Last updated: 21 October 2026
1. Who we are
1.1 This Privacy Policy explains how Simmer Oy (“Simmer”, “we”, “us”) handles personal data when you read the Technical Marketing Handbook at handbook.teamsimmer.com, take its quizzes, claim its certificate, give feedback on a page or subscribe to our newsletter there (together, the “Handbook”).
1.2 Simmer Oy is the controller of your personal data under the EU General Data Protection Regulation (“GDPR”) and the Finnish Data Protection Act (1050/2018). Our details:
- Simmer Oy, Business ID 3176548-7
- Kauppalantie 17, 00320 Helsinki, Finland
- Email for privacy questions and requests: info@teamsimmer.com
1.3 We have not appointed a data protection officer, because the law does not require one for a business of our size and type. Send any privacy question to the email address above.
1.4 The Handbook is free and has no accounts, logins or purchases. Our courses, community and online store at www.teamsimmer.com are covered by the Simmer Privacy Policy. This includes the contact form that the Handbook’s “Contact Us” link leads to.
2. What personal data we collect
2.1 Data you give us.
- Certificate: the name you type when you claim your certificate. It is printed on the certificate image, which is saved on our server so you can download it.
- Quiz answers: your answers and score in Test Your Knowledge. We do not ask for your name or email to take a quiz, and we do not store your IP address with your answers.
- Page feedback: your “Was this helpful?” vote and any comment you choose to write. We do not store your IP address with them.
- Newsletter: your email address.
2.2 Data created when you use the Handbook.
- Reading progress: which topics you have visited, kept only in your own browser (see section 4). We use it to unlock the certificate. It never reaches us.
- Technical data: IP address, browser and device type, pages visited and the time of visit, recorded in our server and security logs.
- Analytics data, only if you consent: see section 4.
2.3 What you must give us. Nothing. You can read the whole Handbook without giving us any data. A certificate needs a name, and the newsletter needs an email address.
2.4 Sensitive data. We do not ask for special categories of data such as health, religion or political opinions. Please do not write them in feedback comments.
3. Why we use your data, on what legal basis, and for how long
3.1 We use each type of data only for the purposes below. The legal basis is the GDPR article that allows each use. When the period ends, we delete or anonymise the data.
| Purpose | Data | Legal basis | How long we keep it |
|---|---|---|---|
| Create your certificate and let you download it | Certificate | Contract: giving you the certificate you ask for (Art. 6(1)(b)) | As long as the Handbook offers certificates, so your download link keeps working, or until you ask us to delete it |
| Show your quiz results and improve the quizzes | Quiz answers | Legitimate interest in seeing which questions are too hard or unclear (Art. 6(1)(f)) | 24 months |
| Improve the Handbook’s content | Page feedback | Legitimate interest in knowing which pages help readers (Art. 6(1)(f)) | 24 months |
| Send the newsletter | Newsletter | Consent (Art. 6(1)(a)) | Until you unsubscribe. We then keep your email address on a do-not-email list |
| Measure and improve the Handbook with analytics | Analytics data | Consent (Art. 6(1)(a)) and section 205 of the Finnish Act on Electronic Communications Services (917/2014) | See section 4 |
| Keep the Handbook available and secure | Technical data | Legitimate interest in protecting the Handbook and its readers (Art. 6(1)(f)) | Server and security logs: up to 12 months |
| Establish, exercise or defend legal claims | Any data relevant to the claim | Legitimate interest (Art. 6(1)(f)) | Until the claim is resolved |
3.2 Where we rely on legitimate interests, we have weighed them against your rights. You may ask us for that assessment and object at any time (section 8).
3.3 We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
4. Cookies and analytics
4.1 We use cookies and similar technologies, such as local storage. Necessary ones run without consent, because the Handbook, or a feature you ask for, cannot work without them. Analytics runs only if you allow it in the cookie banner. Declining has no effect on what you can read or do in the Handbook.
| Name | Provider | Purpose | Type | Lifetime |
|---|---|---|---|---|
| klaro (local storage) | Simmer | Remember your cookie choices | Necessary | Until you clear it |
| visitedItems, lastCertificateGenerationTime (local storage) | Simmer | Track which topics you have read, to unlock your certificate | Necessary | Until you clear it |
| __cf_bm | Cloudflare | Tell people from bots and protect the Handbook from attacks | Necessary | 30 minutes |
| _pk_id.*, _pk_ses.* | Simmer (Matomo) | Matomo: count visits and measure how the Handbook is used | Analytics (consent) | 13 months / 30 minutes |
4.2 How analytics works here. We use Matomo, an open-source analytics tool that we run on our own server, the same one that hosts the Handbook. Analytics data is not sent to Google or any other analytics company, and we do not use it for advertising. Matomo shortens your IP address before storing it, so it cannot be traced back to your connection. We use the reports to see which chapters people read, not to identify you. Matomo deletes the detailed visit data after 180 days. After that we keep only the summary reports, such as page views per chapter, which contain no personal data.
4.3 Tag management. Matomo is loaded through Google Tag Manager. When a page loads, your browser fetches the Tag Manager script from Google, so Google receives your IP address and browser details, as with any file downloaded from Google. Tag Manager does not set cookies, and the Matomo tag inside it runs only after you consent.
4.4 Changing your choice. You can change or withdraw your consent at any time through Consent Settings (a link in the footer that opens the cookie banner). Withdrawing does not affect analytics collected before you withdrew. You can also block or delete cookies and local storage in your browser. If you delete local storage, your reading progress is lost.
5. Newsletter
5.1 We send the newsletter only if you subscribe with the form at the bottom of each Handbook page. We use Kit (formerly ConvertKit) to send it. Kit records whether you open emails and click links, so we can see which topics interest readers.
5.2 You can unsubscribe at any time through the link in every newsletter, or by emailing info@teamsimmer.com.
5.3 We do not sell, rent or share your email address with anyone for their own marketing.
6. Who we share your data with
6.1 Service providers (processors). These companies process data on our behalf, under a data processing agreement, and only on our instructions.
| Provider | What they do for us | Location of processing |
|---|---|---|
| Kinsta | Hosts the Handbook, including Matomo and saved certificates | Kinsta is based in the US |
| Cloudflare | Security and delivery for the Handbook, and serves some of its scripts | Global |
| Google (Tag Manager and Workspace) | Delivers the Tag Manager script, and our email if you write to us | EU and US |
| Kit | Newsletter | US |
6.2 Other people. We also share data in these cases:
- Anyone with the link to your certificate: the certificate’s web address is not listed anywhere, but anyone you share it with can open it.
- Authorities: when the law requires it, for example a court order.
- Advisers: lawyers and auditors, under a duty of confidentiality, when needed to protect our legal rights.
- A buyer of our business: if Simmer is sold or merged, your data passes to the new owner, who must keep honouring this policy. We will tell you before that happens, where we can reach you.
6.3 We do not sell your personal data, and we do not share it with anyone for their own advertising.
7. Transfers outside the EU and EEA
7.1 Some of our providers in section 6 process data in the United States or other countries outside the EU and EEA. We transfer data only when one of these safeguards applies:
- An adequacy decision. For US companies certified under the EU-US Data Privacy Framework, the European Commission has decided that protection is adequate. This currently covers Google and Cloudflare.
- Standard Contractual Clauses. For other transfers, we use the clauses approved by the European Commission, with extra measures where needed.
7.2 You can ask us for a copy of the safeguards that apply to a transfer by emailing info@teamsimmer.com.
8. Your rights
8.1 Under the GDPR you have these rights:
- Access: get confirmation of whether we process your data, and a copy of it.
- Rectification: have inaccurate or incomplete data corrected, for example a misspelt name on your certificate.
- Erasure: have your data deleted when we no longer need it, when you withdraw consent, or when you successfully object.
- Restriction: have us stop using your data, except for storage, while a dispute about it is resolved.
- Portability: get the data you gave us, which we process by contract or consent, in a machine-readable format, or have it sent to another company.
- Objection: object to processing based on legitimate interests, on grounds relating to your situation. You can object to direct marketing at any time, without giving a reason, and we will stop.
- Withdraw consent: at any time, for the newsletter and analytics. This does not affect processing before you withdrew.
8.2 How to use your rights. Email info@teamsimmer.com. Because the Handbook has no accounts, we may need something that links you to the data, such as the name on your certificate, its download link, or the email address you subscribed with. Quiz answers, feedback and analytics are not linked to your name, so we usually cannot find which ones are yours. We reply within one month. For complex or numerous requests we may extend this by up to two more months, and we will tell you why within the first month. Using your rights is free, unless a request is clearly unfounded or excessive.
8.3 Complaints. If you think we handle your data unlawfully, please contact us first so we can try to fix it. You also have the right to complain to a supervisory authority, in particular in the EU country where you live or work. In Finland this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), PO Box 800, 00531 Helsinki, tietosuoja@om.fi.
9. Security, children and changes
9.1 Security. We protect your data with encrypted connections (HTTPS), access limited to the people who need it, two-factor authentication on our admin accounts, and regular software updates. No system is completely secure. If a breach is likely to put your rights at high risk, we will tell you without undue delay, where we can reach you.
9.2 Children. The Handbook is free for anyone to read, but its quizzes, certificate, feedback and newsletter are meant for people aged 16 or over. We do not knowingly collect data from children. If you believe a child has given us personal data, email info@teamsimmer.com and we will delete it.
9.3 Links to other sites. The Handbook links to sites and tools we do not control, such as our social media profiles. Their own privacy policies apply.
9.4 Changes. We update this policy when the Handbook or the law change. The date at the top shows the latest version. If a change significantly affects how we use your data, we will say so on the Handbook before it takes effect. Where a change needs your consent, we will ask for it.
9.5 Contact. Simmer Oy, Kauppalantie 17, 00320 Helsinki, Finland. Email: info@teamsimmer.com.