1. Introduction

Brivra Ltd ("Brivra," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.brivra.fi or use our services.

This policy applies to all visitors, users, and clients of our website and services.

By using our website or services, you consent to the data practices described in this policy.

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2. Company Information

Business Name: Brivra Ltd

Business ID (Y-tunnus): 3578825-6

Registered Address: Helatie 10, 80100 Joensuu

Contact Email: info@brivra.fi

Location of Operations: Finland (EU)

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3. Legal Basis for Processing (GDPR)

As a Finnish company operating within the European Union, we process personal data in accordance with the General Data Protection Regulation (GDPR). Our legal bases for processing include:

• Consent: You have given clear consent for us to process your personal data for specific purposes (e.g., newsletter subscription, survey participation)

• Contract: Processing is necessary for a contract we have with you (e.g., service agreements)

• Legal obligations: Processing is necessary to comply with the law

• Legitimate interests: Processing is necessary for our legitimate interests (e.g., improving our services, marketing)

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4. Information We Collect

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4.1 Information You Provide to Us

We may collect personal information that you voluntarily provide when you:

• Fill out our contact form

• Book a free consultation

• Request a quote or proposal

• Participate in our surveys 

• Subscribe to our newsletter or communications

• Enter into a service agreement with us

• Communicate with us via email or other channels

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Types of information collected may include:

• Name (first and last)

• Email address

• Phone number

• Company name and position/role

• Country and region

• Business communication challenges and needs

• Language preferences

• Any other information we might need for service delivery or you choose to provide

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4.2 Information Automatically Collected

When you visit our website, certain information may be automatically collected, including:

• Log Data: IP address, browser type, browser version, pages visited, time and date of visit, time spent on pages, and other diagnostic data

• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our website and hold certain information (see Section 8 for more details)

• Device Information: Device type, operating system, unique device identifiers

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5. How We Use Your Information

We use the information we collect for the following purposes:

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5.1 To Provide and Maintain Our Services

• Respond to your inquiries and requests

• Schedule and coordinate consultations, training sessions, or facilitation services

• Deliver cross-cultural communication training, consulting, facilitation, and translation services

• Process service agreements and invoices

• Provide customer support

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5.2 To Communicate with You

• Send you service-related communications

• Send you survey findings reports (if you participated in our research)

• Respond to your comments, questions, and requests

• Provide updates about our services (if you have opted in)

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5.3 For Research and Analysis

• Conduct market research on Nordic-GCC business communication challenges

• Analyze survey responses to develop better services

• Create anonymized and aggregated insights for research reports

• Improve our website, services, and customer experience

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5.4 For Marketing and Business Development

• Send you information about services that may interest you (with your consent)

• Identify potential client leads from survey responses

• Share relevant content, case studies, and insights

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5.5 For Legal and Security Purposes

• Comply with legal obligations

• Protect against fraudulent, unauthorized, or illegal activity

• Enforce our terms and conditions

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6. How We Share Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following limited circumstances:

 

6.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Website hosting: website platform and hosting

• Email services: business email services

• Scheduling tools: booking platform

• Analytics: Google Analytics or other tools if used

• Payment processing: Payment processor if applicable

• Survey tools: Microsoft Forms or other forms (survey collection)

These service providers are contractually obligated to protect your information and may only use it to provide services to us.

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6.2 Business Transfers

If Brivra is involved in a merger, acquisition, or sale of assets, your personal information may be transferred. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

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6.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, government agencies).

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6.4 Aggregated and Anonymized Data

We may share aggregated, anonymized data from surveys or research in:

• Research reports

• Website content

• LinkedIn posts and articles

• Presentations and publications

This anonymized data cannot be used to identify individual respondents.

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7. International Data Transfers

Brivra operates in Finland (EU) and serves clients in both Nordic countries (EU/EEA), GCC countries (non-EU), and globally. When we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission

• Adequacy decisions by the European Commission

• Consent from the data subject

Some of our service providers (e.g., Wix, Microsoft) may store data on servers located outside the EEA. These providers have implemented appropriate safeguards for international data transfers.

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8. Cookies and Tracking Technologies

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8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help websites recognize your device and remember information about your visit.

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8.2 How We Use Cookies

We use cookies and similar technologies for:

• Essential cookies: Necessary for the website to function properly

• Analytics cookies: To understand how visitors use our website and improve user experience

• Functional cookies: To remember your preferences (e.g., language selection)

• Marketing cookies: To deliver relevant content and measure effectiveness (if applicable)

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8.3 Your Cookie Choices

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. Please note that disabling cookies may affect the functionality of our website.

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9. Your Rights Under GDPR

As a data subject in the European Union, you have the following rights:

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9.1 Right to Access

You have the right to request copies of your personal data.

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9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

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9.3 Right to Erasure ("Right to be Forgotten")

You have the right to request deletion of your personal data under certain conditions.

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9.4 Right to Restrict Processing

You have the right to request restriction of processing your personal data under certain conditions.

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9.5 Right to Data Portability

You have the right to request transfer of your data to another organization or directly to you.

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9.6 Right to Object

You have the right to object to our processing of your personal data under certain conditions.

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9.7 Right to Withdraw Consent

If we process your data based on consent, you have the right to withdraw that consent at any time.

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9.8 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: support@brivra.fi

Subject line: "GDPR Data Subject Request"

We will respond to your request within 30 days as required by GDPR.

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9.9 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe we have violated your data protection rights.

Finnish Data Protection Ombudsman:

• Website: tietosuoja.fi

• Email: tietosuoja@om.fi

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10. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

General retention periods:

• Contact form inquiries: 2 years from last contact

• Client service data: 7 years (required for accounting and tax purposes under Finnish law)

• Survey responses: 3 years from collection date

• Marketing communications lists: Until you unsubscribe or request deletion

• Website analytics data: 26 months (standard for Google Analytics if used)

After the retention period expires, we will securely delete or anonymize your personal data.

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11. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

Security measures include:

• Secure Socket Layer (SSL) encryption for data transmission

• Secure hosting with Wix (ISO 27001 certified)

• Regular security updates and monitoring

• Access controls and password protection

• Secure email communications via Microsoft 365

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

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12. Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at info@brivra.fi, and we will delete such information from our systems.

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13. Third-Party Websites

Our website may contain links to third-party websites (e.g., LinkedIn, partner organizations). We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

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14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

When we make changes:

• We will update the "Last Updated" date at the top of this policy

• For material changes, we will notify you via email (if we have your email address) or by posting a prominent notice on our website

• Continued use of our website or services after changes constitute acceptance of the updated policy

We encourage you to review this Privacy Policy periodically.

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15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Brivra Ltd

Email: info@brivra.fi

Postal Address: Helatie 10, 80100 Joensuu

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16. Additional Information for GCC Clients

For clients based in GCC countries (UAE, Saudi Arabia, Qatar, Kuwait, Bahrain, Oman) or outside EU, please note:

• Your data may be processed in Finland (EU) and is subject to GDPR protections

• We comply with applicable data protection laws in your jurisdiction where relevant

• Cross-border data transfers from GCC to EU are conducted with appropriate safeguards

• You have the rights outlined in Section 9, as well as any additional rights under your local data protection laws

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