Privacy Policy Smoothly Oy

This Privacy Policy explains how Smoothly Oy processes personal data in connection with its website, services, recruitment, and business operations.

1. Controller

Smoothly Oy
Business ID: 2640746-6
Otakaari 5, 02150 Espoo, Finland

If you have any questions about this Privacy Policy or the processing of your personal data, please contact us at: support@getsmoothly.com

2. Scope of this Privacy Policy

This Privacy Policy applies to the processing of personal data by Smoothly Oy in relation to:
- visitors to our websites
- representatives of our customers and prospective customers
- users of our services
- applicants to Smoothly and Smoothly Network
- other individuals who communicate or do business with us

3. Personal Data We Collect

We may collect the following categories of personal data, depending on the relationship you have with us:
Data you provide directly
- name
- email address
- phone number
- job title and company
- billing and mailing address
- application documents and portfolio information
- other information you choose to provide to us

Data collected when you use our website or services
- IP address
- browser type and version
- device and operating system information
- date and time of access
- referring pages and visited pages
- usage and event data within the service

Data received from third parties or integrations
- profile information from third party services such as Slack, Google, or other integrations you choose to use
- application data submitted through recruitment tools
- information from public sources such as LinkedIn, when relevant for recruitment or business communications

4. Purposes of Processing and Legal Bases

We process personal data only where we have a lawful basis under the EU General Data Protection Regulation (GDPR) and other applicable data protection laws. 

We may process personal data for the following purposes:

To provide our services
This includes creating and managing accounts, delivering services, managing projects, providing support, and communicating with users.
Legal basis: performance of a contract and, where applicable, legitimate interest.

To manage customer relationships and business communications
This includes handling inquiries, maintaining customer relationships, sending service-related communications, and managing agreements.
Legal basis: performance of a contract and legitimate interest.

To process billing and financial administration
This includes invoicing, payment processing, bookkeeping, and compliance with accounting obligations.
Legal basis: performance of a contract and legal obligation.

To improve our website and services
This includes analytics, service development, troubleshooting, testing, and understanding how our services are used.
Legal basis: legitimate interest and, where required by law, consent.

To ensure security and prevent misuse
This includes monitoring, logging, fraud prevention, investigation of misuse, and protection of our systems and users.
Legal basis: legitimate interest and legal obligation, where applicable.

To send marketing communications
This includes newsletters and other marketing messages where permitted by law.
Legal basis: consent where required by law, and in certain business-to-business situations, legitimate interest where permitted.

To manage recruitment and Smoothly Network applications
This includes reviewing applications, communicating with applicants, assessing suitability for current and future opportunities, and, where appropriate, maintaining a candidate pool.
Legal basis: taking steps prior to entering into a contract, legitimate interest, and consent, where applicable.

To comply with legal obligations and defend legal claims
This includes responding to lawful requests from authorities, complying with applicable laws, and establishing, exercising, or defending legal claims.
Legal basis: legal obligation and legitimate interest.

These purposes may relate to website use, customer and prospect communications, service delivery, recruitment, and our general business administration.

5. Cookies and Similar Technologies

We use cookies and similar technologies on our website.

We use the following types of cookies:
- Essential cookies, which are necessary for the website to function properly
- Analytics cookies, which help us understand how visitors use our website
- Marketing cookies, which may be used to measure campaigns or show relevant content or advertising

We rely on:
- legitimate interest for essential cookies where permitted
- consent for non-essential cookies, including analytics and marketing cookies, where required by law

You can manage your cookie preferences through our cookie banner or cookie settings tool. We use Usercentrics to enable users to review and manage their cookie preferences. Some cookies may be set by third-party providers. For more information, please review the privacy and cookie policies of those providers.

6. Sources of Personal Data

We collect personal data:
- directly from you
- from your employer or organisation, where relevant for a business relationship
- through your use of our website or services
- from integrations or third-party tools you choose to use
- from our customers, where relevant for delivering our services
- from recruitment systems and publicly available professional sources, where relevant

7. Data Sharing and Recipients

We do not sell personal data.

We may share personal data with:
- service providers and processors acting on our behalf
- professional advisors such as legal, accounting, or audit service providers
- authorities, where required by law
- parties involved in a corporate transaction, such as a merger, acquisition, or sale of business
- other parties where you have asked us to do so or where disclosure is otherwise lawful

Depending on the context, we may use third-party providers and partners for services such as:
- cloud hosting and infrastructure services
- authentication and identity management services
- communication and collaboration tools
- CRM, project management, invoicing, accounting, and recruitment services
- analytics, cookie consent, and marketing technology services
- legal, audit, and other professional advisory services
- payment and financial administration services, where applicable

We share only the personal data necessary for the relevant purpose and require our processors to protect it appropriately.

8. International Transfers

Some of our service providers may process personal data outside the European Economic Area.

Where personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place as required by applicable law. These safeguards may include:
- an adequacy decision issued by the European Commission
- Standard Contractual Clauses approved by the European Commission
- other lawful transfer mechanisms

You may contact us for more information about the safeguards used for international transfers.

9 Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend on:
- the nature of the relationship with you
- the purpose for which the data was collected
- legal, tax, accounting, and reporting obligations
- the need to resolve disputes or enforce agreements

As a general rule:
- customer and service-related data is retained for the duration of the customer relationship and thereafter as necessary for legal, operational, and contractual purposes
- accounting and invoicing data is retained for the period required by applicable law
- marketing data is retained until you unsubscribe, object, or the data is otherwise no longer needed
- applicant data is retained for one year from the end of the relevant recruitment process, unless a longer retention period is required by law or otherwise permitted under applicable law

Once personal data is no longer needed, we will delete or anonymise it.

10. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, and destruction.

These measures may include access controls, authentication measures, contractual protections with service providers, and other security practices appropriate to the nature of the data and processing.

However, no method of transmitting data over the internet or storing it electronically is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Under the EU General Data Protection Regulation (GDPR) and applicable local laws, you may have the right to:
- access your personal data
- request correction of inaccurate or incomplete personal data
- request deletion of your personal data
- request restriction of processing
- object to processing based on legitimate interest
- object to direct marketing
- receive your personal data in a structured, commonly used, and machine-readable format, where applicable
- withdraw consent at any time, where processing is based on consent
- lodge a complaint with a competent supervisory authority

To exercise your rights, please contact us at support@getsmoothly.com. Before responding to your request, we may ask you to provide additional information necessary to verify your identity.

Please note that some rights are subject to conditions and exceptions under applicable law.

If you are located in Finland, you may lodge a complaint with the Office of the Data Protection Ombudsman.

12. Recruitment and Smoothly Network Applications

If you apply for a role at Smoothly or for Smoothly Network, we process the personal data you provide in connection with your application. This may include:
- name and contact details
- CV, cover letter, and portfolio
- work history, skills, and qualifications
- links to professional profiles such as LinkedIn
- references and other information relevant to the application
- notes related to the recruitment or evaluation process

We process this data to:
- assess your suitability for current and future opportunities
- communicate with you during the application process
- manage our recruitment and selection process
- maintain a candidate pool where appropriate

We use recruitment tools and related service providers in this process and may share applicant data internally with persons involved in recruitment, matching, or decision-making.

Applicant data is retained only as long as necessary for these purposes and in accordance with applicable law. As a general rule, applicant data is retained for one year from the end of the relevant recruitment process.

If you have questions about applicant data, please contact:networksuccess@getsmoothly.com

13. Third-Party Services and Content

Our website and services may contain links, integrations, or features provided by third parties. This Privacy Policy does not apply to third-party services acting as independent controllers.

We encourage you to review the privacy policies of any third-party services you use.

If we display customer logos, testimonials, or content created for customers, we do so on an appropriate legal basis or under an agreement. If you believe content published by us contains your personal data and should be reviewed or removed, please contact us at support@getsmoothly.com.

14. Changes to this Privacy Policy & Contact

We may update this Privacy Policy from time to time. The latest version will always be available on our website. If we make material changes, we will provide notice where required by law.

If you have questions or concerns regarding this Privacy Policy or our processing of personal data, please contact:
Smoothly Oy
Otakaari 5, 02150 Espoo, Finland
support@getsmoothly.com

Last updated: 17.4.2026