Privacy Policy

1) CONTROLLER
Name: Kasvun Roihu Oy (later on Company)
Business ID: 2429459-2
Address: Nisulankatu 78, 40720, Jyväskylä

2) PERSON IN CHARGE OF DATA FILES
Reetta Tehomaa
Phone: +358 40 845 1589
Email: reetta.tehomaa@roihu.com

3) THE CATEGORIES OF DATA SUBJECTS
Company’s Privacy Policy concerns the following categories of data subjects:

3.1) persons who contact Company via phone, email or through the webpages
3.2) persons who operate as contact person of Company customers’, partners’ and other networks company contacts;
3.3) persons who are part of Company specialist network
3.4) persons who are employed by Company or seek employment from Company.

4) THE CATEGORIES OF PERSONAL DATA
The data files concerning the data subjects of Sections 3.1) – 3.4) may contain the following categories of personal data:
• contact information, such as full name, address, phone numbers and e-mail addresses;
• title or profession;
• work and education background;
• data about your device, such as information about the device you use: type of your device, your IP-address and various diagnostic data; and
• possible other information gathered with the data subject’s consent.

The data files concerning the data subjects of Section 3.4) may also contain the following categories of personal data:
• personal identification numbers;
• nationality, age, gender, and mother tongue; and
• bank account number.

5) PURPOSE OF THE PROCESSING OF PERSONAL DATA
Personal data of the data subjects of Sections 3.1) – 3.4) can be handled for following purposes:
• customer service;
• for improving our user experience;
• management and development of the customer relationship;
• analysis and statistics;
• marketing, market surveys and studies; and
• to enable us to comply with our legal and regulatory obligations.

Personal data of the data subjects of Section 3.4) can also be handled for following purposes:
• management and development of the employee and jobseeker relationships; and
• management of employment contracts and other related matters.

Personal data can also be processed by Company’s Finnish affiliate companies, if any, in accordance with the Finnish Personal Data Act, the GDPR and the Finnish Data Protection Act.

6) LEGAL BASIS FOR PROCESSING
The controller has the right to process the personal data of the data subjects based on the:
• consent received from the data subjects;
• contractual relation between company and data subject which is based on acquisition of service; or
• legal obligation to which the controller is subject.

7) REGULAR SOURCES OF INFORMATION
Information regarding the data subjects are regularly gathered:
• from data subjects themselves via phone, internet, e-mail or in other similar fashion;
• via webpages’ forms
• with cookies and other similar tech.

8) PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The controller shall not store the personal data longer than is necessary, taking into consideration the purpose for the processing of personal data.

If a jobseeker is not chosen for the position she applied for, we shall not store any data of her without her consent. If we do not receive her consent, we destroy her data immediately. If she gives us her consent, we may store her data for six (6) months, after which we will destroy all such data.

The controller inspects monthly the necessity of the personal data stored.

9) CATEGORIES OF RECIPIENTS OF PERSONAL DATA
The recipients of personal data may consist of the following categories:
• Company’s Finnish affiliate companies;
• third parties who offer cloud services;
• third parties who offer customer communication platforms;
• third parties who offer accounting, marketing and auditing services; and
• third parties who help Company to fulfill its legal obligations.

All other information than information concerning data subjects of Section 3.4) may be disclosed with the data subject’s consent for marketing purposes in accordance with the Finnish Personal Data Act and the GDPR.

10) REGULAR DISCLOSURE OF DATA AND INFORMATION TRANSFER OUTSIDE OF EU OR THE EUROPEAN ECONOMIC AREA
Information may be transferred and stored to a server outside of EU or the European Economic Area to be processed by the Controller or Controller’s affiliate on Controller’s behalf in accordance with the Finnish Personal Data Act, the GDPR and the Finnish Data Protection Act.

11) DATA SUBJECTS’ RIGHTS
The data subject has a right to use all of the below mentioned rights.

The contacts concerning the rights shall be submitted to the person in charge of the data file stated in Section 2. The rights of the data subject can be put into action only when the data subject has been satisfactorily identified.

Right to inspect
Having presented the adequate and necessary information, the data subject has the right to know what, if any, data the controller has stored of her/him into this register. While providing the requested information to the data subject, the controller must also inform the data subject of the register’s regular sources of information, to what are the personal data used for and where is it regularly disclosed to.

Right to rectify and erasure
The data subject has a right to request the controller to rectify the inaccurate and incomplete personal data concerning the data subject.

The data subject can request the controller to erase the personal data concerning the data subject, if:

• the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• the data subject withdraws consent on which the processing is based on;
• the personal data has been unlawfully processed; or
• the personal data has to be erased for compliance with a legal obligation in EU or Member State law to which the controller is subject to.

If the controller does not accept the data subject’s request to rectify or erase the personal data, it must give a decision of the matter to the data subject in a written form. The decision must include the reasons for which the request was not granted. The data subject may then refer the matter to the relevant authorities (Data Protection Ombudsman).

The controller must inform the party to whom the controller has disclosed the personal data to or has received the personal data from of the rectification or erasure of personal data. However, there is no such obligation where the fulfilment of the obligation would be practically impossible or otherwise unreasonable.

Right to restriction of processing
The data subject can request the controller to restrict the processing of the personal data concerning the data subject where one of the following applies:

• the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; or
• the controller no longer needs the personal data for the purposes of the processing, but the personal data is required by the data subject for the establishment, exercise or defense of legal claims.

If the controller has based the restriction of the processing of personal data on the abovementioned criteria, the controller shall give a notification to the data subject before removing the restriction.

Right to refuse
Where personal data is processed for direct marketing purposes, the data subject shall have the right to refuse at any time to processing of personal data concerning her/him for such marketing, which includes profiling to the extent that it is related to such direct marketing. Data subject can refuse the processing of the personal data by contacting the person in charge of data files.

Right to data portability
The data subject shall have the right to receive the personal data concerning her/him, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided.

Right to withdraw consent
Where the legal basis for the processing of personal data is the consent of the data subject, the data subject shall have the right to withdraw her/his consent.

12) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
The data subject shall have the right to lodge a complaint with a supervisory authority, if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. The complaint can be lodged in the Member State of her/his habitual residence, place of work or place of the alleged infringement.

13) MERGERS AND ACQUISITIONS
In connection with mergers or acquisitions or divestiture of all parts of Company’s business, the acquiring entity, as well as its business partners will obtain access to data managed by Company, and this may include personal data. In the aforementioned case, such external parties will enter into a non-disclosure agreement with Company, which covers the potential disclosure of personal data.

14) DATA PROTECTION PRINCIPLES
Company uses all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect personal information from unauthorized or inappropriate access, but Company notes that the Internet is not always a secure medium. Company restricts access to information about data subjects only to the personnel of Company that need to know the information e.g. for responding to inquiries or requests made by the data subjects.

15) UPDATING THE PRIVACY POLICY
Company strives to develop its services continuously and for that reason privacy policy is subject to change without notice. Latest privacy policy is available at Company’s webpage and from person in charge of data files.