We will set out the following below:
- our contact details
- what kind of data we collect
- where the data is collected from
- for what purpose the data is collected and the legal basis for processing data
- how long the data is stored for
- to whom data is disclosed and transferred
- how we protect the data
- what kind of rights the data subject has
1. CONTACT DETAILS
Business ID 1543822-4
Ilmalankuja 2 L
Person in charge of data file matters:
telephone +358 (0)10 2327 300
2. DATA CONTAINED IN THE DATA FILE
The following basic information will be processed for all data subjects:
- The data subject's basic information, such as their name, address, language, age, telephone number, e-mail address
- Permissions and restrictions, such as direct marketing consent and restrictions
- Areas of interest and other information electively provided by the data subject
- Event data
- Personal ID number for reliable identification
- Data concerning whether the person is a politically exposed person ("PEP")
- Data relating to invoicing and debt collection
- Data relating to the customer relationship and contractual relationship, such as products and services, their date of use, relevant customer wishes, service salesperson details, data concerning the number, type and purpose of keys, reception and handover, and service-related contact and events
With regard to landlords and property sales, the following will also be processed in addition to basic data:
- Ownership relationships and data concerning the property to be leased or sold, such as address, property register or housing company data, condition and renovation data, mortgage, maintenance payment and debt data, size, number of rooms, vacancy date, asking rental or sales price, data on whether the site is meant to be used by spouses as a shared home, and additional information about the site provided by the customer
For tenants, relocation service users and rental property applicants, the following information will be processed in addition to basic data:
- Nature of employment relationship (agreement for an indefinite term, fixed-term agreement)
- Student status, educational establishment, training programme
- Property search criteria
- Date on which the tenancy agreement begins
- Financial data and income, as well as other information relating to the assessment of rental solvency
- Any security, guardian or representative relationship or contact person
In addition, we may process other data provided electively by the data subject in connection with their application or other contact.
We also observe data on the use of our online services in the manner outlined in section 9, “Cookies”. We do not combine data observed through cookies with data on an identified customer.
In addition to basic data, the following are processed in connection with reports submitted via Vuokraturva’s internal whistleblowing channel:
- Information provided by the whistleblower to the whistleblowing channel, to the extent required in order to investigate the case.
3. REGULAR SOURCES OF DATA
Personal data is collected at registration, when services are used, or otherwise directly from the data subject. Personal data may also be collected and updated using the population register and a register of restrictions maintained by Suoramarkkinointiliitto, and other corresponding registers.
4. PURPOSE OF PERSONAL DATA AND LEGAL BASIS FOR PROCESSING DATA
Personal data is used to take care of, manage and develop the customer relationship
and to market services as set out below:
- Agreement: In order for us to carry out a rental or sales commission, we process our client's personal data in order to present and market a site, to match a landlord with a tenant or a buyer and a seller, and to invoice for the commission. Personal data is also processed in applications, offers, counteroffers, and in sale and rental documents and their appendices as part of contractual negotiations.
- Consent: We request consent to process the personal data of a rental property applicant or buyer of a property in order to e-mail the applicant information on properties which have recently become available. We may also request the customer's request for direct electronic marketing. Consent can be withdrawn at any time.
- Grounds of legitimate interest: We process data for marketing, profiling, preventing and investigating fraud and misuse, to advance or defend legal claims and for internal purposes within the Vuokraturva group, such as for developing business operations. These purposes are necessary for our business operations and are justified on the basis of the business relationship between the customer and Vuokraturva, and is therefore in our legitimate interest. The data subject may oppose processing as set out below.
The forms used to collect personal data state separately the data that is mandatory from a service provision perspective, and the data that the data subject can provide electively. For example, the customer may prefer not to provide information on their interests, but this then means that we are unable to customise sites offered to the customer, or any other service offered.
5. DURATION OF DATA STORAGE
We store the customer’s/user's data for as long as is necessary in order to fulfil the purposes defined above and to comply with legislative requirements:
- Section 10 of the Act on Real Estate and Rental Agencies (Välitysliikelaki 1075/2000) stipulates that agencies must store the data and documents (including apartment applications and purchase offers) relating to a commission for five years after the commission ends. The aforementioned five-year storage time is nevertheless a legal minimum requirement, and we store data and documents for 12 years. This is because the limitation period for tort liability is 10 years, and we wish to account for the duration of processes that may begin towards the end of the limitation period.
- We store data relating to the Relocation service for 12 years due to the 10-year limitation period for tort liability and to account for the duration of processes that may begin towards the end of the limitation period.
- For reports submitted via Vuokraturva’s internal whistleblowing channel, we retain data for the period of time required by legislation. Vuokraturva’s internal whistleblowing channel is called First Whistle and it runs on Juuriharja Consulting Group’s server.
The user may also influence the length of the data storage period as set out in section 8 below, which outlines the data subject's rights.
6. DISCLOSURE AND TRANSFER OF DATA
- The Vuokraturva-yhtiöt group: We may process customers' personal data within the Vuokraturva-yhtiöt group.
- Authorities: We may disclose customers' personal data in a manner required by demands from competent authorities or other parties, but nevertheless in a manner that conforms to valid legislation.
- Business reorganisation: If we buy, merge or otherwise reorganise our operations, customers' personal data may be disclosed to the buyer and their negotiators.
- Direct marketing and opinion and market surveys: We may disclose the customer's personal data for direct marketing and opinion and market surveys if the customer has not prohibited us from doing so.
- Debt collection and legal claims: We may disclose personal data to third parties if it is necessary in order to implement the agreement, in order to investigate any possible criminal offences or to compile, present or defend a legal claim.
In addition to personnel at Vuokraturva Oy and its parent company Vuokraturva-yhtiöt Oy, ICT partners in cooperation City Dev Labs / W3 Group Finland Oy and OptimeSys Oy and personnel, for whom it is absolutely necessary to access the information in order to perform their tasks are also granted access to customer data and the customer data systems.
- Concerning Vuokraturva’s internal whistleblowing channel, Juuriharja Consulting Group Oy, which developed the service, processes the personal data - such as name and contact information, technical data relating to software, and other personal data that can be linked to a natural person - of Vuokraturva Oy’s main users and whistleblowers (“Data subjects”) as part of its obligations. Whistleblowers may also save other people’s personal data in the Whistleblowing channel. In its role as platform provider, Juuriharja acts as the processor of the personal data as meant in the GDPR, and Vuokraturva acts as the Controller of the data in accordance with data protection legislation. Any subcontractors used by Juuriharja to provide the service will act as Subprocessors.
7. PROTECTION OF THE DATA FILE
The right to access the data file requires user credentials assigned by the main user of the customer database. The main user also specifies the user access level set for users. A personal password is required to initialise the application. Use of the data file and logins to it are monitored.
Data is collected into the service's shared databases which are secured by means of firewalls, passwords and other technology. The databases are located in locked spaces and only persons specified in advance are allowed to access the data. Only personnel with access to the data are permitted on Vuokraturva Oy's premises, where the data is processed and stored.
8. RIGHTS OF THE DATA SUBJECT
- Checking, rectifying, transferring and erasing data The customer has the right to check the personal data stored about them. At the customer's request, we will rectify, supplement or erase data that is erroneous, incomplete or obsolete with regard to the purpose of processing. The customer may also have the personal data that we process automatically on the basis of consent or an agreement transferred by contacting our customer service.
- Right to restrictions on direct marketing: Our customers can at any time prohibit the disclosure and processing of their data for direct marketing by contacting our customer services or, in the case of electronic direct marketing, by clicking the button at the bottom of the message.
- Right to oppose and restrict data processing: The customer can oppose data processing based on legitimate interest on grounds relating to their personal situation. For example, in such cases processing will be restricted for a period while the grounds to oppose processing are assessed. Processing can also be restricted if the customer disputes the accuracy of personal data, whereupon processing will be restricted for a period while we ensure the accuracy of the data.
- Withdrawal of consent: The customer can withdraw its consent at any time by contacting our customer services or through another separately available method.
Please click here if you would like to block Vuokraturva Oy's electronic direct marketing. Please note that the objection to direct marketing also applies to the search alert. This means that you will be unable to receive emailed information about rental properties that meet the search criteria selected for your search alert.
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