Tietosuojaseloste

1. General Information

Fischi Ab, business ID: 3176930-6 (hereinafter “Fischi”, “we” or “us”) acts as a controller in relation to the processing of personal data in connection with the use of our service Fides, which is available through a mobile application called Fides for mobile devices and through our website www.fides-info.com. This privacy policy applies to the users of the Service. This privacy policy describes how Fischi processes personal data, such as what kinds of personal data we collect, for which purposes the personal data is used, and to which parties the personal data can be disclosed.

Personal data refers to any information relating to a natural person (“data subject”) that can identify the person directly or indirectly. Fischi complies with the General Data Protection Regulation (2016/679, “GDPR”) in all processing of personal data in conjunction with other applicable data protection legislation.

2. Children

The Service is not intended for children under 13 years of age. If you are under 13, please do not use the Service. If we learn that we have collected or received personal data from a child under 13, we will delete that personal data. If you believe we might have any information from or about a child under 13, please contact us via email at oscar@fischi.app.

3. Controller and Contact Information

Controller: Fischi Ab
Business ID: 3176930-6
Address: Handelsesplanaden 25 A 11, 65100 Vasa
Email: oscar@fischi.app
Controller representative: Oscar Gustafsson, Co-owner, Fischi Ab

4. Purposes and Legal Bases for Processing Personal Data

Personal data will be processed for the following purposes based on the defined legal bases:

• Provision of the Service (contract or its preparation, legitimate interest)
• Customer communications and provision of information and required notices regarding the Service (legitimate interest)
• Direct electronic marketing, such as sending newsletters, push-messages, and promotions via emails and SMS (consent)
• Providing marketing in the Service using cookies (consent)
• Enabling social media services such as videos and sharing buttons (consent)
• Developing and improving the Service and our business through analytics (consent)
• Ensuring security of the Service and our business, and preventing abuses (statutory obligation or legitimate interest)
• Complying and fulfilling our legal duties and obligations such as tax law and accounting-related obligations (statutory obligation)
• Establishing, exercising, or defending against legal claims (statutory obligation or legitimate interest)

5. What Data Is Collected, Stored, and Processed?

Fischi collects only such personal data from the data subject that is relevant and necessary for the purposes described in this privacy policy.

5.1 User Data that is Necessary to Use the Fischi Services

The following personal data collected and processed by us is necessary for a proper performance of the contract between you and us:

• Full name, phone number, email address, birthdate, and gender

5.2 User Data You Give Us Voluntarily

Your user or customer experience may be enhanced by providing us with the following information:

• Location data (if you consent)
• Current occupation

5.3 Other Information

We may also process other information provided by you voluntarily such as:

• Restaurants you join as a member and other marketing opt-ins and opt-outs preferences
• Information you provide by phone or in email or chat correspondence with us
• The type of mobile device you use
• Your mobile device's unique device ID
• The IP address of your mobile device
• Your mobile operating system
• The type of mobile internet browsers you use
• Information about the way you use the Service

Once you join as a member to a restaurant, you opt-in and allow the restaurant owners to contact you with relevant marketing messages through various methods, such as emails, SMSs, and push notifications, if you have given consent for marketing. Once you join a restaurant or buy products or tickets, the restaurant owners can see your name, age, date of birth, and other relevant information to provide you with perks, e.g., personal benefits, membership cards, discounts, or similar services.

When you use the Service, we may use GPS technology (or other similar technology) to determine your current location in order to provide you the services and to determine if you have entered one of the supported venues. Additionally, with your consent, we may share your current location with other users or the venue you are in. In order for us to process your location data, we will ask your consent to this kind of processing. Such consent can also be withdrawn. If you do not want us to use your location data for the purposes set forth above anymore, you can turn off the location services for the Service in your mobile phone settings.

Please note that some or all of the personal data mentioned in this privacy policy may be required in order for the Service to function properly. Fides uses different third-party analytics and telemetry providers, marketing or affiliate partners, and other services integrated into our client software listed below:

• Bugs / Error event and performance tracking, with Google Crashlytics
• Google / Google Analytics and reporting

6. Data Sources

The personal data is mainly collected directly from the data subjects themselves, for example, when downloading, signing in, and using the Service. Personal data may also be collected automatically when the data subject downloads the Fides application, visits the Fides website, and uses the Service in general. In addition, and with the permission of the data subject, data may be collected in other ways in a marketing context. Personal data may be updated and supplemented by collecting data from private and public sources.

7. Retention of Personal Data

Fischi does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Fischi Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

After a User has deleted their user account, personal data may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests, such as claims handling, bookkeeping, internal reporting, and reconciliation purposes.

We assess regularly the storage period for personal data to ensure the data is stored only for the necessary time period.

8. Disclosures, Transfers, and Recipients of Personal Data

For the purposes stated in this privacy policy, the personal data may be disclosed, when necessary, to authorities and to selected third parties, such as third-party service providers. In such cases, the personal data will be disclosed for purposes defined above, and any disclosure is always limited to only the strictly necessary personal data included in such purposes.

We may, in certain cases, disclose personal data to our partners for such third parties’ own purposes based on their legitimate interests.

In addition, we may share the personal data in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business and in connection with other similar arrangements.

The personal data is also disclosed to third parties if required under any applicable law or regulation or order by competent authorities, and to investigate possible infringing use of the products and services as well as to guarantee the safety and usability of the products and services. In the event of emergencies or other unexpected circumstances, Fischi may be required to disclose the personal data of registered persons in order to protect human life, health, and property.

9. Data Transfers Outside the EU/EEA

Some of the services used by us for processing personal data may operate outside the territory of the EU or the EEA. Thus, personal data can be transferred outside the European Union and the European Economic Area.

In case personal data is transferred outside the EU/EEA, such transfers are either made to a country that is deemed to provide an adequate level of data protection by the European Commission or transfers are carried out by using appropriate safeguards such as Standard Contractual Clauses (SCC) adopted, including any supplementary measures, where assessed to be necessary, or as otherwise approved by the EU Commission or competent data protection authority in accordance with the GDPR.

10. Protection of Personal Data

Securing the integrity and confidentiality of personal data is important to us. We have taken appropriate technical and organizational measures in accordance with industry standards in order to keep personal data safe and to secure it against unauthorized access, loss, misuse, or alteration by third parties, such as by firewalls, physical security measures, access controls, assignment of access rights, encryption, and active monitoring of the aforementioned measures.

All parties processing personal data have a duty of confidentiality in matters related to the processing of personal data. Access to personal data is restricted to those employees and parties who need it to perform their duties. We also require our service providers to have appropriate methods in place to protect personal data.

11. Use of Cookies and Similar Technologies

We use various technologies to collect and store Usage Data and other information when the Users visit the Fischi Services, including cookies, storing website data, and using web and application telemetry.

Cookies and other website data saved on your device allow us to identify visitors of the Fischi Services and facilitate the use of the Fischi Services and to create aggregate information of our visitors. This helps us to improve the Fischi Services and better serve our Users. The cookies and other website data will not harm your device or files. We use cookies and other website data to tailor the Fischi Services and the information we provide in accordance with the individual interests of our Users.

The Users may choose to set their web browser to refuse cookies. You can manage your cookie preferences through the cookie banner on our websites. Please note that some parts of the Fischi Services may not function properly if the use of cookies is refused.

12. Automated Decision-Making and Profiling

We do not use any automated decision-making or any profiling pursuant to the Article 22 GDPR.

13. Rights of Data Subjects

The data subject has several rights under applicable data protection laws.

• Right of access and right of inspection: The data subject has the right to obtain confirmation as to whether or not personal data concerning them is being processed. They also have the right to inspect and view data concerning them and, upon a request, the right to obtain the data in a written or electronic form. This applies to information provided to us insofar the processing is based on a contract/consent.
• Right to rectification and right to erasure: The data subject has the right to demand the rectification of incorrect personal data concerning them and to have incomplete personal data completed. They also have the right to require us to delete or stop processing personal data where it is no longer necessary for processing.
• Right to data portability: The data subject has the right to receive the personal data they provided to us in a structured, commonly used, and machine-readable format and transmit it to another controller.
• Right to restriction of processing: Under conditions defined by data protection legislation, the data subject can request restriction of processing of their personal data, such as when the data is suspected to be incorrect.
• Right to object to processing: The data subject can object to the processing of their personal data where legitimate interests are the legal ground for processing, such as for marketing purposes.
• Right to withdraw consent: In cases where processing is based on consent, the data subject can withdraw their consent at any time.
• Right to lodge a complaint: The data subject has the right to lodge a complaint with a competent data protection authority if they consider that processing infringes current legislation. The relevant authority in Finland is the Data Protection Ombudsman.

14. Exercising Rights

Requests regarding the rights of data subjects shall be made in written or in electronic form, addressed to the controller, Fischi, using the contact details mentioned in this privacy policy. Identity verification may be required before fulfilling the request. Requests will be responded to within a reasonable time, and where possible, within one month.

If a request cannot be met, the refusal will be communicated in writing. Requests may be refused due to statutory obligations or other rights, such as claims handling or legal requirements. A reasonable fee may apply for manifestly unfounded or excessive requests, particularly if repetitive.

If you have any questions about our data protection policies or wish to exercise your rights, please contact us at oscar@fischi.app. Alternatively, you can request deletion of your account via the Fides mobile app (Profile → My Profile → Delete Account) for faster processing.

15. Changes to This Privacy Policy

We can make changes to this privacy policy at any time by giving notice on our website or in the Fides application and/or by other applicable means. Users are encouraged to review the privacy policy periodically.

If a data subject objects to any changes, they should cease using the services and request the removal of their personal data unless laws require retention.

This privacy policy was last updated on 16th of November 2024.