General Principles for Processing Data
The purpose of this policy is to describe the principles and practices that we follow at Suomen Vaihdepalvelut Oy and the companies belonging to the same group (hereinafter “Suomen Vaihdepalvelut”) in order to guarantee the protection of our customers’ privacy, confidential communications and other legitimate interests. Suomen Vaihdepalvelut Oy updates this policy according to the development of its operations and services. By using Suomen Vaihdepalvelut’s services you agree to this Privacy Policy of Suomen Vaihdepalvelut, and give the consent for the collection, recording and using of your personal data as defined below and in the description of personal data files.
Suomen Vaihdepalvelut Oy is a Finnish company working in the field of switch board services.
Vaihdepalvelut’s business is based on on outsourced switch board services and comprehensive contact details data and the ease of finding. In order to make it easier for users to find what they are looking for, Suomen Vaihdepalvelut Oy offers a wide range of services for various situations. This is why the rules on personal data protection are important not only to individuals, but also to Suomen Vaihdepalvelut Oy and its business.
Suomen Vaihdepalvelut Oy processes personal data and other customer data in accordance with Finnish laws and decrees, along with authority regulations and instructions based on them. The basic principle of data protection regulations is that a data subject needs to be aware of the processing of his/her personal data, and that he/she has the right to have any errors in the data corrected and to give consent and revoke consents to particular types of processing of the personal data. In some cases the personal data needs to be completely deleted.
The processing of personal data and other customer information at Suomen Vaihdepalvelut Oy is often based on a customer relationship, some other relevant connection or the given consent of the data subject. We may process data on other grounds as well, such as by an engagement made by you or reason of provisions laid down by law. Your personal data may be processed within the Suomen Vaihdepalvelut Oy companies belonging to the same group. Personal data can also be collected from selected external sources, such as Trafi (Finnish Transport Safety Agency), subscriber database of Suomen Numeropalvelu Oy (phone number enquiries service) and the Trade Register.
Personal data and other customer data are collected when concluding agreements, registering to use the service and when using the services or, directly from the data subject. When a user visits Suomen Vaihdepalvelut Oy websites, Suomen Vaihdepalvelut Oy obtain different anonymous data or data related to the use of the web browser, such IP address belonging to the operator or organization and browsing history.
Monitoring is based on the use of cookies or similar technologies. This data may be associated with a user only upon his or her consent. We collect personal or contact information on potential customers when someone participates in a competition or customer event or contacts Suomen Vaihdepalvelut. The data is stored in our permanent direct marketing register and processed in accordance with the description of personal data file.
Calls made by Suomen Vaihdepalvelut’s phone-based sales staff are recorded to ensure agreements made, quality of the service and skills development, as well as for handling invoicing-related irregularities. These recordings are handled only by specifically authorized persons, who are subject to the obligation to retain confidentiality.
Services and Subscriber Database
Suomen Vaihdepalvelut’s subscriber database contains personal data. Usually these are comprised of the user’s name, address and phone number. Sometimes this information is associated also with title and name of the subscriber, i.e. the person who concluded the subscription agreement and paid the invoices, and the name of the operator.
A user and a subscriber that is a natural person has the right to prohibit free or charge and in whole or in part, the disclosure and publication of their details in a telephone directory or directory inquiry service. A user may prohibit also forwarding of such data. If published information is incorrect, Suomen Vaihdepalvelut Oy takes appropriate measures to rectify the incorrect information. If a person wants to have his/her details changed or deleted only from a particular Suomen Vaihdepalvelut Oy service, such a request must be made to Suomen Vaihdepalvelut’s Customer Service.
If a customer has added the customer’s other details to Suomen Vaihdepalvelut Oy Internet services, then the customer must ensure that the details added are correct and up to date. Suomen Vaihdepalvelut Oy may send reminder messages concerning updating of the details. Suomen Vaihdepalvelut Oy reserves the right to delete details it deems to be obsolete and inappropriate.
Suomen Vaihdepalvelut Oy as a service provider of directory inquiry services, as well as telecom companies, have the obligation to disclose data to be published in a directory to another company providing directory inquiry service or telephone directory service.
Customer Communication and Direct Marketing
Customer communication here means the communication that is required in maintaining customer relationships. Suomen Vaihdepalvelut Oy may inform of the situation regarding Suomen Vaihdepalvelut’s services, their continuity or changes without prior consent being required.
According to Finnish Tietoyhteiskuntakaari 917/2014 (Information Society Code), direct marketing implemented via automated calling systems, and e-mails, SMS, voice mails, voice messages and image messages may be targeted only at natural persons, who have given their prior consent to this. Other direct marketing (e.g.telemarketing) targeting at a natural persons is allowed, unless this it is specifically prohibited by that person. A natural person must be able to prohibit, free of charge, direct marketing.
Direct marketing targeted at a corporation may be engaged in, unless the corporation has specifically prohibited it.
Corporations must be given the opportunity to easily and free of charge prohibit the use of their contact details in connection with each message sent with the purpose of direct marketing.
The prohibiting of direct marketing shall be addressed primarily at the enterprise practising direct marketing even if Suomen Vaihdepalvelut Oy is mentioned as being the source of the address details.
If Suomen Vaihdepalvelut Oy receives from a customer, who is a natural person, contact details associated with an e-mail, an SMS, a voice mail, a voice message or an image message in connection with the product or service sold, it may use such contact details in the direct marketing of its own products belonging to the same category or in the direct marketing of other similar products or services without prior consent.
Direct marketing and customer communications conducted by Suomen Vaihdepalvelut Oy itself may be prohibited by notifying Suomen Vaihdepalvelut’s Customer Service, tel. +358 20 155 8862, of the matter.
Cookies
Suomen Vaihdepalvelut’s websites and mobile applications use cookies, including third party cookies, and other similar technologies for producing and developing of services, network analysis and marketing targeting. Targeted marketing are used both on websites or services of Suomen Vaihdepalvelut Oy or third parties. Cookies may be disabled in the browser settings. In some cases this may slow down website browsing or prevent access to certain pages altogether. You accept cookies by closing the box informing about the use of cookies or continuing to use the website without changing cookie settings of the browser. Disabling cookies does not prevent advertisements from showing. After disabling cookies advertisements are not targeted based on collected data on earlier behavior and user’s interests.
A cookie is a small text file sent and saved to the user’s web browser cache by the website, an application or an advertisement clicked on. A cookie contains a randomly generated anonymous identifier that allows Suomen Vaihdepalvelut Oy identify different web browsers or terminal devices that are used while visiting Suomen Vaihdepalvelut’s websites and services. Only the server that sent the cookie may later read and use the cookie.
Third parties may place their own cookies to the user’s terminal device with the approval of Suomen Vaihdepalvelut Oy when visiting Suomen Vaihdepalvelut’s websites in order to offer targeted advertising or to create statistics on users of the website. As the advertisement data placed by a third party are downloaded by the user’s web browser from servers outside of Suomen Vaihdepalvelut, these third parties may view, modify and place their own cookies as if the user were on a third party website.
Cookies are used, for instance, for targeting advertising. Suomen Vaihdepalvelut Oy may use the data collected by cookies or similar technologies about the use of its websites in order targeting website advertisements or producing content for a certain web browser by creating different segments for user groups. Advertisements or content that are likely to be of interest to the different user group segments are showed to them on the websites and online services of Suomen Vaihdepalvelut Oy or its partners.
User cannot be identified merely through cookies. Under the description of personal data file, Suomen Vaihdepalvelut Oy may target online marketing as well as other marketing at its customers based on data obtained from its customer registers, Väestötietojärjestelmä (Population Information System), Trafi (Finnish Transport Safety Agency) and other registers by using anonymous identifiers in the cookies upon informed consent of the user.
The Use of Traffic and Location Data
Suomen Vaihdepalvelut Oy processes traffic and location data in accordance with Finnish Tietoyhteiskuntakaari (Information Society Code) for producing services, and also for purposes of invoicing, technical development and, upon the consent of the customer, marketing. Traffic data is processed only by designated Suomen Vaihdepalvelut Oy employees or persons working for Suomen Vaihdepalvelut, whose lawful duties make it necessary to process traffic data.
Processing of data is restricted to the extent necessary for purpose of actions and it does not limit the confidentiality of messages or the protection of privacy. Suomen Vaihdepalvelut Oy stores traffic and location data within the constraints of the existing legislation. Traffic data needed for invoicing is stored at least three months from the due date of the invoice, and for a maximum of three years from the due date of the invoice, unless it has to be stored for a longer time for collection-related reasons.
As regards position-determining services, cell-identification-based position data (accuracy between 100 m – 15 km) are obtained from telecom companies, and these are usually processed in a one-off manner and retained no longer than is necessary for producing Suomen Vaihdepalvelut’s positioning services. Position data are not disclosed to third parties. The technical interface for telecom operators’ position data may be offered to external service providers. These third party service providers bear the responsibility for the legality of their own services and for the administration of consents pertaining to positioning.
Information Security
Suomen Vaihdepalvelut Oy ensures the information security of its services by applying practices that in a manner proportional to the seriousness of the threats as well as to the technical level and costs. Data protection and information security are under responsibility of certain designated persons. Suomen Vaihdepalvelut’s internal guidance regarding information security and data protection are implemented by the means of proactive risk management, by taking information security and data protection into account when designating products and services and by training of personnel.
However, we kindly ask you to bear in mind that no company is able to guarantee perfect security for the services. Everyone must also personally take the necessary and appropriate information security precautions, for example by making sure that they use up-to-date virus and firewall services and operating system updates.
Right to Inspection, Prohibit and Correction
Data subjects are entitled to prohibit the use of the data for direct advertising, telemarketing and other forms of direct marketing, as well as to prohibit the use of the data for use in questionnaires and market research. In addition, data subjects are entitled to request rectification of incorrect data by notifying Suomen Vaihdepalvelut Oy’s Customer Service: phone number +358 20 703 2500 or by e-mail addressed to asiakaspalvelu@suomenvaihdepalvelut.fi.
In accordance with Section 26 Finnish Henkilötietolaki (Personal Data Act), the individual data subject has the right to check what information there is about him in a personal data file. The request must be submitted in writing and signed, and addressed to:
- Suomen Vaihdepalvelut Oy
- Isokatu 16 B 12
- FI-90100, Oulu, Finland
Contact information
