Terms of Registry

Description of the personal data file in accordance with Section 10 of the Finnish Personal Data Act (523/1999)

1. Controller

Havi Oy (Business ID: 0648171-4)
02200 Espoo
Tel. 010 843 4013

2. Contact person in matters concerning the personal data file

Jenna Kuusimäki
Havi Oy

3. Name of the personal data file

Havi Oy’s register based on customer relationship and relevant connection

4. Purpose of use of the register

Personal data will be processed on the basis of Section 8 of the Personal Data Act for the purpose of managing, developing and analyzing the relationship based on customer relationship and relevant connection, customer communication, marketing and business planning.

The personal data held in the data file can be processed in the manner permitted by applicable legislation for direct advertising, distance selling or other direct marketing, opinion polls, market research or other comparable addressed delivery of Havi Oy, companies belonging to the same group and selected co-operation partners of Havi Oy.

5. Data contents of the personal data file

The following types of information can be processed in the personal data file:

Basic information of the data subject, such as
• first and last names
• contact information
• country of residence
• gender
• date of birth
• native language
• identification details of payment instruments

Information related to customer relationship and other relevant connection, such as:
• identification data related to the use of services (e.g. customer number, user ID and passwords)
• date of commencement of the customer relationship
• data on purchases made as an identified customer (e.g. purchases in online store)
• home store
• use of services (e.g. subscription to newsletter)
• product returns
• benefits and campaigns targeted at the data subject and their use
• information related to invoicing and collection
• interests and other information entered by the data subject
• communication related to customer relationship and other relevant connection (such as notices of defect and other feedback and recordings of customer service calls)
• information related to activity on Havi Oy’s website
• direct marketing consents and prohibitions

6. Regular sources of information

Personal data concerning the data subject is collected from the data subject themselves and from information received from the systems arising in connection with the use of and registration in the services.

Personal data may also be collected from and updated on the basis of the data files of Havi Oy and companies belonging to the same group, the Population Information System, credit information registers, registers maintained by ASML Suomen Asiakkuusmarkkinointiliitto ry, and other similar public or private registers and sources offering information services.

7. Data disclosures

Data may be disclosed to Havi Oy’s selected co-operation partners for their marketing purposes, unless the data subject has prohibited such disclosure of the data.

Data will not be transferred to countries outside the European Union or the European Economic Area, unless it is necessary for the technical implementation of the service. In this case, Havi Oy is responsible for ensuring compliance with the requirements of the personal data legislation.

8. Protection of the data file

Databases in which the data is saved are protected by firewalls, passwords and other technical safeguards. The databases and their backups are located in locked premises. Manually processed documents containing information on the data subjects are also stored in locked premises to which unauthorized access is prevented.

Havi Oy will ensure that access to the data is only given to such employees of Havi Oy or companies working on behalf of Havi Oy that need the access in order to perform their duties.

9. Right of access, prohibition and rectification

The data subject is entitled to review what information on the data subject has been saved in the personal data file. A signed request for inspection shall be sent in writing to the contact person responsible for matters concerning the personal data file.

The request for inspection may also be presented in person at Havi Oy’s premises at the address mentioned above.

The data subject is entitled to prohibit the use of their data for direct advertising, distance selling or other direct marketing as well as for opinion polls or market research and has the right to request the controller to rectify any error in their information by notifying Havi’s customer service of this (tel. 010 843 4202, email: info@havis.fi).