Privacy Policy

Argyon Oy
Business ID (Y-tunnus): 3500925-9
Konepajankuja 1, 00510 Helsinki, Finland
office@argyon.com

We have not appointed a data protection officer, as the nature and scale of our processing does not require one. All privacy enquiries can be directed to the address above.

Contact form and direct email. When you contact us through the website form or by email, we process your name, email address, company (if provided), and the content of your message. We use this to respond to your enquiry, to assess and prepare a potential advisory engagement, and to maintain our correspondence with you. The legal basis is taking steps at your request prior to entering into a contract (GDPR Article 6(1)(b)) and, where the enquiry does not lead to an engagement, our legitimate interest in responding to business enquiries directed at us (Article 6(1)(f)).

Field Notes subscription. When you subscribe to our Field Notes newsletter, we process your email address in order to send you the publication, four times a year. The legal basis is your consent (Article 6(1)(a)). You can withdraw consent at any time using the unsubscribe link in every issue or by emailing us; withdrawal does not affect the lawfulness of processing carried out before it.

Client and engagement data. If you become a client, we process the contact and engagement information necessary to perform the advisory agreement (Article 6(1)(b)) and to comply with legal obligations that apply to us, such as accounting requirements under the Finnish Accounting Act (Article 6(1)(c)).

Technical log data. Our hosting provider maintains standard server logs (such as IP address, timestamp, and requested page) for the purpose of operating the website securely and diagnosing faults. The legal basis is our legitimate interest in the security and availability of the website (Article 6(1)(f)). Log data is not used to identify visitors and is not combined with any other data.

We do not collect any personal data beyond the above, and we never purchase, sell, or trade personal data.

This website does not set cookies and does not use analytics, advertising, or social media tracking technologies. This is why you do not see a cookie banner: there is nothing to consent to.

We use Google Search Console to monitor how the website appears in Google search results. Search Console provides us only aggregated, anonymous statistics generated by Google from its own search data. It does not involve placing anything on your device and does not give us access to any personal data about visitors.

Personal data is processed only by Argyon's partners. We use a small number of service providers as data processors, strictly for the purposes described above:

• Lovable Labs Incorporated — website hosting and technical server logs
• Google Workspace (Google Ireland Ltd) — email, document management, and delivery of the Field Notes newsletter

Each processor acts under a data processing agreement and may not use the data for its own purposes. We do not disclose personal data to other third parties, except where required by law or by a competent authority.

Our service providers primarily process data within the EU/EEA. Where a provider (or its subprocessors) processes data in the United States, transfers are safeguarded under the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses, as applicable.

• Enquiries that do not lead to an engagement: up to 24 months after our last correspondence, after which the data is deleted.
• Client and engagement data: for the duration of the engagement and thereafter as long as required by law — for example, accounting material for six years from the end of the financial year under the Finnish Accounting Act — or as needed to establish, exercise, or defend legal claims.
• Field Notes subscriptions: until you unsubscribe, after which your email address is removed from the mailing list.
• Server logs: retained by the hosting provider for a short, rolling period for security purposes.

Under the GDPR you have the right to:

• access the personal data we hold about you and receive a copy of it;
• have inaccurate data corrected and incomplete data completed;
• have your data erased, where the conditions of Article 17 are met;
• restrict processing and object to processing based on legitimate interest;
• receive the data you have provided to us in a machine-readable format (data portability), where processing is based on consent or contract;
• withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, email office@argyon.com. We will respond within one month.

If you consider that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the supervisory authority. In Finland this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), www.tietosuoja.fi.

We do not use personal data for automated decision-making or profiling.

We may update this policy from time to time, for example if our service providers or processing activities change. The current version is always available on this page, with the date of the latest revision shown at the top.