Privacy Policy

1. General

This General Privacy Policy (“Privacy Policy”) describes what personal data of the data subject (“you” or “data subject”) Cactos Oy (3249847–2), Cactos Fleet Management Finland Oy (3296517–3), Cactos Energia Oy (3544975–6), Cactos Fund Management Oy (3544966–8), Cactos B.V (89387228–000055184006) and Cactos Netherlands B.V (89394534–000055190715) (“Cactos”, “we”, or “the controller”) processes as the controller, and how and for what purposes such personal data are processed. This Privacy Policy also describes how personal data is transferred to third parties and how you can exercise your rights related to the processing of personal data.

This Privacy Policy applies to the processing of personal data in connection with Cactos’ marketing, sales and provision of services, as well as to personal data collected through online services such as cactos.com website and cookies.

Cactos complies with applicable data protection legislation, including the General Data Protection Regulation (EU 2016/679) and the Finnish Data Protection Act (1050/2018). Terms not defined in this Privacy Policy shall be interpreted in accordance with applicable data protection legislation.

2. Contact Details for Data Processing Matters

Cactos Oy (3249847–2)

Satamaradankatu 1, 00510 Helsinki

Mikael Lindqvist, General Counsel

Email: mikael@cactos.fi

3. Groups of Data Subjects

The personal data processing described in this Privacy Notice concerns the following groups of data subjects:

• Cactos’ customers and partners, as well as their representatives and other contact persons;
• Potential customers, their representatives, and other contact persons;
• Users of Cactos’ website;

4. Types of Personal Data processed

4.1. Sales, Marketing and Partner Relations

When engaging with partners, and when selling and marketing services to customers or potential customers, Cactos processes the following personal data:

• Name;
• Contact details (email address, postal address, and phone number);
• Employment or service-related information (such as organization, position, and job title);
• Other information related to the customer relationship (such as marketing prohibitions).

4.2. Provision of Services and Contractual Obligations

When providing services to customers and fulfilling contractual obligations, Cactos processes the following personal data of customers or their representatives:

• Name;
• Contact details (phone number, postal address, email);
• Employment or service-related information (such as organization, position, job title);
• Information required by law for fulfilling know-your-customer obligations.

4.3. Website

When using Cactos’ website, the following personal data is processed by Cactos:

• Cookie data such as browser type, operating system, device model, IP address, location data, connection time, and duration;
• Information provided through contact forms, such as name, email, phone number, company, and any other data you fill in.

5. Purpose and Legal Basis of Processing Personal Data

5.1. Sales, Marketing, and Partner Relations

When Cactos engages with its partners and when selling and marketing its services, Cactos processes the above-specified personal data for the following purposes:

• To initiate, enable, maintain, and develop potential customer or partner relationships;
• For direct marketing, such as sending newsletters;
• To develop the services offered by Cactos;

Processing of the personal data for the purposes specified above is based on the data subject’s explicit consent, where specified, or otherwise on Cactos’ legitimate interest. The above-mentioned processing may also be based on a legal obligation.

5.2. Provision of Services and Contractual Obligations

When providing services to customers and fulfilling contractual obligations, Cactos processes the above-specified personal data for the following purposes:

• To maintain, manage, and develop customer and partner relationships;
• To process and deliver contract-based orders;
• For contract management and invoicing;
• To fulfil legal obligations.

5.3. Website

When you visit Cactos’ website, Cactos processes the above-specified personal data for the following purposes:

• To provide, maintain, and develop the website;
• To compile website usage statistics;
• For targeted advertising;
• To process contact requests submitted through the website.

6. Regular Data Sources

Cactos collects personal data from the data subject themself as well as through the Cactos services used by the data subject. Cactos can receive personal data also from third parties in relation to the data subject, such as from our customer, from our cooperation partner, or from public sources.

7. Processors and Recipients of Data

Cactos uses external service providers in the processing of the personal data it collects, such as companies providing IT, consulting, and marketing services. These partners may act as processors of personal data in accordance with Cactos’s instructions. In certain situations, these partners may also act as separate, independent controllers with regard to the personal data necessary for providing the service.

8. Transfers of Personal Data Outside the EU or EEA

Cactos transfers personal data outside the EU or EEA, if necessary. If personal data are processed outside the EU or EEA, Cactos ensures the protection of the data according to applicable regulations.

9. Data Retention Policies

Cactos stores the personal data it processes only as long as necessary for those purposes. Personal data concerning the customer and cooperation relationship are stored for the duration of the relationship and thereafter up to seven (7) years.

10. Policies of Personal Data Protection and Data Security

Cactos follows good information management practices and implements effective data security measures in processing personal data.

11. Data Subject Rights

The data subject has rights concerning the processing of their personal data, including:

• Right to Access and Receive a Copy of Personal Data;
• Right to Examination and Rectification;
• Right to Erasure;
• Right to Restriction of Processing;
• Right to Object to the Processing;
• Right to Data Portability;
• Right to Withdraw Consent;
• Right to Lodge a Complaint with a Supervisory Authority.

12. Changes to Privacy Policy

Cactos may update this Privacy Policy from time to time. The most recent version is always available on Cactos’s website.