PRIVACY

Privacy Notice

Privacy Notice

Genba respects privacy and processes personal data with care, transparency and appropriate safeguards.

Last updated: 15 August 2026

2. Scope of this notice

This notice explains how Genba Consulting Oy processes personal data in connection with the Genba website, enquiries and meeting bookings, potential and existing customer relationships, the administration and delivery of services, and interactions with Genba’s social media accounts.

It also explains how planned HubSpot website analytics and embedded scheduling functionality will be handled before those features are introduced.

3. Personal data processed

3. Personal data processed

Depending on the interaction, Genba may process:

• name, email address, telephone number and other contact details
• organisation, professional role and other business-related information
• information included in enquiries, correspondence and meeting bookings
• the selected meeting time, scheduling preferences and information voluntarily submitted through the HubSpot scheduling page
• social media username, public profile information and the content of messages or interactions
• information necessary for managing a potential or existing customer relationship
• contractual, invoicing and legally required business information
• limited technical information necessary for delivering and securing the website and related services, such as IP address, browser and device information when processed by hosting or security providers

Genba does not intentionally request special-category personal data through the website or the meeting-booking service.

Sensitive, confidential or security-critical information should not be sent through ordinary email or entered into the scheduling form. Contact Genba first to agree on a more suitable communication channel when necessary.

4. Purposes and legal bases

4. Purposes and legal bases

Personal data is processed only for defined business and service-related purposes.

• Enquiries and meeting bookings are processed on the basis of Genba’s legitimate interest in receiving and responding to professional enquiries and, where applicable, taking requested steps before entering into a contract.
• Assignments and services are prepared, delivered and administered on the basis of a contract, steps taken before a contract or a legitimate interest in managing a customer relationship.
• Customer and professional relationships are maintained on the basis of Genba’s legitimate interest in managing relevant communications, relationships and business continuity.
• Invoicing, accounting and other legally required information is processed to comply with legal obligations.
• Website operation, information security, misuse prevention and the establishment or defence of legal claims are based on Genba’s legitimate interests in protecting its services, information and business.
• Any future non-essential website analytics or marketing tracking will be based on the visitor’s prior consent where consent is required by applicable law.

Genba does not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Sources of information

5. Sources of information

Information is primarily received directly from the individual concerned or from the organisation they represent.

Meeting-booking information is received when an individual voluntarily uses the external HubSpot Meetings scheduling page.

Relevant professional information may also be obtained from publicly available sources, such as company websites and professional LinkedIn profiles, when appropriate for an existing or prospective professional relationship.

6. Service providers and recipients

6. Service providers and recipients

Genba uses selected service providers to operate its website and business. These may include:

• Framer for website hosting and privacy-focused website analytics
• Microsoft 365 for email, calendar and document management
• HubSpot for customer relationship management and meeting scheduling

Service providers are given access only to the information necessary for their agreed purpose and are used under appropriate contractual arrangements where required.

At the date of this notice, the HubSpot Meetings service is provided through an external scheduling-page link. The scheduling service is not embedded in the Genba website.

LinkedIn and Meta provide external social media services, including LinkedIn, Facebook and Instagram. When a visitor opens or uses one of these external services, the provider processes information under its own terms and privacy notice.

Genba does not embed social media feeds or use Meta Pixel on the website at the date of this notice.

Personal data is not sold. Information may be disclosed to professional advisers or public authorities when required by law or when necessary for establishing, exercising or defending legal claims.

7. International transfers

7. International transfers

Some service providers or their subprocessors may process personal data outside the European Economic Area.

Where required, transfers are protected by a recognised legal safeguard, such as an adequacy decision, the EU–US Data Privacy Framework where applicable, or the European Commission’s Standard Contractual Clauses together with appropriate supplementary measures.

8. Providing personal data

8. Providing personal data

Providing information for an enquiry or meeting booking is voluntary.

Without sufficient contact information and relevant context, Genba may be unable to respond, arrange a meeting or assess a potential assignment.

Certain information may be required to enter into or perform a contract, issue invoices or comply with legal obligations.

9. Retention

9. Retention

Enquiry and potential customer information is generally retained for no longer than 24 months after the last substantive contact, unless the relationship continues or there is another justified legal or business reason for retaining it.

Meeting-booking information is retained as part of the relevant professional or potential customer relationship and is subject to the same retention principles.

Customer, contractual and service-administration information is retained for the duration of the relationship and afterwards for the periods required by applicable law or reasonably necessary for handling contractual matters and legal claims.

Accounting information is retained for the statutory retention periods.

Personal data is reviewed, deleted or anonymised when it is no longer necessary for the purpose for which it was collected.

10. Information security

10. Information security

Genba applies technical and organisational measures appropriate to the nature of the information and the risks involved.

These measures include data minimisation, access limited to those who need the information, protected accounts and devices, encrypted connections for website and service access, carefully selected service providers, and appropriate retention and incident-handling practices.

Security measures are reviewed when services, systems or relevant risks change. No internet-based service can guarantee absolute security.

Suspected personal data breaches are assessed, documented and reported to the relevant authority or affected individuals when required by applicable law.

11. Website analytics, external scheduling and cookies

11. Website analytics, external scheduling and cookies

The Genba website currently uses Framer’s built-in privacy-focused analytics. According to Framer, this analytics service does not use cookies or persistent identifiers and produces anonymised statistics that cannot be traced back to an individual.

At the date of this notice, the Genba website does not load the HubSpot tracking code, an embedded HubSpot Meetings scheduler, Meta Pixel or another advertising tracker.

The `Book a conversation` link opens an external HubSpot Meetings scheduling page. HubSpot’s privacy and cookie practices apply when that external service is opened. Information submitted through the scheduling page is made available to Genba for arranging the requested meeting and managing the related professional or potential customer relationship.

Genba expects to introduce HubSpot website analytics and an embedded HubSpot Meetings scheduler in a later implementation phase.

Before those features are activated:

• visitors will be provided with a clear opt-in consent mechanism
• non-essential HubSpot analytics and tracking technologies will be prevented from operating before the required consent
• visitors will be able to accept or reject non-essential cookies by category
• visitors will be able to change or withdraw their choices through a persistent Cookie settings control
• this Privacy Notice and its update date will be revised to reflect the functionality actually in use

The website contains ordinary links to other external services. The privacy and cookie practices of those services apply when a visitor opens or uses them.

12. Individual rights

12. Individual rights

Subject to the conditions of applicable data protection law, individuals may have the right to:

• access their personal data
• request correction or completion of inaccurate information
• request deletion of personal data
• request restriction of processing
• object to processing based on legitimate interests
• receive their data in a portable format where applicable
• withdraw consent where processing is based on consent
• lodge a complaint with the Finnish Office of the Data Protection Ombudsman

Genba may request information necessary to verify the identity of the person making the request. Requests are handled without undue delay and within the time limits required by law.

13. Changes to this notice

13. Changes to this notice

Genba may update this Privacy Notice when its services, systems, service providers or processing practices change.

The latest version and its update date are published on this page.