Description of Personal Data Processing
According to the data protection regulation, the data controller has an obligation to inform data subjects clearly. This description fulfills that information obligation.
1. Data Controller
Company name and business ID: Törnberg Partners Ltd, Business ID: 3556243-3
Company contact information and visiting address: info@kptpartners.fi, c/o Boffice Kamppi, Kansakoulukuja 3 A 444, 00100 Helsinki
Contact information regarding the registry: Name and contact details: Kristian Törnberg, kristian@kptpartners.fi, 010 2994 410
2. Data Subjects
Our company's clients and their representatives, users of our website's contact and request a quote forms, newsletter subscribers, and individuals participating in our training sessions and events.
3. Purpose of Personal Data Processing
Basis for maintaining the register:
We only collect, process, and use personal data that is necessary for our business operations, effective customer service, and relevant commercial activities.
We collect and process personal data based on our customer relationships and with your consent. This also helps us manage our relationships with our service providers and other partners.
Individuals may have given their consent for us to process their personal data for one or more specific reasons. This often happens during activities that promote our services, like marketing or social media campaigns. We always inform the individual about why and how their data will be used before asking for their consent.
We may process personal data to meet our legal obligations, such as those related to accounting (like invoicing).
Purpose of Processing Personal Data and the Register
Personal data may only be processed for specific, pre-defined purposes, which include:
Managing customer relationships and delivering services, accounting (invoicing), staying in touch and communicating with customers, handling customer feedback, marketing and improving our services, and meeting our legal duties.
4. Personal Data Stored in the Register
Our customer register includes the following information:
Contact Information
name,
address,
email,
phone number,
personal identification number, but only if a debt relationship is established.
In addition, business customers' business ID
Customer Details
details about products or services purchased.
5. Your Rights as a Data Subject
Data subjects have the following rights; requests to exercise these rights should be sent to info@kptpartners.fi, Törnberg Partners Ltd, c/o Boffice Kamppi, Kansakoulukuja 3 A 444, 00100 Helsinki
Right to Access Your Data
You can check the personal data we have stored about you.
Right to Correct Your Data
You can ask us to correct any inaccurate or incomplete information we hold about you.
Right to Object to Processing
You can object to the processing of your personal data if you believe it has been handled unlawfully.
Right to Object to Direct Marketing
The registered individual has the right to object to their data being used for direct marketing.
Right to Erasure
The registered individual has the right to request the deletion of their data if its processing is no longer necessary. We will process the deletion request and either remove the data or provide a valid reason why it cannot be deleted.
It is important to note that the data controller may have a legal or other right to not delete the requested information. The data controller is obligated to retain accounting records for the period specified in the Accounting Act (Chapter 2, Section 10), which is 10 years. For this reason, accounting-related data cannot be deleted before this period ends.
Withdrawal of Consent
If the processing of a registered individual's personal data is based solely on their consent, and not, for example, on a customer relationship or membership, the individual can withdraw their consent.
The registered individual can appeal the decision to the Data Protection Ombudsman.
The registered individual has the right to request that we restrict the processing of disputed data until the issue is resolved.
Right to Lodge a Complaint
The registered individual has the right to lodge a complaint with the Data Protection Ombudsman if they believe that we are violating current data protection legislation when processing personal data.
Contact information for the Data Protection Ombudsman: https://www.tietosuoja.fi
6. Standard Data Sources
Customer data is typically obtained directly from the customer when a customer relationship is established or through an online form.
We may also combine personal data about the registered individual that we have collected from public sources and various interactions, such as during service provision or marketing communications.
Customers are not obligated to provide us with their personal data, but refusing to do so may have various consequences depending on the situation. For instance, in some cases, we might not be able to offer our services or fulfill a customer's request.
7. Standard Data Disclosures
As a general rule, we do not disclose data for marketing purposes to parties outside of Törnberg Partners Ltd.
We have ensured that all our service providers comply with data protection laws.
We regularly use the following service providers: Finago Oy, Talgraf Oy, Holvi Oy, Best Best Talent Platform Oy, Auronic Oy, and Microsoft.
8. Retention Period
Personal data is retained only for as long as necessary to fulfill the purpose for which it was collected, including to meet legal, accounting, or reporting requirements.
Personal data related to a customer relationship is generally processed for as long as the customer relationship is active. The data is deleted no later than two years after the customer relationship ends.
The retention period for personal data processed based on consent is determined by the purpose of the processing.
Registered individuals can remove themselves from our marketing list via a link provided in every marketing email we send.
9. Personal Data Processors
Personal data is processed by the partners of Törnberg Partners Ltd.
We may also outsource the processing of personal data partly to a third party. In such cases, we ensure through contractual arrangements that personal data is processed in accordance with current data protection legislation and otherwise appropriately.
10. Transfer of Data Outside the EU
The personal data we process is primarily located within the EU or the European Economic Area. However, we may transfer personal data outside these areas if our service provider or partner processing the data operates entirely or partly in a third country. Personal data may also be transferred to third countries in situations where mandatory non-EU legislation binding the partner requires it.
When data is transferred outside the EU and EEA, we ensure an adequate level of personal data protection by, among other things, agreeing on matters related to the confidentiality and processing of personal data as required by law.
11. Data Security
We implement appropriate measures (including physical, technical, and administrative actions) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure.
For example, we restrict access to personal data only to those personnel of the data controller or service providers who need this information for their work. They process the registered person's data only according to our instructions and under confidentiality obligations.
Please note that even appropriate measures cannot prevent all possible data security breaches.
In the event of data security breaches, we will notify you in accordance with applicable legislation.
12. Cookies and affiliate tracking technologies
We also use cookies and other similar technologies on the kptpartners.fi website. Cookies are small text files placed on your device to collect and store useful information, with the aim of improving the functionality and usability of our website. We may also use cookies and other similar technologies for statistical purposes, such as compiling statistics on website usage to understand how users interact with the website and to improve the user experience.
You can prevent cookies from being set, restrict their use, or delete them from your browser. Since cookies enable our website to function, restricting their use may affect the website’s usability.
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