Privacy policy

1 Controller and contact details

The controller is Klarpick, Finland. The site is run by a natural person established in the European Union; there is no separate company and therefore no company registration number. The controller’s name and postal address are provided on request in a matter concerning a data subject’s rights.

Data protection matters: info@klarpick.com. We have not appointed a data protection officer, because the activity does not meet the conditions in Article 37 GDPR.

2 Starting point

The site is built to collect as little as possible. We require no registration, we do not profile visitors, and we do not sell or rent data to anyone. In practice the only data that can identify you is the email address for the newsletter and whatever you write yourself if you contact us.

3 Visitor measurement

We use the cookieless visitor measurement GoatCounter, which records for each page view: the page address, the referring page, an approximate country, and the browser and device type. The service sets no cookies and stores no IP address as such; it forms a daily checksum that separates new visits from returning ones without any persistent identifier.

We cannot identify an individual visitor from this data. The legal basis is legitimate interest (GDPR Article 6(1)(f)): we need to know which articles are useful.

4 Ad links and how they are measured

The site is funded by ad links. When you click an ad link, two separate things happen, and it matters to keep them apart:

• Our own measurement. We record as an event that a given tool’s link was clicked from a given article. No cookie and no identifier is involved — we see counts only. Basis: legitimate interest.
• The partner’s tracking. Once you move to the partner’s site, the partner may set its own cookie to recognise that you came through us and to pay us a commission on any order. The cookie is the partner’s, not ours, and it is set on the partner’s site. Basis: your consent.

The link carries a so-called sub-tag that tells the partner which article and which place on the page you clicked from (for example fi_paras-sahkopostimarkkinointiohjelma_taulukko). It contains nothing about you.

If you do not consent, the ad links take you to the same provider’s page without tracking parameters. You lose nothing: the price and the offer are the same.

There are no ad links on the English pages yet, because the comparisons are published in Finnish first. This section describes how it works across the whole site.

The partner networks we use act as independent controllers for their own tracking. Current list of partners: Ad links and funding (in Finnish).

5 Newsletter

If you subscribe to the newsletter, we store your email address, the time of subscription and which page you subscribed from. We use this only to send the newsletter and to show that you gave consent. Basis: consent.

The newsletter is not in use yet. The form is visible on the site, but it sends nothing and no addresses are stored anywhere. When the newsletter starts, the service used and its location will be named here before the first send. You will then be able to unsubscribe from the link at the end of every message; unsubscribing deletes the address.

6 Getting in touch

If you email us, we keep the message and your address for as long as handling the matter requires. Basis: legitimate interest (responding to enquiries).

7 Cookies and data stored in your browser

The partner cookie’s duration varies by programme: the shortest is 31 days and some programmes use a persistent identifier, in which case the referral is attributed to us indefinitely. The duration is set by the partner rather than by us, and it applies only to the partner whose link you clicked. You can block all partner cookies by choosing “Necessary only” in the cookie bar.

kp_consent is stored in your browser’s local storage and never reaches us. You can change your choice at any time by clearing the site data in your browser.

8 Recipients and processors

• Cloudflare, Inc. — technical hosting of the site and content delivery network. A US company with servers in various parts of the world; the transfer is based on the standard contractual clauses approved by the EU.
• GoatCounter — cookieless visitor measurement. The service states that it sets no cookies and stores no IP addresses.
• Newsletter service — not in use. To be added here before the first send.
• Partner networks — only if you consent and click an ad link; they act as independent controllers.

We do not disclose data to anyone else. We disclose data to an authority only where the law requires it.

9 Transfers outside the EU

Some partner networks and possibly the newsletter service operate in the United States. In those cases the transfer relies on the standard contractual clauses approved by the European Commission or on the EU–US Data Privacy Framework. Current transfer bases per processor are available on request.

10 Retention periods

• Visitor measurement data: at most 12 months.
• Newsletter subscriber data: until you unsubscribe.
• Consent data: 6 months in your browser.
• Email messages: at most 24 months from the contact.

11 Your rights

You have the right to: access your data; have inaccurate data corrected; have your data erased; restrict processing; object to processing based on legitimate interest; port the data you provided from one system to another; and withdraw consent at any time without affecting the lawfulness of processing before the withdrawal.

Requests: info@klarpick.com. We reply within one month. Note that we cannot identify you from the visitor measurement data and therefore cannot extract your data from it (GDPR Article 11).

12 Right to complain

If you consider that we process your data unlawfully, you can complain to the data protection authority of the EU or EEA country where you live or work. We are established in Finland, so the authority of our place of establishment is the Office of the Data Protection Ombudsman (tietosuoja.fi).

13 Security

The site runs over an encrypted connection (HTTPS). Only the controller has access to newsletter subscriber data. We store no payment details and process no special categories of personal data.

14 Children

The site is aimed at businesses and at people over 16. We do not knowingly collect data from anyone under 16.

15 Automated decision-making

We carry out no automated decision-making and no profiling.

16 Changes

When the policy changes, we update the page and its date. We tell newsletter subscribers about substantive changes.