Privacy Notice Klippi
Home

Privacy Notice

Mmx Solutions Oy

Translation notice. This English text is a translation provided for convenience. The Finnish original is the binding version; in case of any discrepancy, the Finnish text prevails.

This notice describes how Mmx Solutions Oy processes personal data as a controller in its own right.

Note. When Mmx Solutions Oy processes material that a customer has stored in the Klippi service (videos, Player data, user accounts), it acts as a processor of personal data on the customer's behalf. That processing is described in the data protection annex to the customer contract, not in this notice.

1. Controller

The company has no statutory obligation to appoint a data protection officer.

2. Whose data we process

3. What data we process

Contact and customer data

Name, position or role, email address, telephone number, the organisation represented and its details.

Contract and invoicing data

Subscription details, licence tier, contract period, the time and version of the acceptance of the terms, invoices, payments made, and any payment defaults.

Transaction and communications data

Email communications, support requests, feedback, telephone calls and meeting notes. In connection with a support request, the sender's IP address and browser information are stored in order to prevent misuse.

Technical data concerning the maintenance of the service

The event log of administrative actions (invoicing, support functions, acting with a user's account) and technical application logs to the extent that they relate to the maintenance of the service, the investigation of errors and information security.

Website usage data

The cookies required for the operation of the service; see section 8.

We do not process data belonging to special categories of personal data in this role.

4. Where the data comes from

Purpose Legal basis
Managing the customer relationship and performing the contract Contract
Invoicing and monitoring of payments Contract and legal obligation
Demonstrating the acceptance of the contractual terms Contract and legitimate interest
Accounting and obligations relating to taxation Legal obligation
Customer support and responding to contacts Contract or legitimate interest
Technical maintenance of the service, investigation of errors and information security Legitimate interest
Developing the service Legitimate interest
Marketing and communications to existing and prospective customers by email, by telephone and at events Legitimate interest
Establishing or defending legal claims Legitimate interest
The cookies required for the operation of the service Legitimate interest

The basis for processing founded on legitimate interest is our business interests, such as managing customer relationships, ensuring the security and functioning of the service, developing the service, and marketing and protecting our business. We have assessed that the processing is necessary in order to achieve these purposes and that it does not override the rights and freedoms of the data subject. The processing concerns the data of the contact persons of organisations in the ordinary conduct of business.

6. Retention periods

Data Retention period
Customer and contact data For the duration of the customer relationship and 24 months from its end
Invoices, vouchers and other accounting material 6 years from the end of the year in which the financial period ends
Financial statements and accounting books 10 years from the end of the financial period
Contracts and records of the acceptance of the terms For the duration of the contract period and 10 years from its end
Support requests and transaction communications 24 months from the most recent event
Administrative event log 24 months
Technical application logs 14 days
Notifications internal to the service Read notifications 90 days, others 12 months
Viewing data (video, viewing position, watched marker) 12 months from the most recent viewing
Login codes Valid for 15 minutes; deleted upon use and at the latest one day after expiry
Marketing permissions and prohibitions For as long as is necessary in order to comply with the data subject's choice
Data of prospective customers 24 months from the most recent contact

Some of the data that has become unnecessary is deleted by an automatic clean-up run daily: notifications internal to the service, viewing data, the administrative event log, support requests and login codes. Technical application logs rotate automatically on a 14-day cycle. The other retention periods are implemented manually in the manner described in section 11.

7. Recipients of the data

Personal data is not sold or disclosed to outside parties for marketing purposes.

Data is disclosed to the following recipients:

Recipient Purpose Role Location
UpCloud Oy server and storage service processor Finland
Twilio Inc. (SendGrid) transmission of emails processor United States / EU
Browser manufacturers' push delivery services (Google, Mozilla, Apple) delivery of push notifications processor United States / EU
Holvi Payment Services Oy transmission of invoices and payment transactions independent controller in respect of its own statutory obligations Finland / EU
AnnaK Consulting accounting and financial statements independent controller in respect of the obligations of accounting and tax legislation Finland

An agreement on the processing of personal data has been concluded with the processors. Recipients acting as independent controllers are responsible for their own processing and provide information about it in their own privacy notices.

In addition, data may be disclosed to the authorities where required by law, and to legal advisers where necessary.

8. Cookies

The service uses only those cookies that are strictly necessary for its operation:

These cookies are necessary in order to provide the service and do not require consent. Cookies are set only for our own domain.

We do not use statistics, analytics or marketing cookies, and we do not load third-party tracking scripts into the service. For this reason there is no cookie consent notice on the site. Necessary cookies can be blocked in the browser settings, but in that case it is not possible to log in to the service.

9. Transfer of data outside the EU/EEA

Personal data is processed as a rule within the EU/EEA. The servers and the storage space are located in Finland.

SendGrid (Twilio Inc.), which is used for transmitting email communications, may process email addresses and the content of messages outside the EU/EEA. The same applies to the browser manufacturers' notification services used for delivering push notifications.

Transfers are carried out using transfer bases and appropriate safeguards in accordance with applicable data protection legislation, such as the standard contractual clauses approved by the European Commission.

10. Protection of the data

The data is protected by appropriate technical and organisational measures. These include, among others:

Personal data is processed only by those persons whose duties require it.

11. Rights of the data subject

The data subject has the right:

Requests are to be addressed to ismo.nybacka@mmx.fi. We respond within one month. We may request identification before carrying out a request. Requests are carried out manually; the service has no self-service export or deletion function.

12. Automated decision-making

We do not make decisions concerning data subjects solely on the basis of automated processing, and we do not engage in profiling that would have legal effects on the data subject or similarly significant effects.

13. Right to lodge a complaint

The data subject has the right to lodge a complaint with the data protection authority if they consider that the processing of personal data is unlawful.

In Finland, the supervisory authority is the Office of the Data Protection Ombudsman. Up-to-date contact details and instructions for lodging a complaint can be found at tietosuoja.fi.

14. Changes to this notice

We develop our operations continuously and may update this notice. The up-to-date version is always available at https://klippi.pro/en/legal/privacy.html. We will inform data subjects of material changes in an appropriate manner, for example on our website or, where necessary, by email.