Equel Oy owns Equel Social (equelsocial.com and our Mastodon server equel.social).

‍During Equel Social’s beta phase, Equel Oy needs to store and process personal data wider and longer than it will once the beta phase is completed. Broader data processing is required to develop Equel Oy’s machine-learning solutions as effectively as possible. We will update this Privacy Policy accordingly once the beta phase is completed.

This privacy policy was last updated on 30.1.2024.

The Controller of these filing systems is the Finnish Limited Liability company Equel Oy (business registration number: 3237268-5) hereinafter referred to as ”Equel” or “We” / “Us.”

Equel’s contact in privacy matters is team@equelsocial.com. 

Our mailing address is Equel Oy, Nummikatu 18-20, 90100 Oulu, Finland.

Please do not hesitate to contact Us with questions, concerns, or ideas about Equel’s personal data procedures.

In the following, the most essential terms used in this Privacy Policy are explained: 

“Customer” means any consumer or representative of a company, association, foundation, or public body that has purchased and/or downloaded and uses something from Equel or has some other relevant connection with Equel. 

“Potential Customer” means any consumer or representative of a company, association, foundation, or public body that is not yet or anymore an active customer.

“Interest Groups” means, among others, representatives of suppliers, the press, entities offering services to Equel, and other stakeholders. 

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”). 

“Consent” of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by explicit affirmative action, signifies agreement to the processing of personal data relating to him or her. 

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

This Privacy Policy covers processing the Personal Data of Customers, Potential Customers, and representatives of different Interest Groups. In the following, we explain the differences in each category. One or more roles and purposes may apply simultaneously. 

3.1 Customers

a. Providing products and services

We use your Personal Data to provide Our products and services for you; for example, when you purchase, download, and/or use Our products and services, use Our other digital services (such as social media profiles), subscribe to Our newsletters, and participate in Our events. 

We use your Personal Data to find and suggest personalized business and career opportunities and help you find conversations worth participating in. You can also add a link to your own social media post and invite others to participate in the conversation you opened.

The Equel algorithms capture and process Personal Data and other data regarding your social connections from the accounts you have added automatically in your own secure, encrypted sandbox environment located on a cloud container or your computer, depending on your settings. Equel’s personnel do not have access to your sandbox. The algorithms generate unique, proprietary metadata that is sent to the Equel Social Graph for machine learning and algorithmic matching of new opportunities for you. Once the metadata is sent, the original raw data is automatically discarded and destroyed.

b. Managing, analyzing, and improving the customer relationship

Equel may use your Personal Data for managing, analyzing, and improving the customer relationship with you and the entity you represent. 

c. Communication with you

Equel may use your Personal Data to communicate with you, for example, to send you invitations, important alerts, and other such notices relating to Our products and services, invitations to market research, and to ask for your feedback on Our products and services. 

d. Marketing to you

Equel may contact you to enhance your experience with Equel by informing you of new products, services, or promotions Equel may offer. Equel may use your Personal Data to personalize Equel’s offering and to provide you with more relevant content. This means, for example, making recommendations and displaying customized content and advertising in Our services (such as websites, applications, and marketing e-mails) and third-party services (such as display advertisements). 

e. Managing and developing products and services

Equel may use your Personal Data to manage and develop Equel’s business operations, including its products and services. 

• Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):
• Processing is necessary for the performance of a contract to which you are party or to take steps at your request before entering into a contract.
• Processing is necessary for the legitimate interests pursued by Equel or a third party.
• You have given Consent to the processing of your Personal Data.
• Processing is necessary for compliance with a legal obligation to which Equel is subject (for example, the duty to keep the records based on the Accounting Act).

The legitimate interests of Equel or a third party referred to above may include, amongst others, the following matters:

• Right to process publicly available data for useful service while not endangering the Data Subjects’ privacy. Equel stores a minimal amount of publicly available Personal Data of people who aren’t subscribed users of Equel products and services and are thus not under the application of Our Terms of Service. This minimal Personal Data includes full name, previous and current job titles, companies or other entities, and URLs to social media profiles. This Personal Data is already part of the public domain through search engines and free accounts on social media. We do not store Personal Data that is not publicly available through other services and websites. All people in the Equel Social Graph have created a publicly available social media profile that has been indexed on search engines, so they have a reasonable expectation of this data being publicly available on the internet.
• The Equel algorithms add proprietary metadata to this publicly available Personal Data, enabling Us to provide unique value-adding services to Our Customers, including helpful recommendations and new insights. We must permanently store this data on Our servers to provide Our services.
• Right to promote the business activities of Equel by way of direct marketing and targeted digital marketing. 
• Business development and investigation of possible misuse of Our products and services. 

3.2 Potential Customers

a. Marketing to you

Equel may contact you to promote its products and services or to invite you to events. Equel may use your Personal Data to personalize its offering and provide you with more relevant content. This means, for example, making recommendations and displaying customized content and advertising in Our services (such as websites, applications, and marketing e-mails) and third-party services (such as display advertisements). 

b. Communication with you

Equel may use your Personal Data to communicate with you, for example, to ask for feedback on our prior engagement. 

Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):

• Processing is necessary for the purposes of the legitimate interests pursued by Equel or by a third party, such as the Partners.
• You have consented to processing your Personal Data.

The legitimate interests of Equel referred to above may include, amongst others, the following matters:

• right to promote the sales of Equel’s products and services by way of direct marketing for the purposes of marketing and sales; 
• customer service for potential customers; and
• business development.

3.3 Interest groups

a. Managing, analyzing, and improving the relationship

Equel may use your Personal Data for managing, analyzing, and improving the relationship with you and the entity you represent. 

b. Communication with you

Equel may use your Personal Data to communicate with you, for example, to send you news, alerts, invitations, and other such notices relating to Our relationship. 

c. Managing and developing products and services

Equel may use your Personal Data to manage and develop Equel’s business operations, including its products and services, as well as to manage and develop the business operations, products, and services of the chosen Partners. 

Processing of your Personal Data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously):

• Processing is necessary for the performance of a contract to which you are party or to take steps at your request before entering into a contract.
• Processing is necessary for the legitimate interests pursued by Equel or a third party.
• You have given consent to the processing of your Personal Data.
• Processing is necessary for compliance with a legal obligation to which the controller is subject (for example, the duty to keep the records based on the Accounting Act).

The legitimate interests of Equel, referred to above, may include, amongst others, the following matters:

• Right to promote the business activities of Equel by way of, for example, press releases, and
• business development.

In addition to the above, Equel uses your Personal Data in whichever role you are if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our agreements or this Privacy Policy.

Content of Equel’s filing system may include the following types of Personal Data and changes made to these data types: 

a. Customers

• first and last names
• username
• display name
• biography
• profile picture
• header image
• contact data (e-mail address, telephone number and/or postal address, social media account names and URLs)
• title and/or job description of current and previous jobs 
• name and business information of the entity you work for currently or previously
• gender
• data available from social media accounts (such as LinkedIn and any federated social accounts supporting ActivityPub)
• campaigns, promotions, and other communication directed to you, as well as their use, including participation in events
• interests and other information or survey data provided by you
• direct marketing choices
• information on the use of Our services as well as digital content created by you
• recordings of customer service telephone conversations as well as e-mail and chat correspondence 
• subscription and purchase history
• automatically collected data (such as IP Address, your device’s operating system, browser type, and language) and mobile device identifiers (such as your unique device ID and your device name) for debugging and diagnostic purposes
• in addition, we store unique machine-learning optimized metadata: part of this metadata is only useful for the algorithms, and some store human-readable symbols to be able to communicate to you why We recommend a person or a conversation to participate in

Public profiles of customer’s social media connections (inside the Customer’s sandbox, Equel’s personnel does not [after the beta phase] have direct access to this data):

• first and last names
• contact data (e-mail address, telephone number and/or postal address, social media account names and URLs)
• title and/or job description of current and previous jobs 
• name and business information of the entity you work for currently or previously
• data available from social media accounts (such as LinkedIn and Twitter)
• in addition, we store unique machine-learning optimized metadata: part of this metadata is only useful for the algorithms, and some store human-readable symbols to be able to communicate to the Customer why We recommend a person or a conversation to participate in

However, specifically for equel.social, we will store:

• Public and unlisted posts and how you interact with posts, including reblogging or favoring. Please also note that all are available publicly.
• Your following
• Other public information such as the date and time when a message is sent, its attachments, as well as the application you submitted the message from
• IPs and other metadata, such as the IP address when you log in and the name of your browser application. We will use IP data to aid in the moderation of the community, for example, comparing your IP address with other known ones to determine ban evasion or other violations.

Please note that on Equel.social: 

• When your followers belong to servers other than equel.social, your posts (public or for followers only) will be delivered to different servers, and copies will be stored there. While we make a good-faith effort to limit the access to those posts only to authorized persons, other servers may fail to do so. Therefore, it’s important to review the servers your followers belong to. You may manually toggle an option to approve and reject new followers in the settings. 
• When you delete posts, this will likewise be delivered to your followers.
• When you reblog or favor another post, that info is also public.
• When posting and messaging, remember that the server operators and any receiving server may view such messages and that recipients may screenshot, copy, or otherwise re-share them. 

b. Potential customers

• first and last names
• contact data (e-mail address, telephone number and/or postal address, social media account names and URLs)
• title and/or job description of current job 
• name and business information of the entity you currently work for 
• campaigns, promotions, and other communication directed to you, as well as their use, including participation in events
• direct marketing choices

c. Interest groups

• first and last names
• contact data (e-mail address, telephone number and/or postal address, social media account names and URLs)
• title and/or job description of current job 
• name and business information of the entity you currently work for
• communication directed to you, as well as their use, including participation in events

Equel gathers Personal Data directly from you, for example, from: 

• website forms, including equel.social registration process, 
• mobile applications, 
• physical forms in events, 
• telephone conversations, e-mail correspondence, chat services, and   
• other customer service communications.

Equel gathers Personal Data from publicly available search engines and websites with crawlers substantially similar to existing search engine crawlers.

Equel may gather Personal Data from the device you use to communicate with us.

Equel may obtain and update the Personal Data in its filing system from companies offering personal data services. Equel may gather Personal Data from companies’ websites, official company registers, social media, and other public sources.  

Equel may gather Personal Data from the Customer when the company’s representative gives the Personal Data of other company employees to Equel.

Equel does not sell, lease, or disclose your Personal Data to third parties unless stated below.

‍Equel shares your Personal Data with authorized third parties that perform services for Equel for the purposes described in this Privacy Policy within the limits of the applicable legislation. This may include providing services such as customer service (including chat services) and software services, managing and analyzing Personal Data, conducting market research, and planning and executing diverse campaigns. 

Equel may share your personal data to obtain payment for products and services, including transferring or selling delinquent accounts to third parties for collection. 

Equel takes the responsibility to safeguard your Personal Data seriously. Equel does not allow the above-described third parties to use your Personal Data for any purpose other than to perform those services on behalf of Equel, and Equel requires them to protect your Personal Data in a way consistent with this Privacy Policy.

Equel may share your Personal Data based on a valid order from a court or other official body with sufficient authority. 

Equel may share your Personal Data as part of any merger, acquisition, sale of company assets, or service transition to another provider. This also applies in the unlikely event of an insolvency, bankruptcy, or receivership in which your Personal Data would be transferred to another entity due to such a proceeding.

Please note that on Mastodon (whose equel.social is part), other servers in the network may download your public content. Your public and followers-only posts are delivered to the servers where your followers reside, and direct messages are delivered to the recipients’ servers when those followers or recipients reside on a different server than equel.social.

When you authorize an application to use your equel.social account, depending on the scope of permissions you approve, it may access your public profile information, your following list, your followers, your lists, all your posts, and your favorites. 

We store and process the Personal Data of your Customer user account for as long as you hold an account with Us or delete your data. Please also see section 8.3 (“Right to erasure”).

We delete all raw data captured by your algorithmic personal assistant automatically immediately after the metadata is extracted and synced to the graph. During the Equel beta phase, we will store the raw data longer for the time being as we develop Our machine-learning solutions. Once the development phase has been completed, we will switch to the above-stated immediate deletion of the raw data without delay and update this Privacy Policy accordingly. 

‍If you are a decision maker that Our crawlers have automatically added to the Equel Social Graph, We store a minimal amount of publicly available information about you, including full name, job title, company, and URLs, to social media profiles on the social graph for a longer period. Our crawlers update the graph regularly. All this information is already freely available through popular search engines and other websites. Otherwise, our crawlers wouldn’t have been able to add you.

We may process your Personal Data for accounting, tax, and/or legal purposes for as long as necessary, required, and/or justified. 

All rights can be exercised personally by contacting Equel’s privacy team using the contact details in Section 1 above. The team will then give further instructions on how to exercise a specific right. Where Equel has reasonable doubts concerning the identity of the person making the request, Equel may request additional information necessary to confirm your identity.

Equel will provide you with information on the action taken on a request within one month of receipt. That period may be extended by two further months where necessary, considering the complexity and number of the requests.

8.1 Right of access to your Personal Data

You have the right to obtain from Equel confirmation as to whether or not Personal Data concerning you are being processed, and, where that is the case, receive information about your Personal Data.

8.2 Right to rectification

You have the right to obtain from Equel without undue delay the rectification of inaccurate Personal Data concerning you. 

8.3 Right to erasure (‘right to be forgotten’)

You have the right to obtain from Equel the erasure of Personal Data concerning you without undue delay where one of the following grounds applies: 

(a) your Personal Data are no longer necessary to the purposes for which they were collected or otherwise processed;

(b) you withdraw consent on which the processing is based and where there is no other legal ground for the processing;

(c) you object to the processing, and there are no overriding legitimate grounds for the processing;

(d) your Personal Data have been unlawfully processed;

(e) your Personal Data have to be erased for compliance with a legal obligation in Union or member state law to which Equel is subject;

(f) your Personal Data have been collected in relation to the offer of information society services.

However, you do not have the right or erasure if the processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation that requires processing by Union or member state law to which Equel is subject; or

(c) for the establishment, exercise, or defense of legal claims.

‍We will delete your user account data immediately at your request unless we are required or entitled to keep the data based on the above. 

We can’t effectively remove a public profile from Our Equel Social Graph because even if we did, the crawlers would automatically re-add it to the graph from public sources like search engines. If you close your publicly available social media accounts and the links to them are removed from search engines, the data will also be automatically removed from the Equel Social Graph when Our crawlers discover a broken, non-existing link.  

8.4 Right to restriction of processing

You have the right to obtain from Equel restriction of processing where one of the following applies: 

(a) the accuracy of the Personal Data is contested by you for a period enabling Equel to verify the accuracy of the Personal Data;

(b) the processing is unlawful, and you oppose the erasure of the Personal Data and request the restriction of their use instead;

(c) Equel no longer needs the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims;

(d) you have objected to processing pending the verification of whether the legitimate grounds of Equel override those of you.

8.5 Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing Personal Data concerning you based on legitimate interests pursued by Equel or by a third party, including profiling. Equel shall no longer process the Personal Data unless Equel demonstrates compelling legitimate grounds for the processing that override your interests, rights, and freedoms for establishing, exercising, or defending legal claims. 

Where Personal Data are processed for direct marketing purposes, you have the right to object at any time to the processing of Personal Data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. 

Please be aware that you cannot opt out of receiving service messages from Equel, including but not limited to security and legal notices. Please also note that Equel products and services may include marketing material of third parties. 

8.6 Right to data portability

You have the right to receive the Personal Data concerning you, which you have provided to Equel, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller where: 

(a) the processing is based on consent or a contract; and

(b) the processing is carried out by automated means.

You may withdraw possible consent by contacting Equel’s privacy team (contact information in section 1) or using possible electronic means provided by Equel.

Equel does not, for the time being, make decisions based solely on automated processing, which could produce legal effects concerning you or similarly significantly affect you.

Our algorithms will make automated recommendations on people to connect with and conversations to participate in based on preferences you give to Us, and you decide what to do with the information.

Equel may target (and measure the performance of) ads to its websites’ and applications’ visitors and users as well as newsletters recipients based on profiling both on and off of Equel’s services, for example, through a variety of ad networks and exchanges, using the following data, whether separately or combined:

(a) data from advertising technologies on and off of Our services, like web beacons, pixels, ad tags, cookies, and device identifiers;

(b) information provided by you (e.g., contact information);

(c) data from your use of Our services (e.g., search history, clicking on an ad or product, etc.); 

(d) information from others (e.g. advertising partners and data aggregators); information inferred from data (e.g., using job titles to infer seniority or names to infer gender).

Equel has established electronic and administrative safeguards to secure the information collected. We store the Equel Social Graph and Personal Data on a secure server in Google Cloud, located in Google’s data centers in Finland and Belgium.

We only store the metadata and a minimal amount of publicly available information of your connections, such as name, job title, company, and URL to social media profile on Equel servers for longer periods, because they constitute the reference Equel Social Graph against which our algorithms compare the new metadata.

We securely store information about your targeted decision makers in encrypted form in your business account on our cloud servers. The data is matched against the Equel Social Graph to provide algorithmic suggestions and insights on building your reach and thought leadership. The decision-maker data is stored in your business account for as long as you use the app or until you delete the data.

‍We only offer aggregated insights on social activity, thought leadership, and reach for such team members under your business account who use Equel for work and have accepted Equel Terms of Service for their account. For clarity, it is against our Terms of Service to track the social media activity of your company’s employees who don’t use Equel for their work. We reserve the right to cancel your business subscription if you violate the Terms of Service.

Only appointed personnel of Equel and organizations operating by Equel’s assignment or on behalf of Equel are entitled to access our Personal Data filing systems. All persons processing the system have a personal right of use granted by Equel or its cooperation partner. Different access levels have been created based on the data a person needs according to his/her job description. Systems are protected with a firewall that prohibits unauthorized access outside of Equel.

All personnel of Equel and its subcontractors are obliged to keep the information of the Personal Data which they obtain in their work confidential. Manually processed documents containing Personal Data are protected against unauthorized access.

All data is stored and processed on Google Cloud servers in Finland and Belgium, inside the European Union. In addition, We use the OpenAI API to create insights from the conversations and Active Campaign and Google Workspace apps to communicate with you. The data shared with Active Campaign and Google is also stored and processed on cloud servers located in the European Union.

(a) Active Campaign GDPR compliance resources: https://www.activecampaign.com/legal/gdpr-updates/gdpr-overview and subprocessors: https://www.activecampaign.com/legal/subprocessors

(b) Google Workspace GDPR compliance resources: https://cloud.google.com/privacy/gdpr and subprocessors: https://workspace.google.com/terms/subprocessors.html

(c) Google Cloud GDPR compliance resources: https://cloud.google.com/privacy/gdpr and subprocessors: https://workspace.google.com/intl/en/terms/subprocessors.html

(d) OpenAI GDPR compliance resources:
https://openai.com/policies/privacy-policy and subprocessors:
https://platform.openai.com/subprocessors/openai-subprocessor-list

We may store the user information of non-EU citizens on Google Cloud servers outside the European Union, depending on the local personal data processing laws and regulations. 

Some of Equel’s services may be provided using resources and servers in various countries worldwide. Therefore, Equel may transfer your Personal Data outside the country where you use Our services, including to countries outside the EU and EEA that do not have laws providing specific protection for Personal Data or have different legal rules on data protection. In such cases, Equel ensures that a legal basis for such a transfer exists and that adequate protection for your Personal Data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

If you suspect a data protection legislation breach, please contact Equel’s privacy team first (contact information in section 1). If the matter is not solved amicably between you and Equel, you may contact the Data Protection Authority of the country where the Equel entity operates, Finland. Contact information of the competent authority can be found here: https://tietosuoja.fi/en/contact-information.

The processing of Personal Data in Equel’s filing systems is governed by the European Union’s applicable data protection legislation and the national laws of countries where Equel is established, currently Finland.

Equel may modify this Privacy Policy, and if We make material changes to it, We will provide notice on Our website, on equel.social, or by other means to provide you the opportunity to review the changes before they become effective. Your continued use of Equel’s products and services after We publish or send a notice about Our changes to this Privacy Policy means that you have become bound by the updated Privacy Policy.