Motley Privacy Notice

1. Controller

Motley Agency Oy (“Motley”, “we”, “us”)

Lönnrotinkatu 5, 00120 Helsinki, Finland

tel. +358 50 591 0314

2. Contacts

All questions about data protection at Motley can be directed to privacy@motley.fi

3. What is this notice for?

Motley collects certain personal data about its clients, potential clients, cooperation partners, individuals wishing to hear news from us as well as our potential future employees. We collect such data, for example, to be able to respond to requests for new business, send newsletters you have subscribed to and process job applications. We also use analytics to learn how our website is used and how we can improve it.

This Privacy Notice explains in more detail the data we collect about you and how we use it.

4. What data do we collect and how do we use such data?

Candidates

If you apply for a job at Motley or its group companies, we collect and process the following information which you may be asked to provide on our website or which we obtain when we get to know you during the recruitment process:

• Your name and contact information
• Professional interests and skills
• Where you would like to work
• LinkedIn profile
• Cover letter, CV and other files/information that you personally wish to send us
• Data relevant for processing the application as obtained during discussions, interviews and other communication between Motley and you

We use this data only to process your application and communicate with you during the recruitment process. Your information is not shared with any other parties unless expressly required by applicable laws or requests by public authorities. If your application concerns some of Motley’s group companies, we may share your data with the representative of such company.

Clients, partners and other contacts

If you are Motley’s client or wish for us to contact you regarding new business opportunities, training offered by Motley or if you wish to receive our newsletter, we collect and process the following data when you send contact requests or when we receive such data from reliable public sources, services or in the context of the services offered to you:

• Name, title, contact information
• Information about your organization and your position
• Your request and communication with Motley and the necessary information and notes concerning such contacts between you and Motley (such as services ordered and provided, billing information, information on meetings and communication between you and Motley)
• Information about newsletters, marketing, events or invitations concerning you
• Data created based on the above-described information we already have

We use this data for

• Managing the client and business relationship between you and Motley
• Processing requests sent to us, providing our services and pursuing the legitimate interests of Motley related to such request and services
• Promoting our services, communicating with you and sending newsletters you have subscribed for
• Analysing, planning and improving our operations.

Your data is not shared with any other parties than Motley’s group companies unless expressly required by applicable laws of public authorities. We may also share your data with our trusted partners if processing your request or provision of our services requires us to do so.

As a rule, we collect the above-described data directly from you or in the context of your dealings with us. We may also obtain certain information from reliable public sources.

Motley has a legitimate interest to process the above listed personal data for the purposes described above. This interest is based on your connection with us and concerns e.g. your position in a company related to us or your request to us.

5. Cookies and analytics

We use cookies on our website to improve it and its user experience. Cookies are small text files that a browser saves on the user’s device. They are used, for example, to save a user’s information when the user moves from one website to another. If you do not want to use cookies you can change your cookie settings at any time in your browser. Please note that disabling cookies might impact the functioning of our website.

When you access our website, we ask for your consent to allow us to store the following cookies on your device:

• Google Analytics – We use Google Analytics to collect information about how users use our website. We use the information to compile reports and to help us improve the site. These cookies collect the number of visitors to the website, where visitors have come to the website from and the pages they visited. You can read more about these cookies and how Google safeguard them here.
• Facebook Pixel – We use Facebook Pixel to measure, optimize and build audiences for advertising campaigns served on Facebook. It allows us to see how users move between devices when accessing our website and Facebook and targeting Facebook advertising to users most likely interested in such advertising by analyzing which content the user has viewed on our website. For more information about Facebook Pixel, please see here.
• Hotjar – We use Hotjar to validate that our website design and user experience are performing as intended.
• Logrocket – We use Logrocket to ensure that our website user experience and performance is as intended.
• Leadfeeder – We use Leadfeeder for generating leads.
• LinkedIn Analytics – We use LinkedIn to evaluate the effectiveness of our updates.

6. Transfer of data outside of the EEA

Data on candidates is stored by Trello, Inc., a U.S. based service provider as necessary for processing the application. Data on our clients, potential clients and other contacts is also processed by service providers located outside of the EEA. We have entered into appropriate contracts such service providers to ensure the lawful processing of such data. Such contracts include the standard contractual clauses based on the decision of the European Commission of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries.

We may also occasionally disclose personal data to Motley group companies located outside of the EEA if required for the above-described purposes and e.g. when a candidate is applying for a job in such a company or when a request sent to us requires disclosing data to such group company. Motley group companies involved in such data transfer have signed the standard contractual clauses based on the applicable decision of the European Commission.

7. How long do we store your data?

As regards the candidate data, we store the data collected in connection with the application process for 3 years from the last contact with the candidate. If the candidate wishes, we may also store her/his data for a longer period for future opportunities.

As for data on our clients, requests for new business and newsletters, we only store data for as long as is necessary for the respective purpose. Since this period depends on the case at hand, we review the necessity of our data regularly and erase the data when it is no longer needed.

8. What rights do you have?

You have the right to request accessing, erasing and correcting your personal data processed by Motley as well as send us any other requests based on then applicable data protection laws such as request restriction of processing of the data. Further, you always have the right to prohibit us from sending newsletters or other marketing messages to you. Please send any requests concerning your data to the email addresses set out above in Section 2.

Data protection laws are supervised in Finland by the Finnish Data Protection Ombudsman. If you have questions belonging to the jurisdiction of the Data Protection Ombudsman or if you wish to lodge a complaint regarding processing of personal data, you may contact the Data Protection Ombudsman’s office as instructed at www.tietosuoja.fi.

9. How do we secure your data?

All personal data we collect is considered confidential. Access to the data is made available only to such employees of Motley and its group companies as is necessary for them to perform their work related to your data. The network and equipment of Motley and its partners have been secured by using appropriate measures to protect the personal data against unauthorised access and accidental or unlawful destruction, alteration, disclosure, transfer or other unlawful forms of processing.

We may outsource our processing of personal data to external service providers. In such an event we enter into appropriate agreements with providers to ensure your personal data is processed confidentially and in accordance with this Privacy Notice and applicable laws.

10. Changes to this Privacy Notice

We may update this Privacy Notice as we improve our website and operations. The updated notice will be made available on our website.