AITOKAIKU PRIVACY POLICY
Effective Date: February 18, 2016

1. GENERAL

Aitokaiku Ltd ("Aitokaiku”) takes your privacy matters very seriously. This Privacy Policy (“Privacy Policy”) details how Aitokaiku receives, collects and uses personal information in connection with our website www.aitokaiku.com ("Website") and Aitokaiku’s software application ("Application"). Website, Application and the other Aitokaiku services offered to you through Application or Website and any part thereof are collectively referred to in these terms as the "Service".

The phrase "Personal Information" in this Privacy Policy means any information on a private individual and any information on his/her personal characteristics or personal circumstances, where these are identifiable as concerning him/her or the members of his/her family or household (including but not limited to your name, address, e-mail address)

The phrase “Identification Information” in this Privacy Policy shall have the same meaning as defined in the section 3 subsection 40) of the Finnish Information Society Code (917/2014, as amended).

Aitokaiku processes Personal Information and Identification Information in accordance with Finnish Personal Data Act (523/1999, as amended) and Finnish Information Society Code and other applicable legislation. This Privacy Policy also includes a description of data file and information document described in sections 10 and 24 of the Personal Data Act and gives user the information regarding the use of Identification Information as described in the Finnish Information Society Code

BY VISITING THE WEBSITE AND/OR INSTALLING THE APPLICATION OR USING THE SERVICE, YOU ARE ACCEPTING THE POLICIES AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY, AS MAY BE AMENDED FROM TIME TO TIME. EACH TIME YOU VISIT THE WEBSITE OR USE THE SERVICE, YOU AGREE AND EXPRESSLY CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF THE PERSONAL INFORMATION THAT YOU PROVIDE AS DESCRIBED IN PRIVACY POLICY AND YOU AGREE AND EXPRESSLY CONSENT TO OUR USE OF IDENTIFICATION INFORMATION. AITOKAIKU RESERVES THE RIGHT TO MODIFY THIS PRIVACY POLICY. YOUR CONTINUED USE OF SERVICE WILL SIGNIFY YOUR ACCEPTANCE OF THE CHANGES TO THIS PRIVACY POLICY. PLEASE DO NOT DOWNLOAD, INSTALL OR USE THE APPLICATION AND/OR USE THE SERVICE OR WEBSITE IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

2. DATA CONTROLLER AND CONTACT INFORMATION

Data Controller is Aitokaiku Ltd (Business Identity Code: 2733250-7), Sipoonkatu 11 A 10, 00520 HELSINKI, Finland.

For questions and information about Privacy Policy, please contact us by email: info@aitokaiku.com or alternatively by mail: Aitokaiku Oy, Privacy Policy, Sipoonkatu 11 A 10, 00520 HELSINKI, Finland.

3. NAME OF THE REGISTER

Aitokaiku’s customer and user register.

4. PURPOSE OF PROCESSING PERSONAL INFORMATION

The purpose of Aitokaiku’s processing of Personal Information is to:

(i) provide the Service to the user;
(ii) ensure an efficient and secure use of the Service;
(iii) provide customized Service and other content recognizing user specific needs and interests;
(iv) improve, develop and analyze our Service and other Aitokaiku’s business activities;
(v) manage customer relations, as well as to provide good customer service; and
(vi) conduct research and collect statistics (e.g. what sections of the Website/Application the users visit, how much the users use the Service and how much time time they spend on the Website, Application or use the Service);

The Personal Information may also be used for direct marketing purposes, market research and to fulfil the requirements based on legislation and authority regulations.

Aitokaiku will store users Personal Information only for as long as is necessary in order to fulfil the purposes set out in this section and/or in accordance with the applicable legislation.

5. DATA SUBJECTS

Aitokaiku collects Personal Information and Identification Information on persons who use the Service or if the collection of Personal Information and/or Identification Information derives from a legal obligation. Most of the Personal Information is collected from the data subjects themselves when the user downloads and/or installs the Application or uses the Service and/or when the user creates a user account. Updates to the Personal Information may also be received from authorities, organizations, companies offering updating services, public directories and other public sources of information.

Application does not record or transmit sensor data from your device to Aitokaiku and no music as such created by you using the Application can be used to identify you.

When visiting the Website, certain technical and other information (that may be Personal Information) may be automatically sent by your computer to us (e.g. IP address, the type of your browser and the source of your visit). Aitokaiku can also collect information about your website usage information by using cookies. Please see the Cookies section of this Privacy Policy for further information. Any or all of the activities with regard to Website usage information may be performed on our behalf by our service providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).

In the event Aitokaiku makes message boards and forums available to users (collectively, "Forums"), users will be solely responsible for the information and any other content you post on and through these Forums and should be aware that when you voluntarily disclose Personal Information (e.g. name, e-mail address, telephone number) on or through these Forums, such information is generally accessible to, and may be collected and used by, other users. This may result in unsolicited messages from third parties, and such messages are beyond our control. Aitokaiku does not exercise control over any users or Website visitors, and in no way is Aitokaiku responsible, nor does Aitokaiku have any liability whatsoever, for any collection or use of information you may disclose through the Forums. This Privacy Policy does not cover such disclosure of information. You are encouraged to exercise discretion when providing Personal Information about yourself in and through Forums. Please do not post any Personal Information on the Website that you expect to keep private.

6. INFORMATION AITOKAIKU COLLECTS

Aitokaiku may collect the following information and Personal Information from you when you use the Service, these come from your user account and Service usage information. By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy.

Usage and other Non-Identifiable Data:

When you use the Aitokaiku Service, Aitokaiku receives and stores certain personally non-identifiable information, such as the total number of visitors to our Website, the number of visitors to each page of our Website, device and browser information as well as Service usage data. We cannot currently use this information to identify you. It is important to note that no Personal Information is available or used in this process.

Aggregated Personal Information and other Information:

In an ongoing effort to better understand and serve our users, Aitokaiku conducts research on user demographics, interests and behaviour based on the Personal Information and other information provided to us. Aitokaiku compiles and analyses this research on an aggregate basis, and may share this aggregate data with partners of Aitokaiku. This aggregate information does not identify you personally. Aitokaiku may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Aitokaiku also collects information regarding the use of Application in order to better understand user behaviour and trends, detect potential outages and technical issues. All log analysis is done in an anonymous, aggregate, non-personally identifiable manner.

7. USE OF IDENTIFICATION INFORMATION

Identification Information is processed and used to the extent permitted by the law and primarily for providing the Service. After processing the Identification Information is destroyed or rendered in a manner that it cannot be associated with the user involved, unless otherwise provided by law or set forth in this Privacy Policy or Terms and Conditions of the Service.

Aitokaiku may also process Identification Information for the following purposes and on following conditions:

(i) Aitokaiku may process Identification Information to the extent it is necessary for billing purposes. In such event, Aitokaiku will inform the user what Identification Information it will process and how long the processing will last.
(ii) Aitokaiku may process Identification Information for marketing its services to such extent and for such period of time as the marketing requires. BY USING THE SERVICE, YOU GIVE YOUR CONSENT THAT THE IDENTIFICATION INFORMATION MAY BE USED FOR MARKETING PURPOSES. YOU WILL HAVE THE RIGHT TO CANCEL YOUR CONSENT REGARDING THE PROCESS OF THE IDENTIFICATION INFORMATION FOR THE MARKETING PURPOSES BY CONTACTING AITOKAIKU IN A MANNER DESCRIBED IN SECTION 9 OF THIS PRIVACY POLICY.
(iii) Aitokaiku may process Identification Information for the purposes of technical development of the Service. In such event, and prior to the start of the processing the Identification Information, Aitokaiku will inform the user what Identification Information it will process.
(iv) Aitokaiku may process Identification Information for the purposes of statistical analysis if 1) the analysis cannot be made by any other means without undue difficulty; and 2) no individual natural person can be identified in the analysis.
(v) Aitokaiku may process Identification Information for detecting, preventing or investigating any non-paying use of fee-based services or similar cases of misuse.
(vi) Aitokaiku may process Identification Information if it is necessary for the purpose of detecting, preventing or investigating a technical fault or error in the transmission of communications.

8. REGULAR DESTINATIONS OF DISCLOSED DATA AND THE TRANSFER OF PERSONAL INFORMATION TO COUNTRIES OUTSIDE OF THE EUROPEAN UNION OR THE EUROPEAN ECONOMIC AREA

Aitokaiku may disclose the Personal Information within the limits of the applicable legislation. Personal Information may be disclosed to co-operation partners chosen by Aitokaiku for their marketing purposes, unless the data subject prohibits such disclosure of his/her data. The recipients of such Personal Information are not allowed to disclose Personal Information further.

Identification Information may only be disclosed to those parties entitled to process it in the given situation.

The confidentiality of the Personal Information or Identification Information may be broken when required by law or statute, or by ruling of authority.

Due to the technical and practical requirements some of the Personal Information or Identification Information may be processed by subcontractors located outside the European Union or European Economic Area or at the subcontractors’ servers outside the European Union or European Economic Area. If any Personal Data is transferred outside the EU or EEA, Aitokaiku will ensure that the country to which the Personal Data is transferred is approved as having a sufficient level of privacy protection by the European Commission, or by using standard contractual model clauses approved by the European Commission.

9. THE PRINCIPLES OF SECURING THE DATA REGISTER

Aitokaiku uses technical and organizational measures to protect Personal Information and Identification Information against unauthorized access, transfer, deletion or other handling that may compromise information security. Such methods include the use of firewalls, encryption technologies and safe server rooms, proper access control systems, the controlled provision of user rights and supervision of their use, providing instructions for data processors, and the thorough selection of competent subcontractors who comply with industry standards for information security management.

Only appointed personnel of Aitokaiku and of companies operating by Aitokaiku’s assignment or on behalf of Aitokaiku are entitled to use Personal Information and Identification Information. All persons processing the Personal Information and/or Identification Information have a personal right of use granted by Aitokaiku.

10. RIGHT OF ACCESS, CORRECTION AND PROHIBITION

You may at any time contact Aitokaiku to check that the Personal Information related to you is accurate. Upon your request, Aitokaiku will modify, remove or supplement any incorrect, unnecessary, incomplete or outdated Personal Information.

The request to must be made in writing to Aitokaiku and it must be signed. The request for right of access can also be presented in person in the main office of Aitokaiku at the address Aitokaiku Oy, Sipoonkatu 11 A 10, 00520 HELSINKI.

The user has the right to prohibit Aitokaiku from processing his/her Personal Information or Identification Information for purposes of direct advertising, distance selling, other direct marketing and market research and opinion polls.

If you no longer wish to receive e-mail communication from Aitokaiku, such as offers, updates and newsletters, you may opt-out of receiving such communications by following the instructions included in each newsletter or communication.

11. COOKIES, CLEAR GIFS AND OTHER AUTOMATICALLY COLLECTED DATA

If you have permitted your computer to accept cookies, Aitokaiku may use cookies on the Website. Cookies are pieces of information that a website transfers to an individual's hard drive for record-keeping purposes. Cookies make web-surfing easier by saving preferences and browsing patterns while you are at the Website. Cookies may be used to analyze the Website usage, improve content, customize the Website's content and layout and for other customer service purposes. A cookie may enable us to relate your use of our Website to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Website. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Site or certain areas or features of the Website.

Aitokaiku may use "clear GIFs" (aka "Web beacons" or "pixel tags") or similar technologies, in the Website and/or in our communications with you to enable us to evaluate Website usage information about visitors to the Website, target campaigns, upgrade visitor information, and know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual's viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.

12. THIRD-PARTY SITES AND PRIVACY PRACTICES

Website may contain links that will let you leave Website and access another website. Websites linked to or from Website are not under the control of Aitokaiku and it is possible that these websites have a different privacy policy. Privacy Policy applies solely to Personal Information that is acquired on the Website or through your use of the Service, and/or your relationship with Aitokaiku. Aitokaiku urges you to be careful when you enter any Personal Information online. Aitokaiku accepts no responsibility or liability for these other websites.

13. ANALYTICS COLLECTION

Aitokaiku may use website analytics, such as Adobe Analytics and Google Analytics to gather anonymous statistics about the users of the Website with the aim to improve the Website. If Aitokaiku uses such analytics, it will provide the user an opt-out function to indicate that you do not want Aitokaiku to track your visits to Website or use of the Application.

14. CHILDREN'S PRIVACY

The Aitokaiku Website, Application and Service are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect Personal Information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

15. CHANGES TO POLICY

From time to time, Aitokaiku may revise this Privacy Policy. Aitokaiku reserves the right to update or modify this Privacy Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Privacy Policy without giving you an opportunity to opt-out of such differing uses.

Aitokaiku will post the revised Privacy Policy on the Website, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Privacy Policy periodically so that you are aware of any modifications. Your continued use of the Website and/or Service indicates your assent to any changes and signifies your agreement to the terms of our Privacy Policy. If you do not agree with these terms, you should not use the Website, Application or the Service.

16. GOVERNING LAW

This Privacy Policy shall be governed by and interpreted in accordance with the laws of Finland, excluding its conflicts of law rules, and shall be subject to the exclusive jurisdiction of the courts of Finland.