Privacy Statement - Application, Website, and Marketing

At Industrial Coding Oy (“we”), we prioritize protecting your privacy and personal data. We process personal data in compliance with applicable privacy laws. This Privacy Statement (“Statement”) explains how we collect, use, and protect your personal data in relation to the use of this application (the “Service”), visits to our websites, and any marketing communications you may receive from us.

If any part of this Statement conflicts with mandatory legal requirements, we will prioritize compliance with the relevant laws or regulations. For any questions regarding this Statement or your personal data, please contact us using the information provided below.

Data controller and contact information

The data controller responsible for collecting and processing personal data under this Statement is:

• Name: Industrial Coding Oy
• Business ID: FI34778371
• Postal address: Itäinen Rantakatu 60, 20810 Turku, Finland
• Email address: privacy@kumite.help

Categories of personal data collected and processed

We process personal data of users of our Service, which includes representatives of our customer companies. We also collect personal data from website visitors and individuals who consent to receive marketing communication.

The personal data categories we may collect include:

• Name
• Work email and work phone number
• Company name (typically your employer)
• Your job title or role within the company
• User credentials, such as user ID
• IP address and website usage data (if visiting our websites)
• Data collected via cookies and analytics tools

Additionally, we may collect anonymized data about how and when the Service is used, such as the referring webpage and browser type.

Purposes for processing personal data

We collect and use personal data for the following purposes:

• Service account management: To create and manage user accounts for accessing the Service. The use of the Service may involve user IDs and passwords and may require registration. In the registration phase we may ask you to give us the categories of personal data listed above.
• Contractual obligations: To fulfill contracts with our customers, including entering into and performing contractual commitments.
• Customer support: To provide assistance with inquiries, resolve issues, and offer technical and commercial support.
• Compliance: In specific cases, we may process personal data to comply with legal or regulatory requirements, handle third-party claims, or conduct audits.
• Marketing and promotions, including direct marketing: With your consent or where permitted by law, we may use personal data for marketing and promotional purposes, such as sending newsletters, promotional emails, and updates about our services, and to manage and respond to requests you submit through our website.
• Analytics and improvement: To analyze customer behavior, enhance the Service, and improve the overall customer experience.

Legal basis for processing personal data

We collect and process your personal data based on one or more of the following legal bases:

• Contractual necessity: The processing of personal data is necessary for the performance of the contract between us and our customers, including the provision of the Service, fulfilment of subscriptions, and management of contractual obligations.
• Legal obligations: We may process personal data as necessary to comply with our legal obligations, such as those related to applicable laws and regulatory requirements.
• Legitimate interests: In certain cases, we may process personal data based on legitimate interests, provided that such processing does not override your fundamental rights and freedoms. Our legitimate interests may include managing customer relationships effectively, providing quality customer support, and improving our products or services.
• Consent: Where required by law or where processing is based on consent, we will obtain the consent of the customer representative before processing personal data for marketing or promotional purposes. You have the right to withdraw your consent at any time.

Sources of personal data

We collect personal data directly from you, your employer, or publicly available sources, including social media, public authorities, and third-party databases such as registers held by credit-rating agencies and other commercial information providers.

When visiting our websites, data may also be collected through cookies and analytics tools.

Data sharing and transfers

We share personal data with service providers and business partners that process data on our behalf, such as IT and technology providers. Access to personal data is limited to those who need it to perform their duties. We may also share contact information between users of the Service when necessary for business purposes.

In certain cases, we may be required by law to share personal data without your consent, such as for tax assessments or court orders.

We do not transfer personal data outside the European Union or European Economic Area.

Data retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected or to comply with legal requirements. If you no longer use the Service, your account will be closed, and your personal data will be deleted. We will also correct or delete any inaccurate data upon notice.

Information security

Personal data may be stored electronically or in hardcopy form. We implement security measures to protect against unauthorized access, use, or disclosure. These measures include: restricting access to personal data to personnel, contractors, and suppliers who need it to perform their duties; securing access to the Service with passwords; and regularly updating security measures, such as firewalls.

Your rights regarding personal data

As a data subject, you have the right to:

• Request access to your personal data.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal data, subject to legal requirements.
• Request restriction or object to the processing of your personal data.
• Request data portability, transferring your data to another data controller where applicable.
• Withdraw your consent for data processing at any time, if the processing has been based merely on your consent.

If you believe we have violated your data protection rights, you may lodge a complaint with the relevant data protection authority. We will consider each request in accordance with applicable data protection laws and provide a response within 30 days.

Changes to this statement

We reserve the right to update this Statement at any time. Please review it periodically for any amendments.

Latest update: 1 January, 2026.