Privacy Statement

Last updated: 6.12.2020

This Privacy Statement is intended to provide you information about how Dream Broker processes personal data. As we acknowledge the importance of your privacy, we would also like to inform you about your rights regarding your personal data.

Dream Broker Ltd with business ID 2092227-2 (“Dream Broker”) processes personal data in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (2016/679, “the GDPR”). All subsidiaries of Dream Broker also apply the principles and policies described herein.

Dream Broker does not sell, rent or trade personal data with third parties. Dream Broker may only share personal data with third parties in accordance with section 6 below.

This Privacy Statement does not apply to processing of Dream Broker’s or its group companies’ customers’ or users’ personal data subject to customer or user agreements. In addition, this Privacy Statement does not apply to the products and services provided by third parties. You may find detailed information regarding processing of personal data in our products and services in the Data Processing Agreement entered into between the parties and in Privacy Notices and Privacy Policies of these products and services.

Data Controller information

Dream Broker Ltd
Energiakuja 3
FI-00180 Helsinki
Finland

E-mail: privacy@dreambroker.com
Telephone: +358 10 232 7770

Purposes of processing personal data

Dream Broker may process personal data for the following purposes:

Sales and marketing

providing the products and services;
developing existing customership, customer management and care;
managing customer or user data and providing technical and user support;
operational and contract management, administration, analysis and categorisation;
informing of changes, informing upon critical alerts and other such notices relating to our products and/or services;
targeting of customer or user communication and marketing;
communicating about Dream Broker’s products and services, enhancing sales and conducting market research;
registration to Dream Broker’s events; and
direct marketing.

Dream Broker’s internal purposes and product development

stakeholder communications (suppliers, job applicants and other cooperation partners);
analysis, reporting, development and personalisation of Dream Broker’s operations, products and services;
improving and developing security, products and services;
ensuring the quality and safety of the products and services;
statistical analyses; and
development and reporting related to the business operations.

Other general objectives

fulfilling the rights and obligations of Dream Broker and the data subject;
processing of personal data of website visitors for the purpose of ensuring and developing the functionality and security of our website;
preventing fraudulent activities;
fulfilling the obligations based on law and orders from authorities; and
removing or prohibiting sharing of illegal or infringing material.

Legal basis of processing of personal data

Personal data is collected and processed based on

legal obligations of Dream Broker;
contract to which the data subject is a party;
consent of the data subject; and
legitimate interests of Dream Broker.

The legitimate interest exists

when there is a material connection between Dream Broker and the data subject, e.g. when the data subject has on its own initiative contacted Dream Broker, or when there is a business or cooperation matter between Dream Broker and the data subject’s employer or other organization;
the processing is necessary to maintain or restore security of Dream Broker’s products or services, including websites; or
the processing is carried out for conventional direct marketing purposes.

On basis of its legitimate interest, Dream Broker may also process personal data of potential customers, users or other stakeholders and their contact persons and representatives which can be, on reasonable grounds, expected to be interested to acquire products and services provided by Dream Broker or sell their products and services to Dream Broker.

When the data subject is requested to give his or her consent, the data subject will be simultaneously informed that withdrawal of consent is possible at any time.

Categories of data processed

Dream Broker will only process personal data, which is needed for the purposes mentioned in section 2. Depending on the purposes of processing, the following information may be collected:

basic information such as name, company/organisation, title, position and profession, address, e-mail address, phone number, language, username and password;
records of purchases and downloads;
all created, shared, imported or posted content in video, audio, text and images and other media and related meta information;
information regarding the use of the products and services;
records of person’s consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data;
records automatically created when the data subject visits online products or websites, such as IP-address, traffic source, pages visited, the links and features used, interactions, the content viewed or requested, device information, browser or application type and access times;
records of person’s participation in Dream Broker events; and
other personal data provided by the data subject.

Regular sources of personal data

Dream Broker may collect personal data when data subject interacts with us or our business partners pursuant to our business, websites, products or services, buys our products or services, participates in a survey or campaigns, submits information through a web solution, by e-mail or by any other way.

Personal data is received and gathered:

directly from the data subjects and customers, users and other stakeholders when purchasing or using our products or services, visiting our websites and otherwise interacting with Dream Broker;
from Dream Broker’s group companies and distribution partners from whom a data subject (or organisation represented by the data subject) has purchased the products or services;
by using cookies and related technology or third-party analytical software; and
from public sources such as Population Information System or other similar external sources or from Dream Broker’s customer/user database and third-party contact information providers.

Data transfers and categories of recipients

Dream Broker does not sell, rent or trade personal data with third parties.

Dream Broker may share personal data with third parties, which provide products or services to Dream Broker (such as subcontractors and contracted service providers). Personal data may also be shared with and between Dream Broker’s group companies.

Personal data may be disclosed to a third party during a negotiation of any merger or acquisition and the receiving party has undertaken to follow non-disclosure liabilities with respect to the disclosed information. Only the necessary personal data is shared with such third parties. In addition, personal data may be disclosed to authorities in cases required by mandatory local legislation or a court order. Personal data may also be disclosed if the disclosure is permitted by applicable law, regulation or agreement or consented by the data subject.

In addition, Dream Broker may also share general, demographic or aggregated information with third parties about data subject and the usage of websites, products and services, but that information will not include or be linked to any personal information without data subject’s consent or other legitimate legal basis.

Whenever Dream Broker or third parties acting on its behalf transfer personal data outside of the European Union or the European Economic Area, Dream Broker ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Your personal data is only transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
Standard data protection clauses approved by the European Commission which give personal data the same protection it has in Europe are used. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or
Binding corporate rules approved by the competent authority.

Data protection principles and rights of the data subject

The information security of personal data processing and confidentiality, integrity and usability are ensured with appropriate technical and administrative measures in accordance with Dream Broker’s information security principles.

Only designated employees and the employees and agents of companies operating on behalf of Dream Broker are entitled to process and maintain personal data. Each designated user has his/her own personal user ID and password. Each employee of Dream Broker and agents of companies operating on behalf of Dream Broker are under a duty of confidentiality for the information obtained by him or her.

Dream Broker will process and retain personal data only as long as it is necessary for the purposes of processing which have been determined in advance. Personal data which has become redundant will be deleted on regular basis. Personal data has become redundant, for example, when the customer, user, business, co-operation or contract relationship to Dream Broker has ceased, notwithstanding cases where legislation requires retaining personal data.

When your personal data is processed, you as the data subject, have the following rights:

Right to access to your personal data. The data subject has the right to obtain confirmation as to whether or not his or her personal data is being processed. Where that is the case, the data subject has the access to the personal data and information concerning data processing.
Right to rectification. The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her.
Right to erasure. The data subject has the right to obtain erasure of personal data concerning him or her, and the data controller will have the obligation to erase personal data, provided that requirements stipulated in the GDPR are fulfilled.
Right to restriction of processing. The data subject has the right to obtain restriction of processing when
- accuracy of the personal data is contested;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; or
- the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right to object. The data subject has the right to object, on grounds relating to his or her particular situation, at any time processing of personal data concerning him or her processed on basis of a legitimate interest of Dream Broker or public interest, including profiling. In such cases Dream Broker will no longer process personal data unless Dream Broker demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Right to data portability. The data subject has the right to receive data concerning him or her, in a structured, commonly used and machine-readable format and has the right to transmit those data to another data controller in cases where processing of personal data is based on consent or contract and the processing is carried out by automated means.
Right to withdraw consent. When the processing of personal data is based on data subject’s consent, the data subject has always right to withdraw his or her consent for processing personal data or for electronic direct marketing.

You may exercise above stated rights regarding your personal data by contacting Dream Broker via sending an e-mail to the address privacy@dreambroker.com. We aspire to provide a reply as soon as possible and where needed, provide you additional instructions or ask additional questions based on your request.

Please notice that prior to fulfilling a request we have a right as well as a duty to verify your identity, due to which we must be able to recognize you and confirm your identity in an adequate manner.

If the data subject considers that there is an infringement of applicable legislation concerning personal data processing and data protection, the data subject has the right to lodge a complaint with the competent supervisory authority. In accordance with Article 77 of the GDPR, the complaint may be lodged in the Member State of his or her habitual residence, place of work or place of the alleged infringement. In Finland, the competent supervisory authority is the Data Protection Ombudsman.

Changes to Privacy Statement

Dream Broker may change or update this Privacy Statement at any time. We recommend that you read this Privacy Statement from time to time.