Level2/Smm Invest Abs customers and potential customers

Level2/Smm Invest Abs employees and job seekers


We value your privacy

Every person values ​​their integrity, including our customers and employees. As personal data manager, we primarily process contact information for contact persons and other project persons in our customer companies as well as the personal data of our employees. The same goes for potential customers and job seekers. Personal information is any information that relates to an identified or identifiable person, such as name, email, personal identification number and photograph.


Level2/Smm Invest Abs processes personal data in connection with its customers, including potential customers, as well as its employees and job seekers in accordance with this data protection description and applicable legislation. We can update the data protection description as our business develops or the legislation changes. Therefore, please read this privacy statement from time to time to keep up to date.


As providers of marketing services, we also often act in the role of personal data assistant for our corporate and organizational customers when they act as personal data managers. For these customers, the principles for the processing of personal data are described in each customer’s data protection description or clause. Therefore, read them if necessary. The processing of the customer’s personal data is always based on a service and data protection agreement between us and the customer organization and we then process the customer’s personal data only for the benefit of the customer in question and on behalf of this customer as long as we have a valid agreement.


Personal data protection

The person responsible for personal data regarding the processing of personal data described in this data protection description is Level2/Smm Invest Abs (hereinafter also “Level2” or “we”):


Level2/Smm Invest Ab

Rådhusgatan 3

68600 Jakobstad

Email: info@level2.fi


Phone: +358 46 538 4594

Fo-no: 3258099-4


Matters relating to the Data Protection, Customer and Marketing Register are handled by Mathias Smeds and personnel matters by Mathias Smeds. Level2’s data protection representative is Mathias Smeds.


For what purposes does Level2 collect personal information and on what grounds?

We collect, store and process personal data about customers and employees for predetermined purposes. We always ensure that we have at least one legal basis for storing and processing personal data. The main uses and grounds for processing personal data are:


Provision and delivery of marketing services

We collect and process personal data to fulfill contractual obligations in connection with marketing service agreements and in connection with the delivery of services. During the customer relationship, we process personal data, primarily to implement projects, for invoicing, collection, complaints and customer response management. With regard to these measures, the bases for processing personal data are primarily to fulfill and prepare agreements and our legitimate interest.


Marketing and customer communication

We produce digital marketing, email marketing and targeted marketing content as well as advertising via social media to potential and current customers and are looking for new potential customers, so companies’ contact information is also processed for marketing and communication purposes as well as to target messages and content related to marketing. Marketing can be based on automated decision-making and customer profiles in social media advertising campaigns, search engine marketing and content on our website. With regard to these, the legal basis for the processing of personal data is mainly our legitimate interest. However, the person has the right at any time to prohibit direct marketing directed at him or her. Direct marketing can also to some extent be based on consent (eg newsletter subscription).


Development of our business operations

We may also process personal data in order to develop our business activities in connection with the provision of marketing services. In this regard, the legal basis for processing personal data is our legitimate interest.


Fulfillment of statutory obligations

We may also process personal data in order to fulfill statutory obligations (including accounting, taxation, labor contract law).


Personnel administrative tasks

Personal data relating to employees is collected and processed mainly for personnel administrative purposes, such as for fulfilling work contract obligations, for monitoring projects and time use, for payroll and taxation and for fulfilling other rights and obligations caused by the employment relationship. In the case of these, the legal basis for processing personal data is to fulfill agreements, fulfill statutory obligations in connection with the employment relationship, sometimes also the consent of the employee.


Recruitment and job seekers

When recruiting, we process personal data mainly for the preparation of agreements or with the consent of an employee candidate. Based on consent, we mainly process personal data in connection with job seekers obtained by persons other than the job seeker himself.


What personal information does Level2 collect? 

From what sources is the data obtained?

We mainly collect and process personal data only in connection with our customers’ contact and project persons, our employees and job seekers.


Customers and potential customers

We collect personal data in connection with our customers and potential customers, mainly by the individuals themselves. In the case of new potential customers, we also collect so-called. prospect information closest to LinkedIn and corporate websites. As far as potential customers are concerned, our website and the forms available on the site are a significant source of personal data. We also collect information related to the use of our site using Google Analytics and Facebook Pixel. During the customer relationship, information also arises and is collected, mainly in connection with customer companies. Information about potential customers can also be obtained from seminars organized together with partners.


We typically collect the following personal data in connection with customers:


First name


E-mail address


Address details

Work Phone

Employers’ companies, the company’s contact details and other information as well as the FO number

The contact person at Level2

Customer relationship level and / or customer relationship life cycle stage

So-called “Buyer personality” that can be linked to the person


Basis for processing personal data (agreement, consent, legitimate interest)

Level2s details (phone call / email / references / meeting)

Notes (telephone call / meeting / Level2s other information)

Call details (time of call and what was discussed)

Information about meetings (time of meeting and what was discussed)

Sales History

Email correspondence

completed forms, opening and clickthrough rate for emails, clickthrough rate for call-to-action requests, website usage information, and various activities related to usage (date, number, traffic sources)

Marketing Consent / bans


We can also get similar information when exploring from LinkedIn or potential customer companies’ websites, but of course to a much more limited extent.



In connection with employees we receive personal data mainly from the person himself and with the consent of other sources. In the case of employees, we may also deal with tasks that otherwise arise during the employment relationship.


We mainly collect and process the following information in connection with employees:



Tax deduction information

personal identity

Salary and information needed for payroll

Use and monitoring of working hours

Contact details

Information on sick leave

The Employment



In connection with job seekers we receive personal information about the job seekers from the job seekers themselves and with their consent from other sources (such as LinkedIn, references and any personal and fitness tests).


In the case of job seekers, we may in particular process the following personal data:


Names and basic contact details

Education, experience, skills and work history

Application and resume

References and recommendations (with consent)

LinkedIn profile (with consent)

Results of any suitability test (with consent)


Who processes personal data at Level2 and gives information to others?

Personal data is usually processed by persons belonging to Level2s employees in connection with the execution of tasks. Access to personnel administrative tasks is more limited than access to customer data, since a large proportion of our employees carry out customer work, while a smaller group has personnel administrative responsibilities.

We may also outsource the processing of personal data, and many systems used to store and process personal data are cloud-based services. Most of the data stored and processed is in electronic form. We use subcontractors and service providers for the processing of personal data, in particular in the following contexts: cloud storage of data, marketing automation and CRM, financial management and payroll, maintaining our website and tracking of visitors, analysis of web services, e-mail marketing and project management.

When using subcontractors and service providers, we ensure that the confidentiality of personal data is ensured and that the data is also otherwise processed legally and only on our behalf. Otherwise, we may also transfer information when required by law, court or competent authority. We may also disclose your information if we are involved in business acquisitions or business acquisitions.


Does Level2 transfer personal information outside the EU?

As a rule, personal data is not disclosed outside the EU, but since data is stored and processed primarily in electronic form and especially in cloud-based services, some of our service providers may be located in countries outside the EU. Such service providers include Google, Mailchimp and HubSpot. In this case, we ensure that the data transfer takes place using appropriate protection methods as required by law. The main options are (1) the transfer of data to a country with an adequate level of protection approved by the European Commission, (2) the transfer of data to an EU-US Privacy Shield Certified Company (recipients in the United States) or (3) use of EU model clauses.


How long does Level2 store personal data?

We do not store your personal data for longer than necessary in view of the purpose of the information or what is required by agreement or law. The period during which personal data is stored may vary by use, legal basis and situation. Personal data can also be deleted when a person withdraws their consent or requests to have their data deleted (and Smm Invest Ab has no other legal basis for processing), the contractual relationship terminates or when the information is outdated or incorrect. The data retention times can also be governed by legislation (eg accounting, taxation, the labor contract law) and deadlines in connection with the presentation of legal requirements (eg times for bringing proceedings). We also strive to update and delete unnecessary, incorrect or outdated information annually.


How does Level2 store and protect personal information?

Personal data is stored almost exclusively in electronic form and the data has been protected in accordance with general standards in the industry. We select reputable service providers for storing and processing the data. We treat the information confidentially and we do not disclose information in general or sell or rent information for marketing purposes. Our premises are also well protected and locked.


Is it mandatory to provide information? What happens if you do not give your information?

Most of the personal data is provided on a voluntary basis. This applies especially to personal data about potential customers and job seekers. However, the provision and processing of personal data in order to fulfill an agreement in a customer relationship is, to some extent, mandatory in order to ensure that the persons who enter into agreements on behalf of our corporate customers have the powers and are competent and that we can fulfill our contractual obligations and at the same time ensure that our own rights are fulfilled. Of potential customers, we generally request on our website information about email address and other information we need for contact. In an employment relationship, we also need personal information in order to fulfill our obligations in connection with the execution of the employment contract and the law.


Does Level2 use cookies on their website and what are they?

We use cookies on our website to provide the best possible user experience for the site’s visitors. Cookies are short text files that the web server stores in the user’s terminal. They give us information on how users use our site. We may use cookies to develop our services and our website, to analyze the use of the website and to target and optimize marketing. The site’s users can allow or block the use of cookies in the browser’s settings. Most browsers allow cookies automatically. Please note that blocking cookies may restrict access to features on our website.


What rights and influence do you have regarding your personal data?

Withdrawal of consent

If we process your information on the basis of your consent, you can revoke your consent at any time by notifying us of the matter, e.g. via email at info@level2.fi.


Access to data and request for data verification

You have the right to receive confirmation from us whether we process personal data about you and to know what personal data concerns you that we process. In addition, you have the right to receive supplementary information on the grounds for the processing of your personal data.


Right to get incorrect information corrected

You have the right to request that we correct incorrect or outdated or otherwise incomplete personal information about you.


Right to prohibit direct marketing

Although we would not process your personal data for direct marketing purposes with the support of consent, you can prohibit direct marketing at any time by sending an email to info@level2.fi.


Right to object

If we process your personal data on the basis of public interest or our legitimate interest, you have the right to object to the processing of your personal data to the extent that there is no such significant cause that weighs more than your rights or the processing is not necessary for the processing of a legal claim. Note that in this situation, we will probably no longer be able to serve you.


Right to restrict treatment

In some situations, you have the right to demand that we limit the processing of your personal data.


Right to data portability

If we have processed your information with the support of your consent or to execute an agreement, you have the right to receive the information you have provided to us electronically in a commonly used format, so that the information can be transferred to another service provider.


How can you exercise your rights?

You can exercise your rights described above by contacting us eg by e-mail at info@level2.fi or by contacting our company via the contact details below. At the same time, we ask you to confirm your identity, e.g. with a self-signed request for verification of data or a copy of your credentials (however, cover your personal identification number and other information that we do not need). If you believe that the processing of your personal data is in violation of law, you may also file a complaint with the competent supervisory authority (Data Ombudsman).


Can this privacy statement be updated?

We may update this privacy statement as our business or personal data processing principles change. Updates may also be applicable in case of changes in legislation. The changes will take effect after we publish the updated data protection description. We therefore ask that you regularly consult the contents of this privacy statement.


Who can you contact in data protection matters?

Level2/Smm Invest Ab

Rådhusgatan 3

68600 Jakobstad

Email: info@level2.fi


Phone: +358 46 538 4594

Fo-no: 3258099-4


Matters relating to the Data Protection, Customer and Marketing Register are handled by Mathias Smeds and personnel matters by Mathias Smeds. Level2’s data protection representative is Mathias Smeds.