PRIVACY POLICY FOR WEBSITE USER AND MARKETING REGISTER

Your privacy is important to us. Trust is the foundation of our customer relationships, and protecting your personal data is a responsibility we take seriously. We are committed to processing your data transparently, fairly, and in accordance with applicable data protection laws.

The website www.klinger.uy (the “Service”) is operated and maintained by KLINGER Finland Oy on behalf of KLINGER Uruguay S.A. This privacy policy describes how the personal data of users visiting and interacting with the Service is processed. The policy complies with both the EU General Data Protection Regulation (GDPR) and Uruguay’s Law No. 18.331 on the Protection of Personal Data and Habeas Data Action, and it applies to the personal data collected through the KLINGER Uruguay website.

KLINGER Finland Oy and KLINGER Uruguay S.A. act as joint controllers for the data submitted through the website (such as contact forms). Data may be viewed and processed in both Finland and Uruguay.

We use your data to provide and improve the Service. By using the Service, you consent to the collection and processing of your data in accordance with this privacy policy.

Data Controller

KLINGER Finland Oy
Tinankuja 3, 02430 Masala, Finlandia
Telephone: +358 10 400 1011
Email: info@klinger.fi
Business ID: FI01955191

Joint Controller

KLINGER Uruguay S.A.
Zonamerica Business & Technology Park, Montevideo, Uruguay
Telephone: +598 9934 8197
Email: info@klinger.uy
Business ID: 220216090013

Contact Person Responsible for the Register

Kim Westerlund
dataprotection@klinger.fi

Name of the Database

Marketing and Advertising Database

The processing of personal data is based on the following legal grounds:

  • Consent: e.g., when submitting the contact form, and cookies
  • Execution of a contractual relationship: e.g., in cases where further business communication is initiated
  • Legitimate interest: e.g., maintaining customer contacts in B2B business, analytics of website use, and essential cookies; exclusively for processing activities subject to the General Data Protection Regulation (“GDPR”) and only to the extent that such basis is valid and appropriate under the GDPR.

The purposes of processing are:

  • Providing and maintaining the Service
  • Responding to enquiries and maintaining customer relationships
  • Marketing communications
  • Analysis and development of the Service
  • Ensuring the technical functionality, security, and usability monitoring of the website

Data is not used for automated decision‑making or profiling.

Data Content of the Register

Data Collected

When you use our Service, we may ask you to provide information that can be used to contact or identify you (“Personal Data”). The data stored may include, for example:

  • Email address
  • First and last name
  • Telephone number
  • Company and position
  • Address, postal code, city
  • Communication history, requests for quotation, orders
  • Cookies and usage data

Usage Data

We may also collect information on how the Service is accessed and used. Usage data is collected automatically either through use of the Service or from its technical infrastructure. This may include, for example:

  • IP address
  • Browser type and version
  • Pages visited and timestamps of visits
  • Duration of use
  • Device and error diagnostic data

Regular Sources of Data

Data entered into the register is obtained from the customer, for example through website contact form or other voluntary interactions, such as email, telephone, social media contacts, contracts or customer meetings. Contact details of representatives of companies and other organisations may also be collected from public sources such as websites, directory services, and other companies.

Usage data is collected automatically when interacting with the website.

Cookies

Our website uses so‑called cookies. Cookies are small text files that are stored on the user’s computer via a web browser. They do not harm your device. We use cookies to help you navigate efficiently and to perform certain functions. Some cookies remain stored on your device until you delete them. They allow us to recognise your browser on your next visit.

We also use third‑party cookies to help analyse how you use our website, save your preferences, and provide relevant content and advertisements. These cookies are stored in your browser only with your prior consent.

You can change your cookie settings in your browser to prevent cookies from being used or to delete cookies already stored. Please note that without cookies, not all functions of our website may be available to you.

Essential Cookies

These cookies are necessary for our website and its functions to work properly (e.g., forms).

Our website contains links to KLINGER Uruguay’s social media channels, such as LinkedIn, and Google Business. The links open in a new browser window and do not establish a connection to the servers of the social media services until the user clicks the link.

Our website does not use social media plug‑ins, such as embedded content or tracking scripts, that would automatically transmit the user’s data to social media platforms without the user’s active action.

We recommend reviewing the privacy policies of the social media service providers before using their services:

  • LinkedIn (LinkedIn Ireland Unlimited Company)
  • Google Business (Google Ireland Limited)

Social Media Channels

KLINGER Finland Oy maintains KLINGER Uruguays’s company profiles on various social media platforms, such as LinkedIn, and Google Business. On these channels, we may act as joint controllers with the platform, unless the platform acts as the sole controller. However, we do not have full visibility into the platforms’ processing activities. For this reason, we recommend familiarising yourself with both KLINGER Uruguay’s privacy policy and the privacy policies of the relevant platforms.

Based on the user’s prior, express and informed consent given upon accepting this privacy policy and accessing the website, as well as on the execution of a contractual relationship, where applicable (Article 9, Law No. 18,331), the user consents to our processing the following data when interacting with our content on social media:

  • Publicly visible user data, such as name and profile picture in public comments
  • Interaction data, such as comments, private messages, reactions, and other contacts

In addition, we receive anonymised statistical data from social media platforms regarding, for example, page views, follower counts, and the popularity of posts. We do not receive user‑specific identifying data without the user’s own interaction or consent.

We recommend checking your social media account privacy settings and reviewing each platform’s privacy notice so you can control what data you share.

Web Analytics

We use Google Analytics to analyse how visitors use our website. The data collected is used to optimise the website and marketing and to develop our services.

The service provider is Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes data relating to the use of our website on our behalf and is contractually obliged to ensure the security and confidentiality of the processed data.

We do not transmit personal data such as names, addresses, or contact details to Google Analytics. Web analytics enables the website operator to review how users use the website. For this purpose, the following types of usage data may be collected: time spent on the site, pages viewed, dwell time, operating system, device information, and screen resolution. It is also possible to monitor whether a user performs certain actions, such as clicks or submitting a form.

User‑ and event‑level analytics data collected by Google Analytics is retained for 14 months, after which it is automatically deleted. Other analytics data is retained in aggregated and anonymised statistical form without identifying information.

Analytics data may be transferred to Google servers outside Uruguay (e.g., to the United States). We note that data protection legislation outside Uruguayan territory may not provide the same level of protection as in Uruguay. Transfers are nevertheless carried out with safeguards required by Uruguayan data protection regulations (Article 23, Law No. 18,331), such as standard contractual clauses.

If you do not want your data to be collected for analytics purposes, you can block tracking by installing the Google Analyticsin opt-out add-on in your browser or by adjusting the cookie settings on our website.

In Google Analytics, the visitor’s IP address is anonymised and we do not attempt to identify individual visitors through analytics.

Analytics Hosting

Service provider: Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Due to anonymisation, profiling or linking data to other sources is not possible. More information about Google Analytics privacy practices can be found here: Safeguarding your data – Google Analytics Help

Data Retention Period

We retain personal data only for as long as necessary to fulfil the purposes defined in this privacy policy and in accordance with applicable legislation.

  • User‑ and event‑level analytics data is retained in Google Analytics for 14 months, after which it is automatically deleted.
  • The retention period for website log data is determined by its purpose, such as ensuring information security or investigating technical disturbances. Data is retained only for as long as necessary for that purpose and is then deleted or anonymised.
  • The retention period for cookie‑related data depends on the type and purpose of each cookie. Cookie settings can be managed on the website.

Regular Disclosures of Data and Transfers

No regular disclosures to third parties are made. Data may be accessed by authorized personnel of KLINGER Finland Oy and KLINGER Uruguay S.A., including technical service providers processing data on their behalf.

Where data is transferred internationally, safeguards are applied according to GDPR and Law No. 18.331.

We never provide Google Analytics with personal data such as names, addresses, or contact details.

Principles of Register Protection

Care is exercised in processing the register, and data processed in information systems is appropriately protected. When register data is stored on internet servers, due care is taken regarding the physical and digital security of the equipment. The controller ensures that stored data, access rights to servers, and other information critical to personal data security are handled confidentially and only by employees whose job responsibilities require it.

Right of Access and Right to Rectification

Every person whose data is stored in the register has the right to access their data and request rectification of any inaccurate data or completion of incomplete data. If a person wishes to review their stored data or request corrections, the request must be submitted in writing to the controller (dataprotection@klinger.fi). The controller may request proof of identity where necessary.

The controller shall respond in a readable, concise, intelligible, and easily accessible manner, within the five (5) business day period prescribed by Uruguayan data protection regulations (Articles 14 and 15, Law No. 18,331; Article 9, Decree No. 414/009).

A person in the register has the right to request the deletion of their personal data (“right to be forgotten”). Data subjects also have other rights under Law No. 18,331, such as the right to update, include or challenge personal assessments, if any, in certain situations. Requests must be submitted in writing to the controller (dataprotection@klinger.fi). The controller may request proof of identity where necessary.

The controller will respond in a readable, concise, intelligible, and easily accessible manner, within the five (5) business day period prescribed by Uruguayan data protection regulations (Article 15 of Law No. 18,331; Article 9 of Decree No. 414/009).

The Supervisory Authority Contact Details

In Uruguay, the relevant authority is:

Unidad Reguladora y de Control de Datos Personales (URCDP)
Liniers 1324 piso 4°– Montevideo, Uruguay
Telephone: (+598) 2901 0065 int. 3
Email: infourcdp@datospersonales.gub.uy
Website: www.gub.uy/urcdp

In Finland, the supervisory authority is:

Office of the Data Protection Ombudsman
Lintulahdenkuja 4, 00530 Helsinki, Finlandia
P.O. Box 800, 00531 Helsinki
Telephone: +358 29 566 6700
Email: tietosuoja@om.fi
Website: tietosuoja.fi/en

Contact