Privacy Policy
Sensofusion Oyj: how we process personal data
Version 1.0, 29 September 2026. Replaces the privacy policy previously published at sensofusion.com.
This privacy policy explains how Sensofusion Oyj (“Sensofusion”, “we”) processes personal data of the contact persons of our customer, supplier and partner organizations, users of Sensofusion-hosted software environments, visitors to our website, persons who contact us, shareholders and investors, and job applicants. Our own personnel are informed in a separate internal privacy notice.
Section 3 explains how personal data is handled in the Airfence and SensoC2 systems. In those systems the customer organization operating the system is the controller. Sensofusion receives operational data only in the deployment models described in Section 3 and, where it does, acts as a data processor on the customer’s instructions.
1. Controller and contact
Sensofusion Oyj, Business ID 2757722-1, Hakamäenkuja 1, 01510 Vantaa, Finland.
Contact for all privacy matters and data subject requests: Legal Counsel, .
Sensofusion has not appointed a data protection officer. A data protection officer is not required under Article 37 GDPR because Sensofusion is not a public authority, its core activities do not consist of regular and systematic monitoring of data subjects on a large scale, and it does not process special categories of personal data on a large scale. The contact above handles all privacy matters.
Sensofusion Oyj’s group companies are Sensofusion UK Ltd, Sensofusion Canada Inc., Sensofusion Inc. (USA), Sensofusion Israel Ltd and Sensofusion Ukraine LLC (in incorporation). Where a group company processes personal data for its own local operations (for example its own customer relationships or personnel), it is the controller of that processing under the law applicable to it, and this policy applies to it to the extent that law permits.
2. What personal data we process, and why
Sensofusion processes a limited amount of personal data, almost exclusively in a business-to-business context. Data subjects are mainly representatives of our customer, supplier and partner organizations, predominantly public authorities, defence and security organizations and other official bodies.
| Purpose | Personal data and source | Legal basis (GDPR Article 6) |
|---|---|---|
| Customer, supplier and partner relationships: contract management, deliveries, installation, service and support, invoicing, communication | Name, employer organization, role or title, business contact details, correspondence and other information necessary to manage the relationship. Collected from you or your organization. | Our legitimate interest (6(1)(f)) in managing the relationship with the organization you represent; statutory obligations (6(1)(c)), including accounting; necessary for the performance of a contract (6(1)(b)) where you are a party. |
| Counterparty due diligence: verifying customers, suppliers and partners before entering into business, including screening against sanctions and export control lists | Name, role, organization, nationality or country where relevant to export control, and information from public sources and sanctions lists. | Statutory obligations (6(1)(c)) under EU and Finnish sanctions and export control legislation; our legitimate interest (6(1)(f)) in not doing business with unreliable counterparties. |
| Support and inquiries: responding to support requests and other messages sent through our website forms, email or other channels | The information you submit (name, email address, organization, message content) and, for website forms, the IP address of the sender. | Our legitimate interest (6(1)(f)) in responding to your request; steps taken at your request prior to entering into a contract (6(1)(b)). |
| User accounts and security logs of Sensofusion-hosted environments: administering access to environments we host for customers and protecting the service against misuse (see Section 3) | Username, e-mail address (optional), password in hashed form, role, organization, session tokens; IP address and browser identifier (user agent) for each login; a log of downloads including the user’s e-mail address. | Our legitimate interest (6(1)(f)) in providing secure access and protecting the service, and the customer agreement. For all other operational data we act as processor for the customer (Section 3). |
| Marketing and communications: informing current and prospective customer organizations about our products, services and events | Name, business contact details, employer organization, role, marketing history. Collected from you, from website forms, or from public sources such as organization websites. | Our legitimate interest (6(1)(f)) in business-to-business marketing. You may object at any time (Section 8) and every marketing e-mail contains an unsubscribe link. |
| Shareholder and investor relations: maintaining the statutory shareholder register, general meetings, communication with shareholders, investors and their advisors | Shareholders: name, personal identity code or business ID, address, holdings and payment details. Representatives of investors, banks, auditors and advisors: name, organization, role, contact details. | Statutory obligations (6(1)(c)) under the Finnish Companies Act (624/2006) and securities legislation; our legitimate interest (6(1)(f)) in communicating with investors. |
| Recruitment: receiving and assessing job applications and communicating with applicants (applications are processed in our recruitment system Teamtailor at careers.sensofusion.com) | Name and contact details, application and CV content, education, work experience, language skills and other information you provide. Assessment or reference information only where relevant to the role. Data is collected primarily from you. | Our legitimate interest (6(1)(f)) based on your application and steps taken at your request prior to entering into a contract (6(1)(b)). Information from other sources (references, assessments) is collected only with your consent, as required by the Finnish Act on the Protection of Privacy in Working Life (759/2004). |
| Security clearance of selected recruitment candidates in Finland: because of the nature of our business, a personnel security clearance is obtained for persons to be employed | Identification details needed for the clearance application. The clearance itself is carried out by the Finnish Security and Intelligence Service (Suojelupoliisi); Sensofusion receives only the outcome. | Your written consent, as required by the Finnish Security Clearance Act (726/2014); our legitimate interest (6(1)(f)) in protecting classified and confidential information. |
3. Airfence and SensoC2: operational data
3.1 The customer is the controller
Airfence and SensoC2 are counter-drone detection and command-and-control systems operated by our customers in their own security or official function. All data generated in the operation of the system (“operational data”) belongs to and is controlled by the customer organization. The customer decides the purposes and legal basis of processing, informs data subjects where required, sets retention periods and is responsible for any data protection impact assessment. Sensofusion does not use operational data for its own purposes.
3.2 Deployment models and what reaches Sensofusion
| Deployment model | What Sensofusion receives | Sensofusion’s role |
|---|---|---|
| Fully self-contained: server and sensors installed in the customer’s own environment with no connection to Sensofusion’s systems | Nothing. The database, logs and detection data remain entirely in the customer’s environment. | None. Sensofusion has access only if the customer separately arranges support (on site or through a connection the customer opens), and then only as processor for the duration of the support. |
| Customer-hosted server with connected sensors: the server is in the customer’s environment, but sensors are configured to connect automatically to Sensofusion’s server | Detection data transmitted by the connected sensors (see 3.3). Sensofusion does not receive usernames, e-mail addresses or other user account data of the customer’s operators. | Processor for the detection data received, on the customer’s documented instructions under the customer agreement. |
| Sensofusion-hosted environment: Sensofusion hosts the server, database and logs for the customer | Operator accounts and login and activity logs (Section 2), detection data (3.3), alert recipient data (3.3) and, where enabled, data flowing to the optional integrations in 3.5. | Processor for operational data; controller only for access administration and security logging as described in Section 2. |
3.3 Personal data that operational data may contain
- Operator data: user account details, login IP addresses and browser identifiers, and activity such as downloads.
- Detection data relating to drone pilots: for drones whose protocol the system demodulates, the system can record the drone’s serial number, the account name associated with the drone (for example a DJI account name), the ground position of the pilot or remote controller, the take-off (home) point, and RF and camera recordings. These may constitute personal data of third parties who have no relationship with Sensofusion or the customer. The customer is the controller of this data on its own legal basis (typically the performance of a public or security task). Because the data involves systematic monitoring of individuals’ location, the customer must assess whether a data protection impact assessment under Article 35 GDPR is required; Sensofusion assists on request.
- Alert recipients: names, phone numbers and e-mail addresses of the persons the customer configures to receive alerts, and the content of alert messages.
- Remote support: when the customer requests remote support, maintenance or software updates, Sensofusion personnel may see operational data while performing the agreed work.
3.4 How Sensofusion processes operational data
Sensofusion processes operational data only on the customer’s documented instructions for hosting, remote support, maintenance, software updates and any analytics the customer orders, under the data processing terms (Article 28 GDPR) forming part of the customer agreement. Sensofusion’s personnel access operational data on a strict need-to-know basis and are bound by confidentiality obligations. Operational data is not used for Sensofusion’s own purposes.
3.5 Sub-processors and hosting
In the configuration in which Airfence and SensoC2 are shipped, no third-party service is enabled. The following are used only in the situations stated, and each is documented in the customer’s data processing terms:
- Amazon Web Services (AWS), Sensofusion-hosted environments only: hosting of the database and logs in the EU (Stockholm, Sweden and Frankfurt, Germany) and in Israel.
- Cloudflare, Sensofusion-hosted environments only: protection and routing of web traffic; processes client IP addresses and request logs (United States).
- Google (Gmail SMTP), only if the customer enables e-mail alerts: all outbound e-mail from the system is sent through Sensofusion’s Google Workspace tenant (United States).
- Twilio, only if the customer enables SMS alerts: recipient phone numbers and full message content (United States).
- ICEYE, only if the customer enables satellite imagery: operator-drawn areas of interest and free-text order references (Finland/EU).
Map links: the user interface and alert e-mails contain plain links to Google Maps. Coordinates are transmitted to Google only if a user clicks such a link, after which Google’s own terms and privacy policy apply. Google Maps is not a sub-processor of Sensofusion.
3.6 Retention and data subject rights
Sensofusion retains operational data for as long as the customer agreement requires and in accordance with the customer’s instructions. On termination of a Sensofusion-hosted environment the data is returned to the customer or deleted within 90 days unless the customer instructs otherwise. Download logs are retained for 4 years. If you wish to exercise your rights regarding data processed in an Airfence or SensoC2 system, please contact the organization operating the system; Sensofusion forwards any request it receives to the customer.
4. Recipients of personal data
We do not sell personal data. Personal data is disclosed only to the following recipients:
- Service providers acting as processors on our behalf under data processing agreements: Google (Google Workspace, e-mail and documents), Microsoft (Microsoft 365), Slack (internal communication), Notion (documentation), DocuSign (electronic signatures), Teamtailor (recruitment), Talenom Oyj (payroll, bookkeeping and financial administration), NAVEX (whistleblowing channel), and, for Sensofusion-hosted Airfence and SensoC2 environments, the sub-processors listed in Section 3.5. Processing by these providers takes place under their data processing agreements, which form part of their service terms (including the AWS Data Processing Addendum, the Google Cloud Data Processing Addendum, the Cloudflare Customer DPA, the Twilio Data Protection Addendum, the DocuSign Data Protection Attachment and the NAVEX Data Processing Addendum).
- Sensofusion group companies (Section 1) for internal administration and to serve customers locally.
- Authorities, courts, banks, auditors, insurers and professional advisors where required by law, to establish, exercise or defend legal claims, or in connection with an audit, financing, insurance or corporate transaction, under confidentiality obligations.
- Website service providers as described in Section 9.
5. International transfers
Personal data is processed primarily within the EU and EEA. Business contact data and, for personnel, basic employee data is shared within the group with our subsidiaries in the United Kingdom, Canada and Israel, all of which are covered by European Commission adequacy decisions, and with our subsidiaries in the United States and Ukraine. Sensofusion-hosted Airfence environments may be hosted in Israel (adequacy decision).
Where personal data is transferred to a country without an adequacy decision, we use the European Commission’s Standard Contractual Clauses (Article 46(2)(c) GDPR) together with a transfer impact assessment and supplementary measures where needed, or, for recipients in the United States certified under the EU-U.S. Data Privacy Framework, that framework. Transfers within the group to the United States and Ukraine are governed by an intra-group data transfer agreement incorporating the Standard Contractual Clauses. Our US-based service providers (Google, Microsoft, AWS, Cloudflare, Twilio, DocuSign, NAVEX) are certified under the EU-U.S. Data Privacy Framework and their data processing agreements also include the Standard Contractual Clauses. You may request a copy of the safeguards from the contact in Section 1.
6. Retention
We retain personal data only for as long as necessary for the purposes described in this policy or as required by law, after which it is deleted or anonymized. The maximum periods are:
| Data | Retention |
|---|---|
| Customer, supplier and partner contact data, contracts and correspondence | Duration of the relationship and 10 years from the end of the financial year in which the relationship ended or the last transaction took place (Finnish Accounting Act 1336/1997 and the 10-year maximum limitation period for claims under the Act on the Limitation of Debts 728/2003). |
| Counterparty due diligence and export control records | The statutory record-keeping period, up to 10 years from the transaction. |
| Support requests and other inquiries | From customers: as part of the customer records above. From others: 3 years from the last contact. |
| User accounts and logs of Sensofusion-hosted environments | Duration of the customer agreement; deleted within 90 days after termination. Download logs 4 years. |
| Marketing data | Until you object or we learn that the data is outdated e.g., due to undeliverable messages or user inactivity; the accuracy of marketing data is reviewed at least every 3 years. |
| Website server logs (IP addresses) | 12 months. |
| Shareholder and investor data | Shareholder register: for as long as the Companies Act requires; information on former shareholders 10 years after removal from the register. Other investor communication: 10 years. |
| Recruitment data | 2 years from the recruitment decision (limitation period for claims under the Finnish Non-Discrimination Act 1325/2014 and Act on Equality between Women and Men 609/1986). Open applications: 12 months from receipt. Security clearance outcome: only until the recruitment decision, unless employment begins. |
| Accounting material | 10 years from the end of the financial year (accounting books and financial statements); vouchers at least 6 years (Accounting Act, Chapter 2, Section 10). |
7. How we protect personal data
Sensofusion protects personal data with technical and organizational measures aligned with ISO/IEC 27001 and the Finnish KATAKRI criteria, including: access limited to persons who need the data for their duties, personal user accounts and multi-factor authentication in all key systems (including Google Workspace, Slack and Microsoft 365), full-disk encryption and centralized management of company devices with remote lock and wipe, encryption of network traffic (TLS, SSH), centralized security logging and monitoring (SIEM), regularly tested encrypted backups, security clearance of all personnel, confidentiality obligations for all personnel, and physical security of our premises with electronic access control, alarm systems and camera surveillance. Sensofusion’s own servers are hosted in a secure data center in Finland; Sensofusion-hosted Airfence environments are hosted as described in Section 3.5.
8. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you and receive a copy of it (Article 15);
- have inaccurate or incomplete data rectified (Article 16);
- have your data erased where there is no legal ground or statutory obligation to retain it (Article 17);
- restrict processing in the situations set out in Article 18;
- object to processing based on our legitimate interest (Article 21(1)), and object to direct marketing at any time, in which case we stop immediately (Article 21(2));
- receive the data you have provided to us in a structured, machine-readable format (data portability, Article 20) where processing is based on a contract or consent and carried out by automated means;
- withdraw consent at any time, without affecting processing carried out before the withdrawal.
Sensofusion does not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you.
To exercise your rights, contact . We respond without undue delay and within one month of receiving your request; where a request is complex or we receive many requests, we may extend this by two further months, in which case we inform you within the first month. Requests are handled free of charge unless they are manifestly unfounded or excessive. We may need to verify your identity before acting on a request.
If you consider that our processing infringes data protection law, you have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence or place of work. In Finland the supervisory authority is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto), Lintulahdenkuja 4, 00530 Helsinki, , www.tietosuoja.fi.
9. Cookies and third-party content on our website
Our website sensofusion.com uses technically necessary cookies required for the site to function and Google Analytics 4 (Google), which is loaded through Google Tag Manager. Google Analytics measures the use of the site, including page views, link clicks and form submissions, and sets analytics cookies on your device (for example _ga and _ga_*). Google receives your IP address and information on your browser and your use of the site, and processes it under its own terms and privacy policy. Google Analytics runs only after you have given your consent to analytics cookies through our cookie banner; until then, no analytics cookies are set and no analytics data is sent to Google. You can change or withdraw your consent at any time through the cookie settings. We do not use marketing or advertising cookies.
When you open a page on our website, your browser loads font files from two third-party providers, Google Fonts (Google) and Monotype. This happens automatically when the page loads and does not currently depend on any cookie choice you make. These providers receive your IP address, the page address and technical browser information in order to deliver the fonts, and process that information under their own privacy policies. We are working on serving the fonts from our own server so that no request is made to third parties before you have given consent; until then, you can prevent these requests only by blocking third-party requests in your browser.
Investor information on our website is provided by Inderes Oyj. When you open the investor pages, Inderes receives your IP address and may set its own cookies; Inderes’ privacy policy applies to that service.
The cookie settings page at sensofusion.com/cookies/ is under repair and does not currently allow you to change cookie settings. Until it is repaired, you can delete cookies and block analytics cookies in your browser settings. Our web server records the IP address and technical details of each request in its server logs for security purposes.
10. Changes to this policy
We may update this privacy policy when our processing or the applicable law changes. The current version is always published at sensofusion.com, with its version date. This version replaces all earlier versions, including any reference to the invalidated EU-US Privacy Shield framework.