Oilon Group Oy and the Oilon Group
1. Introduction and scope
This privacy policy explains how Oilon Group Oy and the companies of the Oilon Group (hereafter "Oilon" or "we") collect, process and use your personal data when you use our websites, our webshops, the Oilon ONE service platform, our applications, our products and related services.
This is a consolidated document: the general part (sections 1–16) applies to all of the services listed below, and the service-specific annexes (A–F) set out exactly what happens in each service. Annex F applies only to internal Oilon users. Annexes G and H contain the statutory supplements required in Mainland China and the United States. If the general part and an annex conflict, the annex prevails.
1.1 Services covered by this policy
| Service | Description | Annex |
|---|---|---|
| oilon.com | Oilon global website (WordPress), multilingual | Annex A |
| oilon.cn | Oilon website for the Chinese market (WordPress) | Annex B, Annex G |
| Oilon ONE | Service platform and device portal: cloud.oilon.com and oilon.one, plus the information and registration pages at info.oilon.com | Annex C |
| shop.eu.oilon.com | Oilon webshop for the EU market (WooCommerce) | Annex D |
| shop.us.oilon.com | Oilon webshop for the US market (WooCommerce) | Annex E, Annex H |
| Origo intranet | Oilon’s internal intranet (Microsoft 365 / SharePoint Online) at all Oilon locations. Accessible only with Oilon work credentials. | Annex F |
1.2 Applicable law
We process personal data in accordance with the EU General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Finnish Data Protection Act (1050/2018) and sections 200, 202 and 205 of the Finnish Act on Electronic Communications Services (917/2014). We also comply with the Personal Information Protection Law of the People’s Republic of China (个人信息保护法, "PIPL") and with applicable US state consumer privacy laws to the extent they apply to our operations. A complete list of the regulations, directives, national laws, authority guidelines and standards on which this policy is based is set out in Annex I.
2. Data controller and contact details
Within the Oilon Group, the data controller is Oilon Group Oy and/or the Oilon Group company with which you have a business relationship. When you buy from an Oilon webshop, the controller is the group company named as the seller on your order confirmation.
| Data controller | Oilon Group Oy |
|---|---|
| VAT number | FI02131514 |
| Postal address | Metsäpietiläkatu 1, FI-15800 Lahti, Finland |
| Privacy matters | datasecurity@oilon.com |
| Data protection officer | Oilon Group Oy, Data Protection Officer, Metsäpietiläkatu 1, FI-15800 Lahti, Finland |
| Representative in Mainland China | Oilon Burners (Wuxi) Co., Ltd. (Art. 53 PIPL) – contact details in Annex G |
If you have questions or comments, or if you need further information about this policy and the use of your personal data, please contact us at datasecurity@oilon.com.
3. Personal data we process
We process only the personal data necessary for the purposes described below. We do not collect special categories of personal data (Article 9 GDPR), such as health data or data on beliefs.
3.1 Data you provide to us
- Name, customer number, postal address, e-mail address and telephone number
- Information about the company you represent, such as company name, address, business ID, VAT number and contact persons
- Professional details such as job title and area of responsibility
- Order, delivery and payment transaction data, and information related to invoicing and collection
- General information about your customer relationship with us
- Your answers to our customer surveys and the feedback you provide
- Consents and prohibitions, for example those related to direct marketing
- The content of enquiries and support requests and the communication between us, including chat conversations
- Recruitment-related information if you apply for a job with us
3.2 Data generated by your use of our services
- Credentials, username and security information used for authentication (passwords are always stored as a salted hash and are not visible to us)
- Demographic data such as your country and preferred language
- Information related to your product: serial number, installation information, system settings and status, environmental data, technical measurement and performance data, and network identification data (IP address, online status)
- Usage data on how you and/or your device interact with us or with our products
- Device data: operating system, browser and browser version, IP address, device identifiers, screen size, regional and language settings and temperature settings
- Error reports and performance data related to our products, services and applications
- Location data at low precision, for example a city- or country-level location derived from your IP address
- Cookie and advertising identifiers and the browsing and click data linked to them (see section 12 and annexes A–E)
Some of this data is anonymous on its own but constitutes personal data when combined with other information. In that case we process it as personal data.
4. Where we collect your data from
- Directly from you, when you register as a user, place an order, complete a form, subscribe to a newsletter, take part in a customer survey or contact us
- Automatically when you use our websites, webshops, applications or the Oilon ONE service, by means of cookies and similar technologies (see section 12)
- From your Oilon products, when the device is connected to the Oilon ONE service
- From the company you represent or from our distributor, as part of a sales or delivery relationship
- From publicly available sources and public registers held by authorities, such as trade and credit registers
- From other companies within the Oilon Group
5. Purposes and legal bases of processing
We process your personal data only where we have a legal basis under the GDPR. The table below sets out the purposes, data categories, legal bases and retention periods.
| Purpose | Data categories | Legal basis | Retention period |
|---|---|---|---|
| Managing the customer relationship, processing orders, deliveries and invoicing | Contact details, company details, order and payment data | Performance of a contract or pre-contractual steps (Art. 6(1)(b)); legitimate interest for contact persons of business customers (Art. 6(1)(f)) | For the duration of the customer relationship; accounting records for 6 years from the end of the year in which the financial period ended (Finnish Accounting Act 2:10) |
| Product support, warranty and service matters | Contact details, device and serial number data, fault data, communication | Performance of a contract (Art. 6(1)(b)); legitimate interest in product safety (Art. 6(1)(f)) | 5 years from the end of the warranty period |
| Providing the Oilon ONE service and remote monitoring of devices | Account data, device measurement, status and log data | Performance of a contract (Art. 6(1)(b)) | For the term of the agreement + 12 months |
| Webshop orders and payment processing | Order, delivery and payment data | Performance of a contract (Art. 6(1)(b)); legal obligation in accounting and VAT (Art. 6(1)(c)) | 6 years from the end of the year in which the financial period ended |
| Customer service and responding to enquiries | Contact details, content of messages and chat conversations | Pre-contractual steps (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f)) | 24 months from the last contact |
| Marketing, newsletters and event invitations | Contact details, marketing consents and prohibitions, interest data | Consent (Art. 6(1)(a)); legitimate interest for contact persons of companies (Art. 6(1)(f)) and sections 200 and 202 of the Act on Electronic Communications Services | Until consent is withdrawn; data on inactive recipients is deleted after 24 months |
| Analytics, measurement and development of our online services | Cookie identifiers, truncated IP address, usage and click data | Consent for cookies (section 205 of the Act on Electronic Communications Services) and Art. 6(1)(a) GDPR | See the cookie tables in annexes A–E; analytics data for a maximum of 26 months |
| Advertising targeting and measurement of advertising performance | Cookie identifiers, advertising identifiers, conversion data | Consent (Art. 6(1)(a)) and section 205 of the Act on Electronic Communications Services | See the cookie tables in annexes A–E |
| Recruitment | Application and CV data, contact details | Consent (Art. 6(1)(a)); pre-contractual steps (Art. 6(1)(b)) | For the duration of the recruitment process; open applications 12 months |
| Information security, prevention of misuse and spam, logging | IP address, log data, reCAPTCHA risk score, order history | Legitimate interest in protecting our services (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) | Log data 12 months |
| Compliance with legal obligations and handling of legal claims | Data necessary on a case-by-case basis | Legal obligation (Art. 6(1)(c)); legitimate interest (Art. 6(1)(f)) | The period required by law, or until the limitation period expires |
5.1 Legitimate interest
For processing based on legitimate interest, we have assessed that it is necessary for our business and does not override your rights. Such purposes include processing the data of contact persons at business customers, developing our services, securing our online services, and establishing and defending legal claims. You may request further information about the assessment and object to the processing (section 11).
5.2 Consent
You may withdraw your consent at any time; withdrawal does not affect the lawfulness of processing carried out before it. Cookie consent is withdrawn in the cookie settings on the site, marketing consent using the link at the end of every marketing message, or by writing to datasecurity@oilon.com.
6. Profiling and automated decision-making
We do not make decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Article 22 GDPR).
We do, however, use light profiling in marketing: our marketing system may group recipients by, for example, industry, country, areas of interest or the pages visited on our website, so that our communication is more relevant. This is based on your consent or on our legitimate interest, and you may object to it at any time. Advertising targeting on third-party platforms (for example Google, LinkedIn and Meta) always takes place only on the basis of the consent you have given for marketing cookies.
7. Recipients of your data
Companies within the Oilon Group may use your personal data for the purposes defined in this policy. In addition, we use carefully selected service providers who process data on our behalf. A data processing agreement under Article 28 GDPR is in place with every processor.
| Recipient | Role | Purpose | Location and transfer basis |
|---|---|---|---|
| Hosting provider for the websites and webshops | Processor | Server environment, backups, technical maintenance | EU/EEA |
| Google Ireland Limited and Google LLC | Processor (Analytics, Tag Manager, reCAPTCHA); independent controller for advertising | Visitor analytics, tag management, spam protection, advertising targeting and measurement | EU and United States; EU–US Data Privacy Framework and standard contractual clauses |
| HubSpot Ireland Limited and HubSpot, Inc. | Processor | CRM, marketing automation, forms, chat and visitor analytics | EU instance (eu1); parent company in the United States; DPF and standard contractual clauses |
| LinkedIn Ireland Unlimited Company | Joint controller for visitor data | LinkedIn Insight Tag: conversion measurement and advertising targeting | EU and United States; DPF and standard contractual clauses |
| Meta Platforms Ireland Limited | Joint controller for visitor data | Meta Pixel: advertising targeting and measurement | EU and United States; DPF and standard contractual clauses |
| Cookie consent platform provider (hu-manity.co) | Processor | Collecting, storing and evidencing cookie consent | EU/EEA |
| Stripe Payments Europe, Limited and Stripe, Inc. | Independent controller for the payment transaction | Payment processing in the webshops | EU and United States; DPF and standard contractual clauses |
| Microsoft Ireland Operations Limited and Microsoft Corporation | Processor | Oilon’s internal intranet and Microsoft 365 working environment, and the mailboxes that receive form submissions from the websites | EU Data Boundary; standard contractual clauses and DPF (see Annexes F and G) |
| Nordic Business House Co., Ltd. / 努蒂商务咨询(上海)有限公司 | Processor | Technical maintenance of oilon.cn on behalf of Oilon Burners (Wuxi) Co., Ltd. | Shanghai, Mainland China; the data does not leave China |
| Logistics and transport companies | Independent controller | Delivery of orders | Case by case |
| Auditors, debt collection agencies, insurers and legal advisers | Independent controller | Legal obligations and legal claims | Mainly EU/EEA |
| Distributors and sales partners | Independent controller | Providing quotations and service | Case by case |
We may also disclose personal data to competent authorities where required or permitted by law, and, in connection with a business reorganisation, to a prospective buyer and its advisers.
8. Transfers outside the EU and the EEA
Some of the service providers we use, or their parent companies, operate outside the EU and the EEA. In such cases we ensure that the transfer has a basis under Chapter V of the GDPR:
- An adequacy decision issued by the European Commission. For US service providers we rely on the EU–US Data Privacy Framework (adequacy decision of 10 July 2023) where the recipient is certified under the programme.
- Standard contractual clauses (SCCs) approved by the European Commission, together with a transfer impact assessment and any necessary supplementary measures. We use these as a parallel basis for all transfers to the United States.
- Other safeguards or derogations under Articles 46 and 49 GDPR where the above are not available.
We actively monitor the legal status of the EU–US Data Privacy Framework. On 3 September 2025 the General Court dismissed the action for annulment of the adequacy decision (Case T-553/23, Latombe v Commission), and that judgment has been appealed to the Court of Justice. We maintain standard contractual clauses as a parallel transfer basis so that transfers remain lawful even if the adequacy decision were to be annulled.
Transfers to and from Mainland China are additionally subject to the requirements of the PIPL, described in Annex G.
You may request a copy of the safeguards we use by writing to datasecurity@oilon.com.
9. Retention periods
We retain personal data only for as long as is necessary for the purpose for which it was collected, or for as long as the law requires. The specific retention periods are set out in the table in section 5 and, for cookies, in the tables in annexes A–E. Once the retention period ends, the data is deleted or anonymised so that it can no longer be linked to you.
10. Information security
Oilon is committed to keeping your personal data safe. We protect it against loss, destruction, falsification, manipulation, unauthorised access and unauthorised disclosure by appropriate physical, technical and organisational measures. These include:
- Access control: only authorised persons who need the data to perform their duties have access to it
- Encryption: personal data is protected by encryption in transit (TLS) and at rest where necessary
- Strong authentication in the Oilon ONE service, including passwordless sign-in (passkeys)
- Firewalls, malware protection and network monitoring to prevent unauthorised access
- Regular backups and testing of recovery procedures
- Regular information security and data protection training for our personnel, and confidentiality undertakings
- Regular reviews and assessments of the effectiveness of our security practices and measures
- Data processing agreements and security requirements with all subcontractors
We recommend using a strong and unique password. Although we do our best, no transmission of information over the internet can be guaranteed to be completely secure.
If we detect a personal data breach, we will notify the supervisory authority within 72 hours and inform you without undue delay where the breach is likely to result in a high risk to your rights and freedoms (Articles 33 and 34 GDPR).
11. Your rights
You have the following rights in relation to the processing of your personal data. You can exercise them by contacting datasecurity@oilon.com.
| Right | What it means | GDPR |
|---|---|---|
| Right of access | You may ask whether we process personal data concerning you and obtain a copy of the data we process. | Art. 15 |
| Right to rectification | You may ask us to correct inaccurate or incomplete data. | Art. 16 |
| Right to erasure | You may ask us to delete your data, for example where the processing is no longer necessary or you withdraw your consent. The right is not absolute: we cannot delete data we are legally required to retain. | Art. 17 |
| Right to restriction of processing | You may ask us to restrict processing, for example where you contest the accuracy of the data. | Art. 18 |
| Right to object | You may object to processing based on legitimate interest. For direct marketing the right is absolute: we will stop the marketing immediately. | Art. 21 |
| Right to data portability | You may ask for the data you provided on the basis of consent or a contract in a machine-readable format, or to have it transferred to another controller. | Art. 20 |
| Right to withdraw consent | You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before it. | Art. 7(3) |
| Right not to be subject to automated decision-making | We do not make significant automated decisions (see section 6). | Art. 22 |
| Right to lodge a complaint | You may lodge a complaint with a data protection authority (see section 16). | Art. 77 |
11.1 How your request is handled
We respond within one month at the latest. For complex or multiple requests we may extend the deadline by up to two further months and will inform you within one month. Exercising your rights is free of charge. We may ask you to verify your identity so that data is not disclosed to the wrong person.
12. Cookies and similar technologies
Cookies are small text files stored on your device when you visit a website. Similar technologies include browser local storage (localStorage and sessionStorage), tracking pixels and device identifiers. In this policy, the word "cookie" refers to all of these technologies.
12.1 Cookie categories
| Category | Description | Consent |
|---|---|---|
| Strictly necessary | Cookies without which the website does not work: session management, sign-in, shopping cart, load balancing, security and storing your cookie consent. These cannot be switched off. | Not required (section 205(2) of the Act on Electronic Communications Services) |
| Functional | Cookies that remember your choices, such as language, region or display settings, and enable enhanced functionality. | Required |
| Statistics | Cookies that let us count visits and traffic sources and measure and improve the performance of our site. The data is aggregated into reports. | Required |
| Marketing | Cookies that allow our advertising partners to build a profile of your interests, show you targeted advertising on other sites and measure the performance of advertising. | Required |
12.2 How consent is requested and managed
We ask for your consent to non-essential cookies via a cookie banner on your first visit. Giving and refusing consent are equally easy and equally prominent, as required by the Finnish Transport and Communications Agency Traficom. You can also select categories individually.
Non-essential cookies are not set and third-party tracking scripts are not loaded before you have given your consent. We use Google Consent Mode v2, which communicates your consent status to Google services; signals sent without consent are cookieless and aggregated.
You can change or withdraw your consent at any time via the "Cookie settings" link in the site footer. Consent is valid for a maximum of 12 months, after which we ask for it again. You can also block or delete cookies in your browser settings; blocking strictly necessary cookies may prevent the site from working. Refusing cookies does not restrict your access to the content of the site.
12.3 Service-specific cookie information
The cookies used by each service are listed in annexes A–E. The lists are based on a technical audit carried out on 21–24 September 2026. Cookie lifetimes are the defaults stated by the supplier; browsers may shorten them (for example, Chrome limits script-set cookies to 400 days).
13. Other websites and social media plug-ins
Our websites may contain links to third-party sites, social media plug-ins and embedded content such as videos. This privacy policy applies only to our own services and no longer applies once you leave our site. We do not control other sites, and their content and privacy practices come directly from the provider in question – we recommend reviewing them. Embedded content is loaded only after you have given consent for the relevant cookie category.
14. Children’s personal data
Our services are directed at businesses and professional users. We do not knowingly collect personal data from persons under 16 (under 14 in Mainland China, under 13 in the United States). If we become aware that we have collected such data without the consent of a guardian, we will delete it without delay. If you believe that a child has provided us with personal data, please contact datasecurity@oilon.com.
15. Changes to this policy
Oilon reserves the right to update or amend this privacy policy. Changes take effect when they are published on our website. If a change is material – for example a new processing purpose or a new category of recipient – we will notify you separately on the website or by e-mail and, where necessary, ask for renewed consent.
The version and effective date of the policy are shown at the beginning of this document. This version was prepared on 14 October 2026 and supersedes the version dated 1 October 2026. If you need earlier versions of this policy, they are available on request using the contact details given in this policy.
16. Contact and right to lodge a complaint
If you have questions about this privacy policy or about the processing of your personal data, please contact us:
| datasecurity@oilon.com | |
| Post | Oilon Group Oy, Data Protection Officer, Metsäpietiläkatu 1, FI-15800 Lahti, Finland |
We aim to resolve any concerns directly with you. You always have the right to lodge a complaint with a supervisory authority:
| Finland, data protection | Office of the Data Protection Ombudsman, P.O. Box 800, FI-00531 Helsinki – tietosuoja.fi |
|---|---|
| Finland, cookies | Finnish Transport and Communications Agency Traficom, National Cyber Security Centre – traficom.fi |
| Other EU/EEA country | The data protection authority of your country of residence, place of work, or the country where the alleged infringement took place |
| Mainland China | The Cyberspace Administration of China (国家互联网信息办公室) or its local office – see Annex G |
| United States | Your state Attorney General, or the California Privacy Protection Agency (CPPA) – see Annex H |
This privacy policy has been drawn up in Finnish, in English and in Chinese. The Chinese version is published on oilon.cn and supersedes the previous Chinese privacy policy that took effect on 11 October 2023. In the event of any discrepancy between the language versions, the Finnish version prevails.
Annex A – oilon.com
Oilon’s global, multilingual website at oilon.com (WordPress). There is no sign-in for ordinary visitors and no webshop functionality; orders are directed to the webshops (Annexes D and E).
A.1 Data collected and why
- Data from contact, quotation request and material download forms (name, company, e-mail, telephone, message content) in order to respond to your enquiry and for sales purposes
- Contact details from newsletter subscriptions, for marketing communication based on your consent
- Data from partner applications and training registrations, in order to process the application or the registration
- Data from warranty notifications (contact details, address, product type and serial number, date of purchase, order number and a description of the fault), in order to handle the warranty matter
- The content of chat conversations, for customer service purposes
- Visitor analytics and advertising measurement data, in accordance with your cookie consent
Two separate routes for form data
Form submissions on this site travel by two different routes, with different recipients and different retention periods.
| Form type | Where the data goes | Retention |
|---|---|---|
| Enquiries, quotation requests, material requests, newsletter subscriptions, partner applications and training registrations | The HubSpot EU instance (account 27126175). The data is not sent by e-mail. | In accordance with the retention practice of the customer relationship management system |
| Warranty notifications | By e-mail to Oilon warranty handling. The website additionally keeps a technical copy of the submission. | For the warranty period and the limitation period following it; the technical copy on the website for 10 years |
The technical copy kept by the website
The website keeps a technical copy of form submissions in its own database. The copy is used solely to establish whether a form has worked correctly. It is not used for marketing, for sales or for customer communication, and it is not disclosed to anyone. The technical copy of warranty notifications is kept for 10 years and that of all other form submissions for no more than 90 days, after which it is deleted automatically.
A.2 Measurement and marketing tools in use
| Tool | Identifier | Purpose |
|---|---|---|
| Google Tag Manager | GTM-KVBJPKJ | Management of measurement and marketing tags |
| Google Analytics 4 | G-591Q5Q0357 | Statistics on visitor numbers and site usage |
| Google Ads | AW-10907140170 | Advertising conversion tracking and remarketing |
| Google reCAPTCHA Enterprise | – | Spam protection on forms |
| LinkedIn Insight Tag | Loaded via Google Tag Manager | Conversion measurement and advertising targeting |
| Meta Pixel | Loaded via Google Tag Manager | Advertising targeting and measurement |
| HubSpot | 27126175 (EU instance, js-eu1) | Forms, chat, marketing automation and visitor analytics |
| Hu-manity cookie consent platform | – | Collecting and storing cookie consent |
| Google Consent Mode v2 | – | Communicating consent status to Google services |
A.3 Cookies
Strictly necessary cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| hu-consent | oilon.com | Stores your cookie consent, the consent ID, the categories you selected and the time of consent. | 12 months |
| _GRECAPTCHA | Google reCAPTCHA Enterprise risk analysis on forms, to prevent spam. | 6 months | |
| wordpress_logged_in_*, wordpress_sec_*, wp-settings-*, wp-settings-time-* | oilon.com | Session and display settings for signed-in content management users. Not set for ordinary visitors. | Session / 12 months |
| PHPSESSID | oilon.com | Server session identifier used in form handling. | Session |
Statistics cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| _ga | Distinguishes visitors from one another in Google Analytics 4. | 2 years (browsers limit this to 400 days) | |
| _ga_591Q5Q0357 | Maintains Google Analytics 4 session state for measurement ID G-591Q5Q0357. | 2 years (max. 400 days) | |
| _gid | Distinguishes visitors from one another over a short period. | 24 hours |
Marketing cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| _gcl_au | Google Ads conversion tracking (Conversion Linker): links an ad click to activity on the site. | 90 days | |
| _fbp | Meta | Meta Pixel visitor identifier used for advertising targeting and measurement. | 90 days |
| IDE, test_cookie | doubleclick.net (Google) | Advertising targeting, frequency capping and measurement of advertising performance. | 13 months / 15 minutes |
| bcookie, lidc, li_gc, li_sugr, UserMatchHistory, AnalyticsSyncHistory | linkedin.com | LinkedIn Insight Tag: browser identification, load balancing, storage of consent, advertising targeting and conversion measurement. | 1 day – 2 years |
| __hstc, hubspotutk | oilon.com (HubSpot) | HubSpot visitor identifier used to link forms, chat and e-mails to the same contact record. | 6 months |
| __hssc, __hssrc | oilon.com (HubSpot) | HubSpot session identifiers: visit duration and browser session detection. | 30 minutes / session |
Discontinued cookies
The following cookies are no longer set, but may still be present in your browser from earlier visits. They are not updated, the data in them is not processed, and they expire on their own. You can delete them in your browser settings.
| Cookie | Origin | Status | Expires |
|---|---|---|---|
| _lfa | Leadfeeder | Leadfeeder visitor identification was removed on 8 September 2026. The cookie is no longer set and no data is collected. | Up to 12 months from removal |
| ontame_id.cb71, ontame_ses.cb71 | ontame.io | Recruitment analytics identifier. The script was not detected in the audit of 21 September 2026; the cookie may be a remnant of earlier use. | Up to 12 months |
| cmplz_* | Complianz | Cookies from a previous cookie consent plug-in. The plug-in has been removed. | Expired |
Annex B – oilon.cn
Oilon’s website for the Chinese market at oilon.cn (WordPress), aimed at Chinese-language visitors. The site has no third-party tracking, analytics or advertising tools whatsoever: no services from Google, Meta, LinkedIn, HubSpot, Leadfeeder or Baidu. Visitor statistics are produced solely by the WP Statistics extension running on Oilon’s own server, which uses no cookies and transfers no data to third parties. The site is operated by 奥林燃烧器(无锡)有限公司 / Oilon Burners (Wuxi) Co., Ltd., which is the personal information handler for this site (see Annex G).
B.1 Data collected and why
- Server logs and visitor statistics (IP address, timestamp, page requested, referring page, browser and device data), to ensure information security, investigate technical faults and compile visitor statistics
- Data from the partner application form (company name and website, contact person name, e-mail and telephone, address, the partnership role applied for, products of interest and market area), in order to process the application
- Contact details of those who have given marketing consent, for marketing communication on the basis of that consent
- Your cookie choice and the time at which it was made
B.2 Tools in use
| Tool | Supplier | Purpose |
|---|---|---|
| WP Statistics | Oilon’s own server | Visitor statistics. Runs on the site’s own server and does not transfer data to third parties. |
| Polylang | Site functionality | Remembering the selected language |
| Hu-manity cookie consent platform | Hu-manity.co | Collecting and storing cookie consent |
WP Statistics collects data on the site’s own server without cookies. The site has no third-party visitor analytics, no advertising tracking, no chat tool and no other external tracking scripts. The only external service the site loads is the cookie consent platform.
Forms on the site
The site has one form: the partner application form on the page 加入奥林集团. It is used to apply to become an Oilon sales representative, dealer or service partner. Applications are sent by e-mail to china-marketing@oilon.com and are handled by Oilon Burners (Wuxi) Co., Ltd. in Mainland China. The mailbox is located in Oilon’s Microsoft 365 environment within the European Union, so the application is stored outside Mainland China. That transfer, and the separate consent requested for it, are described in Annex G.
The two contact forms on the site, the general enquiry form and the quotation request form for industrial heat pumps, were withdrawn on 1 October 2026. Enquiries are made to the telephone numbers and e-mail addresses shown on the site. Some of these belong to Oilon Burners (Wuxi) Co., Ltd. and some to dealers and service partners. An enquiry sent to a dealer is handled according to that company’s own practices.
The website does not keep a copy of form submissions in its own database. Storing submissions in the database was discontinued on 1 October 2026 and the material that had accumulated was deleted.
B.3 Cookies
Strictly necessary cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| hu-consent | oilon.cn | Stores your cookie choice and the time it was made. | 12 months |
| pll_language | oilon.cn | Remembers the language you selected (Polylang). | 12 months |
| PHPSESSID | oilon.cn | Server session identifier. Set only where the server needs a session. | Session |
Discontinued cookies
The following cookies are no longer set. They may still be present in your browser from earlier visits, but they are not updated, the data in them is not processed, and they expire on their own. You can delete them in your browser settings.
| Cookie | Origin | Status | Expires |
|---|---|---|---|
| _lfa | Leadfeeder | Visitor identification discontinued in September 2026. | Up to 12 months |
| ontame_id.94c8 | ontame.io | Recruitment analytics discontinued. | Up to 12 months |
| Cookies set through Google Tag Manager | The GTM container was removed from oilon.cn in September 2026. Those cookies are described in Annex A. | See Annex A | |
| Hm_lvt_…, Hm_lpvt_…, HMACCOUNT | Baidu Tongji | Baidu Tongji visitor statistics discontinued on 24 September 2026. The cookies are no longer set and the data in them is not processed. | Up to 12 months |
| Baidu Shangqiao cookies | goutong.baidu.com | The Baidu Shangqiao customer service tool was discontinued on 24 September 2026. | Session – expired |
B.4 Authority filings for the site in China
A website operated in China must be registered with the authorities. The filing numbers are shown in the site footer and can be verified in the authorities’ public registers.
| ICP filing | 苏ICP备2023006794号 – website filing maintained by the Ministry of Industry and Information Technology (MIIT), beian.miit.gov.cn |
|---|---|
| Public security network filing | 苏公网安备32021402005139号 – network filing maintained by the public security authorities, beian.gov.cn |
Annex C – Oilon ONE service platform
Oilon ONE is a service platform for Oilon customers through which Oilon devices can be monitored and managed remotely. The service comprises the following addresses:
| Address | Description |
|---|---|
| cloud.oilon.com | The service platform user interface and device portal |
| oilon.one | Short address for the service, redirecting to cloud.oilon.com |
| info.oilon.com | Information and registration pages for the service (HubSpot CMS) |
C.1 Data collected and why
- User account data: name, e-mail address, organisation, role and language setting – to provide the service and manage access rights
- Authentication data: password hash, public key for passwordless sign-in (passkey), session identifiers and sign-in logs – to secure the service
- Device data: serial number, installation information, system settings and status, measurement, performance and environmental data, alarms and fault messages – to provide remote monitoring, maintenance and support
- Usage logs: sign-ins, actions performed and timestamps – for information security, prevention of misuse and troubleshooting
Measurement data collected from a device is in principle product data, but it constitutes personal data where it can be linked to an identified user or customer. In that case we process it in accordance with this policy.
C.2 Authentication
Oilon ONE uses a Keycloak identity solution (OpenID Connect) operated under Oilon’s own control. The service supports password sign-in and passwordless passkey sign-in. Authentication cookies are strictly necessary and the service cannot be used without them.
C.3 Cookies
Authentication cookies (Keycloak) – strictly necessary
| Cookie | Purpose | Lifetime |
|---|---|---|
| AUTH_SESSION_ID | Authentication session identifier. | Session |
| KC_AUTH_SESSION_HASH | Session-related checksum. | 1 minute |
| KC_STATE_CHECKER, WELCOME_STATE_CHECKER | CSRF protection for sign-in flows and profile management. | 60 days / 300 seconds |
| KC_RESTART | Restarting the sign-in flow. | Session |
| KEYCLOAK_IDENTITY, KEYCLOAK_SESSION | Maintaining the signed-in user’s session. | 60 days |
| KEYCLOAK_LOCALE | The user’s language selection. | Session |
| KEYCLOAK_REMEMBER_ME | Keeps the user signed in. May contain the user’s e-mail address if you select "Remember me". | 12 months |
Device portal and reporting cookies – strictly necessary
| Cookie | Purpose | Lifetime |
|---|---|---|
| JSESSIONID | Server session identifier for the device portal. | Session |
| oilon_one_exp | Stores the session expiry time. | 60 days |
| locale | The user’s language and location selection. | 60 days |
| theme | User interface theme selection (light/dark). | 60 days |
| webshop-region | Remembers the user’s preferred webshop region (EU/US). | 60 days |
| cookieconsent_status | Stores the cookie choice made on the service platform. | 12 months |
| grafana_session, grafana_session_expiry | Session and session expiry for the reporting views (Grafana). | 1 month |
| mo_oauth_login_app_session, mo_oauth_nonce | Sign-in session and single-use identifiers. | 12 hours / 1 hour |
Information and registration page cookies
The information and registration pages at info.oilon.com and the Oilon ONE sign-in page additionally use the statistics and marketing cookies described in Annex A (Google Analytics 4, Google Ads, LinkedIn Insight Tag, Meta Pixel and HubSpot), in accordance with your cookie consent. Once you are signed in, only strictly necessary cookies are used in the service itself.
Annex D – shop.eu.oilon.com (EU webshop)
Oilon’s webshop for the EU market at shop.eu.oilon.com. The shop is built on the WordPress and WooCommerce platform.
D.1 Data collected and why
- Customer and order details: name, company, business ID and VAT number, billing and delivery address, e-mail and telephone number – to process, deliver and invoice orders
- Order and purchase history and order status – for customer service, returns and warranty matters
- Payment data: payment method, payment status and the payment provider’s transaction identifier. We do not process or store payment card numbers; these are handled directly in the secure environment of the payment provider (Stripe)
- User account data if you create an account in the shop
- Order source data (the channel through which you arrived at the shop), to measure marketing performance
- Visitor analytics and advertising measurement data, in accordance with your cookie consent
D.2 Measurement and marketing tools in use
| Tool | Identifier | Purpose |
|---|---|---|
| Google Analytics 4 | G-89BYPQ6X80 | Statistics on visitor numbers and webshop usage |
| Google Tag (gtag) | GT-P3MGSRP | Management of measurement tags |
| Google Ads | AW-10907140170 | Advertising conversion tracking and remarketing |
| LinkedIn Insight Tag | – | Conversion measurement and advertising targeting |
| HubSpot | 27126175 (EU instance) | Forms, chat and marketing automation |
| Stripe | – | Payment processing and payment fraud prevention |
| Hu-manity cookie consent platform | – | Collecting and storing cookie consent |
D.3 Cookies
Strictly necessary cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| hu-consent | Webshop | Stores your cookie consent and the categories you selected. | 12 months |
| woocommerce_cart_hash | Webshop | Stores a hash of the cart contents so that changes are detected. | Session |
| woocommerce_items_in_cart | Webshop | Stores the number of items in the cart. | Session |
| wp_woocommerce_session_* | Webshop | Links the cart and order data to your session. | 48 hours |
| wordpress_logged_in_*, wordpress_sec_*, wp-settings-*, wp-settings-time-* | Webshop | Session, authentication and display settings for signed-in users. | Session / 12 months |
| wordpress_test_cookie | Webshop | Tests whether the browser accepts cookies. | Session |
| oilon_one_exp | Webshop | Session expiry time for automatic sign-in from the Oilon ONE service to the webshop. The same cookie is used in the Oilon ONE service (see Annex C). | 60 days |
| __stripe_mid, __stripe_sid | Stripe | Payment fraud prevention at checkout. Set only when you proceed to checkout. | 12 months / 30 minutes |
Functional and statistics cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| sbjs_first, sbjs_current, sbjs_first_add, sbjs_current_add, sbjs_session, sbjs_udata, sbjs_migrations | Webshop (Source Buster) | Records the channel through which you arrived at the shop so that an order can be attributed to the correct marketing channel. | Session – 6 months |
| tk_ai, tk_qs | Webshop | WooCommerce platform usage statistics. | Session |
| _ga, _ga_89BYPQ6X80 | Distinguishing visitors and maintaining session state in Google Analytics 4. | 2 years (max. 400 days) |
Marketing cookies
| Cookie | Set by | Purpose | Lifetime |
|---|---|---|---|
| _gcl_au | Google Ads conversion tracking. | 90 days | |
| _fbp | Meta | Meta Pixel visitor identifier. | 90 days |
| IDE, test_cookie | doubleclick.net (Google) | Advertising targeting and measurement. | 13 months / 15 minutes |
| bcookie, lidc, li_gc, li_sugr, UserMatchHistory | linkedin.com | LinkedIn Insight Tag: advertising targeting and conversion measurement. | 1 day – 2 years |
| __hstc, hubspotutk, __hssc, __hssrc | Webshop (HubSpot) | HubSpot visitor and session identifiers. | 6 months / 30 minutes / session |
Annex E – shop.us.oilon.com (US webshop)
Oilon’s webshop for the US market at shop.us.oilon.com. The shop is built on the same WordPress and WooCommerce platform as the EU shop and uses the same data categories, processing purposes and cookie categories as described in Annex D, with the following exceptions.
E.1 Differences from the EU webshop
| Item | shop.us.oilon.com |
|---|---|
| Google Analytics 4 | Google Tag ID GT-TBBSS9XW; measurement is routed to Google’s US regional collection endpoint |
| Google Ads | AW-10907140170 (the same identifier as in the other services) |
| HubSpot | 27126175, EU instance (js-eu1) – customer data is processed in the EU |
| Payment processing | Stripe |
| Applicable law | In addition to the GDPR, US state consumer privacy laws – see Annex H |
| Delivery | Delivery address and customs information are disclosed to the carrier and, where necessary, to customs authorities |
| Automatic sign-in | The oilon_one_exp cookie is also used for automatic sign-in from the Oilon ONE service (see Annexes C and D) |
In all other respects the descriptions in Annex D apply. The rights and choices available to consumers resident in the United States are described in Annex H.
Annex F – Origo intranet
Origo is Oilon’s internal intranet, in use at all Oilon locations. It is built on the SharePoint Online service within the Microsoft 365 environment, and users sign in with their Oilon work credentials through Microsoft Entra ID single sign-on. The intranet comprises the shared Oilon Group site and country- and unit-specific sites.
F.1 Personal data processed and purposes
| Purpose | Data categories | Legal basis | Retention period |
|---|---|---|---|
| Providing the intranet and internal communication | Name, work e-mail, user name, organisational unit, job title, location, language and display settings, profile picture | Performance of a contract (Art. 6(1)(b), the employment contract); the employer’s legitimate interest in internal communication (Art. 6(1)(f)) | For the duration of employment; credentials are deactivated when employment ends |
| Content creation and collaboration | Content created and edited by the user, comments, reactions, document version history and authorship data | Performance of a contract (Art. 6(1)(b)); legitimate interest (Art. 6(1)(f)) | According to the life cycle of the content; version history according to system settings |
| Access management and information security | User identifier, sign-in data, device and network data, multi-factor authentication events | Legal obligation (Art. 6(1)(c)); legitimate interest in protecting information systems (Art. 6(1)(f)) | See section F.4 |
| Investigating misuse and information security incidents | Usage logs, file events, sign-in logs | Legitimate interest (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) | See section F.4 |
| Developing internal communication | Aggregated usage statistics: page views, number of unique visitors, most popular content | Legitimate interest (Art. 6(1)(f)) | According to Microsoft’s reporting service |
F.2 Privacy in working life
The data processed in the intranet is employment-related personal data. In addition to the GDPR, its processing is governed by the Finnish Act on the Protection of Privacy in Working Life (759/2004). In accordance with the necessity requirement in section 3 of that Act, we process only data that is directly necessary for the employment relationship; this cannot be derogated from even with the employee’s consent.
Usage log data is not used to assess an individual employee’s performance, efficiency or use of time. Log data is examined at an individual level only for a justified reason, such as investigating an information security incident or suspected misuse, and such examination is recorded in writing.
The purpose, introduction and methods of technical monitoring of employees, and the principles governing the use of e-mail and the data network, are addressed in the dialogue required by the Co-operation Act (1333/2021) before they are introduced, as required by section 21 of the Act on the Protection of Privacy in Working Life.
F.3 Cookies
Origo is an internal tool behind a sign-in. All of the cookies it uses relate to authentication, session management, load balancing, security or user interface settings, and are therefore strictly necessary to provide the service the user has explicitly requested. For this reason no separate consent is requested for them (section 205(2) of the Act on Electronic Communications Services) and there is no cookie banner in the intranet. The intranet does not use cookies for advertising or cross-site tracking.
The cookies are set by Microsoft as part of the service; Oilon cannot change their names or lifetimes. The information below is based on Microsoft’s public documentation and on observations made on the sign-in page on 21 September 2026. Microsoft states that cookie names and definitions may change without notice.
Authentication and session – SharePoint Online (*.sharepoint.com)
| Cookie | Purpose | Lifetime |
|---|---|---|
| FedAuth | Authenticates the signed-in session for each SharePoint site collection and for OneDrive. Without this cookie the intranet cannot be accessed. | Session. Becomes persistent if the user selects "Stay signed in" when signing in; the session then ends after at most 5 days of inactivity. |
| rtFa | Single sign-on cookie covering Oilon’s entire Microsoft 365 environment, allowing the user to move between intranet sites and OneDrive without signing in again. Removed on sign-out. | Same as FedAuth |
| SPOIDCRL | Cookie for the legacy IDCRL authentication method, used mainly by embedded browsers in older desktop and mobile applications. Microsoft is retiring this authentication method during 2026. | Microsoft has not published a lifetime |
| WSS_FullScreenMode | Remembers the user’s full-screen view selection. Note: this cookie does not appear in Microsoft’s current documentation; the information is based on earlier documentation. | Session (unverified) |
Authentication – Microsoft Entra ID (login.microsoftonline.com)
| Cookie | Purpose | Lifetime |
|---|---|---|
| ESTSAUTH | Contains the user’s session information to enable single sign-on. | Session |
| ESTSAUTHPERSISTENT | Same purpose as ESTSAUTH but as a persistent cookie. Set if "Stay signed in" is selected and permitted. | Persistent; Microsoft has not published an exact lifetime |
| ESTSAUTHLIGHT, SignInStateCookie | Lightweight session state cookies used to carry out sign-out. They contain no user information. | Session |
| esctx | Protects against forged session requests (CSRF) by binding a request to a specific browser. Contains no user information. | Session |
| buid, fpc | Browser-related identifiers used by Microsoft for service telemetry, protection mechanisms and request throttling. | Session |
| brcap | Detects browser capabilities (touch support). Observed on 21 September 2026 as a persistent cookie with a lifetime of approximately 13 months; documented by Microsoft as a session cookie. | Approximately 13 months (measured) |
| AADSSOTILES, ESTSSSOTILES, SSOCOOKIEPULLED | Track sign-out state and prevent sign-in loops. They contain no user information. Observation of 21 September 2026: the sign-in page set the cookies AADSSO and SSOCOOKIEPULLED as session cookies. | Session |
| x-ms-gateway-slice, stsservicecookie | Microsoft Entra gateway cookies for load balancing and request routing. | Session |
| CCState and cookies beginning with Ccs | Session state for the Microsoft Entra backup authentication service. | Session |
| x-ms-refreshtokencredential | Used when the device holds a Primary Refresh Token (PRT) tied to Windows sign-in. | Session |
Telemetry and diagnostics
| Identifier | Purpose | Lifetime |
|---|---|---|
| MSFPC | Microsoft’s shared browser identifier across its services. Microsoft states that it uses it for advertising, site analytics and other operational purposes. This is the only identifier in this annex that is not unambiguously strictly necessary. Oilon does not use it for advertising and its data is not available to Oilon. | Approximately 12 months (according to Microsoft’s other product documentation) |
| MicrosoftApplicationsTelemetryDeviceId, MicrosoftApplicationsTelemetryFirstLaunchTime | Telemetry identifiers of Microsoft 365 browser applications, stored in the browser’s local storage. They relate to monitoring the operation and security of Microsoft’s service (required service data). Not verified from Microsoft’s public documentation. | Not documented |
F.4 Usage logs and monitoring
| Type of log | What is recorded | Retention period |
|---|---|---|
| Microsoft Purview audit log | User and administrator actions: opening, editing, sharing and deleting files, changes to access rights, together with a timestamp and source information. | 180 days by default; 12 months for SharePoint, OneDrive, Exchange and Entra ID events for users licensed with Microsoft 365 E5 |
| Microsoft Entra ID sign-in logs | Sign-in attempts, the device and location used, the result of multi-factor authentication, conditional access decisions. | Determined by the Entra ID licence level in Oilon’s Microsoft 365 environment |
| Site and page analytics | Aggregated usage statistics: page views, number of unique visitors and most popular content. Page-level view counts are visible to content owners. | According to Microsoft’s reporting service |
Log data is available to Oilon’s IT administration and to those responsible for information security. It is processed subject to the limitations described in section F.2.
F.5 Data location and transfers
Microsoft Ireland Operations Limited and Microsoft Corporation act as processors on behalf of Oilon under the Microsoft Products and Services Data Protection Addendum (DPA). Oilon is the controller for the intranet content and user data.
Microsoft has announced that it completed the EU Data Boundary in February 2025. Under it, customer data, pseudonymised personal data and data generated in connection with technical support for an environment registered in the EU or EFTA are stored within the EU and EFTA. The exception is limited security situations that require a coordinated global response. Any remaining transfers are subject to the European Commission’s standard contractual clauses, and Microsoft is additionally certified under the EU–US Data Privacy Framework. Microsoft’s current subprocessor list is available from the Microsoft Service Trust Portal.
F.6 Your rights as an internal user
You have the rights described in section 11 in relation to your data processed in the intranet as well. Note, however, that the right to erasure and the right to object are limited to the extent that the processing is based on the employment contract or on a legal obligation. For example, we cannot delete usage log data or work-related content on request alone.
You can exercise your rights by contacting datasecurity@oilon.com. You may also contact your line manager or human resources.
Annex G – Regional supplement: Mainland China
This annex applies to persons located in Mainland China and supplements the general part of this policy. It is based on the Personal Information Protection Law of the People’s Republic of China (中华人民共和国个人信息保护法, PIPL) and related regulations. If the general part and this annex conflict, this annex prevails for persons located in Mainland China.
G.1 Personal information handler
oilon.cn is operated by 奥林燃烧器(无锡)有限公司 / Oilon Burners (Wuxi) Co., Ltd., a company registered in the People’s Republic of China. It determines what personal information is collected on the site and for what purposes, and is therefore the personal information handler (个人信息处理者) within the meaning of the PIPL for this site. The other services described in this policy are the responsibility of Oilon Group Oy.
| Personal information handler | 奥林燃烧器(无锡)有限公司 / Oilon Burners (Wuxi) Co., Ltd. |
|---|---|
| Address | 无锡市新吴区锡梅路 111-3 号 (No. 111-3 Ximei Road, Wuxi New District) |
| Telephone | +86-510-81120922 |
| Contact for privacy matters | datasecurity@oilon.com |
| Response time | Within 15 working days of receiving the request and verifying your identity |
| ICP filing | 苏ICP备2023006794号 |
| Public security network filing | 苏公网安备32021402005139号 |
| Group companies | Oilon Group Oy (group headquarters, Finland), Oilon US Inc., Oilon Brasil Energia Ltda. |
Because the personal information handler is established in Mainland China, no representative in China under Article 53 of the PIPL is required. We have appointed a dedicated personal information protection team and a person in charge.
G.2 Data processed, purposes and retention (Art. 17 PIPL)
The site has one form, the partner application form. Other processing is limited to what arises automatically from use of the site.
| Type of data | Method of processing | Purpose | Retention period |
|---|---|---|---|
| IP address, timestamp, page requested, referring page, browser and device data | Collected automatically in the server log and in the WP Statistics extension on the site’s own server | Ensuring information security, investigating technical faults and compiling visitor statistics | 12 months |
| Cookie choice, the time it was made and the consent identifier | Stored in the cookie consent platform | Honouring your choice and evidencing consent | 12 months |
| Partner application data: company name and website, contact person name, e-mail and telephone, address, partnership role, product interest and market area | Collected through the partner application form and sent by e-mail to china-marketing@oilon.com | Processing of and response to the partner application | 24 months from the handling of the application, unless a partnership begins |
We do not collect sensitive personal information (敏感个人信息) within the meaning of the PIPL on oilon.cn. The site has no third-party visitor analytics, no advertising tracking and no chat tool, and we do not make significant decisions based on automated decision-making.
G.3 Recipients
| Recipient | Role and purpose | Location |
|---|---|---|
| Nordic Business House Co., Ltd. / 努蒂商务咨询(上海)有限公司 | Technical maintenance of the site on behalf of Oilon Burners (Wuxi) Co., Ltd. (Art. 21 PIPL) | Shanghai, Mainland China |
| Oilon Group Oy – Microsoft 365 environment | Delivery and storage of partner application e-mail in the group mail environment. The applications are handled by Oilon Burners (Wuxi) Co., Ltd. | European Union – see G.4 |
| Cookie consent platform (Hu-manity.co) | Collecting, storing and evidencing the cookie choice | European Union – see G.4 |
We do not provide data collected on oilon.cn to any other third party. We disclose data to the authorities only where the law requires it.
G.4 Separate consent and transfers outside Mainland China
The server logs and the visitor statistics collected by the WP Statistics extension remain on a server located in Mainland China and are not transferred outside China.
The cookie consent platform is a European service. Your cookie choice, the time it was made and the consent identifier are stored on its servers outside Mainland China. This happens whether you accept or refuse non-essential cookies, because the choice has to be remembered and evidenced afterwards.
The data you provide in the partner application form is sent by e-mail to china-marketing@oilon.com, and the application is handled by Oilon Burners (Wuxi) Co., Ltd. in Mainland China. The mailbox is located in Oilon’s Microsoft 365 environment within the European Union, so the data is stored outside Mainland China. This is a transfer within the meaning of Article 39 of the PIPL, and we ask for a separate consent to it on the form before the application is sent. No other transfer of personal information outside Mainland China takes place on the site.
We ask for your separate consent (单独同意) if we provide personal information to a third party (Art. 23 PIPL) or transfer it outside Mainland China (Art. 39 PIPL). In that case we state the recipient’s name and contact details, the purpose and method of processing, the types of data concerned, and how you can exercise your rights against the recipient. Giving consent is voluntary, and you may withdraw it at any time as easily as you gave it. We will not refuse to provide the content of the site on the ground that you decline non-essential processing (Art. 16 PIPL).
Transfers are subject to the Chinese rules on cross-border data transfers, including the Provisions on Promoting and Regulating Cross-Border Data Flows issued in March 2024. The volume of personal information transferred is well below the thresholds that would require filing of a standard contract, personal information protection certification, or a security assessment by the Cyberspace Administration. We monitor the volume and will put in place the appropriate transfer mechanism should a threshold be exceeded.
G.5 Your rights under the PIPL
| Right | What it means | PIPL |
|---|---|---|
| Right to know and to decide | The right to be informed about the processing and to restrict or refuse it. | Art. 44 |
| Right to access and obtain a copy | The right to review your data and obtain a copy of it. | Art. 45 |
| Right to transfer data | The right to request transfer to another handler where the conditions set by the Cyberspace Administration are met. | Art. 45 |
| Right to correction and supplementation | The right to correct inaccurate or incomplete data. | Art. 46 |
| Right to deletion | The right to have data deleted where the purpose has been achieved, you withdraw consent, or the processing is unlawful. | Art. 47 |
| Right to withdraw consent | The right to withdraw consent as easily as it was given. | Art. 15 |
| Right to an explanation | The right to request an explanation of the processing rules. | Art. 48 |
| Rights of a deceased person’s relatives | Close relatives of a deceased person may exercise the above rights to protect their own lawful interests. | Art. 49 |
| Right to complain | The right to lodge a complaint with us and with the authorities. | Art. 50 |
You can exercise your rights by sending a request to datasecurity@oilon.com. We will respond without delay and in any event within 30 days; for requests made through oilon.cn we respond within 15 working days. We may ask you to verify your identity. We do not, in principle, charge a fee for reasonable requests.
G.6 Persons under 14
Our site is directed at business customers and is not intended for persons under 14. Under the PIPL, the personal information of a person under 14 is sensitive personal information, and processing it requires the consent of a guardian and dedicated processing rules. We do not knowingly collect personal information from persons under 14. If we become aware that we have collected such data, we will delete it without delay.
G.7 Supervisory authority
If you consider that we have infringed the PIPL, you may lodge a complaint with the Cyberspace Administration of China (国家互联网信息办公室) or its local office, or with another competent authority. If you are not satisfied with our response and consider that our processing of personal information has harmed your lawful rights, you may in addition bring an action before the People’s Court of the district in which our representative in Mainland China is located (无锡市新吴区, Xinwu District, Wuxi).
Annex H – Regional supplement: United States
This annex applies to persons resident in the United States and supplements the general part of this policy. It is based on US state consumer privacy laws, including the California Consumer Privacy Act as amended by the CPRA, and the corresponding laws of Colorado, Connecticut, Texas, Virginia and other states. We apply these practices to all visitors resident in the United States, regardless of whether an individual law applies to us.
H.1 Categories of personal information collected in the preceding 12 months
| Category (CCPA) | Examples | Sources | Disclosed for a business purpose / shared for advertising |
|---|---|---|---|
| Identifiers | Name, postal address, e-mail, telephone number, IP address, cookie identifiers, account number | Directly from you; automatically via cookies | Disclosed: yes. Shared for advertising: yes (cookie identifiers) |
| Commercial information | Products purchased, order history, payment status | Directly from you; from the payment provider | Disclosed: yes. Shared for advertising: no |
| Internet or network activity | Browsing history on our site, clicks, search terms, advertisement views | Automatically via cookies | Disclosed: yes. Shared for advertising: yes |
| Geolocation data | Approximate location from the IP address (city/state). We do not collect precise geolocation. | Automatically | Disclosed: yes. Shared for advertising: yes |
| Professional or employment information | Job title, employer, industry | Directly from you | Disclosed: yes. Shared for advertising: no |
| Inferences | Interests and product preferences used to target marketing | Derived from the above | Disclosed: yes. Shared for advertising: yes |
| Sensitive personal information | Account log-in credentials in combination with a password | Directly from you | Used only to provide the service. Not sold and not shared. |
Retention periods are set out in section 5 of this policy and in annexes A–E. We do not collect biometric data, health data, precise geolocation, or data on race, religion, union membership or sexual orientation within the meaning of US state privacy laws.
H.2 "Sale" and "sharing" of personal information
We do not sell your personal information for money. Under the laws of California and certain other states, however, the terms "sale" and "sharing" are defined broadly: disclosing identifiers to an advertising partner through advertising and analytics cookies may fall within their scope. Because we use Google Ads, LinkedIn Insight Tag and Meta Pixel cookies to target advertising across sites, we treat this activity as "sharing" within the meaning of those laws as a precautionary measure.
H.3 Your rights and how to exercise them
| Right | What it means |
|---|---|
| Right to know and to access | You may ask what personal information we have collected, from which sources, for which purposes and to whom we have disclosed it in the preceding 12 months, and obtain a copy of the information. |
| Right to delete | You may ask us to delete the personal information we have collected, subject to the exceptions provided by law. |
| Right to correct | You may ask us to correct inaccurate information. |
| Right to opt out of sale and sharing | You may opt out of the sale and sharing of your personal information for advertising. Use the "Do Not Sell or Share My Personal Information" or "Your Privacy Choices" link in the site footer. |
| Right to limit the use of sensitive personal information | We use sensitive personal information only to provide the service and for security purposes, not for any other purpose, so no separate limitation request is needed. |
| Right to opt out of targeted advertising and profiling | You may opt out of the use of your data for targeted advertising and for profiling that produces significant effects (including in Colorado, Connecticut, Texas and Virginia). |
| Right to data portability | You may request your data in a machine-readable format. |
| Right to appeal a decision | If we deny your request, you may appeal by e-mailing datasecurity@oilon.com with the subject "Privacy appeal". We will respond to the appeal within 45 days and explain the reasons for our decision. If we deny the appeal, we will provide instructions on how to contact your state Attorney General. |
| Right to non-discrimination | We will not deny you our services, charge you a different price, provide a different level of service, or otherwise discriminate against you for exercising your privacy rights. |
H.4 Universal opt-out signals (Global Privacy Control)
We recognise and honour the Global Privacy Control (GPC) signal sent by your browser or browser extension as a binding opt-out of the sale and sharing of personal information and of targeted advertising. The signal applies to the browser and device from which it is sent. If you are signed in to your account, we also apply the opt-out to your account.
H.5 Submitting and handling requests
- Send your request by e-mail to datasecurity@oilon.com or use the contact form on our website.
- We verify your identity before processing the request. We ask only for the information necessary for verification and do not use it for any other purpose.
- You may authorise an agent to submit a request on your behalf. In that case we ask for proof of authorisation and may ask you to confirm the authorisation directly with us.
- We respond to requests within 45 days. We may extend the deadline by a further 45 days where the request is complex, and will notify you if we do.
- Handling requests is free of charge.
H.6 Minors
We do not knowingly collect personal information from persons under 13, and we do not sell or share the personal information of persons under 16 without express authorisation. If we become aware that we have collected such information, we will delete it without delay.
H.7 Nevada residents
Under Nevada law (NRS 603A), Nevada residents may opt out of the sale of certain personal information. We do not sell personal information within the meaning of Nevada law, but you may submit an opt-out request to datasecurity@oilon.com.
Annex I – Regulatory basis
This annex lists the regulations, directives, national laws, authority guidelines and standards on which this privacy policy is based, and states what has been applied from each. The list reflects the legislation in force on 24 September 2026.
I.1 European Union regulations and directives
| Instrument | Provisions applied | What has been applied |
|---|---|---|
| Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR) | Articles 5, 6, 7, 9, 12–14, 15–22, 24–28, 30, 32–34, 44–49 and 77 | The structure of the entire policy: processing principles, legal bases, the content of the duty to inform (sections 1–9), data subject rights (section 11), security and breach notification (section 10), international transfers (section 8) and the right to lodge a complaint (section 16) |
| Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (ePrivacy Directive), as amended by Directive 2009/136/EC | Article 5(3) and Article 13 | The requirement of consent for storing and reading information on terminal equipment (section 12 and the cookie tables in annexes A–E), and the conditions for electronic direct marketing |
| Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries | Modules 1 and 2 | Transfer basis for service providers outside the EU and the EEA (section 8) |
| Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 on the adequate level of protection of personal data under the EU–US Data Privacy Framework | The decision as a whole | Transfer basis for certified US service providers (section 8). The action for annulment of the decision was dismissed on 3 September 2025 in Case T-553/23 (Latombe v Commission); an appeal is pending before the Court of Justice |
| Regulation (EU) 2022/1925 (Digital Markets Act) and Regulation (EU) 2022/2065 (Digital Services Act) | As applicable | Taken into account in the description of third-party advertising platforms and embedded content (section 13) |
I.2 National legislation in Finland
| Instrument | Provisions applied | What has been applied |
|---|---|---|
| Data Protection Act (1050/2018) | Sections 4–7, 8–9 and 14 | National supplements to the legal bases, the powers of the supervisory authority, and provisions on the data protection officer (sections 2, 5 and 16) |
| Act on Electronic Communications Services (917/2014) | Sections 200, 202 and 205 | Section 200: conditions for electronic direct marketing to natural persons (section 5). Section 202: direct marketing to legal persons (section 5). Section 205: the consent requirement for cookies and information stored on terminal equipment, and the exemption for strictly necessary cookies (section 12) |
| Accounting Act (1336/1997) | Chapter 2, section 10, subsection 2 | The six-year retention period for vouchers and other accounting records (sections 5 and 9) |
| Value Added Tax Act (1501/1993) | Sections 209n–209p | Retention of invoices and vouchers for webshop orders (section 5) |
| Act on the Protection of Privacy in Working Life (759/2004) | Sections 3–4 | The necessity requirement and the collection of data in recruitment (section 5) |
| Co-operation Act (1333/2021) | Chapter 2 | Handling of technical monitoring of employees and of data network usage principles in that dialogue (Annex F) |
| Consumer Protection Act (38/1978) | Chapters 2 and 6 | Information duties concerning distance selling and marketing in the webshops (annexes D and E) |
I.3 Authority guidance and interpretation
| Guidance | What has been applied |
|---|---|
| European Data Protection Board / WP29: Guidelines on transparency under Regulation 2016/679, WP260 rev.01 (2018) | Clear and plain language, layered presentation, tabular format, and what information must be given before processing begins |
| EDPB: Guidelines 05/2020 on consent under Regulation 2016/679 | Consent must be freely given, specific, informed and unambiguous, and easy to withdraw (section 12) |
| EDPB: Guidelines 03/2022 on deceptive design patterns | Accepting and refusing must be equally easy and equally prominent; no pre-ticked options in the cookie banner |
| EDPB: Guidelines 2/2023 on the technical scope of Article 5(3) of the ePrivacy Directive | Extension of the consent requirement beyond cookies: local storage, pixels and device fingerprinting (section 12) |
| EDPB: Guidelines 07/2020 on the concepts of controller and processor | Definition of roles in the recipients table in section 7, including joint controllership with advertising platforms |
| EDPB: Recommendations 01/2020 on measures that supplement transfer tools | Use of transfer impact assessments and supplementary measures alongside standard contractual clauses (section 8) |
| Finnish Transport and Communications Agency Traficom: Cookie guidance for service providers (recommendation) | How consent is requested, equally easy refusal, information to be given to users, the validity period of consent and its withdrawal (section 12) |
| Office of the Data Protection Ombudsman: guidance on informing data subjects and handling their requests | The structure of the information provided and the deadlines for handling requests (sections 11 and 16) |
I.4 International standards
| Standard | What has been applied |
|---|---|
| ISO/IEC 29184, Online privacy notices and consent | The structure and content of the privacy notice: presentation of processing purposes, requesting and managing consent, and the ease of changing choices |
| ISO/IEC 29100, Privacy framework | Consistency of privacy principles and terminology (Annex J) |
| ISO/IEC 27701, Privacy information management | The structure of the privacy management system and the allocation of controller and processor obligations |
| ISO/IEC 27001 and ISO/IEC 27002 | The structure of the security measures in section 10: access control, encryption, logging, backups, training and auditing |
| W3C Community Group: Global Privacy Control specification | Recognition of and compliance with the universal opt-out signal (Annex H.4) |
I.5 Third-country legislation
| Instrument | Provisions applied | What has been applied |
|---|---|---|
| Personal Information Protection Law of the People’s Republic of China (中华人民共和国个人信息保护法, PIPL), in force since 1 November 2021 | Articles 13–17, 21, 23–24, 28–31, 38–39, 44–50 and 53 | Annex G in its entirety: the content of the duty to inform, separate consent, entrusted processing (Art. 21), data subject rights, persons under 14 and cross-border transfers. Article 53 has been assessed but does not apply, because the personal information handler for oilon.cn is established in Mainland China |
| Cybersecurity Law (网络安全法) and Data Security Law (数据安全法) of the People’s Republic of China | As applicable | General information security and data classification obligations on oilon.cn |
| Provisions on Promoting and Regulating Cross-Border Data Flows (促进和规范数据跨境流动规定), 22 March 2024 | Volume thresholds and exemptions | Annex G.4: assessment of which transfer mechanism applies to the transfer of leads from oilon.cn to Finland |
| Network Data Security Management Regulations (网络数据安全管理条例), in force since 1 January 2025 | As applicable | Obligations regarding keeping the notice up to date and data minimisation |
| National standard GB/T 35273, Information security technology – Personal information security specification | Provisions on cookies, consent and the clarity of the notice | The classification of cookies in Annex B and the intelligibility and prominence of the notice in China |
| California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act, and the regulations issued thereunder (Cal. Code Regs. tit. 11 § 7000 et seq.) | §§ 1798.100, 1798.105, 1798.106, 1798.110, 1798.115, 1798.120, 1798.121, 1798.125, 1798.130, 1798.135 and 1798.140 | Annex H: presentation of data categories for the preceding 12 months, the right to opt out of sale and sharing, the right to limit the use of sensitive information, non-discrimination, and the deadlines for handling requests |
| Consumer privacy laws of Colorado (C.R.S. § 6-1-1301 et seq.), Connecticut, Texas, Virginia and other states | Universal opt-out mechanism, right to appeal, opt-out of targeted advertising | Annex H.3 and H.4: the appeal procedure with its 45-day deadlines, compliance with the GPC signal, and the right to opt out of targeted advertising and profiling |
| Nevada Revised Statutes 603A | §§ 603A.300–603A.360 | Annex H.7: the opt-out right of Nevada residents |
| Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506) | The Act as a whole | Annex H.6 and section 14: restrictions concerning persons under 13 |
I.6 Legislation under monitoring
We actively monitor the progress of the following and will update this policy as necessary:
- The European Commission’s Digital Omnibus package, which contains a proposal to move the cookie consent provisions from the ePrivacy Directive into the General Data Protection Regulation. The proposal is under negotiation and is not in force. If adopted, it may change how consent is requested and the status of browser-based consent signals.
- The appeal pending before the Court of Justice in Case T-553/23 (Latombe v Commission) concerning the adequacy decision on the EU–US Data Privacy Framework.
- The entry into force of new US state consumer privacy laws and California’s new regulations on automated decision-making technology.
- China’s measures on personal information protection certification, which entered into force on 1 January 2026.
Annex J – Definitions and version history
J.1 Key definitions
| Term | Explanation |
|---|---|
| Personal data | Any information relating to an identified or identifiable natural person. |
| Controller | The party that determines the purposes and means of the processing of personal data. In this policy, Oilon. |
| Processor | A party that processes personal data on behalf of and on the instructions of the controller. |
| Joint controllers | Two or more parties that jointly determine the purposes and means of processing. |
| Cookie | A small text file stored on your device when you visit a website. |
| Tracking pixel | An invisible image or script embedded in a page, used to measure whether a page was opened or an action taken. |
| Consent | A freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data. |
| Profiling | Automated processing of personal data to evaluate personal aspects, such as interests. |
J.2 Document version history
| Version | Date | Changes |
|---|---|---|
| 1.0 | 16 Oct 2023 | First published version |
| 2.0 | 16 Jun 2025 | Updated cookie tables and contact details |
| 3.0 | 28 Sep 2026 | Consolidated all five customer-facing services into a single document and added the internal Origo intranet. Cookie information audited and updated to reflect the actual situation. Added service-specific annexes A–E, an annex on the Origo intranet (F), a China annex (G) and a United States annex (H). Added processing purposes, legal bases and retention periods in tabular form, a section on international transfers, and Annex I setting out every regulation, directive, national law, authority guideline and standard on which the policy is based. Updated on 23 September 2026 following comments from Oilon specialists: the representative in Mainland China specified as Oilon Burners (Wuxi) Co., Ltd.; the Baidu tools removed from Annex B; the oilon_one_exp cookie added to the webshop cookie tables and referenced in Annexes C and E. The business VAT number was added. Baidu Tongji and Baidu Shangqiao were removed from oilon.cn entirely on 24 September 2026 at the request of Oilon’s China organisation, and the removal was verified technically the same day. Annex B and Annex G were updated accordingly: the site no longer has any third-party tool and no non-essential cookies. The contact address for Mainland China was changed to datasecurity@oilon.com, and the site’s ICP and public security filings were added to Annex B. On 28 September 2026 the roles for oilon.cn were clarified: the site is operated by, and the personal information handler is, Oilon Burners (Wuxi) Co., Ltd., so no representative under Article 53 PIPL is required. The site’s contact form is being withdrawn, after which no personal data is collected through forms on the site. The maintenance partner Nordic Business House Co., Ltd. was added to the recipients. A Chinese-language version was published, incorporating the still-current content of the Chinese privacy policy that took effect on 11 October 2023; that policy is superseded by this version. |
| 3.1 | 1 Oct 2026 | Corrected to reflect the actual situation on oilon.cn and oilon.com. Version 3.0 stated that the contact form on oilon.cn would be withdrawn and that no personal data would be collected through forms on the site. A review of the site on 1 October 2026 established that there were three forms. The general enquiry form and the quotation request form for industrial heat pumps were withdrawn, and the partner application form remained in use; the data it collects is sent to china-marketing@oilon.com and the applications are handled by Oilon Burners (Wuxi) Co., Ltd., while the mailbox is located in Oilon’s Microsoft 365 environment within the European Union, which is described in Annex G as a transfer and as the separate consent requested for it. Annex B was clarified accordingly. The Flamingo extension in use on both sites had been storing a copy of every form submission in the website database with no retention period: on oilon.cn storage was discontinued and the accumulated material deleted in full, and on oilon.com a retention period was introduced under which warranty notifications are kept for 10 years and all other form submissions for no more than 90 days. Annex A was extended with the two separate routes for form data, with warranty notifications as processing in their own right, and with the retention periods for the technical copy kept by the website. |
| 3.2 | 14 Oct 2026 | The statutory references in Annex I were checked against the consolidated Finnish legislation in force. The retention obligation in the Value Added Tax Act is in sections 209n–209p, not 209e–209g, and the six-year retention period in chapter 2, section 10 of the Accounting Act is in subsection 2. The name of Act 1333/2021 was corrected from that of its repealed predecessor to the Co-operation Act, and the procedure was renamed dialogue. Section 202 of the Act on Electronic Communications Services, which concerns direct marketing to legal persons, was added to the regulatory basis; section 200 applies only to natural persons. In the recipient table in section 7, the Microsoft row now also covers the mailboxes that receive form submissions from the websites. The retention period for sign-in logs in Annex F is now expressed as the criterion that determines it. Legal-language and date harmonisations were also made. |
Oilon Group Oy · VAT number FI02131514 · Data protection: datasecurity@oilon.com