Privacy notice.

1. Data controller

Poggers Oy (Finnish Business ID 3171525-2) is the data controller for personal data processed in connection with samuli.info and commercial enquiries resulting from the site.

Privacy enquiries: [email protected].

2. Purposes and legal bases

Data is processed to deliver and protect the site, understand its use, and respond to enquiries.

• Website delivery, security, and aggregate usage statistics are based on our legitimate interest in maintaining a secure and functional company and portfolio website.
• Requests for quotations or engagements are processed as steps taken at your request before entering into a contract. Other enquiries are processed on the basis of our legitimate interests.

3. Data we process

The site has no contact form or user accounts. The following data may nevertheless be processed when the service is used or you contact us directly:

• Technical request data such as the IP address, time, requested URL, referring page, and basic browser and device information.
• Your name, contact details, message, and subsequent correspondence if you contact us by email or phone.
• Aggregate traffic, performance, and security statistics that are not intended to identify an individual visitor.

4. Service providers and recipients

We use the following service providers to operate the site and communications:

• Amazon Web Services (AWS) for website hosting and content delivery.
• Cloudflare for DNS, traffic proxying, security, email-address protection, and aggregate traffic and performance statistics.
• Google for providing email services.

5. Analytics and cookies

Cloudflare may produce aggregate page-view, performance, and security statistics from the traffic it handles. The site does not set analytics or marketing cookies or store analytics data in localStorage.

Cloudflare browser-based Web Analytics, or RUM, is configured to exclude visitors in the EU. Outside the EU, it may process page-specific performance data from browser Performance APIs. According to Cloudflare, the measurement does not use browser storage, track visitors across sites, or retain the source IP address in analytics databases.

Cloudflare may set strictly necessary security cookies only when required by site protection or a separate verification step.

6. Processing outside the EU and EEA

The service providers operate globally, so data may be processed outside the EU or EEA. Transfers rely on an applicable legal transfer mechanism, such as a European Commission adequacy decision or Standard Contractual Clauses, together with any necessary supplementary safeguards.

7. Retention periods

Technical log and analytics data is retained under the service providers’ settings and terms only for as long as required for service delivery, security, or aggregate statistics. Enquiries are retained for no more than 24 months after the last active communication unless longer retention is required for a client relationship, legal claim, or statutory obligation.

8. Your rights

Under applicable data protection law, you may request access to, correction of, or erasure of your data, restriction of processing, or object to processing based on legitimate interests. You may also lodge a complaint with the competent supervisory authority; in Finland, this is the Office of the Data Protection Ombudsman.

Send privacy requests to [email protected].