Data controller
Ilmari Salmisto (sole trader), PolkuAI
Business ID: 3578199-4
Karkkila, Finland
Email: info.polkuai@gmail.com
If you have questions about privacy, send a message. I usually reply the same day.
What data I collect and where it comes from
For enquiries, bookings and the chat I only collect what you give me yourself. For direct marketing to business decision-makers I also use work contact details compiled from public sources and B2B contact databases. That is described in its own section below.
- Contact form. First name, last name, email address, company name and the message itself. These are needed so I can reply to you.
- Booking. When you book a discovery call from the calendar, the booking service collects your name, email and the chosen time. The calendar is Cal.com.
- Chat assistant. The chat on this site is an AI, not a person. It produces answers automatically with a language model and it can be wrong. The message you write is sent to my own server to produce a reply. Please do not write sensitive information in the chat. I read the conversations myself afterwards and answer important questions personally if you have left your contact details.
- Server logs. The web server records technical data such as IP address and browser type. This is ordinary web server behaviour and necessary for security.
Direct marketing to business decision-makers
I send targeted sales emails to decision-makers at Finnish companies, such as CEOs and founders, at their work email addresses. Here I use data you did not give me yourself, so it deserves its own explanation.
- What data. Name, work email address, job title, company name and industry, and information the company has published about its services on its own website.
- Where it comes from. Company websites, public registers (for example the Finnish Business Information System), publicly available professional profiles and B2B contact databases (for example Apollo.io). I do not collect data about private life and I do not use private email addresses.
- Why it is allowed. The legal basis is legitimate interest (GDPR Article 6(1)(f)). The messages concern the recipient's work responsibilities and are sent only to role-related work addresses, as permitted by the Finnish Act on Electronic Communications Services. You can object at any time, free of charge.
- How to opt out. Reply to the message with as little as "no thanks", or email info.polkuai@gmail.com. I remove you immediately and your address stays on a suppression list so you are not contacted again.
- How long. Contact details are kept for at most 12 months after the last message, unless the conversation leads to a client relationship. The suppression list is kept permanently, because that is the only way to make sure an opt-out holds.
- Tools. Messages are sent through Smartlead from my own mailboxes (Google Workspace). Addresses are verified before sending.
The sender is always clearly identified: Ilmari Salmisto, PolkuAI. These messages use no open or click tracking.
What the data is used for
- Replying to enquiries and arranging a discovery call.
- Preparing a proposal and running the client relationship.
- Keeping the site working and secure.
- Direct marketing to business decision-makers by email (see the section above).
I do not use the data for profiling or automated decision making. I do not sell or rent data to anyone.
Use of AI on this site
Saying this plainly, because it should be said: the chat assistant on this site is an AI, not a person. It says so itself as soon as you open a conversation. The answers are produced by a language model, so they can be inaccurate or wrong. Do not make decisions based on a chat answer alone.
The EU AI Act requires that people are clearly informed when they are interacting with an AI system. This page and the chat's own opening message meet that obligation.
In addition:
- The AI does not make decisions about you and does not profile you.
- The chat does not give binding offers or prices. Those always come from me.
- Every message that goes to a client is reviewed by a human before it is sent.
- You can always skip the chat and contact me directly by email.
Legal basis
For enquiries and bookings the basis is preparation of a contract and legitimate interest: if you get in touch, there has to be a way to answer you. For server logs the basis is legitimate interest, meaning the technical operation and security of the service. For direct marketing to business decision-makers the basis is legitimate interest, and you can object at any time.
How long data is kept
- Enquiries that do not lead to a client relationship: up to 24 months.
- Client data: for the duration of the relationship and afterwards as accounting law requires.
- Server logs: according to the hosting provider's normal log practice.
- Direct marketing contact details: at most 12 months after the last message. Suppression list: permanently.
You can ask for earlier deletion if no statutory retention duty prevents it.
Who the data is shared with
I do not pass data to outsiders for marketing. I use the following providers to deliver the service, and they process data on my behalf:
- Cal.com: booking calendar.
- Hostinger: website hosting and the chat assistant backend.
- Google: the email account that receives enquiries, and the mailboxes used for direct marketing.
- Smartlead: sending direct marketing emails and handling replies.
Some providers may process data outside the EU and EEA. Such transfers rely on the European Commission standard contractual clauses or an equivalent lawful transfer mechanism.
Cookies
The site does not use marketing tracking cookies. Visitor measurement is built so that no identifying cookies are stored without consent. The booking calendar and the chat assistant may store data in your browser that is strictly necessary for them to work.
Your rights
You have the right to
- see what data is stored about you,
- ask for incorrect data to be corrected,
- ask for your data to be deleted,
- object to processing or ask for it to be restricted,
- receive the data you provided in a portable format,
- lodge a complaint with the supervisory authority.
Send requests by email to info.polkuai@gmail.com. I respond within one month. The Finnish supervisory authority is the Office of the Data Protection Ombudsman, tietosuoja.fi.
Security
The site runs over an encrypted connection. Access to enquiries and client data is limited to me. Processing terms are in place with the providers listed above.
Changes to this policy
If the services or the tools in use change, I update this page. The update date is shown at the top.