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Privacy policy

Last updated: September 13, 2026

We appreciate your visit to our websites and your interest in our company and services.
Protecting your privacy when processing personal data as part of our business activities is a priority for us, and we place great importance on this commitment.

We treat the personal data collected during your visit to our website, or otherwise obtained, always in compliance with legal requirements. We adhere to Regulation (EU) 2016/679, commonly known as the General Data Protection Regulation (GDPR).

1. Data Controller

We are the entity responsible for processing your personal data, referred to as the Data Controller, unless stated otherwise in this Privacy Policy.

Homie Labs Oy
Business ID: 3489764-5

Radiokatu 10 C 6
FI-00240 Helsinki
Finland

hello@usehomie.com

We have appointed a Data Protection Officer (DPO), who independently oversees our compliance with data protection laws, ensures that our data processing practices align with legal requirements, and addresses concerns related to the handling of personal data. The DPO serves as a point of contact for the supervisory authority and provides guidance within the Data Controller organization on data protection matters. DPO can be contacted at dpo@usehomie.com.

We act as the sole data controller for your personal data in connection with our business operations. However, when our customers utilise the Homie platform, they act as independent data controllers. In such cases, Homie serves as a data processor, managing personal data on behalf of our customers.

If your enquiry relates to data processing by one of our customers, we recommend that you contact the respective customer organisation directly for further information.

2. Data Collection and Purpose

Personal data means any information that relates to an identified or identifiable natural person. This includes names, addresses, phone numbers, email addresses, contractual data, social media identifiers, and other data that can help identify a natural person.

We collect, process, and use personal data only when there is a legal basis for doing so or when you have provided us your explicit and informed consent.

As part of our business activity we process the following categories of data:

  • Communication data (e.g. name, phone number, email and IP address)

  • Social media data (e.g. your connections and social media identifiers)

  • Business connections data (e.g. your board and executive office positions)

  • Customer network data (e.g. connections to other businesses)

Homie, along with service providers engaged by us, process your personal data for the following purposes:

  • Online Services: Fulfillment of our contract for the services you have ordered, along with our legitimate interest in conducting direct marketing.

  • Customer Support and Contact Forms: Our legitimate interest in replying to your requests regarding our products and services, as well as engaging in direct marketing and improving our products and services, provided it complies with data protection regulations, contractual obligations, or consent.

  • Platform Security and Error Identification: Compliance with our legal obligations in data security and our legitimate interest in resolving errors and ensuring the data security.

  • Advertising and Market Analysis: Your consent or our legitimate interest in conducting direct marketing.

  • Defending and Protecting Legal Rights: Our legitimate interest in safeguarding our legal rights, for example, in connection with legal disputes.

  • AI Features and Network Analysis: Our legitimate interest in providing the core functionality of the Homie platform, namely analysing business network and relationship data in order to identify how closely a person is connected to a user and to suggest possible warm introduction paths. This processing is described in more detail in the section Artificial Intelligence Features.

3. Artificial Intelligence Features

The Homie platform includes, and may from time to time include, features that use machine learning, large language models, or other artificial intelligence or automated-reasoning technology (AI Features). The results these features produce are referred to as AI Output. This section explains how personal data is processed in connection with the AI Features.

Our AI Features analyse business network and relationship data in order to identify how closely a person is connected to a user of the platform within their professional network, and to indicate possible warm introduction paths between a user and a prospective business contact. AI Output may therefore include connection-strength or proximity indicators, suggested introduction paths, and related summaries.

The AI Features may process the following categories of data, as described in the section Data Collection and Purpose:

  • Communication data

  • Social media data

  • Business connections data

  • Customer network data

  • Network and relationship data

We process personal data in connection with the AI Features on the basis of the performance of our contract and on the basis of our legitimate interest in providing and improving the core functionality of the Homie platform and in facilitating business-to-business networking. Before relying on our legitimate interest we carried out a balancing test weighing that interest against the interests, rights and freedoms of the individuals concerned. Where we act as a data processor for a customer, that customer determines the legal basis for its own use of the AI Features.

AI Output is generated using probabilistic models and is advisory only. It may be incomplete, inaccurate or outdated, and it does not constitute professional advice. We do not use the AI Features to take decisions based solely on automated processing that produce legal effects concerning you, or that similarly significantly affect you, within the meaning of Article 22 of the GDPR. Our customers are contractually required to ensure meaningful human review of AI Output before relying on it, and not to use it as the sole basis for such decisions.

We do not use customer data or user data submitted to the platform to train the general-purpose AI models underlying the AI Features. The only exceptions are (a) processing that is necessary to provide, maintain, secure and improve the service for the user’s own account, and (b) the use of data that has been aggregated and anonymised so that it can no longer reasonably identify a customer or any natural person.

The AI models used by the AI Features are operated by us or by AI service providers whose services are hosted within the EU/EEA. Personal data processed by the AI Features is not transferred outside the EU/EEA for that purpose. Where an AI service provider processes personal data on our behalf, it acts as our processor and, where we act as a processor for a customer, as a sub-processor under our Data Processing Addendum. Each such provider is bound by confidentiality and data protection obligations that are materially equivalent to those we undertake ourselves.

Data submitted to, and generated by, the AI Features is retained only for as long as necessary for the purposes described in this policy. We require our AI service providers not to retain data submitted to their models for longer than is necessary to return the output and to comply with their own legal obligations, and not to use that data for their own purposes.

The AI Features are not intended to process special categories of personal data within the meaning of Article 9 of the GDPR, and our customers and users are not permitted to submit such data to the platform unless we have expressly agreed otherwise in writing.

We follow the requirements of Regulation (EU) 2024/1689 (the “AI Act”). The AI Features are not designed, marketed or intended for use in a manner that would constitute a prohibited AI practice under Article 5 of the AI Act, or as a high-risk AI system within the meaning of Article 6 and Annex III of the AI Act. Where required under Article 50 of the AI Act, we inform individuals that they are interacting with an AI system or that content has been generated by one.

If you would like more information about how the AI Features have processed your personal data, wish to object to that processing, or wish to request human intervention in relation to it, please contact us using the details in the section Data Controller. If your enquiry concerns a customer’s own use of the AI Features, we will direct you to that customer, who acts as an independent data controller.

4. Children

We do not offer any of its services to minors under 18 years of age. If we become aware of the processing of personal data concerning minors, we will promptly remove such information. If you notice any information about minors, we kindly ask you to inform us.

5. Data Sharing

We share your personal data with other data controllers when it is necessary for the fulfilment of a contract, when we or a third party have a legitimate interest in the data transfer, or when you have provided your consent for the transfer to another controller.

For more details about the legal basis, please refer to the section above. Additionally, data may be shared when required by law, a regulatory authority, or a court order.

We want to be transparent, and we want to emphasise that Homie never sells or shares your personal data for marketing purposes without your explicit consent.

6. Service Providers

We engage service providers for tasks such as marketing, programming and data hosting. These providers are carefully selected by us and monitored regularly, particularly regarding their processing of personal data on behalf of us.

All service providers are contractually obligated to maintain confidentiality and comply with the legal requirements, including the GDPR. When engaging service providers outside of the EU/EEA, we ensure that relevant safeguards are in place.

The categories of service providers we engage include hosting and infrastructure providers, AI service providers, analytics and marketing providers, and customer support and communication tools. Where we process personal data on behalf of a customer, these providers act as sub-processors under our Data Processing Addendum. A current list of the sub-processors we engage is available at www.usehomie.com/legal/sub-processors/.

7. Data Transfers Outside the EU/EEA

We may transfer personal data to third countries outside the EU/EEA. Before initiating any such transfer, we ensure that a valid legal basis is established and verify that the recipient provides an adequate level of data protection. Alternatively, we obtain your explicit consent for the transfer of data to the third country.

For transfers to the United States, we currently rely on the EU-US Data Privacy Framework (DPF) and, where necessary, on Standard Contractual Clauses (SCCs). Some third countries, such as the United Kingdom and Canada, have adequacy decisions provided by the European Commission pursuant to Article 45 of the GDPR, in which case we rely on the applicable adequacy decision for the data transfers.

You may request a detailed overview of transfers to third countries and the specific measures implemented to ensure adequate data protection by contacting us.

8. Data Retention and Storage Period

We retain personal data only for as long as necessary to fulfill the purposes for which it was initially collected, such as providing services under the contract we have with you or where we have a legitimate and balanced interest in retaining the personal data.

In some cases, we may be required to retain personal data to comply with legal obligations, such as bookkeeping requirements under the Accounting Act (1336/1997). In all other instances, we delete your personal data through either automated or manual means.

When feasible, we use automated methods to erase personal information. For example, if you withdraw your consent for third-party service integration, any personal data connected to the integration will be automatically removed from our systems.

Where a user closes their account, or where the agreement between us and a customer ends, we may remove all data associated with that account in accordance with our Terms and Conditions, subject to any retention obligation imposed on us by law. Retention of data submitted to, and generated by, the AI Features is described in the section Artificial Intelligence Features.

9. Cookies

As part of our online services, we use cookies and tracking mechanisms. Cookies are small text files stored on your device when you visit our website or use the platform. In addition to cookies, technologies such as tracking pixels may also be employed.

Cookies serve various purposes, including ensuring the functionality of our online services, resolving technical issues, providing marketing, enhancing your user experience, and offering personalised services.

We use the following types of cookies on our website and the Homie platform:

  • Strictly Necessary Cookies: These cookies are essential for ensuring the functionality and secure use of the website and platform.

  • Statistical Cookies: These cookies help us measure key metrics, such as page views and audience data, to improve our services.

  • Marketing Cookies: These cookies allow us to tailor communications and advertisements to better match your preferences.

  • Conversion Tracking: These cookies, provided by our conversion tracking partners, generate statistics, demographic data, and records of website visitors who clicked on ads and were redirected to conversion-tracking tagged pages.

The use of cookies is voluntary, and you can control which categories of cookies are used by managing your preferences in the cookie consent settings on our website and platform.

Strictly necessary cookies, which are essential for supporting core functionalities and ensuring the security of our services, are always enabled. However, you may choose to disable all cookies through your browser settings. Instructions on how to do so are available for Chrome, Safari and Firefox.

Cookies have pre-determined lifecycles, which are specified further in our website cookie settings. However, you can also choose to clear your browser’s cookie history at any time through your browser settings. For further details on clearing your browser’s cookie history, please consult the instructions for Chrome, Safari and Firefox.

10. Content Delivery Networks

To optimise the loading times of both our website and platform, and to balance traffic effectively, we utilise the Amazon CloudFront Content Delivery Network (CDN). This service is provided by Amazon Web Services EMEA SARL.

The CDN enhance the delivery of our online content, in particular large media files such as graphics, text, or scripts, by leveraging a network of geographically distributed servers. This significantly reduces latency, improving loading times for website visitors and platform users.

The use of CDN services is based on our legitimate interest under Article 6(1)(f) of the GDPR, ensuring the efficient and reliable provision of both our website and platform.

As part of this processing data may be transferred to the United States. Amazon is certified under the EU-US Data Privacy Framework (DPF), which serves as a basis for the transfers. We may however also rely on Standard Contractual Clauses (SCCs) where feasible.

You can read here more about data protection in the Amazon CloudFront.

11. External Links

Our website or platform may include links to third-party services that are not affiliated with us. Once you click on such a link, we have no control over the collection, processing, or use of personal data transmitted to the third party (e.g. your IP address or the URL of the page containing the link), as we cannot influence the processing activity of these third parties.

Please consider this while opening any links leading to external sites. We do not assume any responsibility for the processing of personal data by these third parties.

12. Third-Party Integrations

The platform may allow you or our customers to connect third-party services, such as a social network, calendar or email account, through interfaces such as application programming interfaces (APIs). Where such an integration is enabled, personal data may be shared with, or accessed by, the relevant third-party provider for the purpose of operating the integration, as authorised when the integration is configured. The third party’s own privacy policy governs its processing of that data, and we recommend reviewing it before enabling an integration.

You may withdraw your consent to an integration at any time. When you do so, the personal data connected to that integration is removed from our systems as described in the section Data Retention and Storage Period, and it is no longer used by the AI Features.

13. Security

We have implemented the necessary technical and organisational measures to ensure the secure and safe processing of personal data. These measures include encryption of data at rest and in transit, access controls, and administrative safeguards to protect against accidental or unlawful destruction, disclosure, access, or alteration of data.

We continuously enhance the security of our systems in line with technological advancements and deploy relevant updates to our system infrastructure as needed.

All of our staff members and any service providers authorised by us are required to maintain confidentiality and comply with applicable data protection laws.

14. Your Rights

You have several rights in connection to the personal data we process about you as a data controller. In order to use the rights please contact us using the contact details specified in the section Data Controller.

  • Right to be informed: As a data controller, we are obligated to provide you with clear and transparent information about how we process your personal data. This privacy policy serves as our official statement detailing our data processing practices.

  • Right of access: You have the right to request access to the personal data we hold about you and obtain a copy of the data, along with details on how it is processed.

  • Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request its correction or completion.

  • Right to be forgotten: You can request the deletion of your personal data under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent.

  • Right to restrict processing: Under specific circumstances, you can request that we limit the processing of your personal data, meaning we can store it but not process it further.

  • Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and request that it be transferred to another data controller where technically feasible.

  • Right to object: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing or processing based on legitimate interests.

  • Rights related to automated decision making and profiling: You have the right not to be subject to decisions based solely on automated processing, including profiling, that have legal or significant effects on you. You may also request human intervention in such decisions. How this applies to our AI Features is described in the section Artificial Intelligence Features.

Please remember that when requesting the exercise of your rights, we need to be able to identify you. Identification can be performed using a variety of methods, ranging from email verification to bank credential authentication, depending on the type of data involved. You are always welcome to suggest a suitable means of identification.

As a data subject, you also have the right to lodge a complaint with the competent supervisory authority. You may appeal our decisions to the supervisory authority in your place of residence, the authority in a state with which you have a relevant connection, or the supervisory authority in the jurisdiction where we are established.

In Finland, where we are established, the supervisory authority is the Office of the Data Protection Ombudsman, with contact details available at www.tietosuoja.fi. For contact details of other European supervisory authorities, please visit the European Data Protection Board’s website at www.edpb.europa.eu.

Before lodging a complaint with the supervisory authority, we always suggest contacting us first. This ensures that our data privacy team is aware of your concern and can address it directly, even before any proceedings with the supervisory authority.

15. Changes to the Policy

We may update this policy from time to time to ensure it accurately reflects how we process personal information as part of our operations. We always suggest consulting this policy regularly. The policy will always indicate the latest date of amendment.

16. Contact Us

You have questions regarding the processing of your personal data and wish to contact us, please refer to the contact details provided in the Data Controller-section. This also applies when exercising your rights referred to in the Your Rights-section.