Waitlist Privacy Notice
1. Controller
Optima Systems Oy (Business ID 3347527-2) is the controller for waitlist personal data. Its address is Yliopistonkatu 14 A 18, 40100 Jyväskylä, Finland. The privacy contact is contact@sulo.app.
2. Data we process
We process the email address you provide and the request language and source. We also store request, confirmation, invitation, and withdrawal times and states, a consent ID, and the versions of the consent text and privacy notice in use.
Confirmation and withdrawal link values are stored only as hashes. Security and delivery logs can contain technical event data, but we do not write the email address to application logs.
3. Purpose and legal basis
We use the data to send one operational confirmation email and, after confirmation, one personal invitation when Sulo access is available. Sending the invitation is based on your consent.
After withdrawal, we keep minimum proof that consent was withdrawn. The legal basis is the legitimate interest of Optima Systems Oy in proving consent status and preventing messages after withdrawal.
4. Providing the data
You need to provide an email address only if you want to join the waitlist. Without it, we cannot send the confirmation or invitation. Joining does not create a duty to buy Sulo.
5. Service providers and transfers
Amazon Web Services processes waitlist data for Optima Systems Oy. The main database and service functions use the AWS Stockholm Region (eu-north-1). Amazon SES delivers the email messages.
AWS support and subprocessor operations can involve processing outside the European Economic Area.
6. Retention
An unconfirmed request is deleted seven days after the first request. A confirmation link expires after 24 hours. A confirmed record is deleted no later than 12 months after confirmation unless new consent is obtained.
After an invitation is sent, the active waitlist record is deleted within 30 days. Minimum withdrawal proof is kept for 12 months. Service logs are kept for one month. AWS recovery data can remain for up to 35 days.
7. Your rights
You can withdraw consent at any time with the withdrawal link. Withdrawal does not affect processing that was lawful before withdrawal.
- ask for access to and a copy of your data
- ask us to correct inaccurate data
- ask us to erase data or restrict processing when the law applies
- object to processing based on legitimate interests
- receive data you provided by consent in a portable form when the law applies
8. Complaints and contact
You can contact us at contact@sulo.app. You can also complain to the competent supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman.
9. Automated decisions and changes
The waitlist does not use automated decisions or profiling. If processing changes, we will update the version and effective date. We will not extend this email consent to newsletters, partner marketing, SMS, or another purpose.