PRIVACY POLICIES

Data protection is corporate responsibility. Safe and careful processing of personal data is of utmost importance to us.

See our registers below

Marketing register
Customer register
Partner register

ISLET GROUP LTD’s Marketing Register Privacy Policy

1. Controller
Islet Group Ltd
Company ID: 1445054-7
Metsänneidonkuja 12
02130 Espoo
[“Islet”]

2. Contact person for matters relating to the register
Piia Hoffsten
Email: dataprotection(at)isletgroup.fi

3. Name of the register
Islet Group Ltd´s Marketing Register.

4. Use and basis for processing personal data
Personal data of existing, previous and potential customers are used for marketing purposes. These purposes are for example notifications of future campaigns and sending the newsletter. We also use personal data for direct marketing. In addition, we maintain a website which shares information of current activity in our company.

The ground for processing personal data for marketing is the legitimate interest of Islet.

5. Data content of the register
The following information can be stored of registered:
– Name and title
– Contact information: phone number and email
– Name and contact details of the represented company
– Prohibition to direct marketing
– Information about the use of website, for example IP address
– Participation in training events

6. Retention of personal data
Islet retains personal data in Marketing Register no more than 5 years from the end of the
marketing relationship. This period of 5 years is calculated from the last communication to the data subject.

Unnecessary and outdated information are deleted in certain intervals.

7. Information sources of the register
Information about the representatives of customer companies are collected from the customer
company or straight from the data subject. In addition, we collect information through our website.
Personal data relating to potential customers are obtained from the following sources:
– From the registered, for example contact or business card;
– LinkedIn;
– Fonecta;
– Companies own websites (Google);
– Participant list of events.

8. Collecting information from our website
We use google analytics that collects information from our website. Google Analytics gathers the
following information:
– The language used
– Location (country and city), Google Analytics does not reveal the IP address
– Device used and the web browser that is used
– Visitor behaviour: is the first visit, which pages are visited, how long is the visit and what
is the navigation path

More information about Google Analytics: https://support.google.com/analytics/.

9. Provision of information
We disclose information to BPS Consulting Hungary Kft (Islet subsidiary) if needed. In addition, we disclose information to the companies that maintain the customer relationship management system and newsletter transmission system which we use. At the moment we use the customer relationship management system of SAP and newsletter transmission system of MailChimp. Personal data are also provided to Elisa Plc, who is the IT Service provider of Islet.

10. Transfer of data outside the EU or EEA
We transfer your personal data to countries outside EU/EEA, such as United States. We will
ensure to make the transfers in accordance with the legislation on the processing of personal
data. In all situations we will ensure that we only transfer your personal data with one of the
following legal basis:
– data is transferred to a country, where European Commission has decided that there is
an adequate level of protection;
– the controller or processor has provided appropriate safeguards, and on condition that
enforceable data subject rights and effective legal remedies for data subjects are
available; or
– you have given your explicit consent, or there is a legitimate basis for the transfer of your
data outside the EU/EEA, such as the Privacy Policy Shield, which has been agreed with
United States and European Commission.

MailChimp is part of the Privacy Policy Shield arrangement agreed with United States and
European Commission.

11. Protection of the register
Islet processes all personal data in a secure way and constantly aims to develop their systems.

The register is held in the datacentre of Elisa, hosting partner of Islet, which is isolated with
firewall, access authorization and network encryption. Only authorised persons, whose job
description contains marketing, have access to the register.

12. Rights of the data subject
At any time, the data subject has a right to object to the processing of his personal data for direct marketing purposes. Emails send by Islet contain either a link from which you can object to direct marketing in the future or alternatively you can answer the message with a request to end direct marketing in the future.

At any time, the data subject has the right:
– to obtain information on the processing of personal data;
– of access to the information and check information regarding themselves;
– to demand correction or completion of inaccurate information;
– to demand the erasure of personal data;
– to obtain from the controller restriction of processing;
– to object, on grounds relating to his or her particular situation, at any time to processing of
personal data concerning him or her, in case where personal data is processed based on
the legitimate interest of Islet;
– to receive the personal data concerning him or her in a structured, commonly used and
machine-readable format and have the right to transmit those data to another controller;
– to object processing of personal data;
– withdraw their consent and object to the processing, which is based on that consent.

We may ask the data subject to clarify their request. In addition, we may verify your identity before
processing the request. We may refuse to execute your request on the basis of data protection legislation.

Data subject has a right to lodge a complaint with a supervisory authority if it thinks that Islet has not complied with the applicable data protection legislation.

13. Contact
Questions about the processing of personal data or request for the use of rights of data subject must be done in writing or by email to the following address:

Islet Group Ltd
Metsänneidonkuja 12
02130 Espoo
Email: dataprotection(at)isletgroup.fi

Islet will respond to the requests as soon as possible. However, the respond will be given within one month unless there are special reasons to extend this time.

14. Changing the Privacy Policy
We may change this privacy statement from time to time, if necessary. We will inform the
registered from changes to this Privacy Policy.

Last update to this Privacy Policy was made: 21.5.2018