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PRIVACY POLICY OF THE CUSTOMER REGISTER OF HAMMAS HOHDE OY

 

1 CONTROLLER

 

Hammas Hohde Oy, Busines ID 23395589-3, Koljonniemenkatu 2, 70100 Kuopio

 

2 CONTACT PERSON IN MATTERS CONCERNING THE PERSONAL DATA FILE

 

Data Protection Officer Ville Pesonen, ville.pesonen@hammashohde.fi, 010 5050 830

 

3 NAME OF THE PERSONAL DATA FILE

 

Customer register of Hammas Hohde Oy

 

4 PURPOSE AND LEGAL BASIS OF PROCESSING

 

The primary purpose of the processing of personal data is the customer relationship between the customer and Hammas Hohde Oy, the consent of the customer, an assignment given by the customer or other suitable connection.

 

Personal data may be processed for the following purposes:

 

The management of the customer relationship, customer service, and the communication and marketing related thereto, as well as their performance, development, study, and monitoring.

 

The analysis of customer relationships, their classification, reporting, implementing a frequent customer program, and other purposes related to the development of the customer relationship as a whole, as well as the business of Hammas Hohde.

 

The collection and processing of customer feedback and information regarding customer satisfaction.

 

The performance of market research, other research, and polls.

 

The recording of phone calls in the customer service center to verify transactions, to ensure protection of legal rights and security and to train customer service personnel and to develop the quality of the customer service.

 

The profiling purposes as described in more detail in Section 10 of this Privacy Policy.

 

The processing may be outsourced to group companies of Hammas Hohde Oy and/or to third party service providers in accordance with, and to the extent allowed by, the applicable data protection legislation.

 

5 DATA INCLUDED IN THE PERSONAL DATA FILE

 

For example, the following information may be processed about the data subject:

 

Name, social security number, customer number, sex, language, address, telephone number, email address and other necessary contact information.

 

Next of kin, guardian, dependent, the number of children under 18 and their ages, household information, and size of household.

 

 

 

 

 

The use and purchase information related to services, the transactional information related to marketing and communication in various channels, such as on-line services and automatic services, including the storage of phone calls to the customer service center.

 

The information provided by the data subject, such as customer feedback and additional information provided by the data subject such as customer requests, customer satisfaction information, areas of interest, hobbies, and other similar information.

 

Information of the data subject’s possible insurances, occupational health services and plans, sports club memberships and other similar information.

 

The services used and request by the data subject together with their payment information.

 

Information on the persons who have treated the data subject. Professionals, services, service units and requests and notes concerning other such matters.

 

Refusals, restrictions, consents, and other choices.

 

Other information related to the client relationship, such as information from which the client may be identified, concerning the data subject’s use of web sites, such as the user’s IP-address, the time of the visit, visited web pages, browser type (such as Internet Explorer, Firefox), the web address from which the user has come to the web site, and the server from which the browser has come to the web site.

 

Information necessary for the use of identification and certification tools and services.

 

Information related to the processing of the information such as the date of storage and the source of the information.

 

6 RETENTION OF PERSONAL DATA

 

Hammas Hohde Oy retains the personal data in the customer register until the customer relationship between the data subject and Hammas Hohde Oy may be determined to have ended. The termination of the relationship is determined from the last service-related contact based on information regarding business fundamentals of Hammas Hohde Oy.

 

7 REGULAR SOURCES OF DATA

 

The data is collected primarily from the following sources:

 

The data subject itself, transactions related to the client relationship, use of services, communication, and business of the data subject.

 

A third-party offering identification, certification, address, on call duty, credit agency or other equivalent services.

 

The population information system provided by the Digital and Population Data Services Agency and other public records systems.

 

Information from other partners of Hammas Hohde Oy, such as an insurance company or a sports club can be added to the data file.

 

8 REGULAR DISCLOSURES AND TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION OR THE EUROPEAN ECONOMIC AREA

 

Information is disclosed to the group companies of Hammas Hohde Oy for the purposes described in Section 4 of this Privacy Policy, as well as to the OmaHohde service’s register and to the direct marketing register of Hammas Hohde Oy and to other register the Hammas Hohde group may have, however, always in accordance with the applicable data protection legislation.

 

We can disclose information related to invoicing of services to our partners for the purposes of invoicing.

 

Customer information is not disclosed to outside of Hammas Hohde and parties taking part on the performance of services, communication, development, or maintenance for Hammas Hohde other than by contract, express consent and/or express regulation.

 

Customer information may be transferred limitedly outside the European Union or the European Economic Area in accordance with the applicable data protection legislation. In such cases the transfer is executed using the model contractual clauses of the European Commission or using another mechanism allowed by applicable data protection legislation.

 

9 DATA SECURITY

 

Manual material, if any, is stored in a locked space that may only be accessed by persons having the right to access the space. Digital material is accessible only by employees, professionals and partners having the right to access such material and by using their personal use credentials and passwords. Multiple levels of user rights exist, and each user is given the necessary, but as restricted as possible, right to access the material.

 

10 PROFILING

 

As a part of the processing activities of the personal data stored to the customer register, Hammas Hohde Oy may use the information to monitor and analyze and profile the users’ interests, their choices and requests regarding services and service points and to develop its customer service.

 

11 DATA SUBJECT’S RIGHT TO OBJECT PROCESSING OF PERSONAL DATA AND DIRECT MARKETING (RIGHT TO OBJECT)

 

The data subject has the right, on grounds relating to their particular situation, to object to the profiling and other processing of the data subject’s personal data by Hammas Hohde Oy to the extent the legal basis of the processing is the customer relationship between the data subject and Hammas Hohde Oy. The data subject can present their objection in accordance with Section 13 of this privacy policy. The data subject must specify the special reason in their request, that form the grounds for the objection. Hammas Hohde Oy may decline to fulfil the request on legal grounds.

 

The data subject may give Hammas Hohde Oy consents or bans concerning direct marketing.

 

12 OTHER RIGHTS OF THE DATA SUBJECT RELATED TO THE PROCESSING OF PERSONAL DATA

 

12.1 Data subject’s right to access the data (right of inspection)

 

The data subject also has the right to inspect what information concerning themselves has been stored to the customer register of Hammas Hohde Oy. The request must be made in accordance with Section 13 of this privacy policy. The request may be declined on legal grounds. The use of the right of access is primarily free of charge.

 

12.2 Data subject’s right to request the rectification of data, the erasure of data and to restrict the processing of their data.

 

If the customer is a user of the OmaHohde service, the customer can update their information in the OmaHohde service. If the data subject or user can correct the information themselves, they must, without undue delay, after having become aware of the incorrect information or having noticed the incorrect information themselves, correct, remove, or complete the incorrect, unnecessary, incomplete or out-of-date information in the data file.

 

If the data subject cannot correct the information themselves, the request to correct the information must be made in accordance with Section 13 of this privacy policy.

 

The data subject also has the right to request the controller to restrict the processing of their personal data, for example in a situation where the data subject waits for the reply of Hammas Hohde Oy to their request to rectify or erase their information.

 

12.3 Data subject’s right to data portability

 

For the data the data subject has provided to the customer register themselves, and which data is processed based on consent or an assignment, the data subject has the right to receive such information in a primarily machine-readable format and has the right to transmit such data to another controller.

 

12.4 Data subject’s right to file a complaint to a supervisory authority.

 

The data subject has the right to file a complaint to a supervisory authority if the controller has not complied with applicable data protection legislation in its activities. The supervisory authority in Finland is the Data Protection Ombudsman, www.tietosuoja.fi.

 

12.5 Other rights

 

If personal data is processed based on the consent of the data subject, the data subject has the right to withdraw their consent by a notification to Hammas Hohde Oy in accordance with Section 13 of this privacy policy.

 

13 CONTACT

 

The data subject shall contact, as regards all questions and the use of their rights, Hammas Hohde’s office or via mail to the following address: Hammas Hohde Oy / Data Protection Officer, Koljonniemenkatu 2, 70100 Kuopio. Hammas Hohde may ask the data subject to specify their request in writing and the identity of the data subject may be verified, if necessary, prior to taking other action.

 

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