Privacy Policy

Date of preparation: 1.2.2023 | Last update: 19.11.2025

In this privacy policy, we explain what personal data we process, for what purposes, on what grounds, and how you can exercise your rights as a data subject. We process personal data responsibly and in accordance with applicable data protection legislation.

1. Data Controller

Rawian Oy (trade name: Spinio)
Business ID: 2401190-0
Ilvesvuorenkatu 21 A, 01900 Nurmijärvi

2. Registry name

Rawian Oy's customer, partner, financial administration, and marketing register.

3. Purposes and legal bases for personal data processing

We process personal data for the following purposes:

Customer Relationship Management and Service Delivery Customer data management, order and contract processing, customer communication.
Accounting and payroll: Invoicing, payment tracking, accounting, employee data processing.
Marketing and sales support: Marketing communications, newsletters and campaigns, cookie-based analytics.
Cookies and website tracking: consent-based analytics and advertising targeting.

4. Content of the register

The registry may process the following information:

Basic information: Name, email, phone number, address details, company, and job title.
Customer-related information: Order details, contracts, service usage, customer communication, and support requests.
Accounting and payroll information: Invoicing and payment information, employee employment details, and salary information.
Marketing information: Marketing consents and prohibitions, campaign history.
Technical specifications IP address, browser type and operating system, information generated by cookies and analytics tools (e.g., website behavior).

5. Standard information sources

Information is obtained:

from the registered person themselves (forms, email, calls, contracts)
of events arising during customer or service usage
from employees during employment
Website cookies and analytics tools

6. Recipients and Processors of Personal Data

The following partners and service providers may process personal data on behalf of the data controller:

Accounting and Payroll: Financial management system
Technical and web service partners: Technical partners for online services, partners related to website and cookie management, partners related to marketing analytics (viewing rights for analytics data), partners related to sales tools and invoicing.
Internal Staff: Rawian Oy's employees to the extent required by their job duties.

7. Data transfers outside the EU/EEA

Information is not transferred outside the EU or EEA without appropriate safeguards. If the service provider is located outside the EU/EEA, transfers will be carried out in accordance with data protection mechanisms approved by the European Commission.

Data retention period

We retain personal data only for as long as is necessary to fulfill the purpose of use or to comply with legal obligations.

Accounting materials at least 6 years
Customer Information: up to 5 years from the termination of the customer relationship, unless a statutory obligation dictates otherwise
Marketing lists 12 months since last activity or until consent is withdrawn
Employee Information: in accordance with the retention periods required by law

9. Registered person's rights

The registered person has the right:

check their own personal data
request correction of incorrect information
request data deletion ("right to be forgotten")
restrict processing in certain situations
object to processing, when the legal basis is legitimate interest
withdraw consent (e.g., for marketing or cookies)
transferring data from one system to another when processing is based on consent or contract

Requests are typically answered within 1 month.