Privacy policy

Updated 16.10.2024

At A-lehdet, we want you to use our services with confidence, trusting that we will protect your privacy. This privacy policy applies to the users of A-lehdet online services, existing customers, potential customers and partners. Below, we provide more details about:

In the processing of personal data, we comply with applicable legislation and industry self-regulation, such as the guidelines issued by the Data & Marketing Association and the Interactive Advertising Bureau (IAB), such as IAB Europe's Transparency and Consent Framework.

Please read this privacy policy carefully. Please note that some services, such as Kotona-kaupat (A-lehdet online store for housing media), are subject to a service-specific privacy policy (in Finnish): The privacy policy of Kotona-kaupat online store.

A-lehdet Oy

Business ID: 1708790-7

Risto Rytin tie 33

FI-00570 HELSINKI

tietosuoja-asiat@a-lehdet.fi

We process personal data only to the extent necessary for the purposes described in this privacy policy.

The scope of the personal data that we collect and process varies depending on the type of relationship between you and A-lehdet, the processing and marketing options you have accepted or rejected, and the cookie settings you have made.

Information collected on the use of online services: We automatically collect data about the use of our websites through server logs and cookies. This information includes, for example:

We may identify you based on the digital identifier when you register or log in to a digital account, place an order on the website or arrive at an online service through customer or marketing communications, such as subscriber gift selection. In this case, we may combine the data collected about the use of the Services with the information described in more detail below.

Some of our services can also be used without logging in or providing personal data that would allow us to identify you directly, such as your name or email address, in which case we will not be able to identify you personally. Please note that if you have been identified in one of our services, we can also identify you elsewhere in the A-lehdet network: for example, if you have created an user ID for Apu website, we will be able to connect data pertaining to this ID to data about your visit to Kotona website.

Learn more about our cookie policy.

Information related to consumer customers and users of online services: You may provide us with personal data in various contexts, such as in connection with a subscription to a magazine, product or newsletter, registration for an online service or commenting on blogs, or it may otherwise be collected while the contractual relationship or other relevant connection. This data includes, for example:

Information related to business customers: We store the following information about the contacts of our existing business customers, such as advertisers:

Information related to potential customers: For potential customers, such as people who may be interested in our services or our former customers, we typically process information about name and contact information, as well as a brief summary of order and supply history. In addition, we process information related to the person's work duties, such as position or area of responsibility in the company.

Information obtained from external sources: We collect the above-mentioned data primarily from you yourself during the validity of the order, registration, contractual relationship or other relevant connection. Data can be collected and updated from the personal data registers of other companies belonging to the A-lehdet Group. When you log in to our services through social media accounts, such as Facebook, Apple or Google, the platform shares with us more detailed information in the consent banner shown to you, such as your public profile information and email address. We may also collect information from registers kept by authorities, credit information and customer default registers and other similar registers. With regard to potential corporate customers and influencers, we also collect information from publicly available sources, such as company or blog websites or social media.

Derived and combined data: In order to better serve you, we refine the above-mentioned categories of personal data by analysing them using various statistical methods and combining data collected from different sources. We may make assumptions, for example, about consumers' interests, gender, age group, purchasing behaviour or other similar characteristics. These assumptions are based on the information provided or collected mentioned in the previous paragraph. We do not make assumptions about what is considered sensitive data, and we take technical and organisational measures to ensure that your privacy is protected during analysis. Typically, we do not process data on a personal level, but do statistical modelling, in which case we generalise the data to a wider group.

We process your personal data mainly for managing customer relationship, offering products and services, their development and marketing. Below we describe in more detail the purposes for which personal data is processed and the related legal basis of processing.

Delivery of products and services: We process your data to fulfil the contract for the service or product you have ordered. We cannot make an offer, fulfil a contract such as deliver a magazine, enable you to log in to a digital account, invoice our services or communicate with you in matters related to the contract, provide customer service or communicate with customers without processing personal data. When collecting data, we try to inform you which information is mandatory for the execution of the contract and which you can provide if you wish.

Development of products and services: We use data to develop products and services, compile reports, improve service quality and offering, and personalize services. For example, contacting our customers, analysing the use of our websites, responses to consumer surveys and questionnaires help us understand what kind of features are desired for our services and which content is of interest to you. This processing is based on our legitimate interest. The purpose and storage of the data collected in surveys and questionnaires will be described separately in connection with each survey or questionnaire. You can object to the processing as described below.

Marketing, advertising and targeting of these: We use the data to market and advertise our products and services. Marketing messages or advertising may be tailored using information you provide or information collected from your use of the Services. We may also disclose information for marketing purposes to our selected partners. A-lehdet bloggers may use commentators' email addresses to invite commentators to events or sweepstakes.

We use Facebook's "Custom Audiences" to target advertising to our existing customers on Facebook. Facebook Custom Audiences are built by using your email address or phone number to create an encrypted identifier in your browser that compares to Facebook's encrypted identifiers. This can be used to target advertising on Facebook to A-lehdet customers or create target groups that resemble the profiles of A-lehdet customers. A-lehdet does not receive information on which identifiers forwarded to Facebook end up in the final target group and which identifiers have no equivalent on Facebook. Facebook, on the other hand, does not receive information from A-lehdet about who is behind the identifier. Facebook is committed to using the target group only for A-lehdet advertising. For more information, visit Facebook.

Advertising on Facebook may also be targeted based on your customer information (such as your age or place of residence). With this, we aim to ensure that the A-lehdet advertising shown to you on Facebook would be as timely and relevant as possible. Customer data is sent to Facebook and is always processed by Facebook in hashed form to ensure your privacy.

The processing is based on your consent or the legitimate interest of A-lehdet. You can object to marketing or withdraw your consent at any time. To the extent that cookies are used for targeting, you can influence the use of cookies and other similar technologies as described in the cookie policy.

Competitions and sweepstakes: We may process your data to carry out a competition or sweepstakes and to draw or select winners. In this case, the processing is based on your consent given in connection with your participation or on our legitimate interest.

Prevention and investigation of misuse: From time to time, we need to use information to prevent and investigate misuse. For example, automatically collected log data allows us to monitor and investigate the actions of the user of the information system and the lawfulness of the use of data in accordance with our legitimate interest. The email addresses of blog commenters or forum contributors can also help investigate possible abuse.

Performance of legal obligations: We may be obliged to retain some of your personal data in order to comply with accounting or other mandatory legislation. From time to time, we also need to disclose information to authorities, such as the police, in order for them to investigate suspected crimes. In this case, the processing is based on compliance with a legal obligation.

Exceptions related to sensitive data: We treat sensitive or special categories of personal data with special care. This includes, for example, data related to children or health status. We follow the industry's self-regulatory guidelines and, for example, do not use sensitive or special categories of personal data in targeting advertising. Our services are aimed at adults or young people over the age of 13 and we do not knowingly process data from children under this age.

If you ask a question to a doctor in our terve.fi service, we process the data to implement the question-answer service. We do not combine the information provided in the question with other information we collect and delete information that identifies you personally, such as your email address, after your doctor has answered your question. The processing of sensitive data is based on your explicit consent.

Legitimate interest as a basis for processing: To the extent that we develop our services, carry out marketing or tackle the cases of misconduct on legitimate interest, we consider that the processing benefits both A-lehdet and the users of its services. The processing of personal data enables us to offer even better services, inform people likely to be interested in our products and services, tailor content and offers, and keep our services safe for all users. We strive to be as transparent as possible about our practices and to provide you with choices to use your rights as described in Section 5. We consider that the processing does not conflict with your fundamental rights or freedoms.

Automated decisions: To the extent that we make a tailored offer based on, for example, your order history, we carry out profiling. However, we do not make automated decisions that would have legal effects on you or otherwise significantly affect you.

We will retain your personal data for as long as is necessary to fulfil the purposes defined in section 3. Typically, we process your data for the duration of the customer relationship and for approximately 48 months from the end of the subscription or the last login to the digital account. This allows us to send you offers based on your previous order history or inferred interests, allows you to reactivate our services, develop our services and respond to any complaints. Before we delete a digital account due to inactivity, we will contact you. After this period, we minimise the data we process and typically transfer information about your name and contact information as well as a brief summary of your order and supply history to the marketing register.

The data of potential customers, such as those who have participated in sweepstakes or competitions or who have previously ordered A-lehdet products, is processed for marketing purposes as long as you have not refused to receive marketing messages. If you opt-out of marketing and there is no other basis for processing, we will retain information about the opt-out and contact information so that we can ensure compliance with it.

Public comments on blogs are stored for as long as the blog is published on the A-lehdet platform. As a rule, commenters' email addresses and other non-public information, such as IP address, are removed from the comment within six months of the comment being published. If the commentator has registered in the A-lehdet online service, the data will be processed for the period described in the first paragraph of this section 4.

Current legislation, such as accounting or other mandatory legislation, may impose to store personal data after the end of the customer relationship or other main processing purpose. In such situations, -storage is subject to the retention periods defined in applicable legislation. Accounting legislation requires that receipts for the financial year, correspondence concerning business transactions and any other accounting material certifying transactions be kept for at least six years from the end of the year during which the financial year ended.

We strive to keep the personal data we process up-to-date and correct by removing unnecessary data and updating outdated data. However, we ask you from time to time to check that your information is up to date by logging in to the personal information sections of the services or by using your user ID (A-tunnus) to digital customer service. You can also influence the retention period of your data through the possibilities described below, such as requesting the deletion of your data.

You have several options available to you when it comes to the processing of your personal data:

Right of access, rectification and erasure: You have the right to access the personal data stored about you by contacting our customer service. At your request, we will rectify, supplement or delete any personal data that is incorrect, incomplete or outdated with regard to the purpose of processing.

Right to data portability: You may also choose to have the personal data you have provided transferred, which we process automatically on the basis of consent or agreement, by contacting our customer service.

Right to opt-out of direct marketing and related profiling: You may prohibit the disclosure and processing of your data for direct marketing purposes at any time by clicking on the link at the end of the message or by contacting our customer service.

Right to object and restrict: You can object to processing based on legitimate interest on grounds relating to your personal situation. In such a situation, for example, processing is restricted for the time necessary to assess the grounds for objecting to the processing. Processing may also be restricted, for example, if you contest the accuracy of your personal data, in which case the processing will be restricted for a period during which we can verify the accuracy of the data.

Withdrawal of consent: You may withdraw your consent at any time by contacting our customer service or other separately provided means. You can withdraw your consent to direct marketing by clicking the link at the end of the message or by contacting our customer service.

Exercising your rights: In order to exercise your data protection rights, we ask you:

If necessary, we may request additional information in order to verify your identity. If you wish to act on behalf of another person, please be prepared to present a power of attorney or other proof that you have the right to act on behalf of another person.

As a rule, the information you have requested or an acknowledgement of the fulfilment of your request will be sent to you within one month of your request or the delivery of additional information to the e-mail or postal address you have provided. Please note that we cannot comply with your data erasure request if you have an active customer relationship (for example, a valid subscription or invoices that are open in invoicing). We also cannot delete data to the extent necessary to comply with our legal obligations, such as accounting legislation.

Cookie choices: The cookie consent management tool allows you to manage your choices regarding cookies and the use of data collected with them, such as giving consent, withdrawing consent or objecting to processing based on legitimate interest. As a rule, you can find the cookie settings in the sub-navigation of each site or in the "About us" section in the top navigation of the site. You can also find more information about our cookie policy.

Third-party choices: You can influence the advertisements displayed on A-lehdet’s social media platforms, such as Facebook, in the advertising selections of the platform in question. If you use a social media account to log in to A-lehdet services, you can change the login method in the A-tunnus settings or in the settings of the social media service in question.

Right to complain: You can lodge a complaint with an authority if you consider that your data has been processed in violation of this privacy policy and the legislation in force at any given time.

We process personal data within the A-lehdet Group in order to fulfil the purposes described in section 3 above. In addition, we may disclose personal data to third parties in the following situations, for example:

Authorities: We may disclose your personal data as required by the competent authorities and based on the legislation in force at the time.

Consent: We may disclose your information to third parties if you have given your consent.

Research and development: We may disclose your data for research and product development. As a rule, the data has been changed in such a form that the subject of the data can no longer be personally identified from them.

M&A: If we sell, merge or otherwise reorganize our business, your personal data may be disclosed to buyers and their advisors.

Direct marketing, opinion polls and market research: We may disclose your personal data for direct marketing, opinion polls and market research, unless you have prohibited this.

Debt collection: We may disclose your data to selected partners to collect our claims.

Legal claims and breaches: We may disclose your personal data to third parties if it is necessary for the performance of a contract, investigation of possible breaches or the establishment, exercise or defence of legal claims.

In addition, personal data may be processed by third parties in the following cases:

Processors: We use third-party services, whereby we ensure the lawful processing of data through contractual arrangements and by instructing third parties on data processing. These third parties process data only on assignment and on our behalf as processors of personal data.

Joint controllers: We may cooperate with third parties, such as Facebook, so that we are joint controllers, i.e. we define together why and how personal data is processed. For more information on joint controllership, please see section 8 of this privacy policy.

Independent controllers: We may cooperate with third parties so that the party in question may collect personal data for its own independent purposes through functionality integrated into the webpages of A-lehdet, such as cookies or embedded content. For example, buying and selling advertising space is typically done automatically and in real time using software. Our partners use the information collected on our websites to make a purchase decision about advertising space, target advertising to the desired target group and measure campaign results. The information is typically collected through cookies and other similar technologies, and the information cannot be used to identify the user personally. You can find more information about this processing of personal data in our cookie policy or in connection with each functionality.

As a rule, we do not transfer or process data outside the European Union or the European Economic Area. If, exceptionally, data is transferred outside the EU/EEA, we will ensure an adequate level of protection of personal data in accordance with applicable legislation, for example by using standard contractual clauses approved by the European Commission.

We protect personal data from loss, destruction, misuse, unauthorized access and disclosure with appropriate security measures. We ensure secure processing, for example, by firewalls and other technical means, by restricting access to data and by ensuring that our employees and subcontractors process personal data in accordance with the instructions given, the access rights granted to them and agreements. Persons processing personal data are bound by confidentiality.

This privacy policy applies to situations where A-lehdet defines the purposes and means of processing personal data and thus acts as the controller referred to in data protection legislation.

This privacy policy also applies when A-lehdet acts as a joint controller with a blogger operating on the A-lehdet platform. In this case, A-lehdet defines the purposes and means of processing the personal data of blog commentators together with the blogger. A-lehdet is primarily responsible for informing data subjects and implementing other opportunities to influence in accordance with this privacy policy. A-lehdet provides itself or with the help of its subcontractors a platform for publishing blogs and processing related personal data, and is responsible for the technical security of the platform. If a blogger terminates cooperation with A-lehdet, the personal data of the commentators will be transferred to the blogger and the agreement on joint controller will end. To the extent that a blogger or other influencer, such as a YouTuber, has publication channels outside A-lehdet websites, such as YouTube, Facebook, Instagram or Snapchat, the influencer is responsible for the processing of personal data. In this case, the terms and conditions of the relevant platform also apply.

A-lehdet also acts as a joint controller when it maintains a page on Facebook or utilises Facebook's functionalities on its pages, such as the Like button. With regard to the visitor data of A-lehdet Facebook pages, Facebook and A-lehdet are joint controllers. For more information on how we process personal data, please refer to Facebook's Privacy Description. We collect statistical information e.g. Likes and visits to our Facebook Pages, visibility of our posts and demographic profiles of people who have reached our posts. We do not combine this information with other information described in this privacy policy.

You can download applications made by A-lehdet (such as the Apu360 application) to your iOS or Android device from their respective app stores (Apple App Store or Google Play -store). Apps collect information about how and when apps are used, and they send information with an identifier that identifies the user. With this information, we can develop the application to make it more pleasing to the user, personalize the content of the application and target advertising.

When you download the iOS application, you will be asked whether A-lehdet is allowed to track your activities using a device identifier. Since the journalistic content read through the app and our other services is partly advertising-funded and tracking enables targeted advertising, we ask you to allow tracking by clicking "Allow".

In addition, you may be asked to allow notifications to be sent to your terminal device, i.e. push notifications. The purpose of the advertisements is to try to serve you as well as possible by providing you with information about the themes you have chosen.

You can control the privacy settings of the application through the settings of the application or operating system. For example, on Apple's iOS devices, you can go to the operating system settings and further to the "Privacy and security" settings, where you can, among other things, influence application tracking. You can change the settings related to notifications and cookies under "Profile and Settings" in the application.

We reserve the right to update this privacy policy due to, for example, the development of services, mandatory legislation or decisions by authorities. Changes and updates to the Privacy Policy will be announced in our services.

We recommend that you review the contents of the privacy policy regularly. The changes, published on 25.5.2018, were based on the requirements of the EU's General Data Protection Regulation. Subsequently, a new paragraph 8 (A-lehdet as a joint controller) was added and clarifications were made especially related to blogs, descriptions of the data subject's opportunities to influence and the A-tunnus on 5.3.2019. On 20.3.2019, we added a link to IAB Europe's Transparency and Consent Framework and specified who our services are aimed at. On 31.3.2020, we specified our cooperation with third parties when we introduced an online store implemented by a third party on our website. On 22.9.2020, we added a clarification regarding the possibilities of influencing cookies. On 24.11.2021 we added specifications related to the targeting of marketing and advertising. On 22.4.2022, we made changes due to the renewal of the Kotona -stores. On 18.8.2022, we removed the reference to the information request form. On 05.06.2023, we added paragraph 9. App privacy. On 23.9.2024, we added a section on data processing when you log in to our sites through social media accounts, such as Facebook.