Updated on 2.7.2024.
Codeo Oy works with corporate clients and processes the personal data of its job applicants. Codeo handles personal data carefully and securely. This privacy policy describes the procedures that apply to personal data processed by Codeo.
This document is prepared in Finnish and in English. In case of differences between these two, the version in Finnish applies.
This privacy policy covers Codeo’s
- Customer and Marketing Register
- Recruitment Marketing Register
- Job Applicant Register
- Website codeo.fi Cookie Register
- General Information Regarding the Registers
1. Customer and Marketing Register Policy
Name of the Register
Codeo Oy Customer and Marketing Register
Purposes of Personal Data Processing
| Purpose | Basis | Maximum Retention Time or Criteria for Determination |
|---|---|---|
| Contacting the customer by email and phone with the aim of initiating a customer relationship. | The customer has given written or oral consent. | 7 years 0 months from consent or renewal, unless the person requests removal from the register before that. |
| General management, maintenance, and development of the customer relationship. | An assignment agreement and/or framework agreement has been concluded with the customer. | 7 years 0 months from the agreement or its renewal. |
| Production of software development services offered by Codeo to the customer. | An assignment agreement has been concluded with the customer. | 7 years 0 months from the agreement or its renewal. |
| Implementation of the rights and obligations of the customer and the controller. | Legal obligation of the controller. | Data stored for this purpose will be deleted last, immediately after the other purposes have ended. |
Information content of the register
The register contains the necessary identification details of the registered person and other information necessary for the purpose of use of the register.
The register may contain the following information about the customer’s persons:
- First and last name
- Email address
- Title and job description
- Phone number
- LinkedIn address
- Organization name, business ID and postal address
- Historical information about contacts (including dates, written messages and notes from meetings and calls)
- Instructions for communication
- Billing information
- Date added to the register
Regular sources of information
The information in the customer and marketing register is obtained directly from customers either through discussions, by email, or by the customer filling out Codeo’s contact request form. When making customer agreements, the customer representative’s right to sign can be checked from the Trade Register.
Disclosure and transfer of data
The information will not be disclosed, except when required by official actions. Due to data processing, some of the data may be located at Codeo Oy’s service providers (financial, marketing, enterprise resource planning). Personal data will not be disclosed outside the EU or EEA.
2. Recruitment Marketing Register Policy
Name of the Register
Codeo Oy Recruitment Marketing Register
Purpose of Personal Data Processing
| Purpose | Basis | Maximum Retention Time or Criteria for Determination |
|---|---|---|
| Directing recruitment marketing, i.e., sending career and newsletters. | The person has given their written or oral consent. | Until the register is discontinued, unless the person requests removal from the register before that. |
| Implementation of the rights and obligations of the job seeker and the controller. | Legal obligation of the controller. | Data stored for this purpose will be deleted last, immediately after the other purposes have ended. |
Information Content of the Register
The register contains the necessary identification information of the data subject. The following information may be processed in the register:
- Email address
- First and last name
- Date added to the register
Regular Sources of Information
Personal data may be collected within the framework of the Personal Data Act from the data subject themselves by phone, email, in meetings or when the person fills in the career and newsletter subscription form.
Disclosure and Transfer of Data
The information will not be disclosed, except when required by official actions. Due to data processing, some of the data may be located at Codeo Oy’s service providers (marketing, enterprise resource planning). Personal data will not be disclosed outside the EU or EEA.
3. Job Applicant Register Policy
Name of the Register
Job Applicant Register
Purpose of Processing Personal Data
| Purpose | Basis | Maximum Retention Time or Criteria for Determination |
|---|---|---|
| Communicating with job applicants by email and phone. | The person has given their written or verbal consent. | 3 years 0 months, unless the person requests removal from the register before that. |
| Fulfilling the rights and obligations of the job applicant and the controller. | Legal obligation of the controller. | Data stored for this purpose will be deleted last, immediately after the other purposes have ended. |
Information Content of the Register
The register contains the necessary identification information of the data subject and other information necessary for the purpose of use of the register. The following information may be processed in the register:
- First and last name
- Email address
- Phone number
- LinkedIn address
- CV
- Skills profile and job preferences
- Notes from meetings and discussions
- Date added to the register
Regular Sources of Information
Personal data may be collected within the framework of the Personal Data Act from the data subject themselves by phone, email and in meetings.
Disclosure and Transfer of Data
The information will not be disclosed, except when required by official actions. Due to data processing, some of the data may be located at Codeo Oy’s service providers (marketing, enterprise resource planning). Personal data will not be disclosed outside the EU or EEA.
4. Website Codeo.fi Cookie Register
Name of the Register
Codeo Oy Website codeo.fi Cookie Register
Purpose of Processing Personal Data
| Purpose | Basis | Maximum Retention Time or Criteria for Determination |
|---|---|---|
| We do user statistics. | Controller’s legitimate interest. No balancing test has been done. | Google, LinkedIn and Meta are responsible for the matter. |
| We target direct marketing (Google Ads, LinkedIn Ads, Meta Ads). | Controller’s legitimate interest. No balancing test has been done. | Google, LinkedIn and Meta are responsible for the matter. |
Information Content of the Register
The register contains the necessary identification information. The following information may be processed in the register:
- Device ID
- Anonymous ID generated for the visitor
- Visitor’s activity on the website
Regular Sources of Information
In the cookie register, Google, LinkedIn Ireland Unlimited Company and Meta are joint controllers. Register information may be disclosed to them so that Codeo can target marketing to Codeo website visitors. Google, LinkedIn and Meta may also perform profiling on the data for their own use.
Except for Google, LinkedIn and Meta the information is not disclosed, except when required by official actions. Transfer of data outside the EU/EEA to the United States may be possible by Google, LinkedIn and Meta. More information in their privacy policy, which also describes the contractual data protection procedure approved by the EU Commission for data transfers.
Limiting and Preventing Data Collection
We notify you of the use of cookies with a separate notice while browsing the site. If you do not want to receive cookies, you can change the settings of your Internet browser so that you receive a notification whenever cookies are being sent to your computer. Alternatively, you can disable the use of cookies altogether. If you decide to block cookies, we will still use the mandatory cookie, which is the following:
- Cookie information that you do not allow other cookies on the site. Without this cookie, the cookie query will be renewed every time you move from one page to another on our site.
The use of cookies can be limited or completely blocked through the Internet browser (see the browser’s instructions for more details). If you block the storage of cookies or disable them, the cookie query will be renewed with each page load.
5. General Information Regarding the Registers
Contact Information
Controller
Codeo Oy
Rautatienkatu 21 B, 33100 Tampere
Phone: +358 44 5673520
Email: contact@codeo.fi
Contact Person for Register Matters
Tommi Aho, Chief Sustainability Officer
Rautatienkatu 21 B, 33100 Tampere
Phone: +358 44 5673520
Email: tommi.aho@codeo.fi
Rights of the Data Subject
The data subject may contact the controller’s Contact Person by email (see contact details above) if they want to review, change, or correct their information, if they want to withdraw their consent, or if they want all their information to be removed from the register.
Based on the contact, the controller will update the register without undue delay. The controller may also act on its own initiative.
The data subject has the right to prohibit the processing and disclosure of their data for direct marketing, distance selling, research, or similar purposes. The user can disable website cookies related to advertising in the manner described in the Codeo.fi cookie register policy.
The data subject has the right to request the transfer of their data to another system. In this case, the instructions found at tietosuoja.fi will be followed.
The data subject has the right to complain to the supervisory authority, i.e., the Office of the Data Protection.
Register Protection and Data Security
The information security of Codeo’s registers and the confidentiality, integrity, and availability of personal data are ensured by appropriate technical and administrative measures. The databases and their backups are located in locked premises and are protected by firewalls, passwords, and other technical safeguards. Personal data is processed only by Codeo’s specially designated persons who are employed by Codeo and whose duties expressly include the processing of personal data, as well as by third parties who maintain or develop services on Codeo’s behalf.
Changes to the Privacy Policy
The controller may make changes to this privacy policy. Persons in the register will be notified if the changes are significant. Notification will primarily be done by email.