Privacy Statement
Name: Finnish Flow Oy (“Finnish Flow” or “we”)
Correspondence address:
c/o Sofia Helsinki Sofiankatu 4 C, 00170 Helsinki
Contact person:
Risto Kuulasmaa
risto@finnishflow.com
General information regarding our processing activities
This Privacy Statement is applicable to Finnish Flow’s database of customers and suppliers, users of our website omegaleader.com (“Website”) as well as our marketing database.
We mainly process personal data subject to this Privacy Statement when offering or promoting our services to our existing and potential clients or when maintaining the customer relationships with our clients as well as other business relationships with our suppliers and other relevant interest groups.
All of our processing activities are conducted in accordance with the General Data Protection Regulation (2016/679) ("GDPR") and other applicable national data protection laws.
This Privacy Statement describes how we process personal data concerning the representatives of our clients, potential clients, suppliers and other business partners as well as the users of the Website. The word “you” refers to all the aforementioned individuals whose personal data is processed in accordance with this Privacy Statement.
We may update this Privacy Statement if it is necessary in order to reflect the changes in data processing practices or otherwise.
Please note that this Privacy Statement applies to processing of personal data carried out by Finnish Flow as data controller.
Personal data processed and sources of data
The personal data collected and processed by us in accordance with this Privacy Statement can be divided into two general data categories: i) Company and Contact Data and iii) Analytics Data.
Company and Contact Data
We may process the following Company and Contact Data relating to you:
name and contact details
organisation and title
phone number
date of birth
personal identification number
email address
correspondence between Finnish Flow’s representatives and you, including e.g. personal correspondence as well as event invitations and other promotional communication
information relating to meetings between Finnish Flow’s representatives and you
invoicing and billing information
information relating to your participation to our events, including dietary preferences
marketing opt-outs and opt-ins
Typically we receive the Company and Contact Data directly from you, from other representatives of your employer or from your employer’s counterparts, in the course of an engagement with your employer.
In addition, Company and Contact Data may be collected and updated from public sources, such as public search engines, other public websites and social media as well as public registers (e.g. information relating to your contact details).
Some of the Company and Contact Data may also be generated by us. This information includes correspondence between you and our representatives as well as information relating to meetings between you and our representatives.
Analytics data
The logging systems on our Website automatically log certain Analytics Data when you visit the Website. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with Company and Contact Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Website:
Device Information
We collect the following information relating to the technical device you use when using the Website:
device and device identification number, device IMEI
country
IP address
browser type and version
operating system
name of your Internet service providers
advertising identifier of your device
Usage Information
We collect information on your use of the Website, such as:
time spent on the Website
interaction with the Website
time and date of your visits to the Website
sections of the Website you visited
Cookies
We use various technologies to collect and store Analytics Data and other information when you visit our Website, including cookies.
Cookies are small text files sent and saved on your device that allow us to identify visitors of our Website and facilitate its use and to create aggregate information of our visitors. This helps us to improve our Website and better serve you. The cookies will not harm your device or files. We use cookies to tailor our Website and the information we provide in accordance with your individual interests.
You may choose to set your web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:
Safari
Google Chrome
Internet Explorer
Mozilla Firefox
Please note that some parts of our Website may not function properly if use of cookies is refused.
Web analytics services
Our Website uses Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve our Website. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Purposes and legitimate grounds for processing of personal data
Personal data is processed by us for the following purposes:
To provide our services and to run our business and carry out our contractual obligations:
We process personal data in the first place to be able to offer our legal services to our customers and to run, maintain, promote and develop our business. Personal data may be processed in order to carry out our contractual obligations towards you, if you are a private indivual.
When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
You may be requested to grant your consent for the processing of personal data. When the processing of personal data is based on a consent, you may withdraw your consent at any time.
Transfer to countries outside Europe
We store your personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or your domicile.
If we transfer your personal data outside the European Economic Area, we provide adequate protection for such transfers through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy
Shield Framework.
Personal data recipients
We do not share personal data with third parties outside of our organization unless one of the following circumstances applies:
For legal reasons and legal processes:
We may share personal data with third parties outside Finnish Flow’s organization if access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; or (ii) detect, prevent, or otherwise address crime or security issues.
To authorized service providers:
We may share personal data to authorized service providers who perform services for us (including data storage, legal, accounting, sales and marketing services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Statement.
Storage period
We do not store personal data longer than is legally permitted and necessary for the purposes set out in this Privacy Statement. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
For instance, Company and Contact Data relating to you is typically stored as long as we have an ongoing service or business relationship with the organisation you represent. Information relating to your participation to our events is stored until the end of the event in question.
When the storage of personal data is no longer necessary for the purpose for which it was initially collected, we may continue storing the data only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting, reconciliation purposes and direct marketing.
We will store Analytics Data relating to the Website for a period of six (6) months.
Your rights
Right to access: You have the right to access your personal data processed by us and to request a copy of your personal data undergoing processing.
Right to withdraw consent: In case the processing is based on a consent, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify: You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.
Right to erasure: You may also ask us to erase the your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object: You may object to the processing of personal data on grounds relating to your particular situation if such data are processed for our legitimate interest. In case we do not have compelling legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.
Right to restriction of processing: You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data.
Right to data portability: You have the right to receive some of your personal data that you have provided us with in a structured and commonly used format.
How to use the rights: The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Direct Marketing
You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or the unsubscribe possibility offered in connection with any direct marketing messages.
Lodging a complaint
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman www.tietosuoja.fi
Information Security
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data.
Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you as well as relevant authorities about the breach as soon as possible in accordance with law.