PRIVACY POLICY

Regulation (EU) 2016/679

1. DATA CONTROLLER

Best Friend Group Oy (1073893-0), (“Best Friend” or “we”)
PL 1769 (Kellonkierto 3)
70461 Kuopio
Finland

2. CONTACT PERSON IN MATTERS CONCERNING THE PRIVACY POLICY

Janne Iivanainen
Best Friend Group Oy
Puhelin: + 358 (0) 40 757 6237
Sähköposti: [email protected]

3. NAME OF THE REGISTER

Hurtta.com Customer register

4. PURPOSE AND LEGAL GROUND FOR THE PROSESSING OF PERSONAL DATA

Personal Data is handled for managing, analyzing and developing relationships with customers and other relevant relationships, business planning, marketing and customer communications, which can also be carried out electronically.

5. DATA CONTENT OF THE REGISTER

The following data is stored in the register:

Name, email address, street address, country, place, postal code, sex, date of birth, information on direct marketing permission, marketing prohibition and other consent.

6. REGULAR INFORMATION SOURCES

Personal data relating to a registered person will be collected from the data subject him-/herself in connection with a trade, use of various services and registration, such as e-commerce, other electronic services and various marketing activities such as events.

Third party tools such as Google Analytics can also be used to collect personal data. These may include, for example, the visitor's IP address, visit times for pages, and information on the device and operating system used by the site visitor

7. HOW LONG IS THE PERSONAL DATA STORED?

Personal data will be kept for as long as it is necessary for the purpose of processing personal data or to comply with the statutory obligations of the controller. Personal data for passive customers is deleted regularly.

8. DISCLOSURE OF PERSONAL DATA

Best Friend will not disclose your personal data to third parties without the consent of the customer or statutory grounds.

We may use subcontractors (“data processor”) to develop and maintain services, so that information on the customer database can be disclosed to subcontractors to the extent necessary to implement the services.

The data processor processes your personal data on behalf of and in the extent approved by Best Friend and in accordance with documented instructions provided by Best Friend.

Best Friend shall use only data processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of applicable data protection legislation and ensure the protection of your rights.

Best Friend will ensure through contractual measures that your personal data is handled appropriately and in compliance with this Privacy Policy and appropriate data protection legislation.

The personal data contained in the register may be processed in other services belonging to the Best Friend as well as units besides Hurtta. Personal data in the register will never be given / sold to third parties unless it is a transaction with a partner or, for example, a marketing campaign.

9. TRANSFER OF DATA OUTSIDE OF EUROPIAN UNION OR THE EUROPEAN ECONOMIC AREA

We typically store our data in the EU or the EEA. If any data is transferred outside the EU or EEA, we will ensure that the country to which the data is transferred is approved as having a sufficient level of privacy protection by the European Commission, or by using standard contractual model clauses approved by the European Commission.

10.  FILE PROTECTION POLICY

We use technical and organizational measures to protect personal data against unauthorized access, transfer, deletion or other handling that may compromise information security. Such methods include the use of firewalls, encryption technologies and safe server rooms, proper access control systems, the controlled provision of user rights and supervision of their use, providing instructions for data processors, and the thorough selection of competent subcontractors who comply with industry standards for information security management.

11.  YOUR RIGHTS AS A REGISTERED PERSON

According to applicable data protection legislation you have the right, at any time to:

• obtain information on the processing of your personal data;

• have access to your personal information and verify the personal data we are processing about you;

• require correction and supplementation of inaccurate and incorrect personal data;

• require the removal of your personal data;

• withdraw your consent and object to the processing of your personal data if the processing of your personal data is based on your consent;

• object to the processing of your personal data on the basis of your personal circumstances, if your personal data is processed based on our legitimate advantage;

• obtain your personal data in a formatted form and transfer this information to another registrar, provided that you have personally provided such personal information to us;

• require your personal data to be restricted;

• object to the processing of your personal data for direct marketing purposes;

• file a complaint with the appropriate supervisory authority if you consider that we have not processed your personal data in accordance with applicable data protection legislation.

We may ask you to clarify your request and verify your identity before processing your request. We may refuse to execute your claim on the basis of the applicable law.

12.  CHANGES TO THIS PRIVACY POLICY

We are continuously developing our services and therefore reserve the right to change this Privacy Policy. Changes may also be based on changes in legislation. We recommend that you read this Privacy Policy on regular basis to keep track of changes.

13.  CONTACT

We kindly ask you to send any requests regarding your rights in writing or by email to the following address:

Best Friend Group Oy

PL 1769

70461 Kuopio, Finland

Or:

E-mail. [email protected]