With this Blue Berry Share’s Privacy Notice we provide you information on why and how we process your personal data in our Blue Berry Share service.

We process your personal data as a controller for the following purposes:

a)     Conclusion of an agreement with LCs and fulfillment of contractual obligations towards LCs in regard to Blue Berry Share service

b)     Provision of Blue Berry Share service to the Investors

c)     Technical maintenance of Blue Berry Share service

d)     Marketing

e)     Communications

f)      Compliance with legal obligations

Please note that we process IR Representatives’ personal data also as a processor, as is described in Section 3 below.

Controller means a party that is in charge of the personal data processing activities.

Data subject is a term for a human being in accordance with data protection laws.

DPO means an independent representative of a controller or a processor who helps the controller or the processor ensure that it complies with relevant data protection laws.

Investor means our customer who uses our Blue Berry Share service to participate in events as an investor.

IR Representative means an investor relations representative of an LC.

LC means our customer that uses our Blue Berry Share service to arrange events and meetings to which Investors may participate.

Legal basis for processing means the legal basis with which the controller processes personal data of a data subject. Article 6 of the GDPR contains provisions on legal basis for processing.

Personal data means any data concerning a data subject or data with which a data subject can be identified with.

Privacy Notice means a data protection document that has been drafted according to Articles 13 and 14 of the GDPR, and with which the controller may inform its data subjects of the ways their personal data is processed.

Processor means a party that processes personal data for and on behalf of the controller.

Purpose for processing means the reason why the controller processes personal data of a data subject.

Blue Berry Share Oy (Company ID: 3282399-2) is the controller of your personal data. The address of the controller is PL 24, Tammisaari 10601, Finland.

If you have any questions relating to this privacy notice, please contact us via email: palvelut@blueberrycom.fi .

Yes. Blue Berry Share Oy is also a processor of LCs when Blue Berry Share Oy processes IR Representatives’ personal data in the Blue Berry Share service. Blue Berry Share Oy is the processor of LCs in the aforementioned situation since it processes IR Representatives’ personal data only to enable LCs to use Blue Berry Share service, meaning that Blue Berry Share Oy processes IR Representatives’ personal data only on LCs’ behalf.

We process your personal data for the below mentioned purposes of processing. Below you will also find information on what personal data we process and what are the legal basis for our processing activities.

a) Conclusion of an agreement with LCs and fulfillment of contractual obligations towards LCs in regard to Blue Berry Share service

Explanation: Personal data is processed to provide our Blue Berry Share service to the LCs.
Category of data subjects: LCs’ contact persons with whom we communicate.
Categories of personal data: Contact details.
Legal basis for processing: Performance of our contractual obligations with LCs.

b) Provision of Blue Berry Share service to the Investors

Explanation: Personal data is processed to provide our Blue Berry Share service to the Investors.
Category of data subjects: Investors.
Categories of personal data: Contact details, title in a company, name of the employer, username and password.
Legal basis for processing: Performance of our contractual obligations with Investors.

c) Technical maintenance of Blue Berry Share service

Explanation: Personal data is processed to carry out technical maintenance of Blue Berry Share service.
Category of data subjects: People using Blue Berry Share service.
Categories of personal data: All personal data available in the Blue Berry Share service.
Legal basis for processing: Our legitimate interests, according to which we carry out our technical maintenance of Blue Berry Share service. Our interests are in line with people with data subjects, as their personal data is processed to better fulfil Blue Berry Share service. NB: You may have a right to object data processing for these purposes (see section concerning your rights).

d) Marketing

Explanation: Personal data is processed to market Blue Berry Share Service.
Category of data subjects: Investors and LC’s contact persons with whom we communicate.
Categories of personal data: Contact details.
Legal basis for processing:
(I) Our legitimate interests, as we need to market our services in order to carry out business. Our interests override the interests of our customers and potential customers since we carry out direct marketing in accordance with applicable laws. NB: You may have a right to object data processing for these purposes (see section concerning your rights).
(II) Where we may not legally rely on our legitimate interests, our legal basis for processing shall be consent.

e) Communications

Explanation: Personal data is processed to carry out communications.
Category of data subjects: People with whom we communicate.
Categories of personal data: Contact details and other data disclosed to us.
Legal basis for processing: Our legitimate interests, according to which we carry out our communications. Our interests are in line with people with whom we communicate, as they expect us to process their data for communications purposes. NB: You have a right to object data processing for these purposes (see section concerning your rights).

f) Compliance with legal obligations

Explanation: Personal data is processed to comply with our legal obligations (e.g. accounting obligations).
Category of data subjects: Investors and LC’s contact persons with whom we communicate.
Categories of personal data: Data we are required to process under our legal obligations.
Legal basis for processing: Legal obligations.

We may also process your personal data if processing is necessary for compliance or statutory requirements.

We collect personal data directly from the data subjects themselves.

Transfers to third party service providers: We may transfer your personal data to third party service providers, as it is a normal course of doing business in a digitalized world (i.e. data storage service providers, communications services providers). When personal data is transferred to third parties, we aim to ensure that we conclude adequate personal data processing agreements and safeguards in relation to the data transfers.

Transfers outside the EU/EEA: We may transfer personal data outside the EU and the EEA. When doing so, we aim to ensure adequate safeguards for the data transfer, such as standard contractual clauses.

Disclosure of Investor’s personal data to LC’s: As a part of Blue Berry Share Service, it is necessary for us to disclose Investor’s personal data to LCs, for example when an Investor interacts with LCs in the Blue Berry Share Service.

Disclosure of Investor’s personal data to other Investors: As a part of Blue Berry Share Service, we may disclose Investor’s personal data to other Investors if more than one (1) Investor participates in a group meeting arranged by an LC via Blue Berry Share Service; all participants of a group meeting can see all participants of the group meeting.

By using this Service, certain parts of which are provided by third parties, Investor agrees to be aware of the Terms, Conditions and Privacy Policies of the third parties.

Depending on the legal basis for processing personal data, we process and store your personal data for as long as:

- (consent) you provide us your consent for processing personal data,
- (contract) it is necessary to fulfill our contractual obligations,
- (our legitimate interests) it is necessary for the fulfillment of the processing activities, or
- (our legal obligations) it is necessary required by our legal obligations.

You may have the right to use the below listed data protection rights under the GDPR:

- Right to inspect (art. 15)
- Right to rectify (art. 16)
- Right to erasure (art. 17)
- Right to restriction of processing (art. 18)
- Right to data portability (art. 20)
- Right to object (art. 21)
- Automated individual decision-making, including profiling (art. 22)

If you would like to use your rights or inquire something about data protection, please be in touch with us by email: palvelut@blueberrycom.fi .

You may also have a right to lodge a complaint with the data protection authorities, if you think that the processing of your personal data infringes data protection laws.

We have a unilateral right to modify this Privacy Notice. The modifications take effect immediately when we post the up-to-date version of our Privacy Notice to our website.

Last update on 1 April 2022.