1. Controller

Vincit Plc (Business ID: 2113034-9)
Street address: Visiokatu 1, Tampere, Finland
Tel: +358 3 217 3762

Bonsky Digital Oy (Business ID: 1583006-6)
Street address: Kivääritehtaankatu 6 C (3. krs.), Jyväskylä, Finland
Tel: +358 40 520 8477

2. Name of the filing system

Vincit Plc’s customer, marketing and job applicant filing system

Bonsky Digital Oy’s customer, marketing and job applicant filing system

3. Person responsible for matters concerning the filing system

Customer and marketing filing system:
Vincit Plc
Name: Jarkko Järvenpää
E-mail: jarkko.jarvenpaa@vincit.fi

Job applicant filing system:
Bonsky Digital Oy
Name: Miika Hirvonen
E-mail: miika.hirvonen@bonsky.com

4. Purpose of and grounds for the filing system

Personal data is processed for the following purposes:
– Customer relationship and customer service management
– Invoicing
– Purposes related to the products and services of the controller, such as the development, provision, implementation and marketing of products and services
– Implementation of the rights and obligations of the customer and the controller
– Remarketing based on website behavior online and on social media
– Processing of job applications and communications related to recruitment

Depending on the purpose of the processing, the legal grounds for the processing of personal data are the legal obligations of the controller, contract, consent and the legitimate interest of the controller.

The legitimate interest of the controller is the grounds for the processing when there is relevant connection between the data subject and the controller. Such a relevant connection may be formed, for example, when the data subject has on his/her own initiative contacted the controller, or when the controller processes the data subject’s personal data in connection with business or cooperation between the data subject’s employer and the controller, for example.

On basis of its legitimate interest, the controller may also save to its customer filing system personal data of contact persons and representatives of potentials clients which can be, on reasonable grounds, expected to be interested to acquire products and services provided by the controller.

Personal data is processed based on the consent of the data subject (for example, subscribing to Vincit Plc’s newsletter, downloading manual content or entering and storing data in the recruitment system). The data subject has the right to withdraw his/her consent for the processing of personal data at any time by using the contact methods indicated in this privacy statement.

5. Data content of the filing system

The filing system contains data on the following persons:
– The controller’s customers as well as their representatives and contact persons
– Representatives and contact persons of the controller’s subcontractors and suppliers
– Potential customers
– Job applicants
– Other stakeholders

The following data necessary for each purpose is processed on the data subject:

Customer and marketing filing system
– Name
– E-mail
– Phone number
– Company and position
– Company address information
– Customer relationship and order information
– Newsletter subscription and analytics
– Ordering of electronic material from the website
– Website behavior and analytics
– Participation in events
– Marketing ban

The controller shall process and store personal data only for as long as is necessary for the predetermined purpose of the personal data. Personal data which has become redundant and which the controller no longer has the grounds to store or process will be erased at regular intervals in accordance with the controller’s own data protection practices.

6. Regular data sources

Personal data is generally obtained from the following data sources:
– Directly from the data subject to manage the customer relationship
– Directly from the data subject as part of the job application process and recruitment
– Directly from the data subject as part of another cooperation relationship
– From public/publicly available sources (such as the Internet and the Trade Register)
– From a representative of the data subject’s employer or other party in a customer, cooperation or other contractual relationship with the controller

Customer and marketing filing system
Personal data is stored in the filing system when a user orders material to download from Vincit Plc, signs up for an event or webinar or submits a contact request. In addition, personal data is stored in the filing system if a person belongs to a partner or customer company of Vincit Plc. Direct marketing filing system data is obtained from the data subject or from the public network.

7. Disclosure and transfer of data

In principle, the controller will not disclose the personal data of data subjects to third parties unless legally required to do so by authorities or if compulsory legislation so requires. In addition, in the technical implementation of its services, the controller uses reliable service providers that process personal data on behalf of the controller.

In principle, personal data is not transferred outside the European Union or the European Economic Area. Any transfers of personal data are always carried out in compliance with applicable data protection legislation.

The data contained in the job applicant filing system is stored and processed outside the EEA in the Recruiterbox system. Recruiterbox meets the requirements of the EU General Data Protection Regulation (GDPR) for the processing of personal data.

8. Protection and data security of the filing system

Customer and marketing filing system
Access rights to the filing system are restricted to persons who need the data in the course of their duties. Personal data may be processed in various information systems managed either by Vincit Plc or its partners. We have ensured that our partners comply with data protection legislation.

We do not use automated decision-making, such as automated profiling, as part of our personal data processing activities.

9. Rights of the data subject

The data subject has the following rights applicable on a case-by-case basis:

Right of access to personal dataThe data subject has the right to obtain confirmation from the controller on whether personal data concerning him/her is being processed or not. If personal data is being processed, the person has the right to access the data.
Right to demand data rectification, erasure or restriction of processingThe data subject has the right to object to the processing of his/her personal data relating to his/her particular situation when the controller is processing personal data on the basis of a legitimate interest.The data subject has the right to request the controller to rectify inaccurate data concerning him/her and to erase some personal data concerning him/her, or to request that the processing be restricted on the grounds provided by law.
Right to objectThe data subject has the right to object to the processing of his/her personal data relating to his/her particular situation when the controller is processing personal data on the basis of a legitimate interest.
Right to lodge a complaint with a supervisory authorityIn Finland, the supervisory authority is the Office of the Data Protection Ombudsman, whose contact information and instructions are available at www.tietosuoja.fi/en.

Exercise of rights
The data subject may exercise his/her rights by contacting the controller using the contact information provided in section 3. We strive to reply to you as soon as possible and, if necessary, provide additional instructions or ask further questions on account of your request.

Please note that before implementing the request, we have the right and obligation to verify your identity, which means that we must be able to identify you in an adequate way.

If your request is blatantly unfounded or unreasonable, we may either charge a reasonable fee based on administrative costs for the implementation of the request or refuse to carry out the requested action.

10. Cookies

We use cookies on this website to help us process and analyze information related to the use of our website. Cookies are small text files that are stored on your computer when you visit certain websites. Cookies help us better understand what kind of content the users of our site are interested in and provide them with relevant content.

Cookies do not harm users’ computers or files. However, the user may choose to disable the use of cookies through browser settings.

11. Additional information

Mikäli sinulla on kysyttävää liittyen suorittamaamme henkilötietojen If you have any questions regarding our processing of personal data, you can contact us using the contact information provided in section 3 of this privacy statement.

The privacy statement was last updated on 22 April 2020.