Privacy policy

Information on processing of personal information

Introduction

When Marketing Marina Oy (3391472-2), (“MM”, “we”, “us”, ”our”) is processing personal data as a data controller in terms of GDPR (Regulation (EU) 2016/679), we are obliged to provide certain information on the processing.

In this document ("privacy notice"), you will find the information that we are obliged to provide in the context of our processing of personal data about external persons (others than MM employees), aside from job applicants.

Terms used in this privacy notice

Unless otherwise stated, terms defined in the GDPR, such as "personal data" and "processing", shall have the same meaning in this privacy notice.

"Applicable Data Protection Laws" means all legislation and regulations, including regulations issued by relevant supervisory authorities, protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data that from time to time applies to this privacy notice, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "GDPR") as well as laws and regulations supplementing the GDPR.

Accordingly, "personal data" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organizing, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

2. Data controller

The data controller is:

Marketing Marina Oy

3391472-2

Erottajankatu 11

00130 Helsinki, Finland

Telephone: +358201552200

E-mail: info@marketingmarina.com

Depending on which MM group company you are communicating with, one of the MM group companies may also act as data controller. However, in such a case, you can use the contact details above.

3. Processing activities

3.1 Business communications

If you sign up to subscribe newsletters, catalogues, press releases or similar information regarding MM and its business or fill up contact form or survey on our website, we will process your personal data for the purposes of providing the requested subscription or information to you.

3.1.1 Categories of personal data

We process the following categories of personal data:

· Name

· Contact information such as e-mail address, phone number, and address

· Professional information such as your employee and role in the organisation

We collect this information through forms completed on our website or via communication facilitated by our website's features.

3.1.2 Legal basis

Legitimate Interest: In scenarios where communications are directed to you in your professional capacity or are not classified as electronic direct marketing (such as when you opt-in for specific content), we process your data based on our legitimate interest to provide the requested information. This ensures that we can effectively deliver the content you have sought.

Consent: When communications can be considered electronic direct marketing, like subscribing to our newsletter, we process your data to fulfill your request for such subscriptions and information. This also enables us to promote MM's brand and products. It's important to note that you have the right to withdraw your consent or object to the use of your data for electronic direct marketing at any time. Upon receiving such a request, we will cease processing your data for these purposes.

3.1.3 Recipients of personal data

The information will be accessible for our IT suppliers (data processors), storing the information on our behalf and processing the information in accordance with our instructions.

Furthermore, if necessary, we share your personal data with other recipients for certain purposes e.g. when fulfilling legal obligations and handling and/or defending legal claims.

MM Group Companies

Purpose: Sharing essential personal data for internal administrative functions, such as website maintenance.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interests relating to internal administration purposes.

Public Authorities

Purpose: Disclosing necessary data as required by law.

Legal Basis: Legal obligation. The processing is necessary in order to fulfill legal obligations.

External Advisors (e.g., Audit and Law Firms)

Purpose: Sharing information as legally required or for managing and defending legal claims.

Legal Basis: Legal obligation and legitimate interest. The processing is necessary in order to fulfill legal obligations or, alternatively, to fulfill our legitimate interest of managing and defending legal claims.

Courts, Counterparties, etc.

Purpose: Managing and defending legal claims.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interest of managing and defending legal claims.

Law Enforcement Authorities (e.g., Police)

Purpose: Disclosing information as required by law.

Legal Basis: Legal obligation. The processing is necessary in order to fulfill legal obligations.

Potential Buyers and Sellers (During Business Acquisitions or Mergers)

Purpose: Sharing data for business acquisition or merger processes.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interest of carrying out the acquisition or the merger.

Advertising Partners

Purpose: Providing relevant marketing content.

Legal Basis: Consent. The processing is necessary in order to provide you with relevant marketing content.

3.1.4 Retention and deletion

Your personal data is stored for this purpose until you unsubscribe from the information requested. After you have unsubscribed from communication from us, we will erase personal data processed for this purpose within 90 days.

Information may, however, be retained for a longer period if necessary to comply with a legal obligation to which MM is subject, or if retaining the information is necessary for MM to establish, exercise or defend a legal claim.

3.2 Evaluating and Monitoring Website Usage

In order to evaluate and follow-up, and develop on the use of our website, we process your personal data, e.g. in connection with collection of visitor statistics on our website. Processing conducted for the purpose set above may include the use of statistical and analytical cookies.

3.2.1 Categories of personal data

We process the following categories of personal data:

· Online identifiers

· User generated information

We will automatically collect personal data about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version. Furthermore, our website may also download cookies to your device.

3.2.2 Legal basis

Consent. The processing is necessary in order to evaluate and improve our website by way of utilizing cookies.

Legitimate interest. Where allowed by applicable legislation, after obtaining your consent for the use of cookies, the subsequent processing may also be necessary in order to fulfill our legitimate interest of evaluating and improving our website.

3.2.3 Recipients of personal data

The information will be accessible for our IT suppliers (data processors), storing the information on our behalf and processing the information in accordance with our instructions.

For more information, please see the section 3.1.3 of this privacy notice.

3.2.4 Retention and deletion

You may at any time, delete cookies that have been saved on your device by changing the settings in your web browser. In case you do not delete cookies by changing settings in your web browser, the cookies that are used for this purpose will be erased when your session has ended or, in case of persistent cookies, they will be erased in accordance with the expiration date for each cookie. Reports on an aggregated level which do not contain any personal data and statistics are stored until further notice or until they are deleted.

3.3 Delivering Relevant Marketing and Communications

We collect and process your personal data to enable both our team and our advertising partners to deliver tailored advertising and communications on our website, in social media and by email. This processing includes the deployment of marketing cookies, specifically aimed at enhancing the relevance of the content presented to you

3.3.1 Categories of personal data

We process the following categories of personal data:

· Online identifiers

· User generated information

· Geographic data (only if you are using mobile device)

We will automatically collect personal data about you and your visit on our website and regarding our email marketing, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version. Furthermore, our website may also download cookies to your device.

3.3.2 Legal basis

Consent. The processing is necessary in order to provide you with relevant marketing content and for us to understand how visitors interact with the website.

3.3.3 Recipients of personal data

The information will be accessible for our IT suppliers (data processors), storing the information on our behalf and processing the information in accordance with our instructions.

For more information, please see the section 3.1.3 of this privacy notice.

3.3.4 Retention and deletion

3.4 Securing and Managing Our Website and IT Systems, and Enhancing User Experience

In order to manage and protect our website, services and related IT systems, upon logging, troubleshooting, backup, change and problem management in systems and in connection with potential IT incidents, we process, to the extent necessary, your personal data. Furthermore, your personal data may be processed for the purposes of enabling our website to be delivered on your device and to fulfil your requests on our website. Processing conducted for the purposes set above may include the use of technically necessary cookies. In addition, in order to improve your experience at the website and provide you with tailored content when appropriate, we will process your personal data.

3.4.1 Categories of personal data

We process the following categories of personal data:

· Online identifiers

· User generated information

3.4.2 Legal basis

The legal basis depends on the specific reason for communicating with the data subject.

Legitimate interest. The processing is necessary in order to fulfil our legitimate interest of managing and protecting our website, services and related IT systems. Where allowed by applicable legislation, after obtaining your consent for the use of cookies, the subsequent processing may also be necessary in order to fulfill our legitimate interest of evaluating and improving our website.

Consent. The processing is necessary in order to evaluate and improve our website by way of utilizing cookies.

3.4.3 Recipients of personal data

The information will be accessible for our IT suppliers (data processors), storing the information on our behalf and processing the information in accordance with our instructions.

For more information, please see the section 3.1.3 of this privacy notice.

3.4.4 Retention and deletion

Personal data in logs are stored as long as necessary for troubleshooting and incident handling Cookies used for this purpose are stored as long as necessary for trouble shooting and incident handling.

3.5 Administration

For the purpose of our general administration and business operations, we process personal information about (contact persons at) suppliers, business partners and others with whom we are interacting in the course of our business operations.

3.5.1 Categories of personal data

We process the following categories of personal data:

· Name

· E-mail address

· Telephone number

· Address

· Information on previous correspondence/business

· Other information we may receive when handling queries.

For persons who are contact persons at suppliers and business partners, information on address, telephone number and e-mail address will typically be business address, business telephone number and business e-mail address.

We generally receive the information directly from the data subjects or from the businesses, they represent.

3.5.2 Legal basis

The legal basis depends on the specific reason for communicating with the data subject.

Legitimate interest (legal entities). The processing is necessary in order to fulfil our legitimate interest of managing the business relationship.

Performance of a contract (sole traders). We are required to process your personal data in order to fulfil the agreement concluded with you.

3.5.3 Recipients of personal data

MM Group Companies

Purpose: Sharing essential personal data for internal administrative functions, such as website maintenance.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interests relating to internal administration purposes.

Public Authorities

Purpose: Disclosing necessary data as required by law.

Legal Basis: Legal obligation. The processing is necessary in order to fulfill legal obligations.

Banks

Purpose: We share your personal data with relevant banks for the purposes of managing the producer relationship, e.g. in connection with issuing payments in accordance with our contractual obligations.

Legal Basis:

Legitimate interest (legal entities). The processing is necessary in order to fulfill our legitimate interest of managing the business relationship.

Performance of a contract (sole traders). We are required to process your personal data in order to fulfil the agreement concluded with you.

External Advisors (e.g., Audit and Law Firms)

Purpose: Sharing information as legally required or for managing and defending legal claims.

Courts, Counterparties, etc.

Purpose: Managing and defending legal claims.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interest of managing and defending legal claims.

Law Enforcement Authorities (e.g., Police)

Purpose: Disclosing information as required by law.

Legal Basis: Legal obligation. The processing is necessary in order to fulfill legal obligations.

Potential Buyers and Sellers (During Business Acquisitions or Mergers)

Purpose: Sharing data for business acquisition or merger processes.

Legal Basis: Legitimate interest. The processing is necessary in order to fulfill our legitimate interest of carrying out the acquisition or the merger.

Advertising Partners

Purpose: Providing relevant marketing content.

Legal Basis: Consent. The processing is necessary in order to provide you with relevant marketing content.

3.5.4 Retention and deletion

Your personal data is stored during the business relationship and thereafter for a period of 10 years in order for us to fulfil our legitimate interest of handling and meeting any legal requirements. We store only accurate and up-to-date personal data. In case you are no longer the relevant contact person for this purpose, we will delete your personal data and update the required personal data with accurate data..

3.6 Fulfilment of legal obligations

We process your information to fulfil legal obligations to which we are subject, e.g. to meet accounting and bookkeeping requirements.

3.6.1 Categories of personal data

We process all categories of personal data necessary to fulfil the legal obligation, such as names and transaction data.

We generally receive the information directly from the data subjects or from the companies they represent.

3.6.2 Legal basis

The legal basis for processing personal data is article 6 (1) para. (c) of the GDPR, as the processing is necessary for compliance with legal obligations to which we are subject.

3.6.3 Recipients of personal data

We may transfer personal data to authorities, external advisors or others if it is necessary to comply with our legal obligations.

3.6.4 Retention and deletion

Information is stored for the period of time it is necessary, in order to fulfil a legal obligation to which MM is subject, for example under the Bookkeeping Act.

3.7 Establishment, exercise or defense of legal claims

We process your personal data for the establishment, exercise or defense of legal claims.

3.7.1 Categories of personal data

We process all categories of personal data necessary for the establishment, exercise or defense of legal claims, such as names.

We generally receive the information directly from the data subjects or from the companies they represent.

3.7.2 Legal basis

The legal basis for processing personal data is article 6 (1) para. (f) GDPR, the processing is necessary for the purposes of our legitimate interest in establishing, exercising or defending legal claims, such as in a dispute and legal proceedings.

3.7.3 Recipients of personal data

We may disclose data to authorities, external advisors or others if it is necessary for the establishment, exercise or defense of legal claims.

3.7.4 Retention and deletion

Personal data may be retained during the statutory limitation period for the purpose of establishing, exercising and defending legal claims.

4. Transfers of Personal Data

We always strive to store and process personal data within the EU/EEA. However, some of our service providers are located outside the EU/EEA and in such a case personal data will be processed outside the EU/EEA. In order to ensure that the personal data is protected we make sure that appropriate safeguards are in place in relation to the service providers which handle your personal outside the EU/EEA, e.g. by way of data transfer agreements (which include standard data protection clauses adopted by the EU Commission). If you have questions regarding to which countries your personal data is transferred and which safeguards we take to protect your personal data, or to request a copy of such safeguards and information, respectively, where they are available, please contact us at info@marketingmarina.com.

5. Your rights

In connection with our processing of your personal data, you may, under the conditions set out below, exercise the following rights:

Access

You can request confirmation of whether or not your personal data is being processed and, if it is being processed, request access to your Personal data and additional information such as the purpose of the processing. You also have the right to receive a copy of the personal data that is processed. If the request is submitted electronically, the information will also be obtained in a commonly used electronic form unless you request otherwise.

Rectification

If you notice that personal data about you is inaccurate or incomplete, you have the right to have your personal data rectified or completed.

Object to specific processing

You can object to processing of your personal data if it is based on a legitimate interest, on grounds relating to your particular situation or if the processing takes place for direct marketing purposes. Upon such an objection, we are obliged to cease the processing, unless we can demonstrate compelling legitimate grounds to continue processing and those grounds override your interests. We may also continue processing that is necessary to establish, exercise and defend legal claims. Processing for the purpose of direct marketing will, however, always be ceased upon your objection.

If you object to processing of your personal data, you have the right to request restriction of the processing pending our verification of whether we may continue to process it, in accordance with the below (see Restrict processing).

If, upon your objection, we no longer have a right to process your personal data, you have a right to have the personal data erased in accordance with the below (see Erasure).

Erasure

You can have your personal data erased under the following circumstances;

· If the personal data is no longer necessary in relation to the purposes for which it were collected or otherwise is processed;

· If our processing of the personal data can only be carried out based on your consent; if you withdraw such consent;

· If our processing is based on legitimate interest, you object to the processing are no overriding legitimate grounds for the processing, and if you object to the processing for direct marketing purposes;

· If your personal data has been unlawfully processed; and

· If your personal data has to be erased for compliance with a legal obligation in Union or Member State law to which we are subject.

The right to erasure does not apply when our processing of your personal data is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires the processing; or for the establishment, exercise or defense of legal claims.

Restrict processing

Under the following circumstances, you can request that we restrict the processing of your personal data to only involve the storage of your personal data;

· If you contest the accuracy of the personal data, we will restrict processing for the time required to verify its' accuracy.

· If the processing is unlawful, you may oppose the erasure of the personal data and request that its' use is instead restricted.

· If we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, you have the right for the processing to be restricted.

· If you have objected to processing, you have a right to restriction pending the verification of whether our legitimate grounds override your interests.

We may, however, still use your personal data for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Withdraw consent

To the extent that the processing of personal data is based on your consent, you always have the right to withdraw your consent. If there is no other legal ground for the processing, you have the right to have the relevant personal data erased in accordance with the above (see above Erasure).

Data portability

Unless it adversely would affect the rights and freedoms of others, you have the right to request a machine-readable copy of the personal data processed based on your consent or when the processing is necessary to fulfil an agreement with you as well as when personal data has been obtained from you (data portability), and to request that the information be transferred to another data controller (if possible).

If you wish to exercise your rights, please contact us at info@marketingmarina.com. Your request will be processed in accordance with the legislation in force at the given time. To the extent necessary, we will contact you and ask for additional information required to handle your request correctly.

Please be aware that certain conditions and/or restrictions may apply for some of the rights; it depends on the specific circumstances relating to the processing activities. Therefore, we might not be obliged or able to fulfil your request.

If you need further information about your rights, please visit the website of the Office of the Data Protection Ombudsman, www.tietosuoja.fi.

6. Filing a complaint

You have a right at any time to file a complaint with a supervisory authority. In Finland this is the Office of the Data Protection Ombudsman, www.tietosuoja.fi.

Käyntiosoite: Lintulahdenkuja 4, 00530 Helsinki

Postiosoite: PL 800, 00531 Helsinki

A complaint may be filed by email to tietosuoja@om.fi or through the website of the the Office of the Data Protection Ombudsman www.tietosuoja.fi.

However, we encourage you to reach out to us before filing a complaint with the authorities – our contact information can be found in section 2.

7. Updates to the privacy notice

MM may update this privacy notice on an ongoing basis when this is necessary to provide a fair description of our processing of personal data.

This privacy notice was last updated in April 2024.