to further execute our agreement, including for the delivery of customer services.

(ii)           What legal ground justifies the processing of personal data for this purpose?

We process personal data for this purpose based the contractual relationship with you and legitimate interest. We do so on the basis of the contract that you have engaged in with Pauli Saari relating to the provision of the specific Service. We also hold a legitimate interest to process your data in order to ensure compliance with law.  

(iii)         Which personal data do we process for this purpose?

For this purpose, we process your contact details such as your address, phone number, and email address, personal details such as your name and date of birth, payment and credit information, order history and other data stored in our database with all relationships of Pauli Saari.

(iv)          For what period do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for 7 years after the end of our relationship with you. After this term, your personal data will be deleted from our systems.

(7)  To protect health and safety 

(i)             What does this purpose encompass?

Due to the nature of our Services, we maintain high standards when it comes to your (mental) health and safety. When it is necessary to process our personal data to protect your vital interests, we will do so. This could be, for example, notes taken during one of our sessions which will be kept in order to give you the best help we can.

(ii)           What legal ground justifies the processing of personal data for this purpose?

We process this personal data on the basis of your consent and our legitimate interest. Our legitimate interest is to ensure your safety, security, and (mental) health. 

(iii)         Which personal data do we process for this purpose?

For this purpose, we will process health data, medical data, and any other demographic information relating to your physical or mental health or condition.

(iv)          How long will we hold on to your personal data?

We will hold on to this personal data for as long as you use our Services plus a maximum of 1 year. 

3. Cookies

We also collect information about you by using cookies. Read more about the manner in which we use cookies in our Cookie Policy

4. Special personal data 

We insist on not processing any personal data of minors, unless this is explicitly consented to by a parent or legal guardian. However, as it is hard to detect whether we are doing so, we strongly encourage you to inform us if you have reason to believe we process the personal data of a minor. We will delete this personal data instantly. 

5. Who has access to your personal data?

Based on the various purposes of Pauli Saari’s processing of personal data set out above, it follows that personal data, normally, will not be shared with third parties except for these instances as mentioned. However, if it occurs that, for any reason, we will have to share your data with a third party, we will only do so if the various measures as set out under this section are in place. 

Pauli Saari is committed to providing a high level of security regarding your personal data and will therefore taken the necessary steps in order to execute this security. Only those who are authorized to access personal data within the context of their employment with Pauli Saari will do so, but only to the extent this is absolutely necessary within their particular job-function.  

Pauli Saari only shares personal data with third parties if it is necessary to serve its applicable purpose as set out above. In all cases, we will ensure that third parties with access to your personal data have implemented appropriate technical and organizational safeguards to maintain our envisioned level of privacy and security. We furthermore insist that all data protection and privacy laws are adhered to at all times by these third parties. In any case, we ensure that these third parties have at least the same level of technical and organizational safeguarding measures implemented as we have done. 

If your personal data is transferred to a recipient in a country outside the EEA or where an adequate level of protection of personal data is not provided for, Pauli Saari will take measures to ensure that your personal data is adequately protected in those countries as well, such as entering into the EU Standard Contractual Clauses with these third parties.

When a third party processes your personal data, they can only do so following our instructions. They therefore act as our data processor. We enter into the necessary agreement with the data processing where we include obligations to ensure your personal data is processed solely in order for the data processor to fulfil its duty to provide services to us.

In any other case, your personal data will not be supplied to third parties, except where mandated by law. 

6. Security

Your personal data will be stored securely at all times. We value the protection of your privacy. We treat personal data very carefully, and, possibly together with third parties, we ensure that appropriate organisational and technical protection measures are implemented to safely store personal data. In this manner, we ensure that the personal data is only accessible to those particular individuals who are authorized based on their job function, and therefore is only used for its intended purpose. Additionally, we have implemented measures to guarantee your safe visit to and use of our websites. In doing so, we prevent any abuse of your data. These measures include computer safeguards and secured files and facilities. 

Our website has a certified Secure Socket Layers (SSL) certificate[LvD2] . This is the standard security technology for establishing an encrypted link between a web server and a browser. This link ensures that all data passed between the web server and browsers remain private and integral. Your payment data is by encryption as well, and can only be accessed by password authentication. 

Pauli Saari has taken the necessary technical and organizational measures to prevent, signal, rapport, and handle any breach in its data protection. In the event that a data breach does occur, however, Pauli Saari will, without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the relevant Data Protection Authority. 

7. Accessing, correcting or removing personal data

You have the right to access, correct, or remove your personal data that we have stored. You also have the right to withdraw your previously given consent to the processing of your personal data, or to object to the processing of your personal data by Pauli Saari. Finally, you have the right to have a file sent to you, containing details of which of your personal data we have stored. You can send us a request to receive such a file in writing. Any request is subject to the applicable law, which means that we might need to keep the personal data stored.

We also want to inform and remind you of the ability to issue a formal complaint at the relevant national Data Protection Authority. 

If you object to Pauli Saari using your personal data, want your personal data to be forgotten, want to withdraw your previously given consent to process your personal data, or you have a different enquiry concerning your personal data, you can at any time send a request to:

Pauli Saari

Vikstensvägen 34 121 56 Johanneshov Sweden

pauli@paulisaari.com

External links 

Our website could sometimes display links to other websites. We are not responsible for the privacy policy that this other website adheres to, nor its content. We advise you to inform yourself by reading the privacy policies on these websites. 

Any questions?

In the event you still have questions after reading this Privacy Policy, or when you have any suggestions or comments about its content, you can always contact us at: pauli@paulisaari.com.