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Latest update - June 1, 2018
for JCDecaux Finland Oy’s customer, co-operation partner and marketing register
1 Data controller
JCDecaux Finland Oy (Business ID 0201696-2)
00810 Helsinki, Finland
2 Contact details in register matters
Tel. +358 20 7758 200
3 Name of register
Customer, co-operation partner and marketing register
4 Purpose and basis of personal data processing
The processing of personal data is based upon contract or JCDecaux Finland Oy’s legitimate interest (direct marketing). The intended purpose of use of the personal data is the management, upkeep, development, analysis and statistical analysis of the relationship between JCDecaux Finland Oy and its customers and co-operation partners. Furthermore, information is used for the direct marketing of JCDecaux and its co-operation partners, organisation of marketing raffles as well as polls and market research. The information may also be used for the planning and developing of JCDecaux’s business operations and services, as well as for measuring customer volumes.
5 Data content of the register and categories of data subjects
The register contains the following information regarding the decision-makers and contact persons of customer or co-operation partner companies and entities (incl. newsletter subscribers, image bank customers and lessors):
- name, position, company, postal address, email address, telephone number
- customer history (e.g. contacts made)
- direct marketing prohibitions as well as
- any other information necessary for the purpose of use of the register
The register contains the following information regarding the decision-makers and contact persons of potential customer companies and entities:
- name, position, company, postal address, email address, telephone number
- information concerning the data subject’s tasks and position in business life or in public office
- direct marketing permissions and prohibitions
6 Data sources
The data in the register is collected as a rule from the data subjects themselves over the telephone, in meetings or through other comparable methods. The register is compiled in connection with concluding a customer or co-operation agreement with JCDecaux and from the information provided by the customer during the contractual relationship as well as from the information otherwise obtained during the relationship. Personal data may be collected and updated also from public and private registers.
7 Disclosures and transfers of information as well as transfers of information outside of the EU or EEA
As a rule, personal data are not disclosed to third parties or transferred outside of the EU or EEA. Information may, however, be occasionally transferred in accordance with the laws of Finland on one of the below-mentioned grounds:
- the European Commission has decided that the recipient country in question has ensured an adequate level of data protection;
- we have implemented the appropriate security measures for the transferring of your personal data by utilising the standard contract clauses for data protection approved by the European Commission. In such a case you have the right to obtain a copy of the said standard clauses by contacting us; or
- you have granted your express consent to the transferring of your personal data or there is another lawful basis for transferring your personal data outside of the EU/EEA area, such as the Privacy Shield arrangement approved by the European Commission as concerns the United States.
JCDecaux Finland Oy retains a third party service provider for the administration and management of information. This entails transferring of personal data to the service provider to the extent necessary for the provision of the said service. The service providers may have access to your personal data from outside of the EU/EEA area, such as from the United States. In all cases, we ensure the appropriate and lawful implementation of any transfers in accordance with the personal data legislation.
8 Principles for protecting the register and data retention period
The right of use to the system containing personal data is only granted to employees who by virtue of their job description have the right to process customer, marketing register or co-operation partner information. Each user has their own user ID and password to the system. The information is collected into databases that are protected with firewalls, passwords and other technical means. The databases and the backup copies of same are located in locked spaces and only certain pre-designated persons have access to same. JCDecaux Finland Oy ensures the implementation of data protection by means of data processing agreements concluded with those of its subcontractors that process personal data.
Personal data is retained for as long as necessary for the purpose of use. As a point of departure, customer information is retained for 1.5 years after the cessation of the customer and/or contractual relationship or the latest interaction (invitation to tender, order or meeting) (except where the legislation requires for the information to be retained for longer).
Personal data regarding the decision-makers and contact persons of potential customer companies and entities are retained permanently within the limits stipulated by law. JCDecaux Finland Oy assesses the necessity of retaining the information on a regular basis, in addition to which JCDecaux Finland Oy effects such reasonable actions that ensure that no personal data concerning the data subjects that are incompatible, out-dated or erroneous considering the purpose of the processing are retained in the register.
9 Data subject’s rights
Right of access and the right to demand rectification.
The data subject has the right to access information concerning them recorded in the personal data register and to require the rectification of erroneous information and the erasure of information. Requests regarding the matter must be submitted in writing to the email address mentioned under Section 2.
Pursuant to the EU General Data Protection Regulation, the data subject has the right to object to or request a restriction of the processing of their data and to lodge a complaint regarding the processing of their personal data with the Data Protection Ombudsman.