Privacy Policy and Register Description

RNTM Trading Oy's CUSTOMER REGISTER PRIVACY POLICY

1 Controller

The controller of the register is RNTM Trading Oy (business ID 2822174-5)

RNTM Trading Oy
Address: Sepäntie 20 D
Phone: 010 508 1200
Email: info@gn-store.com

2 Name of the register

The name of the register is RNTM Trading Oy's customer register.

3 Purpose of personal data processing

Personal data is processed for purposes related to the management, administration, and development of customer relationships, the provision and delivery of services, and the development and invoicing of services. Personal data is also processed for purposes required for investigating possible complaints and other claims.

In addition, personal data is processed in communications directed at customers, such as for informational and news purposes, and in marketing, as part of which personal data is also processed for purposes related to direct marketing and electronic direct marketing.

The customer has the right to prohibit direct marketing aimed at them.

The controller processes the data themselves and utilizes subcontractors acting on behalf of and for the controller in the processing of personal data.

4 Legal bases for processing

The legal bases for processing personal data are the following grounds in accordance with the EU General Data Protection Regulation (hereinafter also "GDPR"):

1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes (GDPR Art. 6(1)(a));
2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (GDPR Art. 6(1)(b));
3. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (GDPR Art. 6(1)(f)).

The aforementioned legitimate interest of the controller is based on a relevant and appropriate relationship between the data subject and the controller, arising from the data subject being a customer of the controller, and when the processing is carried out for purposes that the data subject could reasonably expect at the time of data collection and in the context of the appropriate relationship.

5 Data content of the register (personal data groups processed)

The register primarily contains the following personal data for all registered individuals:

1. basic information and contact details of the person: first name, last name, address, phone number, email address;
2. information related to the person's company or other organization and the person's position or job title in said company or organization;
3. the person's direct marketing permits and prohibitions.

6 Regular sources of data

Personal data is collected from the data subject themselves.

Personal data is also collected and updated, within the limits of applicable law, from generally available sources related to the implementation of the customer relationship between the controller and the data subject, and with which the controller fulfills its obligations related to maintaining customer relationships.

7 Personal data retention period

Data collected in the register will only be stored for as long as and to the extent necessary for the original or compatible purposes for which the personal data was collected.

The controller regularly assesses the necessity of data retention in accordance with its internal codes of conduct. In addition, the controller takes all possible reasonable steps to ensure that inaccurate, incorrect or outdated personal data for the purposes of processing are deleted or rectified without delay.

8 Recipients of personal data (categories of recipients) and regular disclosures of data

Personal data will not be disclosed to external parties.

9 Transfer of data outside the EU or EEA

Personal data contained in the register will not be transferred outside the EU or EEA.

10 Principles of register protection

Materials containing personal data are stored in locked facilities, to which only designated persons authorized to access them due to their duties have access.

The database containing personal data is on a server stored in a locked facility, to which only designated persons authorized to access it due to their duties have access. The server is protected by an appropriate firewall and technical protection.

Access to databases and systems is only granted with separately issued personal user IDs and passwords. The controller has restricted access rights and authorizations to IT systems and other storage platforms so that only persons necessary for the lawful processing of data can view and process the data. In addition, user events of databases and systems are recorded in the IT system's log data.

The controller's employees and other persons are committed to confidentiality and to keeping secret the information they receive in connection with the processing of personal data.

11 Rights of the data subject

The data subject has the following rights under the EU General Data Protection Regulation:

1. the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data concerned; (iii) the recipients or categories of recipient to whom the personal data have been or will be disclosed; (iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (v) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (vi) the right to lodge a complaint with a supervisory authority; (vii) where the personal data are not collected from the data subject, any available information as to their source (GDPR Art. 15). This described basic information (i)–(vii) is provided to the data subject on this form;
2. the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (GDPR Art. 7);
3. the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her and the right to have incomplete personal data completed, including by means of providing a supplementary statement, taking into account the purposes of the processing (GDPR Art. 16);
4. the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, provided that (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) the data subject withdraws consent on which the processing is based, and where there is no other legal ground for the processing; (iii) the data subject objects to the processing on grounds relating to his or her particular situation and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purposes; (iv) the personal data have been unlawfully processed; or (v) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject (GDPR Art. 17);
5. the right to obtain from the controller restriction of processing where (i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; (ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use; (iii) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or (iv) the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject (GDPR Art. 18);
6. the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent as defined in the regulation and the processing is carried out by automated means (GDPR Art. 20);
7. the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the EU General Data Protection Regulation (GDPR Art. 77).

Requests regarding the exercise of data subject rights should be addressed to the contact person of the controller mentioned in section 1.