1 CONTROLLER AND CONTACT DETAILS FOR REGISTER MATTERS

OWS Finland Oy
Business identity code: 2517012-9
Tiedekatu 2 
60320 Seinäjoki 

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

 

2 REGISTER'S NAME

OWS Marketing Register  
OWS Customer Register 

 

3 JUSTIFICATION FOR KEEPING A REGISTER 

We process personal data with the consent of the data subject, customer relationship or other appropriate basis, such as the register’s controller’s legitimate interest based on the balance test and the basis of data protection direct marketing legislation. 

 

4 THE PURPOSE OF PERSONAL DATA PROCESSING AND THE MARKETING REGISTER

We only process and use personal data for predefined purposes, which are:

  • Contents and their personification
  • The marketing and communication of services
  • Offering and delivering our services, and customer management
  • Purchasing and the realisation of services
  • Gathering feedback
  • Developing customer service and business operations 
  • The management and development of customer relations
  • Analysis and the compilation of statistics
  • The fulfilment of legal obligations
  • Personal data can also be processed by our parent company Rauhala Yhtiöt and our affiliated company, Priima Yrityslaskenta acting in accordance with data protection legislation.

 

5 THE DATA CONTENT OF THE REGISTER 

The register can contain the following data. 

5.1 Data given by the user or personally identifiable data:

  • contact details, such as name, address, phone numbers, e-mail addresses
  • demographic data, such as age, gender, title or profession  
  • employer’s name, address and business identity code
  • personal picture
  • data concerning the customer relationship, such as product and order information, customer feedback, data from competition answers and cancellation information
  • data concerning the realisation of communications and data concerning the use of services, such as browsing and search data, identification data, data on the use of services and offered benefits
  • possible permissions and consents
  • possible supply blocking data
  • event and user analysis data
  • profiling and interest data possible given by the user  
  • other possible data collected given with the consent of the customer

5.2 Observational data from use of services:

  • characteristics of use and browsing data of a service
  • contents, which are shown, and data on clicking on contents
  • page, from which the users has arrived at our pages, device model, individual device and/or cookie recognition, data acquisition channel (internet browser, e-mail, mobile browser, application), version of browser, IP address, session identifier, session time and length as well as screen resolution and operating system
  • The identified user is identified as a random number series or other comparable identifier, which cannot identify the user personally
  • The identifier of the observation (unidentifiable) user is typically a cookie or another corresponding identifier
  • The location estimated with the help of the GPS of the WLAN connection point or mobile phone network base station
  • other data collected with the consent of the customer

5.3 Data derived from use of services: 

By derived data we mean data, which can be deduced, with the help of analytics, from   observational behaviour of the service and/or data given by the customer themselves. This kind of data can be for example, points of interest or classification of certain type of users into groups.

 

6 CUSTOMER REGISTER’S REGULAR SOURCES OF INFORMATION

We normally obtain data concerning customers as follows:

  • from the data subject themselves, on the internet, by e-mail, phone, by a form or other corresponding manner
  • through cookies or other equivalent technology
  • from OWS Finland’s register 
  • from OWS Finland’s customer register 
  • from OWS Finland’s partners 
  • from the data subject themselves by different marketing procedures and campaigns
  • from the internet pages of the data subject’s employer or other company sources
  • we utilise prospecting tools, telephone companies’ contact information registers, internet social networking services or other equivalent public and private registers according to legislation.

We combine data for marketing and for targeting its contents.

We complete the users’ identified data for the utilisation purposes in point 4.

 

7 DATA RETENTION PERIOD

We retain personal data only as long as necessary for the described purposes presented above in relation to point 4. At all times we observe the valid legislation and operate accordingly.

We only process the necessary personal contact data. All unnecessary contacts’ contact details are deleted from the system. Unnecessary contacts means people, who are not included in the definition in point 4.

We go through the users monthly and annually and delete monthly those users who do not fall within the definition of point 4. Furthermore, if a person has not used our e-services within the previous twelve months, the user is deleted, and they are handled according to the principles of data protection’s right to be forgotten. In this way the subject in question can no longer be identified.

 

8 PROCESSORS 

In addition to the controller, personal data can be processed by OWS Finland’s parent company, Rauhala Yhtöt, and by the affiliated company Priima Yrityslaskenta. When required, we outsource or give commissions for the whole or part of the personal data to a third-party processor, such as a marketing agency. Nevertheless, we remain the controller and are responsible for the legality of the processing. The contractor submits to contractual liability, which obligates the careful processing of data and its protection. A written contract is made with the contractor, which also defines matters concerning the processing of personal data. A legal notification about the matter is given to the Office of the Data Protection Ombudsman and a register notification concerning outsourcing. For their part, the contractor makes the legal operational notification. All our processes are appropriate and observe data protection legislation.

Transfer of personal data out of the EU or European Economic Area.
We only disclose data to third parties in the cases presented in point 9. 

 

9 REGULAR DICLOSURES OF DATA

We do not rent or sell the personal data of an identified user to third parties. We only disclose data to third parties in the cases presented below:

  • We only disclose user’s data to a third party if the data subject has given consent.
  • If necessary, we disclose data needed for target advertising of the observed users to our marketing service providers. The data is not for use for other than Rauhala Yhtiöt’s marketing purposes.
  • We disclose user personal data in a manner required by the demands presented by authorities or official quarters. In this we observe legislation.
  • In the event that our company organisation changes, the users’ personal data can be disclosed within the new organisation.
  • Personal data can be transferred to social networking and search engine services for marketing targeting purposes.
  • We disclose to the companies we represent such personal data which concerns familiarisation with, adoption and or use of their products and or services.

 

10 AUTOMATED DECISION-MAKING AND PROFILING

We follow and profile user actions in our digital services, so that we can target them as well as possible with contents that serves their interests, needs and job description.  

 

11 COOKIES AND BROWSER TRACKING 

We collect data concerning the users’ terminal, through cookies and other corresponding technology, such as marketing automation. The browser saves a cookie of the user’s terminal, which contains a unique identifier, which allows us to recognise anonymously browsers and actions visiting our web pages. Measurement and monitoring services can set cookies on the user’s terminal, when visiting our services. We do not take responsibility for these privacy protection policies or contents.

 

12 LOCATION DATA

We can utilise the location data on the user’s terminal to target advertising displayed, provided that the user has given consent to utilise data location. The user can withdraw their consent at any time through the settings on the terminal or application.

 

13 THE RIGHTS OF THE DATA SUBJECT 

We offer our users the possibility to select and manage their personal data in accordance to data protection. The user can affect the collection and processing of data in different ways:

13.1 Data check 

The user has the right to obtain information on what data about them is saved on our register. The data subject has the right to check their information. You can contact our concern’s switchboard with a data check request. A data check requires personal identification.

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

13.2 The correction of incorrect data 

The user has the right to have incorrect data corrected. You can contact our concern’s switchboard with a data correction request. Data correction requires personal identification.

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

Incorrect and altered data are corrected immediately.

13.3 Refusal of personal data processing 

The user has the right to refuse the processing of personal data, which concern direct marketing, distant selling or other direct marketing. You can be removed from our marketing list by finding the “Unsubscribe from all future e-mails" link from our e-mail marketing message or by contacting our switchboard. If a person contacts us, it is desirable that they send the refusal of personal data processing, from the e-mail the refusal concerns. In other cases, a refusal requires personal identification.

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

13.4 Clearing and preventing cookies

Cookies can be totally cleared from browser files by modifying the settings. Clearing cookies at regular intervals changes the user’s identifier, on which profiling is based.   Clearing cookies does not totally stop data collection, but resets the profile based on previous behaviour data.

By changing the browsers settings, the user can prevent the use of cookies. Preventing the use of cookies may affect the functionality of our services.

Further information on clearing and preventing cookies. 

13.5 The use of location data 

The user can give consent or withhold consent for the use of location data from the settings on the terminal or application. Previously given consent can be cancelled at any time from the settings.

13.6 Deleting/forgetting data

The user can request that the personal data concerning them is deleted, in other words, forgotten from our register. When contacting us concerning deleting/forgetting data, it is desirable that the person sends a request for deleting/forgetting the personal data from the e-mail which the request concerns. In other cases, deleting/forgetting requires personal identification.

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

13.7 Transfer of data from one system to another 

The user can demand that the controller transfers personal data concerning the user in a commonly used transfer format to another system. The right only concerns the data which the user themselves has given to the controller. Data transfer requires personal identification.

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi 

13.8 Objection to automated decision-making and profiling 

The user can object to automated decision-making and profiling by contacting our switchboard:

Switchboard telephone number: +358 201 210 200 
E-mail address: info@ows.fi  

 

14 REGISTER STORAGE AND THE PRINCIPLE OF DATA PROTECTION

Every person, who has as at least left their e-mail address, has their own profile in our marketing’s automated profile, where their data is assembled.

Furthermore, our customers’ personal data is useable in an e-mail programme used for communications and a survey tool. Also, personal data of people who have participated in events can be in our survey tool, through which we collect feedback about the event we arrange.

The register’s personal data can be utilized in social networking services and in social media in target marketing.

The marketing register’s manual and digitally saved and processed data is stored in protected conditions and on secure computers, which are protected by firewalls, passwords and other technical methods. The database is supervised around-the-clock.

 

15 CHANGES TO THE DATA PROTECTION POLICY 

Our marketing is constantly developing. We retain the right to change this marketing data protection policy and its settings. We will notify of changes to the data protection policy in news on our internet pages. The up-to-date data protection policy is always easy to find in the footer of our internet pages, as well as in connection with every data collection form. Changes can be based on legislation. We recommended regular familiarisation with our marketing data protection policy.