Privacy Notice of HPP Attorneys Ltd’s Marketing Data Filing System
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: email@example.com.
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 5 March 2021.
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;
- Information provided by the Data Subject on food allergies and special diets when registering for an event; and
- Potential photos and video material taken of the Data Subject in HPP’s events provided that the Data Subject has given his or her consent for this when participating in an event.
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’s legitimate interest (art. 6.1.f.) based on purposes of use determined below.
In relation to information on food allergies and special diets and photos and video material possibly taken of the Data Subject in HPP’s events, the basis for processing is, however, the Data Subject’s consent (art. 6.1.a.).
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 organizing educational or training events and 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:
- Lyyti Oy
- Micromedia Oy
- Printix Oy
- Social Cocktail Oy
Data Subject’s personal data may be disclosed to event organizers (e.g. disclosing information on food allergies and special diets to catering service providers) that process the Data Subject’s personal data as a data controller. Such recipients of personal data will not process the disclosed personal data for any other purposes.
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 unior or the European Economic Area
HPP does not transfer the Data Subject’s personal data outside the European Union or the European Economic Area.
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. Personal data relating to a specific event organized by HPP will, however, be deleted at the latest within two years of the event in question.
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;
- withdraw his or her consent and object to the processing of his or her personal data in so far as the processing is based on the Data Subject’s consent;
- 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;
- receive his or her personal data in a machine-readable format and transmit those data to another controller; 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 the Data Subject’s personal data. Manual material containing personal data are stored in HPP’s locked premises. Personal data processed digitally are stored in information systems protected by firewalls and accessible to HPP’s personnel and parties involved in the maintenance of such information systems with their personal user credentials and passwords.
All requests concerning the use of the aforementioned rights, questions about this privacy notice and other contacts should be made by e-mail to firstname.lastname@example.org.