Data Protection Record of Climecon Oy’s Customer and Marketing Data Filing System

 1    General

Climecon Oy (later “Climecon”, “Company” or “We”) is committed to ensure the confidentiality and data protection of personal data at its possession. This data protection record is applied to personal data that we collect in relation to our customer and marketing data filing system (later “Data Filing System”). The personal data and related processing is described in this data protection record. Additional information regarding the processing of personal data in the Data Filing System is provided by our contact tommi.uksila@climecon.fi .

We may update this data protection record from time to time, for example due to changes in applicable legislation. We endeavour to carry out reasonable means to inform you of any possible changes and their effects in due time beforehand.  Therefore, we advise you to review this data protection record always after becoming aware of changes regarding the data protection record. This data protection record was last updated on 15.5.2018.

2    Data Controller and Data Protection Officer

Name:    Climecon Oy
Address:    Lämmittäjänkatu 4 A 00880 Helsinki, Finland
Tel:    +358 20 198 6600
Business ID:     1907673-4

Climecon’s data protection officer:
Name:     Tommi Uksila
Cellphone:  040 544 4451
Email: tommi.uksila@climecon.fi

3    Whose Personal Data Do We Collect?

We process the personal data of our customers’ and potential customers’ representatives (later also “You”) in the Data Filing System.

4    What Categories of Personal Data Do We Process?

We process the following categories of personal data of our customers’ or potential customers’ representatives:
-    your name;
-    your contact details: email address and telephone number;
-    the company you are representing and your position in the company; and
-    information concerning the exploitation of electronic services and content (e.g. subscription to a newsletter), technical information sent to our server by your browser (e.g. IP-address, browser, browser version, the webpage from which you came to our webpage) as well as the cookies sent to your browser and information related to them (additional information on cookies and similar technologies below in Section 13).

5    Which Sources Do We Use to Collect Personal Data?

We collect personal data primarily from the data subjects themselves (e.g. your contact requests through our webpage and business cards delivered to us). Basis for, Purposes and Impacts of Processing Your Personal Data

The basis for processing your personal data is, depending on the case, our legitimate interest based on our purposes of use determined below, and in relation to our customers, a contractual relationship with our Company. We also send you electronic direct marketing messages based on your consent.

If you are already our customer:

The purpose of the processing of your personal data as an existing customer is in particular the management and maintenance of our customer relationships. In addition, your personal data are processed for the sales and direct marketing of our products and services and for carrying out our research and product development. By processing your personal data we are able to provide better services for you and develop our products and services to better fit the needs of our customers. The processing of your personal data will have no other impact on you.

-    In such case, the basis for the processing is a contractual relationship and/or consent.

If you are our potential customer:

The purpose for which the personal data concerning our potential customers are used is carrying out direct marketing and other sales and marketing measures regarding our services and products, i.e standard marketing procedures such as sending marketing messages by email. The processing of the personal data of our potential customers has no other impacts than targeting of marketing messages.

-    In such case, the basis for the processing is our legitimate interest.

We do not further process your personal data for other purposes than those described in this data protection record.

6    Regular Disclosures and Transfers of Your Personal Data to Third Parties

Your personal data may be transferred to our sales and marketing business partners; newsletter platform, ERP and contact requests through our websites.

Our business partners may process your personal data only for marketing measures carried out on our behalf. We always ensure that our partners do not process the personal data transferred to them for any other purposes.

7    Transfers of Your Personal Data outside the EU or European Economic Area  

We do not transfer your personal data outside the European Union or European Economic Area.

8    Principles for the Retention of Your Personal Data

We retain your personal data in the Data Filing System in accordance with the following principles:
-The personal data of our customers shall be retained for as long as the customer relationship exists. After the termination of the customer relationship your personal data shall be retained for a maximum of one year following the termination of the customer relationship.

-The personal data of our potential customers shall be retained in the Data Filing System for as long as you hold a position to which our marketed product or service is related, provided that you have not prohibited direct marketing. In such case information on the prohibition of direct marketing can be retained in the Data Filing System.

-Your personal data may be retained for longer if applicable legislation or our contractual obligations towards third parties require a longer retention period.

9    Rights of a Data Subject in Relation to the Processing of Personal Data

As a data subject you have the right, at any time, to object to the processing of your personal data for direct marketing purposes. You may give us channel-specific consents and prohibitions concerning direct marketing (e.g. prohibit marketing messages sent by e-mail but allow marketing messages sent by mail).

In addition, you have the right to, according to applicable data protection legislation, at any time:
-    be informed about the processing of your personal data;
-    obtain access to data relating to you and review your personal data we process;
-    require rectification and completion or erasure of inaccurate and incorrect personal data;
-    withdraw your consent and object to the processing of your personal data in so far as the processing of your personal data is based on your consent;
-    object to the processing of your personal data on grounds relating to your particular situation in so far as the processing of your personal data is based on our legitimate interest;
-    receive your personal data in a machine-readable format and transmit those data to another controller (provided that you have delivered us such data yourself, we process such personal data based on an agreement or your consent and the processing of personal data is carried out by automated means); and
-    obtain a restriction of processing of your personal data.

If you withdraw your consent, it will not affect the lawfulness of the processing based on consent be-fore its withdrawal. You may withdraw your consent in accordance with section “Contacts” below. The only impact caused by withdrawal of your consent is that we will not be able to send direct marketing to you.

You should present your request for exercising any of the aforementioned rights in the manner described in the ‘Contacts’ Section of this data protection record. We may ask you to specify your re-quest in writing and to verify your identity before processing the request. We may refuse to fulfil your request on grounds set out in applicable data protection legislation.

You also have the right to lodge a complaint with the supervisory authority concerned or with the supervisory authority of the EU member state of your habitual residence or place of work, if you consider that we have not processed your personal data in accordance with applicable data protection legislation.

10    Principles of Data Security

We respect the confidentiality of your personal data. Tangible material containing personal data shall be kept under lock and key in a space to which only separately appointed persons have access. Personal data processed digitally are protected and stored in our information system accessible to per-sons on a need-to-know basis only. Such persons have personal user credentials and passwords.

We encrypt Personal data transmitted outside our Company.

11    Information on Cookies and Similar Technologies

A “Cookie” is a commonly used small text file that the internet browser installs on your computer or other terminal when you visit a website. The browser sends information on your visit back to the website when you revisit it. All contemporary websites use cookies in order to offer you a more personal browsing experience.

Each cookie is separately installed on each terminal you use and cookies can be read only by the server that installed the cookie. Because the cookie is bound to the browser, and is not distributable between separate browsers or terminals in general (unless a browser, plugin or other application separately enable this), your choices relating to the management of cookies are applicable only to each separate browser. A cookie cannot control software, and it cannot be used as a medium for vi-ruses or other malware, nor to harm your terminal of files. A single user cannot be identified solely through the use of cookies or similar technologies.

We use Google Analytics on our website in order to analyse, how users use use the website. Google Analytics is a web analytics service offered by Google Inc. (“Google”) that functions by using cookies. Please note that Google’s terms and conditions are applied to cookies installed by Google. More information on Google’s terms and conditions can be found from https://www.google.com/policies/privacy/partners/. You can prevent the use of Google Analytics on your terminal(s) by contacting us in accordance with Section 14 below. Please note that if you decide to prevent the use of Google Analytics, it may affect your use of website and hinder the functioning of its properties and functions.

12    Contacts

All requests concerning the use of the rights mentioned above, questions about this data protection record and other contacts should be made by e-mail to the address tommi.uksila@climecon.fi. You may also contact us in person in our offices or in writing:

Climecon Oy
Tommi Uksila
Lämmittäjänkatu 4 A
00880 HELSINKI

If you wish to withdraw your consent for direct marketing, it can be done by clicking on a link found in each direct marketing message.