Hohde

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PRIVACY POLICY OF THE OMAHOHDE SERVICE

 

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

 

OmaHohde service personal data file

 

4 PURPOSE AND LEGAL BASIS OF PROCESSING

 

The OmaHohde service (also service) is directed especially to the customers of Hammas Hohde Oy, but the service may also be used by any person that has access to online banking credentials necessary to register to the service.

 

The processing of personal data is primarily based on the customer relationship between the data subject and Hammas Hohde Oy, which is formed when the data subject creates a user account to the OmaHohde service and for example in cases where the data subject themselves inputs data to the OmaHohde service concerning their health and previous treatment history, to the consent of the data subject.

 

Personal data is processed to supply and make available the web browser and application based OmaHohde service, as well as to manage the customer relationship with the data subject.

 

Hammas Hohde Oy may use the personal data for customer history, feedback, customer satisfaction, polls and research undertaking, monitoring and analyzing purposes, for verifying transactions, quality control, for developing its business and service, the targeting of communication, marketing and services, and other management, development and making available of services, and for profiling purposes as described in more detail in Section 10 of this privacy policy. The service may contain marketing via telephone calls, SMS messages, emails or multimedia messages, as well as marketing and other communication within the service, the web site or the mobile application.

 

Furthermore, the service displays health information about the client contained in the patient register. Processing of such data is subject to the privacy policy of the patient register.

 

Processing activities may be outsourced to the group companies of Hammas Hohde Oy and/or to third party service providers in accordance with 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.

 

The services requested, used and purchased by the data subject with their payment information.

 

The information provided by the data subject, such as health information, information on care received elsewhere than at Hammas Hohde, areas of interest, hobbies and other similar information.

 

The health and wellbeing information concerning the data subject transferred by the data subject to the service.

 

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

 

The contents of messages between the data subject and the personnel of Hammas Hohde and chat messages in the OmaHohde service, in addition to any files uploaded by the data subject, log information, information on the sender and recipients of the messages as well as sending times.

 

Other information related to the personal data file, for example information from which the data subject may be identified, concerning the data subject’s use of 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 user 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.

 

The OmaHohde data file does not contain patient information. The information contained in the OmaHohde data file are not transferred to the patient information system unless the data subject as separately agreed on this with a professional treating the data subject. The information saved to the OmaHohde service by the data subject, e.g. health information of the data subject or information concerning treatments or examinations performed elsewhere, are not visible to the personnel of Hammas Hohde.

 

6 RETENTION OF PERSONAL DATA

 

Hammas Hohde Oy retains the personal data in the OmaHohde service for as long as the data subject uses the OmaHohde service, meaning that they have an account in the service. Hammas Hohde may remove the information prior to this, if it is clear that the user does not use the service anymore and that their customer relationship with Hammas Hohde has ended.

 

We store personal data in the OmaHohde service at most ten (10) years from the last use of the OmaHohde service or a transaction with Hammas Hohde.

 

7 REGULAR SOURCES OF DATA

 

The data is collected primarily from the following sources:

 

The data subject themselves, and information created while the data subject uses the OmaHohde service.

 

The customer register of Hammas Hohde.

 

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

 

Information obtained from partners of Hammas Hohde may also be added to the data file, such as information obtained from insurance companies.

 

We update contact information and other basic information form the information received from the Digital and Population Data Services Agency. Furthermore, contact information may be updated as regards an occupational health customer with information received from the customer’s employer.

 

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

 

Information may be 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 customer register and direct marketing register of Hammas Hohde.

 

Information is not disclosed outside of Hammas Hohde and parties taking part in the performance of services, communication, development or maintenance for Hammas Hohde other than on the basis of a contract, express consent of the data subject and/direct legal requirement.

 

Personal data may be transferred limitedly outside of 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 Standard Contractual Clauses of the European Commission or using another safeguard 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.

 

The OmaHohde service is an online service, and it may be used through encrypted connection with the browser of a computer, mobile phone, mobile device or other smart device or through an application made available by Hammas Hohde from time to time.

 

The OmaHohde service may be accessed by using personal on-line banking credentials or other identification methods approved by Hammas Hohde. Hammas Hohde takes adequate technical measures to provide the service and ensure data security.

 

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.

 

Hammas Hohde removes all information contained in the service input by the user themselves as well as the user’s OmaHohde credentials when the use of the service is terminated, but other information concerning services (such as customer feedback and information used to target services) are transferred to and/or remain in the customer register of Hammas Hohde.

 

The purpose of the aforementioned activities is to ensure the confidentiality of the OmaHohde service, the availability and integrity of the information, as well as realization of the data subject’s rights.

 

10 PROFILING

 

As a part of the processing activities of the personal data stored to the Oma Hohde service, 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 based on legal grounds.

 

The OmaHohde service may contain advertisements. The customer cannot ban advertisements through the service.

 

The data subject may give consents or bans concerning direct marketing through the OmaHohde service on a channel-by-channel basis.

 

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

 

12.1 Data subject’s right of access (right of inspection)

 

When logging in to the OmaHohde service, most of the information the OmaHohde service contains about the data subject is visible to the data subject.

 

The data subject also has the right to inspect what information concerning themselves has been stored to the OmaHohde service. 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 data

 

The customer can update their basic 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, delete or complete the information in the data file that is contrary to the purposes of the OmaHohde service, incorrect, unnecessary, incomplete or out-of-date.

 

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 OmaHohde service themselves, which data is processed based on consent, 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. In practice such information is e.g. information concerning the data subject’s health or earlier treatment history input by the data subject themselves to the OmaHohde service.

 

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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