Privacy policy — contact form (draft)
Draft
This is a draft for legal review before publication. Items in square brackets are placeholders, not the company’s registered details.
The notice covers only the contact form on polarcurve.fi. It is not a full customer or employee privacy policy.
Controller
Polar Curve Oy (“Polar Curve”, “we”) is the controller for personal data sent through the contact form on polarcurve.fi.
Business ID (Y-tunnus): 2221464-0
Postal address: Osmalahdenmutka 3, 21570 Sauvo, Finland
Privacy contact: Tommi Nieminen, tommi.nieminen@polarcurve.fi
Whose data, and what we collect
If you submit the form we process the details you enter: name, company, email address, phone number (if you provide one), area of interest (if you choose one), message, and the language of the form. You decide what to write in the message. Please do not send sensitive data (for example health information) unless we have asked for it.
Technical data used only to protect the form: a session cookie that holds a security token so the form works without JavaScript, and a short-lived rate-limit record (a hash of your IP address and timestamps) in a file that is not published as a page. We do not keep a database of inquiries.
Purpose
We use the form data to read and reply to your inquiry, including questions about maritime safety equipment, waterway maintenance, and Geoforce asset tracking. The correspondence stays in the recipients’ mailboxes. The security data is used to reduce spam and abuse.
Legal basis
Draft basis, to be confirmed by counsel: where your message is a request for steps before a contract, the basis is those pre-contractual steps at your request (GDPR Article 6(1)(b)). Otherwise we rely on our legitimate interest in handling business inquiries and protecting the form from abuse (Article 6(1)(f)). This form is not used to build a marketing list. The consent checkbox records that you have read this notice; it is not the legal basis for the processing.
Retention
The website does not store your message in a database. The message exists as email in the mailboxes of the recipients named below. Inquiry emails are kept for 12 months and then deleted.
Rate-limit files are removed automatically after the rate-limit window (default 15 minutes). The session cookie ends when the session ends.
Recipients
Messages are emailed to Tommi Nieminen, tommi.nieminen@polarcurve.fi, and Jan Komaro, jan.komaro@polarcurve.fi.
The website is hosted at Domainkeskus (domainkeskus.fi). The message is sent from tommi.nieminen@polarcurve.fi. That sending address is one setting in the server config and can be changed without editing the form. [PLACEHOLDER: any other processors, once confirmed.] We do not sell personal data.
Transfers
[PLACEHOLDER: confirm whether Domainkeskus or any other processor stores this website or mailbox outside the EU/EEA. Their public pages list offices in Turku and Tampere and a data-centre services phone line, and do not say where this subscription is stored.]
Your rights
You can ask for access, rectification, erasure, and restriction, and you can object where we rely on legitimate interests. Where processing is based on consent (this form does not use consent as its basis), you may withdraw it. You can lodge a complaint with the Office of the Data Protection Ombudsman (Tietosuojavaltuutettu), tietosuoja.fi.
Contact
Privacy contact: Tommi Nieminen, tommi.nieminen@polarcurve.fi. You can also write to Polar Curve Oy at the address above, or reach Jan Komaro using the contact details on this website.
Changes
Last updated: 24 September 2026.