Educational lifestyle and productivity content only — not medical, psychological, or therapeutic advice. We are not a healthcare provider. Full disclaimer

Shoulderbrhip.ddd logo

Privacy Policy

Last updated: 5 June 2026

This Privacy Policy describes how Shoulderbrhip.ddd ("we", "us", "our") collects, uses, stores, and protects your personal data when you visit our website or contact us.

We process personal data in accordance with:

  • Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR)
  • Finnish Data Protection Act (Tietosuojalaki 1050/2018)
  • Finnish Act on Information Society Services (Laki tietoyhteiskunnan palvelujen tarjoamisesta 917/2014)
  • Directive 2002/58/EC (ePrivacy Directive), as implemented in Finland — see our Cookie Policy

1. Data Controller

The data controller responsible for your personal data is:

We have not appointed a Data Protection Officer (DPO), as our processing activities do not meet the mandatory DPO appointment criteria under Article 37 GDPR. For all data protection matters, please contact us using the details above.

2. Categories of Personal Data We Collect

2.1 Data You Provide Voluntarily

  • Contact form: name, email address, message content, and confirmation of consent to data processing.
  • Cookie preferences: your choices regarding analytics and marketing cookies, stored locally in your browser.

Providing data through the contact form is voluntary. However, we cannot respond to your inquiry without your name, email address, and consent.

2.2 Data Collected Automatically

  • Technical data: IP address, browser type and version, device type, operating system, referring URL, date and time of access.
  • Usage data: pages visited, time spent on pages, navigation paths (only if you consent to analytics cookies).
  • Server log data: collected by our hosting provider for security and troubleshooting.

2.3 Data We Do Not Collect

We do not intentionally collect special categories of personal data (such as health data, political opinions, or religious beliefs) through this website. Please do not include sensitive personal data in contact form messages.

3. Purposes and Legal Bases for Processing

Under Article 6 GDPR, we process your personal data only where a legal basis applies:

PurposeLegal BasisDetails
Responding to contact form inquiries Consent (Art. 6(1)(a)) and legitimate interest (Art. 6(1)(f)) Processing is necessary to handle your request and maintain correspondence.
Website functionality and security Legitimate interest (Art. 6(1)(f)) Ensuring the website operates correctly and protecting against abuse.
Storing cookie consent choices Legitimate interest (Art. 6(1)(f)) and legal obligation Demonstrating compliance with consent requirements under Finnish and EU law.
Analytics Consent (Art. 6(1)(a)) Only activated after you explicitly accept analytics cookies.
Marketing Consent (Art. 6(1)(a)) Only activated after you explicitly accept marketing cookies, in line with the Finnish Advertising Act (Mainontalaki 493/2021).
Legal compliance and authority requests Legal obligation (Art. 6(1)(c)) When required by Finnish or EU legislation.

Where we rely on legitimate interest, we have assessed that our interests do not override your fundamental rights and freedoms. You may object to such processing (see Section 8).

4. Data Retention Periods

We retain personal data only for as long as necessary for the purposes stated above:

  • Contact form submissions: up to 12 months after the inquiry is resolved, unless a longer retention period is required by Finnish law (e.g. accounting or limitation periods).
  • Analytics data: up to 26 months from collection, or until you withdraw consent — whichever is earlier.
  • Cookie consent records: up to 12 months in your browser's local storage, to demonstrate valid consent.
  • Server logs: up to 90 days for security and incident investigation purposes.

After the retention period expires, data is deleted or anonymised so it can no longer be linked to you.

5. Recipients and Data Transfers

We do not sell, rent, or trade your personal data. Data may be shared with the following categories of recipients:

  • Hosting and IT service providers — primarily located within the EU/EEA, providing website hosting and technical infrastructure.
  • Analytics service providers — only if you have given consent; may include providers outside the EEA.
  • Advertising service providers — such as Google Ads, only if you have given consent to marketing cookies; used to measure campaigns and improve relevance of educational content promotion.
  • Embedded service providers — such as Google Maps on our contact page, governed by their own privacy policies.
  • Public authorities — when disclosure is required under Finnish or EU law.

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:

  • European Commission adequacy decisions, or
  • Standard Contractual Clauses (SCCs) approved by the European Commission, or
  • Other mechanisms permitted under Chapter V GDPR.

You may request a copy of applicable transfer safeguards by contacting us.

6. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you, as defined in Article 22 GDPR.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

  • HTTPS/TLS encryption for data transmitted via the website
  • Access controls limiting who can view personal data
  • Secure hosting within the EU/EEA
  • Regular review of security practices

In the event of a personal data breach likely to pose a risk to your rights, we will notify the Office of the Data Protection Ombudsman and, where required, affected data subjects in accordance with Articles 33 and 34 GDPR.

8. Your Rights Under GDPR and Finnish Law

As a data subject, you have the following rights under the GDPR and the Finnish Data Protection Act:

  • Right of access (Art. 15) — obtain confirmation of whether we process your data and receive a copy.
  • Right to rectification (Art. 16) — request correction of inaccurate or incomplete data.
  • Right to erasure (Art. 17) — request deletion where processing is no longer lawful or necessary.
  • Right to restriction of processing (Art. 18) — request that we limit how we use your data in certain circumstances.
  • Right to data portability (Art. 20) — receive data you provided in a structured, machine-readable format, where processing is based on consent or contract.
  • Right to object (Art. 21) — object to processing based on legitimate interest, including direct marketing at any time.
  • Right to withdraw consent (Art. 7(3)) — withdraw consent at any time without affecting the lawfulness of prior processing. You can withdraw cookie consent via our Cookie Policy instructions or by contacting us.

To exercise any of these rights, contact us at inquiry@shoulderbrhip.world. We will respond without undue delay and within one month, as required by Article 12(3) GDPR. This period may be extended by two further months for complex requests; we will inform you of any extension.

We may need to verify your identity before processing your request. There is no fee for exercising your rights, unless a request is manifestly unfounded or excessive.

9. Right to Lodge a Complaint

If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with the supervisory authority:

  • Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto)
  • Address: Lintulahdenkuja 4, 00530 Helsinki, Finland
  • Website: tietosuoja.fi
  • Email: tietosuoja@om.fi

10. Children's Personal Data

Under Finnish law, the age of digital consent is 13 years. Our website is intended for a general audience and is not directed at children. We do not knowingly collect personal data from anyone under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, technology, or our practices. Material changes will be indicated by updating the "Last updated" date. Where required by law, we will seek renewed consent or provide additional notice. We encourage you to review this page periodically.

12. Contact

For privacy-related questions or to exercise your rights: