HPP Asianajotoimisto

Privacy Notice of HPP Attorneys Ltd’s Marketing Data Filing System

1 General

HPP Attorneys Ltd (”HPP”) is committed to ensure the confidentiality and data protection of personal data at its possession. This privacy notice is applied to personal data that HPP collects in relation to HPP’s marketing data filing system (“Data Filing System”). The personal data and related processing in the Data Filing System are described in this privacy notice. Additional information regarding the processing of personal data in the Data Filing System is provided by HPP’s contact person: Katja Anttila (katja.anttila@hpp.fi).

HPP may update this privacy notice from time to time, for example, due to changes in applicable legislation. HPP endeavors to carry out reasonable means to inform you beforehand of any potential amendments and those effects. HPP advises you to review this privacy notice every time you receive information of such amendments. This data protection record was last updated on 14 May 2018.

2 Data Controller

Name: HPP Attorneys Ltd
Address: Bulevardi 1 A, 00100 Helsinki
Tel: +358 9 474 21
Business ID: 0224138-5

3 Whose Personal Data Are Collected?

HPP processes the personal data of its clients, potential clients, representatives of HPP’s business partners and HPP’s former employees (“Data Subject”).

4 What Categories of Personal Data Are Processed?

HPP process the following personal data in the Data Filing System:

  • Name of the company the Data Subject represents;
  • Data Subject’s name and position in the company;
  • Data Subject’s contact details: postal address, email and telephone number; and
  • Potential photos and video material taken of the Data Subject in HPP’s events.

5 Which Sources Are Used to Collect Personal Data?

HPP collects Data Subject’s personal data from the following sources:

  • from Data Subject himself or herself (e.g. Data Subject’s contact requests and business cards provided to HPP);
  • from other employees of the company the Data Subject is representing;
  • from HPP’s employees and partners;
  • through events (e.g. trade fairs and seminars); and
  • from publicly available sources.

6 Basis, Purposes and Effects of Processing Personal Data

The basis for processing Data Subject’s personal data is HPP legitimate interest (art. 6.1.f.) based on purposes of use determined below.

The purpose of the processing of Data Subject’s personal data is the sales and marketing of HPP’s services and events to Data Subject and exercising other sales and marketing measures which are regularly marketing measures, such as sending marketing emails via email. HPP does not market any third party’s products or services to the Data Subject.

There are no other effects of the processing of Data Subject’s personal data than targeting and enhancing HPP’s marketing.
HPP does not process further Data Subject’s personal data for any other purposes than mentioned in this data protection record.

7 Regular Disclosures and Transfers of Personal Data to Third Parties

HPP transfers Data Subject’s personal data to HPP’s sales, marketing and other business partners who act on HPP’s mandate and for HPP for the purpose of implementing marketing and marketing events. HPP always ensures that its business partners do not process the personal data transferred to them for any other purposes.

List of HPP’s sales, marketing and other business partners:

  • Config Oy
  • CSI Helsinki Oy
  • Emaileri Oy
  • Hanna Latvanen Tmi
  • Lyyti Oy
  • Printix Oy

Data Subject’s personal data may be disclosed to event organizers that process the Data Subject’s personal data as a data controller.

HPP may also, if necessary, disclose Data Subject’s personal data to a competent authority, in accordance with applicable data protection legislation.

8 Transfers of Personal Data outside the European Union or the European Economic Area

HPP transfers Data Subject’s personal data outside the European Union (“EU”) or the European Economic Area (“EEA”), in accordance with data protection legislation based on Data Subject’s prior and explicit oral or written consent, to the following operators: Facebook, Instagram and LinkedIn.

HPP may also use other service providers established outside the EU or the EEA in processing of Data Subject’s personal data. In all situations HPP transfers Data Subject’s personal data outside the EU or the EEA only based on one of the lawful grounds mentioned below:

  • the EU Commission has decided that the recipient country in question ensures an adequate level of protection;
  • HPP has established appropriate safeguards for the transfer of personal data by using standard data protection clauses approved by the Commission. Data Subject shall then have the right to obtain a copy of such standard clauses by contacting HPP in the manner described in the section ’Contacts’; or
  • Data Subject has given his or her explicit consent for the transfer of Data Subject’s personal data or another lawful basis for the transfer of Data Subject’s personal data outside the EU or the EEA exists.

9 Principles for the Storage of Personal Data

HPP stores Data Subject’s personal data in the Data Filing System as long as the Data Subject holds a position to which HPP’s marketed product or service is related to.

Data Subject’s personal data may be stored for longer period if applicable legislation or HPP’s contractual obligations towards third parties require a longer storage period.

10 Rights of Data Subject in relation to Processing of Personal Data

Data Subject has the right, in accordance with the applicable data protection legislation, at any time:

  • be informed about the processing of his or her personal data;
  • obtain access to data relating to Data Subject and review his or her personal data processed;
  • require rectification and correction of his or her inaccurate and incorrect data;
  • require erasure of his or her personal data;
  • object the processing of Data Subject’s personal data on grounds relating to his or her particular situation; and
  • require restriction of processing of his or her personal data.

Data Subject should present his or her request for exercising any of the aforementioned rights in the manner described in the ‘Contacts’ section of this privacy notice. HPP may ask Data Subject to specify his or her request in writing and verify Data Subject’s identity before processing the request. HPP may refuse to fulfil Data Subject’s request on grounds set out in applicable data protection legislation.

Data Subject also has the right to lodge a complaint with the supervisory authority concerned or with the supervisory authority of the EU member state of Data Subject’s residence or place of work if Data Subject considers that HPP has not processed his or her personal data in accordance with the applicable data protection legislation.

11 Principles of Data Security

HPP respects the confidentiality of Data Subject’s personal data. Manual material containing personal data shall be restored in HPP’s locked premises. Personal data processed digitally are protected and restored in the information system administered by HPP and accessible to HPP’s employees and representatives of HPP’s business partners with their personal user credentials and passwords. Several different backup copies of the data processed in HPP’s data systems are maintained in differentiated systems. Data recovery and integrity can be ensured in case problematic situations occur.

12 Contacts

All requests concerning the use of the aforementioned rights, questions about this privacy notice and other contacts should be made by e-mail to Katja Anttila to the address katja.anttila@hpp.fi. Data Subject may also contact HPP in writing or in person:

HPP Attorneys Ltd
Katja Anttila
Bulevardi 1 A
00100 Helsinki