Accepted on: 29/06/2020
Pyhäjärvenkatu 5 A 25
tel. +358 3 33991300
email address: firstname.lastname@example.org
(hereafter ”we” or “Haarla”)
2. Contact person for register matters
tel. +358 3 33991314
email address: email@example.com
3. Name of register
4. What is the purpose and the legal basis of processing personal data?
The purposes of processing personal data are:
- the delivery and development of our products and services,
- fulfilling our contractual and other promises and obligations,
- taking care of the customer, supplier or stakeholder relationship,
- analyzing and profiling the behavior of a customer, supplier, stakeholder or other data subject,
- electronic direct marketing and
We use profiling but not automated decision-making to identify online behavior. We use this information e.g. to to develop our services and webpages.
The basis of processing personal data is our legitimate interest based on customer relationship and/or other relevant connection, to perform a contract and consent.
5. What data do we process?
We process the following personal data of our customers, suppliers, stakeholders or other data subjects, such as the participants of our events, in connection with the customer register:
- information of company and company’s contact persons* such as business ID, names and contact details of the contact persons;
- basic and contact information of the data subject* such as name, customer number, email address, phone number and preferred language;
- possible prohibitions of direct marketing;
- information of the participants of events and possible information regarding the event, such as special diets;
- information regarding the customer relationship and the contract* such as past and current contracts and orders, user profile formed based on the customer relationship, correspondence with the customer/data subject and other contacts, cookies and data related to using them;
- other possible information gathered with data subject’s consent.
Providing personal data marked with an asterisk is a requirement for our contractual and/or customer relationship. Without the necessary information we are not able to provide the product and/or service.
6. From where do we receive data?
We receive information primarily from the following sources: yourself, credit information companies, contact information service providers and other similar reliable sources.
For the purposes described in this privacy notice, personal data may also be collected and updated from publicly available sources and based on information received from the authorities or other third parties within the limits of the applicable laws and regulations. Such updating of data is performed manually or by automated means.
7. To whom do we disclose data, and do we transfer data outside the EU or the EEA?
We don’t disclose data from the register to external parties.
We use subcontractors that process personal data on our behalf. We have outsourced the IT-management to an external service provider, on whose administrated and secured server the personal data is stored.
We transfer personal data outside the EU/EEA. When personal data is processed outside the EU/EEA, we make sure that the subcontractor has committed to use the EU Commission’s standard contractual clauses and/or is covered by the Privacy Shield -system.
8. How do we protect the data and how long do we store them?
Only those of our employees, who on behalf of their work are entitled to process customer, supplier or stakeholder data, are entitled to use the system containing personal data. Each user has a personal username and password to the system. The data is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and their backup copies are in locked premises and can be accessed only by certain pre-designated persons.
We store the data as long as it is necessary for the purpose of processing the data. Personal data in the customer, supplier and stakeholder register is erased after the claim period related to a specific customer, supplier or service relationship has elapsed. This period is typically ten (10) years. Data related to marketing activities is processed until further notice.
We estimate the need for data storage regularly, taking into account the applicable legislation. In addition, we take care of such reasonable actions that ensure no incompatible, outdated or inaccurate personal data is stored in the register taking into account the purpose of the processing. We correct or erase such data without delay.
9. What are your rights as a data subject?
You have the right to inspect the personal data stored in the register concerning yourself and the right to demand rectification or erasure of the data. If you have access to your data, you may edit the data yourself. Insofar as the processing is based on consent, you also have the right to withdraw or change your consent. Withdrawing your consent does not affect the lawfulness of processing before the withdrawal of the consent.
You have the right to object or to demand restriction of the processing of your data and to lodge a complaint with the supervisory authority.
On grounds relating to your particular situation you also have the right to object other processing activities when the legal basis of processing is legitimate interest. In connection with your request, you shall identify the specific situation, based on which you object to the processing. We can refuse the request of objection only on legal grounds.
10. Who can you be in contact with?