01

Data Controller

The data controller for this website and the Struxiva service is Struxiva Oy (business ID / Y-tunnus pending registration), Helsinki, Finland. Contact for all data-protection matters: info@struxiva.com.

02

Data We Collect

We collect only data that is necessary to operate the service or that you voluntarily provide.

Contact & enquiry data

Building & operational data (pilot customers)

Technical & analytics data

03

Legal Basis for Processing

Processing is based on one or more of the following grounds under GDPR Article 6 and the Finnish Data Protection Act (tietosuojalaki 1050/2018):

04

Finnish Social Security Numbers (Henkilötunnus)

Current status: Struxiva does not currently collect or process Finnish Social Security numbers (henkilötunnus / HETU) for any purpose, including credit assessment.

If Struxiva were to extend its service to include credit checks or identity verification for property transactions (e.g., tenant screening or buyer verification), the processing of henkilötunnus would be governed by the following framework:

Legal framework

Under Section 29 of the Finnish Data Protection Act (1050/2018), the processing of a henkilötunnus is permitted only when: (a) the data subject has consented; (b) processing is necessary for performing a task assigned by law; (c) the processing is necessary to reliably identify the data subject when it is important for the performance of a contract; or (d) processing is based on another specific legal provision.

Credit assessment basis

If SSN processing is introduced for credit or identity purposes, the legal basis will be contract performance (GDPR Art. 6(1)(b)) and Section 29(1)(3) of the Finnish DPA 1050/2018 — the necessity to reliably identify a party to a transaction.

We will obtain explicit consent before any such processing begins, provide a dedicated privacy notice at point of collection, and limit processing to the minimum necessary for the stated purpose.

Safeguards

We will update this policy and notify existing users before any SSN processing is introduced.

05

Cookies & Tracking

We follow Traficom's guidelines on cookie consent, which require that "Reject all" is presented with the same ease and prominence as "Accept all." No pre-ticked boxes, no dark patterns, no additional clicks required to reject.

Strictly necessary (no consent required)

Analytics (consent required)

You can withdraw cookie consent at any time by clearing your browser's local storage or by clicking "Reject all" in the cookie banner (reachable by refreshing the page after clearing the struxiva_cookie_consent key).

06

Data Transfers & Processors

We use a limited number of sub-processors. All processors are bound by GDPR-compliant data processing agreements (DPA).

No personal data is transferred outside the European Economic Area (EEA) without adequate safeguards (Standard Contractual Clauses or adequacy decision).

07

Retention Periods

08

Your Rights

Under the GDPR and the Finnish Data Protection Act (1050/2018) you have the following rights. We respond to all requests within 30 days.

You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi).

To exercise any right, email info@struxiva.com with the subject line "Data Subject Request."

09

Security

10

Contact & Data Protection Officer

Struxiva Oy does not currently have a mandatory Data Protection Officer (DPO) under GDPR Art. 37, as we are not a public authority and do not carry out large-scale systematic monitoring of individuals. Data protection responsibilities are held by the co-founding team.

For all data-protection enquiries, requests, or complaints:
Email: info@struxiva.com
Post: Struxiva Oy, Helsinki, Finland

We may update this policy to reflect changes in law or our practices. Material changes will be communicated by posting a notice on this page with an updated date. Continued use of the service after such notice constitutes acceptance.