Privacy Policy

Giveaway App's privacy policy was last updated 17.04.2019.

Your privacy is important to Giveaway App. So we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your information. When processing personal data, we rely on our legitimate interests in maintaining business relationships and communicating with you about our operations and services. We process your personal data in accordance with the applicable laws, including the General Data Protection Regulation (GDPR) in particular.

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

This Privacy Policy may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Policy or reduce the rights of the Users under this Privacy Policy without providing a notice thereof.

This Privacy Policy applies to processing of personal data carried out by Giveaway App as a data controller.

Please take a moment to familiarise yourself with our privacy practices and let us know, if you have any questions.

Together with the Terms of Use, this Personal Data Policy comprises the terms and conditions governing the User’s agreement with Giveaway App.

1. Giveaway App's contact details


Name: Giveaway App Oy Ab

Company ID: 2943712-6

Address: Yliopistonkatu 10, 00100, Helsinki


2. General

Giveaway App Oy Ab (“Giveaway App”, “we”) process personal data of its users of Giveaway App's product and service discovery services ("The App"), users of Giveaway App for Business ("For Business") and the visitors of the website (“Website”).

In this Privacy Policy, the word “Giveaway App Services” refers jointly to The App, For Business and the Website. In this Privacy Policy, the word “User” or “you” refers jointly to our and our group companies’ customers, potential customers and the users of the Giveaway App Services.

Giveaway App is the data controller of personal data processed within the framework of this policy. Giveaway App processes the User’s personal data in accordance with the Finnish Personal Data Act (523/1999) and with the EU General Data Protection Regulation (GDPR). By registering a user account or ordering services from Giveaway App, the User consents to Giveaway App processing such User’s personal data in accordance with the provisions below.

By using this webpage, i.e., the User consents to this Personal Data Policy.

Together with the Terms of Use, this Personal Data Policy comprises the terms and conditions governing the User’s agreement with Giveaway App.

3. Personal data processed and sources of data

The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.

User Data


User Data is personal data collected directly from you. We may collect User Data from our Users in a variety of ways, including, when they register to the Giveaway App Services, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through the Giveaway App Services (only applies to Giveaway App for Business users).

User Data that is necessary in order to use the Giveaway App Services


The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for the compliance with our legal obligations.

When you register to Giveaway App Services (excl. Giveaway App for Business services) and create a user account, you need to provide us with the following information: full name and email address.

When you register to Giveaway App for Business services and create a user account, you need to provide us with the following information: full name, telephone number, email address, company details, billing details, information relating to your payment instrument; such as the number of your payment instrument and your payment instrument’s expiration date (required for the purposes of ordering services via the Giveaway App for Business services), and link your social media channels (required for the purposes of publishing posts to Giveaway App Services).

User Data you give us voluntarily

Your user or customer experience may be enhanced by providing us with the following information:

Additional Account Information:

  • Location data (if you consent to the processing of your location data).

  • Other information you provide either when creating a user account or later when modifying your account profile.

Other Information

We may also process other information provided by you voluntarily such as:

  • Information you provide when rating our services.

  • Marketing opt-ins and opt-outs.

  • Information you provide by phone or in email or chat correspondence with us.


In addition to User Data collected from you, we process certain personal data third party service providers provide about you. If you connect or login to your account with Facebook, Facebook shares with us personal information about you such as your name, email address, profile picture, a sample of your Facebook friends and your Facebook ID.

Analytics Data

Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognised from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.

We may automatically collect the following Analytics Data when you visit or interact with the Giveaway App Services:


Device Information

We collect the following information relating to the technical device you use when using the Giveaway App Services:

  • Device and device identification number, device IMEI

  • Country

  • IP address

  • Browser type and version

  • Operating system

  • Internet service providers

  • Advertising identifier of your device

Usage Information

We collect information on your use of the Giveaway App Services, such as:

  • time spent on the Giveaway App Services

  • interaction with the Giveaway App Services

  • information on your orders made through the Giveaway App for Business services

  • the URL of the website you visited before and after visiting the Giveaway App Services

  • the time and date of your visits to the Giveaway App Services

  • the sections of the Giveaway App Services you visited

  • the content and services you searched for while using the Giveaway App Services



We use various technologies to collect and store Analytics Data and other information when the Users visit the Giveaway App Services, including cookies and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify visitors of the Giveaway App Services and facilitate the use of the Giveaway App Services and to create aggregate information of our visitors. This helps us to improve the Giveaway App Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the Giveaway App Services and the information we provide in accordance with the individual interests of our Users.

The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Google Chrome
Internet Explorer
Mozilla Firefox


Please note that some parts of the Giveaway App Services may not function properly if use of cookies is refused.

A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.


Web Analytics Services

The Giveaway App Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Giveaway App Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.

4. Purposes and legitimate grounds for the processing of your personal data


There are several purposes for the processing of your personal data by Giveaway App:


To provide the Giveaway App Services and carry out our contractual obligations


(legal ground: performance of a contract)


Giveaway App processes your personal data to be able to offer the Giveaway App Services to you under the contract between you and Giveaway App.

We use the data for example to handle your payments or any refunds and to publish your content to Giveaway App Services (applies to Giveaway App for Business services). We use the data to for example customise your experience and deliver relevant content and services to you (where applicable). If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint.

For our legal obligations


(legal ground: compliance with a legal obligation)


Giveaway App processes data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.

For claims handling and legal processes


(legal ground: legitimate interest)

Giveaway App may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.

For customer communication and marketing


(legal ground: legitimate interest)

Giveaway App processes your personal data to contact you regarding the Giveaway App Services and to inform you of changes relating to them. Your personal data are also used for the purposes of marketing the Giveaway App Services to you.


For quality improvement and trend analysis


(legal ground: legitimate interest)


We may also process information about your use of the Giveaway App Services to improve the quality of the Giveaway App Services e.g. by analysing any trends in the use of the Giveaway App Services. In order to ensure that our services are in line with your needs, personal data can be used for things like customer satisfaction surveys. When possible, we will do this using only aggregated, non-personally identifiable data.

Legal grounds for processing

Giveaway App processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

In some parts of the Giveaway App Services, you may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.

5. Transfer to countries outside of Europe

Giveaway App stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.


We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.


More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.

6. Recipients

We only share your personal data within the organisation of Giveaway App if and as far as reasonably necessary for the purposes of this Privacy Policy.

We do not share your personal data with third parties outside of Giveaway App’s organisation unless one of the following circumstances applies:


For the purposes set out in this Privacy Policy and to authorized service providers.

To the extent that third parties need access to personal data in order for us to perform the Giveaway App Services, we provide such third parties with your data to be processed on behalf of us. Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales and marketing) to process it for us and to payment service providers to process your payments to us.

When data is processed by third parties on behalf of Giveaway App, Giveaway App has taken the appropriate contractual and organisational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Giveaway App Services, the processing is typically based on their policies and standards.

For legal reasons and legal processes


We may share your personal data with third parties outside Giveaway App if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Giveaway App, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.

For other legitimate reasons


If Giveaway App is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the Users concerned when the personal data are transferred or become subject to a different privacy statement.

With your explicit consent


We may share your personal data with third parties outside Giveaway App when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

7. Retention period of personal data

We comply with our statutory obligations regarding retention of data. Giveaway App does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Giveaway App Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

We will retain the User’s information in accordance with current legislation for as long as necessary for the purposes defined above. After that time, we will remove unnecessary data and continue to process the User’s name and contact details and individual data items describing the User’s profile for marketing purposes as long as the data subject has explicitly given us the right to send marketing messages.

8. Your Rights

Right to access

You have the right to request access to the personal data relating to you. This includes e.g. the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. You also have the right to request that inaccurate or incomplete personal data be corrected.

Right to withdraw consent

In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.


Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Giveaway App Services.


Right to erasure

You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement.

Right to object

You may have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Giveaway App Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Giveaway App Services.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use the Giveaway App Services.

Right to data portability

You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.

How to use your rights

The above mentioned rights may be used by sending a letter or an email to us on the addresses set out above, including the following information: the full name, address, email address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

9. Direct marketing

The User has the right to prohibit us from using the User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Giveaway App Services or the unsubscribe possibility offered in connection with any direct marketing messages.

10. Lodging a complaint

In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (

11. Information security

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Giveaway App Services, systems, and other assets for security vulnerabilities.


Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

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