Second Friend Oy (“Second Friend”), collect personal data of its Users and visitors of its websites whilst providing its services. By using our website and/or Platform (Personal account registered in the program Kirpalle Kalle), you hereby consent to our Privacy Policy and agree to its terms.

Second Friend processes the data with due care, in accordance with all applicable laws and regulations. Our Privacy Statement explains what data we process, how we do that and how you may use your rights as a data subject (e.g. right to object, right of access).
This Privacy Statement constitutes a description of the data file of the Users of our services and websites as set out in the General Data Protection Regulation of the European parliament and of the Council 2016/679 (GDPR)

This Privacy Statement may be updated from time to time. You can find the current version on our website. This Privacy Statement applies to all personal data that Second Friend processes during the execution of our services, including the personal data of visitors of the Second Friend websites.

This Privacy Statement only covers data processing carried out by Second Friend. The Privacy Statement does not address and we are not responsible for, the privacy practices of any third parties.

1. IDENTITY OF THE CONTROLLER OF THE PROCESSING OF YOUR PERSONAL DATA
The controller of the processing of the personal information is: Second Friend Oy Company ID in the Finnish Trade Register: 3242621-7
Correspondence address: Itälahdenkatu 22 A, 00210, Helsinki, Finland
E-mail address: secondfriendthriftstore@gmail.com
Web site: secondfriendthriftstore.com

2. PERSONAL DATA PROCESSED AND SOURCES OF DATA
Second Friend collects two types of information from our Users: (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify User as an individual, he/she can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.

We may collect and process the following User Data about the Users and legal representatives of Users, as applicable: (i) first and last name; (ii) telephone number, (iii) e-mail address, (iv) postal address and country of domicile / residence, (vi) date of birth, (vii) preferred language of correspondence; (vii) tax identifier, (ix) bank / payment service account number and (x) transactions with the Platform ́s internal payment account.

We may collect User Data from our Users, their representatives and visitors in a variety of ways, including, when they register to Kirpari Kalle Platform or fill out a form. Further, please note that we also collect details of any transactions and payments Users carry out through Kirpari Kalle Platform. We will collect User Data from Users and visitors only if they voluntarily submit such information to us or carry out transactions or payments through our services or Platform.

We and/or our authorized third-party service providers, may automatically collect Technical Data when you visit or interact with our services or sites. Technical Data may include the browser name, the type of computer or device, time spent on website, interaction with the Services, URL of the website you visited
before and after visiting the Services, the time and date of user visits, surfing habits, IP address, operating system and the Internet service providers utilized and other similar technical information

3. COOKIES
As is common practice with almost all professional websites Second Friend site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This section describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites functionality.

How We Use Cookies
We use cookies for a variety of reasons detailed here. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Cookies allow us to calculate the aggregate number of people visiting our websites and monitor the use of the websites. This helps us to improve our websites and better serve our users. We also use cookies that make the use of the website easier for Users, for example by remembering usernames, passwords and (language) preferences. We also use tracking and analytics cookies to see how well our services are being received by our users.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

Account related cookies
When you create a User Account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases, they may remain afterwards to remember your site preferences when logged out.

Login related cookies
We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

Email newsletters related cookies
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed / unsubscribed users.

Orders processing related cookies
This site offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.

Forms related cookies
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site and Platform:

You may consult this list to find the Privacy Policy for each of the advertising partners of Second Friend.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Second Friend, which are sent directly to Users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Note that Second Friend has no access to or control over these cookies that are used by third-party advertisers.

4. Purposes and legitimate grounds for the processing of your personal data
Purposes
There are several purposes of the processing of your personal data by Second Friend:

To provide our services and carry out our agreement with the Users
Second Friend processes personal data in the first place to be able to deliver our services to the Users and to run, maintain and develop our Platform and Services. We use the data for example to handle Users ́ payments or any refunds (where applicable) and to provide our Users with the information necessary for the Implementation of the Advertising campaigns. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. In order to ensure that our services are in line with your needs, these data can be used for things like customer satisfaction surveys. We might also request another party to do this for us.

For customer communication (including marketing)
Second Friend processes personal data to contact the Users regarding our services and to inform the Users of changes to our services. User data are also used for research and analysis to improve our services and our websites. We may also use personal data entered on our websites in certain cases to send information by e-mail about other services of Second Friend to the Users ́ representatives, provided that representatives have given us consent to that.

For quality improvement and trend analysis
We may also process information about use of the services to improve the quality of our services e.g. by analysing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally (by user or by user representative) identifiable data.

Legitimate grounds for processing
Second Friend processes personal data to perform our contractual obligations towards the Users and to comply with legal obligations. Furthermore, we process the personal data to pursue our legitimate interest to maintain and develop our businesses.

5. Transfer to countries outside Europe
Second Friend may transfer personal data to countries outside the European Union and the European Economic Area. When we transfer any data to a country for which no adequacy decision of the European Commission exits, such transfer will be strictly on the basis of a written agreement and subject to the provisions of the (standard or other) clauses adopted by the European Commission. If you wish to know more about international transfers of your personal data, you may contact us via the contact details given in the general Terms.

6. Recipients
We only share personal data within the organisation of Second Friend if and as far as reasonably necessary to perform and develop our services, e.g. with our customer service and marketing employees. We do not share personal data with third parties outside of Second Friend unless one of the following circumstances applies:

It is necessary for the purposes of this Privacy Statement
To the extent that third parties (such as the counterparties other User being a counterparty to advertising agreement, i.e. Advertiser or the Publisher) need access to personal data to perform such services, Second Friend has taken the appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations. Furthermore, we may provide personal data to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in accordance with our Privacy Statement and any other appropriate obligations of confidentiality and security measures.

For legal reasons
We may share personal data with third parties outside Second Friend if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any Applicable Law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Second Friend, our users or the public as far as in accordance with the law. When possible, we will inform Users about such processing.

For other legitimate reasons
If Second Friend is involved in a merger, acquisition or asset sale, we may transfer the personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all customers concerned before the personal data are transferred or become subject to a different privacy policy.

With subject ́s explicit consent
We may share your personal data with third parties outside Second Friend for other reasons than the one mentions before, when we have the subject ́s explicit consent to do so, unless such is necessary for the provisions of our services (such as sharing with the counterparty of a Purchase Agreement or Order concluded through Second Friend or Kirpari Kalle Platform). You have the right to withdraw this consent at all times.

7. Storage period
Second Friend does not store personal data longer than is legally permitted and necessary for the purposes for which the data were collected. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. In general, we store data for the provision of services for a maximum of two years after our relation ended. Whenever the registered
representative of the User is changed, personal data of the previous representative is erased from Second Friend.

8. Your rights

Right to access
Second Friend offers to the representatives of Users access to the personal data we process. This means you as a subject of data processing can contact us asking us to inform you about your personal data that we have collected and processed and the purposes such data are used for. We may charge a processing fee in case less than 12 months have passed since your last data request.

Right to correct
You have the right to have incorrect/unprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed by contacting us.

Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data have been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Kindly note, that if we delete all your data, or some essential parts of it (such as identifying data for your User Account) we may not continue to provide our Services to you and your use of the Platform will be terminated simultaneously.

Right to object
You may object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of our services or for compliance with a legal obligation. You may also object any further processing of your personal data after prior given consent. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our websites and other services.

You may opt in to receiving electronic direct marketing communications from us, and allow us to use your personal data for direct marketing purposes, market research and profiling by clicking on the opt-in link provided in the Second Friend User profile.

Right to restriction of processing
You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our websites and other services.

Right to data portability
You have the right to receive your personal data from us in a structured, commonly used format in order to transmit the data to another controller.

How to use your rights
You may use these rights by sending a letter or e-mail, including your name, address, phone number and a copy of a valid ID to us on the addresses set out above. If your request regards personal data in a cookie, you have to enclose a copy of the said cookie. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case you consider our processing activities of your personal data to be
inconsistent with the applicable data protection laws, you have a right to lodge a complaint with a supervisory authority (the Finnish Data Protection Ombudsman, Tietosuojavaltuutettu, www.tietosuoja.fi).

9. Information security
We will take all reasonable, appropriate security measures to protect Second Friend and our Users and their representatives from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible.

10. Applicability and changes
Our Privacy Statement applies worldwide, to all of the services offered by Second Friend. This Privacy Statement is published in English. Our Privacy Statement may change from time to time. You can find the current version on our website secondfriendthriftstore.com. We will not make substantial changes to this Privacy Statement or reduce your rights under this Privacy Statement without providing you with a notice.