Privacy Statement of the Customer Register
This document is the privacy statement of the customer register following the Finnish Personal Data Act (10§ and 24 §) and EU’s General Data Protection Regulation (GDPR).
1. Register Administrator
Louhi Net Oy
(Hereinafter referred to as “we” or “Louhi”)
2. Register Contact Information
Louhi Net Oy Customer Service firstname.lastname@example.org +358 10 841 5656.
3. Name of the Registry
4. Legal basis and purpose of processing personal data
The processing of personal data is based on the legitimate interest of the company in implementing the customer relationship and / or contact.
The purpose of processing personal data is to:
- Deliver and develop our products and services, for example through surveying.
- Fulfil our contractual and other promises and obligations.
- Manage our customer relationships.
- Research and statistical purposes for maintenance of the service.
- Targeting advertising in our company’s and others’ online services.
We use automated profiling to identify registered personal profiles, online behavior, and acquisition history. We use this information to target marketing and for service development.
5. What information do we handle?
In connection with the Customer Register, we process the following personal data of the customer or other registered person:
- Registered basic information such as name*, customer name*, username and/or other unique identifier*, password*
- Registered contact information such as email address*, phone number*, address information*
- Company / association and company / association contact information such as Business ID*, Association Registration Number*, Contact Persons*, and Contact Details*
- Customer relationship and contract information such as past and current contracts and orders, other transaction information such as electronic billing information and electronic communications
- Personal profile and online behavior
Information marked with an asterisk is a prerequisite for our contractual relationship and / or customer relationship. Without the necessary personal information we cannot deliver the product and / or service.
6. Where do we get information from?
We primarily get information directly from the registered user.
In addition, personal data may be collected and updated for the purposes described in this Privacy Statement as well as publically available sources and from information received from authorities or third parties on the basis of applicable law. Such updating of information is performed manually or by automated means.
7. To whom do we disclose and share information to, and do we transfer data outside of the EU or EEA?
Louhi Net Oy is obliged to notify the international WHOIS register of the customer’s contract details when registering domain names. This obligation has been set up by the Internet Corporation for Assigned Names and Numbers (“ICANN”), an organization responsible for domain controlling and partial management (see www.icann.org) .
We use subcontractors through which we may process personal data. We have outsourced IT management to third party service providers who manage and protect personal data stored on the server. We have taken care of your privacy with our subcontractors by elaborating processing agreements for the processing of personal data. In some cases, personal data may be disclosed outside the EU/EEA, such as the United States or Russia. The disclosure of the information depends on the service purchased by the customer, whose contract more closely refers to specifically what kind of information is disclosed and transferred. We have taken appropriate safeguards for the transfer. We use standard contractual clauses approved by the EU or other transfer procedures approved by the EU Commission.
8. How do we protect your data and how long do we store it?
The use of the system containing personal data is only warranted by employees who have the right to handle customer information on their behalf. Each use has their own username and password in the system. Information is collected in databases protected by firewalls, passwords, and other technical means. Databases and backups are located in locked spaces and only pre-designated persons can access the data.
We store personal data for 3 months following the termination of the contract and accounting data in accordance with accounting law 6 years after the date of registration of the invoice.
We estimate the need for data retention in the light of regular legislation. In addition, we will take reasonable measures to ensure data subjects are not kept in the registry for incompatible, obsolete or incorrect personal information. We will rectify or discard such information without delay.
9. What are your rights as a registrant?
As a registered user, you have the right to inspect the information stored on your personal record and to claim for correction or deletion of incorrect information. You also have the right to cancel or alter your consent.
As a registered user you have the right to object or request restriction of processing of your data and file a complaint against the processing of personal data to the supervisory authority, as of 25 May 2018.
For specific personal reasons, you also have the right to object to profiling and other processing actions that are relevant to you when processing data is based on our relationship with you. In connection with your claim you will need to identify the specific situation on which you object to handling. We can refuse to apply the objection only on the basis of law.
As a registered person you also have the right at any time and without change to object to the processing, including profiling as far as it relates to direct marketing.
10. Who can I be in contact with?
All contacts and requests related to this statement must be made in writing or personally to the addresses designated in part two (2).
11. Changes to the register statement
Louhi Net reserves the right to change the contents of the statement without personally notifying each registrant.
It is the responsibility of the registered person to review the content of the statement on a regular basis.