DATA PROTECTION POLICY FOR FINMUG Ltd’S CUSTOMER REGISTER

1 Controller

The controller is Finmug Ltd (business ID FI29256341)

Contact person for matters related to the file: Jakke Niskanen, Managing Director

Finmug Ltd

Address: Jahtikuja 1D10, 90540 Oulu (Finland)

Telephone: +358442555649

E-mail: info@finmug.fi

2 Name of file

The name of the file is Finmug Ltd's customer register.

3 The purpose of processing personal data

Personal data are processed for purposes related to maintaining, managing and developing the customer relationship, offering, supplying and developing services as well as invoicing. Personal data are also processed for the purposes necessitated by resolving any possible complaints and other claims.

Furthermore, personal data are processed in communications directed at customers as well as marketing, in conjunction to which the data are also processed for purposes pertaining to direct marketing and electronic direct marketing.

Customers have the right to refuse direct marketing targeted at them.

The controller processes personal data directly and also utilises subcontractors working on its behalf in the processing activities.

4 Legal grounds of the processing

The legal grounds for processing personal data are the following grounds specified in the European Union’s General Data Protection Regulation (hereinafter referred to as “GDPR”):

1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes (GDPR Art. 6(1)(a));
2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (GDPR Art. 6(1)(b));
3. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (GDPR Art 6(1)(f)).

The aforementioned legitimate interest of the register keeper is based on a meaningful and appropriate relationship between the data subject and controller as a result of the data subject being a customer of the controller and the processing being conducted for purposes that the data subject can have reasonably anticipated at the time of collecting the personal data and in the context of the appropriate relationship.

5 Data content of the file (categories of personal data processed)

As a general rule, the file contains the following personal data on all data subjects:

1. basic information and contact information for the person: first name, last name, address, telephone number, e-mail address;
2. information related to the person’s company or other organisation and the person’s position or title in the company or organisation in question;
3. direct marketing permissions and bans for the person.

6 Regular sources of information

Personal data are collected from the data subjects themselves.

In addition to this, personal data are collected within the framework of the applicable legislation from generally available sources that pertain to fulfilling the relationship between the controller and data subject, and that the controller can use to perform its duties related to maintaining customer relationships.

7 Storage period of personal data

Personal data collected in the file are stored only for as long and to the extent that is necessary in relation to the original or a compatible purpose for which the personal data has been collected.

 

The need to retain personal data is assessed every five years and, in any case, data concerning a data subject are removed from the file five years after the end of the customer relationship between the data subject in question and the controller has ended, and the obligations and measures related to the customer relationship have been fulfilled. For example, accounting records are kept for six years after the end of a financial period.

 

The controller shall regularly assess the necessity of storing the data in accordance with its internal code of conduct. Furthermore, the controller shall by all reasonable measures ensure that any personal data that are inaccurate, erroneous or contain obsolete information in terms of the purposes of processing the data are deleted or corrected without delay.

8 Recipients of personal data (recipient groups) and regular data disclosures

Personal data will not be disclosed to third parties.

9 Transferring data outside the EU or EEA

Personal data contained in the file will not be transferred outside the EU or EEA.

10 Register protection principles

[Materials containing personal data are stored in locked spaces that can only be accessed by the appointed persons with task-based authorisation.

The database containing personal data is on a server which is stored in a locked space that can only be accessed by the appointed persons with task-based authorisation. The server is protected with the appropriate firewall and technical safeguards.

The databases and systems can only be accessed with separately provided personal user IDs and passwords. The controller has restricted access rights and authorisations to information systems and other storage platforms so that the data can only be viewed and processed by persons who are required to do so to ensure the lawful processing of the data. Furthermore, the database and system interactions are registered in the log data of the controller’s IT system.

The controller’s employees and other persons have undertaken to observe secrecy and keep secret any information they may gain in the context of processing personal data.]

11 Rights of the data subject

The Data subject has the following rights under the EU General Data Protection Regulation:

1. the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data concerned; (iii) the recipients or categories of recipient to whom the personal data have been or will be disclosed; (iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (v) the existence of the right to request from the controller the rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (vi) the right to lodge a complaint with a supervisory authority; (vii) where the personal data are not collected from the data subject, any available information as to their source (GDPR, Art. 15); This basic information (i)–(vii) is provided to the data subject on this form;
2. the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (GDPR, Art. 7);
3. the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and, taking into account the purposes of the processing, the right to have incomplete personal data completed, including by means of providing a supplementary statement (GDPR, Art. 16);
4. the right to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the following grounds applies: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing; (iii) the data subject objects to the processing based on a special personal situation and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purposes; (iv) the personal data have been unlawfully processed; or (v) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject (GDPR, Art. 17);
5. the right to obtain from the controller restriction of processing where one of the following applies: (i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (iii) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or (iv) the data subject has objected to processing on grounds relating to his or her particular situation pending the verification of whether the legitimate grounds of the controller override those of the data subject (GDPR Art. 18);
6. the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent referred to in the regulation and the processing is carried out by automated means (GDPR, Art. 20);
7. the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the EU General Data Protection Regulation (GDPR, Art. 77).

Any requests regarding the enforcement of the data subject’s rights are to be addressed to the controller’s contact person listed in Section 1.