REGISTRY AND PRIVACY STATEMENT

This is a Registry and Privacy Statement in accordance with the Company Personal Data Act (Sections 10 and 24) and the EU General Data Protection Regulation (GDPR). Prepared on September 16th, 2020. The last change was made on December 1st, 2021.

1. THE REGISTRAR

Villa Griini Oy, Kaltiokuja 4, 40500 Jyväskylä

2. CONTACT PERSON RESPONSIBLE FOR THE REGISTER

Matti Paananen, [email protected], +358443559554

3. NAME OF THE REGISTER

Villa Griini Oy’s customer register

4. LEGAL BASIS AND PURPOSE OF THE PROCESSING OF PERSONAL DATA

The legal basis for the processing of personal data under the EU General Data Protection Regulation is

– the person’s voluntary consent to the marketing

– legitimate interest of the controller (eg customer relationship, membership)

The purpose of the processing of personal data is to communicate with customers, maintain a customer relationship and market it (if the person has given permission to do so.)

The data is not used for automated decision making or profiling.

The data is stored in the Zoner UP cloud, whose servers are located in Equinix’s data center in Helsinki.

5. INFORMATION CONTENT OF THE REGISTER

The information stored in the register is: person’s name, position, company / organization, contact information (phone number, e-mail address, address), website addresses, IP address of the network connection, IDs / profiles in social media services, information about subscribed services and their changes, billing information, other information related to the customer relationship and the services ordered.

6. REGULAR SOURCES OF INFORMATION

The information stored in the register is obtained from the customer e.g. Messages sent via web forms, e-mail, telephone, via social media services, contracts, customer meetings and other situations in which the customer discloses their information. Data is also collected using Google Analytics, as well as Facebook, Instagram, LinkedIn and Google tag manager.

7. REGULAR DATA TRANSMISSION AND TRANSFER OF DATA OUTSIDE THE EU OR THE EEA

The information is not regularly disclosed to other parties. The information may be published to the extent agreed with the customer.

The data may also be transferred by the controller outside the EU or the EEA.

Personal information may be disclosed to the following partners: Laukaan Peurunka Golf, Hotel and Spa Peurunka, Restaurant Hox.

8. PRINCIPLES OF PROTECTION OF THE REGISTER

The register shall be handled with due care and the data processed by the information systems shall be adequately protected. When registry data is stored on Internet servers, the physical and digital security of their hardware is adequately addressed. The controller shall ensure that the data stored, as well as the access rights to the servers and other information critical to the security of personal data, are treated confidentially and only by the employees whose job description it belongs to.

9. RIGHT OF INSPECTION AND RIGHT TO REQUEST CORRECTION OF INFORMATION

Every person in the register has the right to check the information stored in the register and to request the correction of any incorrect information or the completion of incomplete information. If a person wishes to check or request the rectification of data stored about them, the request must be sent in writing to the data controller. If necessary, the controller may ask the applicant to prove his or her identity. The controller will respond to the customer within the time limit set by the EU Data Protection Regulation (generally within one month).

10. OTHER RIGHTS RELATING TO THE PROCESSING OF PERSONAL DATA

A person in the register has the right to request the removal of his or her personal data from the register (“right to be forgotten”). Data subjects also have other rights under the EU’s general data protection regulation, such as restrictions on the processing of personal data in certain situations. Requests must be sent in writing to the controller. If necessary, the controller may ask the applicant to prove his or her identity. The controller will respond to the customer within the time limit set by the EU Data Protection Regulation (generally within one month).

0