Privaatsusteade

The controller for the purposes described in this notice is Aivomaa Oy (business ID 3592993-6), Kankarepolku 5F B335, 00770 Helsinki, Finland. For data protection matters: admin@rahtis.eu.

This notice concerns representatives of companies, users of the service, drivers and the contact persons of transports. Data concerning a legal person is not necessarily personal data, but data concerning its employees and self-employed operators is protected in accordance with applicable law.

Shippers and carriers may themselves determine the purposes of processing the data of their own employees and contacts. Their obligations do not replace those of Aivomaa Oy. In a carrier's own jobs (section 2.14), the carrier is the controller of the data of its customer and the transport's contact persons, and Aivomaa Oy processes that data on the carrier's behalf in accordance with section 16.5 of the carrier agreement; requests concerning that data are directed to the carrier, and Aivomaa Oy forwards to it the requests it receives.

Company and settlement data: name, business ID, VAT number, addresses, billing details, bank account, e-invoicing address, payment data, and the record of accepted terms with their version and time of acceptance.

User data: name, email address, telephone number, role and the company the user acts for. Driver data: name, telephone number, email address, languages used, the vehicle the driver is linked to and the history of those links, and the link to a job. The telephone number is the driver's identifier in the service and in the driver app. This data is entered by the carrier.

Transport data: stop addresses and coordinates, schedules, cargo details, the contact details of the sender and the consignee at the stops, the naming of the performer, and the stages and change log of the order with authors and times.

Driver position points: when the driver arrives at a stop, takes a loading, unloading, damage or consignment note photo, or marks a stop as passed, the browser may provide the device's location. One point is stored for each such moment; for the stop confirmation its accuracy in metres is stored as well. Likewise, one point is stored when a work shift starts and when it ends. This is not continuous tracking: the location is neither requested nor stored at any other time, and if the browser does not provide it, the action is carried out without coordinates. The arrival, photo and confirmation positions are visible to the shipper of that order in the service and through the interface, and to the operator; they show where and when the work was done, for example to settle waiting time or damage. Shift positions are visible to the driver, the driver's carrier and the operator. From the confirmation position and the address of the next stop, an estimated time of arrival at the next stop is calculated with the routing supplier (section 5.2), taking traffic into account; the estimate is visible to the shipper, the carrier and the operator. Showing the position points to the shipper is based on the legitimate interest of the shipper and Aivomaa Oy in demonstrating the performance of the transport and settling waiting time and damage (Article 6(1)(f) of the General Data Protection Regulation). Points exist only for the confirmation moments, and they cannot be used to follow the driver continuously. The carrier informs its drivers of the position points before they start using the app, and the driver may object to the processing in accordance with section 9.

Documents and materials: consignment notes, loading, unloading and damage photographs, signatures, company licences and insurance certificates, and other evidence attached to the order. Such material may contain contact persons' details, vehicle registrations and images of people.

Technical data: sign-ins, status changes, messages sent and their delivery state, incident records, and the data used to limit abuse of sign-in. The service uses no marketing cookies. Site analytics is used only with the visitor's consent as described in section 2.15; without consent a visitor who is not signed in is given no cookie at all and no identifier is stored in the browser, signing in sets a session cookie, and switching language sets a cookie that remembers the choice.

Working time data: the start and end of shifts, breaks, the vehicle used, odometer readings, notes and the change log of these entries with authors and times. They are recorded by the carrier or by the driver in the driver app. The pay model and rates the carrier sets for a driver, and the indicative sums computed from them, are visible to that carrier and to the driver in the driver app. The driver does not see what the carrier receives for a job, only their own share. The shipper and other carriers do not see this data.

Training data: the training section of the driver app (Koulutus) stores the driver's per-question progress: the number of correct and incorrect answers, the time of the last answer and the next review time. The data is visible only to the driver; it is not shown to the carrier, the shipper or Aivomaa Oy's staff. The progress of a user who is not signed in is stored only on their own device, and on signing in the driver can transfer it to the service.

Validity of qualifications: the type of the driver's certificates and cards (for example the certificate of professional competence, ADR, occupational safety card, first aid, road safety, driver card), the date of issue and the expiry date. The data is entered by the driver or by the carrier, and it is visible to the driver, their carrier and the operator. The service sends reminders six, three and one month before expiry in the driver app, and to the carrier in the cabinet and by email.

Use of the interface: for the API keys a company creates, the name, the beginning of the key, a checksum (not the key itself), the creator and the times of creation, use and revocation are stored. For API requests, the key used, the type of request, the address without query parameters, the response code and the duration are stored. The request log is retained for 90 days. If a company subscribes to event notifications, the service sends the events of the company's own orders and claims to the address the company has given: the order and claim number, status, the town of a route stop and the agreed time and the times of arrival, estimated arrival and confirmation, the estimated delay, the start of waiting and the end of free waiting, the identifier of an offer, the type of a route change and the type of a document. The driver's position is not sent in notifications. The company is the recipient of this data. The delivery log is retained for 30 days. The logs are deleted automatically. Through the interface a company receives the same data as in its own view of the service.

Invitations: when a carrier invites its customer or another carrier to the service, the invited company's name, business ID and the email address given by the carrier, the sender and time of the invitation, a checksum of the invitation link (not the link itself) and whether an application was made on the basis of the invitation are stored. One invitation message stating who sent the invitation is sent to the address; no other messages are sent there unless the recipient applies. The invitation data is visible to the inviting carrier and the administrator. Invitations are deleted automatically 12 months after they were sent. Aivomaa Oy may also itself send one invitation to the general email address a company publishes on its website; the company's name, business ID, address, website and the time of sending are then stored. If the recipient refuses messages by replying, the address is marked as refused and no further messages are sent to it. Sending the invitation message is based on the legitimate interest of the inviting carrier and Aivomaa Oy in business-to-business contact (Article 6(1)(f) of the General Data Protection Regulation). The message states the name of the inviter. The recipient may ignore the message or ask for its data to be deleted by writing to admin@rahtis.eu.

Carrier key figures: the figures of clause 6.9 of the terms of use are calculated from the data of orders, route stops, consignment notes, claims and direct orders and are not stored separately. They concern the company; for a sole trader they may be personal data. In offers the shipper sees the number of jobs and the on-time share without the company name. Key figures for individual drivers are not calculated. The legal basis is the legitimate interest of shippers and Aivomaa Oy in assessing the reliability of the performer (Article 6(1)(f) of the General Data Protection Regulation). A sole trader may object to the processing on grounds relating to their particular situation in accordance with section 9.

Job messages: once a vehicle has been assigned to a job, the messages sent about the job by the shipper, the carrier and the driver are stored, together with the sender's role, the driver's first name, the time of sending and machine translations of the message. The messages are visible to the job's shipper, carrier and driver; Aivomaa Oy's staff see them only if a claim has been made concerning the job. The messages are retained for 24 months from sending and are deleted automatically. The basis for processing is the parties' legitimate interest in performing the transport and demonstrating its course. The carrier informs its drivers of job messages and who can see them before they start using the app.

Own jobs: when a carrier adds a transport of its own customer to the service, the customer's name and the business ID and email address given by the carrier are stored, and a random tracking link identifier is created for the job. The tracking link is sent to the customer's email only if the carrier has given the address. The link shows the carrier's name, the job's reference and status, the trailer or container number and the names, towns and times of the route stops; the driver's contact details, location and the price are not shown. The customer's data is visible only to that carrier and the administrator, and Aivomaa Oy does not use it for its own marketing. The retention periods are the same as for other orders (section 8.4).

Site analytics: on the public pages (front page, blog, application, terms of use, privacy notice and the interface description), data on the use of the pages is collected with the visitor's consent using the HeyCatch analytics service: pages viewed, clicks and form submissions, the source of the visit (for example a campaign link), the type of browser and device, an approximate location derived from the IP address and a random identifier stored in the browser. From the application only the type of company and the country are passed on, not the name, business ID or email address. No data is collected from the signed-in service, the driver app or tracking links, and the query part (for example an invitation link identifier) is removed from page addresses. Without consent the analytics sends nothing and stores nothing in the browser. Consent can be withdrawn at any time through the Analytics settings link at the bottom of the page. The processing is based on consent (section 4.4).

Worksite haulage: when a carrier adds its customer's worksite to the service, the name and address of the site, the customer's name and the business ID and email address given by the carrier, the pricing and the default load are stored. In the driver app, the arrival at the site, the vehicle and trailer used, the loads (type of load according to the list of wastes, scale or receiving site, gross, tare and net weight, weighing ticket number and unloading time) and the end of the day are stored. From these, the working hours, the waste transfer document under section 121 of the Waste Act, the carrier's report and the invoice sent to the customer in the carrier's name are formed; for the invoice, the customer's billing address and VAT identifier are stored. The site manager may approve a day through a link the carrier has given them; the name they enter, the time of approval and any note are then stored. A driver may add a receiving site, in which case its name and location are stored; this information does not concern a person.

Data is obtained from the person themselves, from the company they act for, from the shipper, from the carrier, from those taking part in performing the order, and from the actions and documents in the service. The name, business ID and email address of an invited company are given by the carrier that sent the invitation. Company registration details are checked against public registers.

Access, dealing with the representatives of companies, arranging and following transports, communication, delivering documents and showing performance: the legitimate interest of Aivomaa Oy and of the companies concerned in conducting and documenting a business relationship, assessed for necessity and against the rights of those concerned. Where the person is themselves a party to the contract, the data needed may be processed to conclude or perform their contract.

Accounting, invoicing and meeting statutory requirements: a legal obligation of Aivomaa Oy. A contract with a company does not make each of its employees a party to that contract.

Security, access control, prevention of misuse, verification of payment details, investigation of incidents and defence of claims: the legitimate interests of Aivomaa Oy and of the parties to the orders, with the necessary balancing of rights.

For optional processing that requires consent, consent is requested separately and for a specified purpose. Consent may be withdrawn, which does not affect the lawfulness of processing carried out before withdrawal. Accepting the terms, or an employer entering a telephone number, is not a general consent to location data, marketing or the disclosure of data to AI services.

The data needed to identify a company, to communicate, to perform an order and for statutory accounting is a precondition for those functions. Without it, registration, performance of the work or settlement may not be possible.

Working-time data and pay models are processed so that the carrier obtains its drivers' working-time records and an indicative pay calculation from the service, and the driver can see their own hours and earnings. Aivomaa Oy processes this data on behalf of the carrier as a processor; the controller is the carrier as the employer. The legal basis is the carrier's statutory obligation to keep working-time records and the management of the employment relationship. Working-time and pay calculation data is retained for six years from the end of the calendar year to which the data relates. If the carrier needs the data for longer, it is responsible for retaining it in its own records. Aivomaa Oy assists the carrier in handling drivers' requests concerning this data.

Training data is processed so that the driver can review and continue unfinished training on different devices. The validity of qualifications is processed for the reminders and so that the carrier can make sure the driver holds the qualifications the work requires. Legal basis: for training data, Aivomaa Oy's legitimate interest in offering the driver a review function the driver has chosen to use; using the training is voluntary. For qualification data, the legitimate interest of the carrier and Aivomaa Oy in verifying the driver's qualifications, and the carrier's statutory obligations. Retention: the driver can delete their own training progress at any time (Reset progress), and the driver or the carrier can delete a qualification entry in the service. Training progress is deleted automatically 24 months after the last answer. Training progress and qualification data are deleted automatically three months after the driver has been archived in the carrier's records. Progress stored on the device of a user who is not signed in remains on the device until the user clears it. Training results are not used to assess the driver and are not given to the carrier at an individual level; any summary for the carrier will be introduced only once this policy has been updated to cover it.

The parties to a transport receive the data their role requires: the performer receives the job, the addresses and the necessary contacts; the shipper receives the progress and documents of its own order, and the recipient of an own job's tracking link the data listed in section 2.14. Registration alone gives no access to the data of other companies or to other orders.

The technical suppliers of the service process data on behalf of Aivomaa Oy: Vercel Inc. (application platform; server functions run in the Paris region), Supabase (database, authentication and file storage; the project is in the AWS Paris region), TomTom (address suggestions and heavy-vehicle routing), MapTiler (map background tiles to the user's browser) and Resend (email delivery).

The address and routing service receives the address text, the coordinates of the stops and the technical details of the request in order to resolve coordinates and compute distance. No other personal data is passed to it. The map service receives the map tiles requested by the user's browser.

When the service's assistant is used, its answers are produced with OpenAI's language model; the automation is built with n8n. These receive the content of the question and the job data needed to answer it. Using the assistant is voluntary, and the same work can be done in the cabinet. OpenAI may process data outside the EEA, and clause 6.4 applies to the transfer.

Data may be disclosed to banks and payment infrastructure for settlements, to professional advisers and insurers for the matter concerned, and to competent authorities on a lawful basis. Disclosure is limited to what is necessary.

Translations of job messages are made with OpenAI's language model; the automation is implemented with the n8n tool. They receive the text of the message and the languages into which it is translated, but not the sender's name, the job number or other job data. OpenAI may process data outside the EEA, and clause 6.4 applies to the transfer.

The application platform and the database are configured to run in Europe: server functions in the Paris region, and the database and files in the AWS Paris region.

Some suppliers are established outside the EEA or may process data there. That is so in particular for the assistant's language model, the site analytics of section 2.15 and any remote support.

A transfer outside the EEA is permitted only under an applicable legal mechanism. The mere use of a well-known cloud service does not demonstrate that the requirements are met.

Where personal data is transferred outside the EEA, the transfer is based on an adequacy decision of the European Commission, such as the EU–US Data Privacy Framework for suppliers certified under it, or on the standard contractual clauses approved by the European Commission and included in the data processing agreement with the supplier. Data in transit is encrypted. Information on the transfer mechanism used in each case is available from admin@rahtis.eu.

The service uses the coordinates of route stops and the events of an order. The device's location is requested only at the moments listed in section 2.4 — arriving at a stop, taking a photo, passing a stop, and the start and end of a work shift — and one point is stored for each. Providing the location is decided by the browser's permission; refusing it prevents neither the action nor performing the work.

The telephone number links the driver to their company, vehicle and jobs in the driver app. Notices for the driver are delivered in the service and in the driver app; the service does not relay messages through WhatsApp.

The service makes no decisions based solely on automated processing that would produce legal effects concerning a person or similarly significantly affect them. The automatic checks concern equipment and jobs: they limit which vehicles a job is visible to, close the decision window when the deadline passes, and send notifications.

Data is retained no longer than the purpose concerned requires, taking into account statutory accounting, contracts in force, possible claims and the defence of rights. The ending of access does not mean the immediate deletion of all settlement and transport documents.

Accounting material is retained for the periods required by applicable law. For transport documents, the time limits for claims and the need to show performance are also taken into account. The retention period for invoices is not extended, without a separate basis, to all photographs, position points and technical logs.

The following can be verified about technical data: resolved incident records are deleted 90 days after they were last seen, and the records limiting abuse of sign-in are deleted within a day. The cabinet shows completed jobs for the last eight weeks; that is a limit on the view, not a deletion period.

Retention periods by category: orders, invoices, settlements and consignment notes (CMR) are retained for six years from the end of the calendar year in which the job ended. The position points of section 2.4 and loading, unloading and damage photos are retained for 24 months from the end of the job or shift; the place of capture is then removed from a consignment note that is kept longer. Driver app events, assistant conversations, the job messages of section 2.13 and support requests are retained for 24 months. Service notifications, the log of sent emails and the invitations of section 2.11 are retained for 12 months; an address marked as refused is retained for as long as the refusal applies. The analytics data of section 2.15 is retained for at most 24 months; the browser identifier expires after 12 months. The waste transfer documents of section 2.16 and the load data they are based on are retained for six years from the end of the year of the transfer, as the Waste Act requires; worksite hours and approvals are retained like orders. When the period ends, the data is deleted automatically; order and invoice data required for bookkeeping is deleted or anonymised at the end of its retention period. If a claim or other demand concerning a job is pending, its data is retained as set out in section 8.5.

Data needed for a pending dispute or a statutory claim may be retained until the matter is resolved and the applicable period has passed. Access to it is limited to that purpose.

In the situations provided by law, a person has the right to be informed and to access their own data, to have inaccurate data corrected, to request erasure or restriction of processing, to object to processing based on legitimate interest, and to receive data in a portable form where the conditions of that right are met. These rights are not an unconditional requirement to delete documents that must be retained by law.

Requests are sent to admin@rahtis.eu. Aivomaa Oy may request proportionate verification of identity in order to protect the data. A driver may address Aivomaa Oy directly about its own processing; a prior request to the employer is not a precondition for handling it.

A reply is given without undue delay, normally within one month. Where the law allows an extension because of the complexity or number of requests, the extension and its reasons are communicated within the prescribed period. A refusal is reasoned.

A person has the right to lodge a complaint with a supervisory authority, in Finland the Office of the Data Protection Ombudsman: https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman. Contacting Aivomaa Oy does not limit that right.

Access to data is restricted by role, and the restriction is enforced in the database rather than only in the interface. Secret keys exist only on the server side. Documents are served through a time-limited link that expires in five minutes.

When Aivomaa Oy is the shipper's contracting party, the shipper does not see the carrier's name or its personnel contact details, and the carrier does not see the shipper's name, contact details or billing details; the shipper is shown to the carrier by a code. When the parties invoice and pay each other — the direct jobs of a carrier that uses the service for a monthly fee — they see each other by name, because otherwise an invoice can neither be addressed nor paid; the shipper is then also shown the carrier's account number and BIC code. On the offer table a carrier sees only the city of the points, and on the map they are presented with an accuracy of about ten kilometres; the name of the place, the exact address, the booking reference, notes and contact persons open only once the job has been assigned to it. Loading and unloading place details are visible to the carrier and the driver to the extent the transport requires. A carrier does not see other carriers' vehicles or their locations. For vehicles that have performed the shipper's jobs and whose carrier has allowed direct orders, the shipper sees the registration number and the carrier's rating and, for contact, the driver's name, telephone number and email address. Showing the driver's contact details is based on the legitimate interest of the shipper and the carrier in handling communication about the transport (Article 6(1)(f) of the General Data Protection Regulation). The carrier informs its drivers of this, and the details are no longer shown once the carrier withdraws the shipper's direct orders.

A user must not pass their credentials to outsiders or upload unnecessary data to the service. The extent of the measures is set according to the nature of the data and the risks; no measure makes processing absolutely secure.

When processing changes, this notice is updated and states its version and date. Material changes are notified to the users concerned, and where consent is required it is requested separately.

The notice is available through the Privacy link on the RAHTIS site. Earlier versions and their acceptance records are retained.

This notice is drawn up in Finnish and in English. If the language versions conflict, the Finnish version prevails.