October 17^th, 2022

1 The Application of this Privacy Policy

1.1 The Scope and Application of this Privacy Policy

We at SCellex are committed to protecting your privacy and to complying with applicable data protection legislation and privacy laws. This Privacy Policy applies to

Customers and potential customers of SCellex’ products and services (“Product”)
Use of SCellex websites (“website visit(or)”)

This Privacy Policy explains and governs our data collection, processing and usage practices within this scope.

Throughout this Privacy Policy the term “personal data” means information relating to an identified or identifiable individual (i.e. a natural person) and as may be further defined in applicable data protection legislation.

The term “customer” used in this Privacy Policy means the customer and potential customer of SCellx as well as any person (data subject) who is employee, manager or officer of such customer, as applicable. The terms “Website Visitor” or “website user” used in this Privacy Policy means you as a user or visitor of our website. The terms “you”, or “your” used in this Privacy Policy means the customer or Website Visitor, as applicable.

1.2 Data Controller

This Privacy Policy applies to personal data that is processed by SCellex as a data controller. The terms “SCellex”, “we”, “us” or “our” used in this Privacy Policy refer to:

SCellex Oy
c/o Terkko Health Hub
Haartmaninkatu 4
00290 HELSINKI
Finland

Business ID FI2938279-4

2 The Information We Collect

2.1 Customers

We may collect information you may provide us or is publicly available, which we have grouped together as follows:

Identity Data such as first name, last name or similar identifier.
Contact Data such as address, email address, telephone numbers, social media contact.
Employment Data such as title and occupation, company name, department name.
Profile Data such as purchases or orders made by you, your interests, preferences, feedback and responses to surveys and queries as well as other content you have provided us.
Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences such as language.
Direct interactions such as personal data you provide us in seminars, exhibitions or conferences or by filling in forms by corresponding with us by chat, post, phone, email or otherwise.
Demographic attributes, when tied to personal information that identifies you.
Photographs and videos that identify you and testimonials.
Publicly available information, such as social media posts or information from various third parties and public sources, such as technical data from analytics providers, advertising networks and search information providers.
Recording and chat transcript data from Sales and customer support calls and live chat sessions or interviews.

2.2 Website Visitors and Cookies

We may collect, use, store and transfer different kinds of personal data about you as our website visitor:

Technical Data such as internet protocol (IP) address and information that may be derived from IP address, such as geographic location, your login data, unique IDs such as your mobile device identifier or cookie ID on your browser, information about a device you use, such as device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, the presence or use of “apps”, screen resolution and the preferred language and other technology on the devices you use to access our website.
Usage Data such as information about how you use our website, products and services.
Certain location or geolocation information you provide directly or through automated means, if you choose to enable location based services from your device or app.
Behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.
Any information and data we collect as you being our customer, as relevant and applicable to website use

We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Your consent options, use and sharing of such information is described in cookie choices and related policies of our homepage. You may exercise your cookie preferences by visiting the cookie policy and preferences.

2.3 Children

The SCellex Product is a business-to-business product and not intended for children under the age of 18 who are not legally capable of forming binding contracts in most jurisdictions. We do not knowingly collect personal data from children under 16. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that personal data.

3 How We Use the Information We Collect

3.1 Use of Personal Data and Legal Bases for Processing

3.1.1 Customers

When you are our customer, we may use your personal data to:

Set up and maintain your registration and to fulfill your requests and orders;

Improve and develop the Product or services as well as marketing and customer communications;
Perform research, and to analyze and compile statistical information about your orders and use of the Product, including your interaction with content made available therein;
Communicate with you for purposes related to the management of Customer or user relationship (including billing, surveys, queries, newsletters etc.);
Sales and customer relationship management, such as implementing, developing and maintaining the business relationship with our customer, asking you to leave a review or take a survey or managing invoicing, reporting and contracts
Administer and protect our business, website, rights and/or our property and to prevent and investigate fraud and other misuses, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
Perform other compatible, complementary and additional uses to the extent permitted by the applicable law.

Legal basis for processing, as applicable:

Performance of a contract with you: Processing of your personal data is necessary for the performance of a contract to which you are a party or in order to take, at your request, steps before entering a contract.
Necessary for our or third party legitimate interests: For managing our customer relationship and delivering and managing the Product, to satisfy legal, accounting or reporting requirements, to define types of customers for our products and services, to keep our website updated and relevant, to study how customers use our Product, to develop the Product, to grow our business, to prevent fraud and other misuses
Necessary to comply with a legal obligation
Your consent for specific purpose

3.1.2 Website Visitors

When you are visiting or using our website, we may use your personal data to:

Provide the functionalities, personalize and improve our website, for example by providing customized or localized content;
To manage our relationship with you, including managing and answering to your requests submitted on the website, notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey or communicating with you
To administer and protect our business, website, rights and/or our property and to prevent and investigate fraud and other misuses, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
Other compatible, complementary and additional uses to the extent permitted by the applicable law.

Legal basis for processing, as applicable:

Necessary to comply with a legal obligation
Necessary for our or third party legitimate interests, such as to keep our records updated, to develop our website, for running our business, provision of administration and services, network security, to prevent fraud and other misuses, to grow our business
Your consent for specific purpose

3.1.3 Marketing Communications

Whether you are our customer or Website Visitor, we may use your personal data to send or to deliver you direct electronic marketing, promotional material, advertising and other marketing communications relating to our products or services to the extent permitted by applicable law or by your consent. For example, applicable law may permit marketing to an individual working in the organization, when the products or services marketed relate to such employee’s duties.

Legal basis for processing, as applicable:

Your consent for this specific purpose
Our legitimate interest

3.2 Requirements for providing personal data

We require your personal data to provide you with access to this site; to deliver any ordered goods or services; and to comply with statutory obligations. The provision of your personal data as described in this Privacy Policy is partially a contractual requirement. For example, when you purchase our Product, you are required to provide us with certain personal data for processing purposes specified in this Privacy Policy. Failure to provide us personal data may prevent us from performing our contractual obligations, which may be with you or your employer, and lead to you or your employer being unable to receive or use our Product.

If our use of your personal data is based on consent, we may not be able to perform or satisfy your request without it; for example, we may require your personal data to provide you with access to our newsletter or personalized content of our web site. In these cases, it is not possible to satisfy your request without certain personal data.

3.3 The Recipients of Personal Data

Our employees are authorized to access personal data only to the extent necessary to serve the applicable purpose(s) and to perform their job functions, for instance, in connection with the supply of the Product. Our employees have received training on the restrictions relating to the processing of personal data and do not process personal data on a wider basis.

We may transfer the data (personal data, pseudonymized personal data or anonymous data) to our subcontractors, service providers or other partners for the purposes set out in this Privacy Policy. In such cases, these subcontractors and partners act as our data processors and process the personal data on our behalf. In case we transfer the data, we will ensure that personal data is transferred and processed only to the extent necessary and only for the intended purpose. Such third parties are also required to maintain the confidentiality of your personal data.

We may also sell, transfer or otherwise share some or all of our assets to relevant third parties, including your personal data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

We may be obligated to disclose your personal data to authorities or third parties pursuant to mandatory applicable law or an order of a regulatory or statutory authority.

Such third parties, with whom we may share personal data, may include also:

order fulfilment, customer service, e-mail delivery;
analytics, website management;
event/campaign management and partners or conference sponsors
information technology and related infrastructure provision;
auditing;
other similar service providers

4 Transfers to Third Countries

We may transfer your personal data outside the country where it was collected, or outside of European Economic Area (EEA), as applicable.

If personal data is transferred to country that does not provide adequate level of protection for personal data, such transfers shall be subject to appropriate safeguards, such as standard contractual clauses approved by the European Commission and/or other appropriate transfer mechanism as required under relevant data protection laws.

5 External Websites

Our websites may include links to third party websites. Please note that we do not control, and are not responsible for, the content or practices of such websites, which are also subject to their own terms and privacy policies.

6 Security

We employ appropriate technical, physical and organizational security measures designed to protect your personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

7 Retention Period of Personal Data

Personal data is retained as long as it is necessary for the execution of the processing purposes mentioned in this Privacy Policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

We will delete your personal data in case you revoke your consent, if we are processing your personal data based on your consent, such as direct marketing. In such case, the information regarding prohibition of direct marketing is, however, retained.

Your personal data will be deleted in case you have requested the deletion of your personal data and we have no legitimate ground for the processing of such data.

We will also retain your personal data for additional periods if it is required by mandatory law or where your personal data is required for us to assert or defend against legal claims. We will retain your personal data until the end of the relevant retention period or until the claims in question have been settled.

After the end of applicable retention period, personal data will be deleted in course of next regular database updates.

8 Your Rights with Respect to Personal data

In case you wish to know what personal data we hold about you, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us through the contact points referred to below.

Also, in case you wish to rectify any incomplete, incorrect or outdated personal data, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us through the contact points referred to below.

You also have the right at any time to request us to erase personal data concerning you and processed by us and we are obliged to erase such data if we have no legal ground to continue processing such data.

In some cases, you have the right to object to the processing of your personal data if the data has been processed on the basis of our legitimate interest, and we are obliged to discontinue processing such personal data unless we can demonstrate compelling legitimate grounds for further processing of such personal data. You also have the right to object processing of your personal data for purposes of direct marketing.

In addition, you may, under certain circumstances have the right to request us to restrict processing of your personal data. Should the restriction of processing apply, the respective personal data will be marked and may only be processed by us for as defined in the applicable law.

Where your personal data has been processed by automated means based on your consent or an agreement entered into between you and us, you have the right to receive such personal data from us that you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another entity without hindrance from us. In exercising your right to this data portability, you shall have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

You have also the right to file a complaint with the competent supervisory authority regarding our processing of your personal data.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

9 Changes to this Privacy Policy

SCellex may modify this Privacy Policy from time to time and will update the date appearing at the beginning of this Privacy Policy when modifications take place. The most current Privacy Policy will be available on the SCellex website. You accept the application of most up-to-date version of Privacy Policy by continuing to be our customer or by using our website, as applicable. However, in respect of personal data collected prior to such change of this Privacy Policy, we will not use it in conflict with applicable data protection legislation, unless we notify you thereof or obtain your consent in accordance with applicable data protection legislation. You must review this Privacy Policy from time to time for the most up-to-date version.

10 Contact Details

Should you have any questions or comments about this Privacy Policy, including any requests to exercise your legal rights, please contact us at support@scellex.com.

You have the right to make a complaint at any time to the competent supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority. So please contact us directly in the first instance.