Privacy Notice

Ultima Lead Oy (trading as Nordic Edge) Business ID: 3411000-5 Helsinki, Finland

Liisa Holma, CEO liisa@nordicedge.fi

Ultima Lead Oy customer, marketing and newsletter register.

We process personal data for the following purposes: • Sending newsletters and waitlist communications • Managing and developing customer relationships • Developing customer service and the business • Delivering our services and marketing • Analysis and statistics • Other comparable purposes

We process personal data based on: • Performance of a contract with the customer or pre-contractual measures • Our legitimate interest in communicating with contact persons of our stakeholders about matters within their responsibility • Consent (e.g. newsletter subscription and joining a program waitlist) • Compliance with legal obligations

We collect personal data directly from the data subject through the forms on our site (newsletter signup and program waitlist forms) and by email when you contact us.

The register contains the following personal data: • Email address • Name (on waitlist forms) • Program of interest (e.g. Stay Relevant, Own Your Edge) • Language preference (Finnish/English) • Communication-related data such as message status and recipient interaction with newsletters • Any other information you provide when contacting us

Our website uses Vercel Web Analytics and Speed Insights for aggregate, cookieless and anonymous traffic and performance measurement. We do not use Google Analytics or advertising tracking pixels.

As a rule, personal data is processed by our own personnel to the extent necessary for their duties.

We use the following third-party services as data processors: • ActiveCampaign (email marketing and contact management) • Vercel Inc. (website hosting infrastructure and aggregate, anonymous traffic and performance analytics) These third parties process data only on behalf of Ultima Lead Oy under a lawful data processing agreement.

We may also disclose personal data to fulfil contractual obligations, when required by law or a competent authority, and in connection with a possible merger or business transfer.

We may transfer data to servers located outside the EU or EEA within the limits allowed by data protection law. Such transfers are carried out using, for example, the Standard Contractual Clauses approved by the European Commission.

We do not retain personal data longer than necessary for the purpose, the contract or the law. Retention periods are determined by, among other things: • Processing was based on consent that has been withdrawn and there is no other basis • The person requests deletion (and there is no basis to continue processing) • The contractual relationship has ended and no new contract is expected • The data is inaccurate or outdated • A statutory retention period has passed (e.g. accounting law) We update data as needed and delete personal data that is no longer required.

A cookie is a small text file that the browser stores on the user's device. Our site uses only strictly necessary cookies and local storage, for example to remember the state of the cookie notice and your language preference.

The site does not currently use third-party analytics or advertising cookies. We do not track visitors across other sites.

You can manage cookies in your browser settings or clear them from your browser. Note that changing cookie settings may affect how the site works.

Personal data is treated as confidential. Electronic registers are protected by usernames and passwords, with access limited to people who need it for their work. The site uses https/TLS encryption to protect data in transit.

You have the following rights. Requests to exercise them should be sent to liisa@nordicedge.fi:

Right of access. The right to check whether we process personal data concerning you and what data we process.

Right to rectification. You may ask us to correct inaccurate or incomplete data concerning you.

Right to object. You may object to the processing of your personal data if you believe it has been processed unlawfully.

Right to opt out of direct marketing. You have the right to prohibit the use of your data for direct marketing.

Right to erasure. You have the right to request deletion of your personal data when processing is no longer necessary.

Right to withdraw consent. If processing is based solely on consent, you can withdraw it at any time (e.g. the unsubscribe link in our newsletters).

Right to lodge a complaint. You have the right to lodge a complaint with the Data Protection Ombudsman if you believe that the processing of your personal data breaches applicable data protection law. Contact details: www.tietosuoja.fi.

We may make changes to this privacy notice and related information. We recommend that you review this notice regularly for any changes.