See also Cookie Statement
Effective date: 14 November 2019
Last Updated: 4 January 2020
Priceff Ab, Finnish Business ID 2769207-8 (hereinafter “Priceff”)
Address: Maria 01, Lapinlahdenkatu 16, 00180 Helsinki, Finland
Telephone: +358 40 7507417
Contact Person in Data File Related Matters
Mailing address above
Customer Contact Data File
Employees and other representatives of both actual and prospect customer companies and business partners (hereinafter “Customers”) of Priceff.
Legal Basis for the Processing and Purpose of Use of Customer Contact Data
Processing of personal data (hereinafter “Customer Contact Data”) is based on legitimate interests of Priceff as processing of Customer Contact Data is a necessary prerequisite for conducting Priceff business activities (incl. ability to hire employees, maintain employments, commit to investments, create value for shareholders and respond to corporate liabilities such as corporate taxes).
The purposes for the processing of the Customer Contact Data are the following:
- Marketing, sales, production and delivery of Priceff services and products (incl. direct marketing);
- Managing relationships with Customers and their contact persons;
- Priceff business development (incl. development of services and products);
- Priceff business reporting;
- Development of Priceff IT environment and applications;
- Invoicing, taxation and other financial transactions;
- Collecting and processing feedback from the Customers and their contact persons; and
- Establishing compliance with all applicable laws as well as establishing and exercising Priceff legal rights (incl. claims) and defending Priceff against any legal claims.
Priceff does not process Customer Contact Data for profiling purposes.
Customer Contact Data Content (Data Attributes and Information)
Identification and general contact data attributes such as:
- Email; and
- Telephone number;
Information related to Customers such as:
- Customer name; and
- Position and/or title within Customer
Business information, such as:
- Purchase information;
- Business correspondence (incl. emails, SMS);
- Agreements (both drafts and executed);
- Sales funnel information and its phases;
- Information of business activities (incl. calendar and meeting information);
- Reporting views (if applicable);
- Customer contact targets (if any);
Information necessary for invoicing and execution of other financial transactions related to Customers and their contact persons;
Sources of Customer Contact Data
- Customer contact persons themselves (including their digital behavior in Priceff digital services);
- Customers and other representatives of them;
- Priceff employees (incl. direct email contacts to them) and external resources supporting Priceff business processes (e.g. service providers);
- Media (both online and offline, including websites and social media channels such as LinkedIn and Twitter);
- Exhibitions and fairs;
- Customer leads obtained from third parties (incl. lead generators such as Vainu); and
- Inquiries received through Priceff website.
Disclosures and Transfers of Customer Contact Data and Transfer of Customer Contact Data to countries outside European Union or the European Economic Area
Customer Contact Data are not generally disclosed (to another controller for independent use) unless required by the mandatory law such as to authorities. As an exception, some personal data related to use of Priceff digital services can be disclosed to our business partners as described in the Cookie Description available here.
If Customer Contact Data are transferred to/from external data processors (typically subcontractors or vendors of Priceff) to be processed on behalf of Priceff, appropriate data processing agreements, as required by the applicable laws, are always executed between Priceff and data processors.
Exceptionally, Customer Contact Data may need to be transferred to purchaser or potential purchaser of Priceff business or part of it. Such sharing of personal data will involve only smallest possible amount of Customer Contact Data and always in the limits of applicable legislation.
Due to necessary technical and practical processing requirements, it may be necessary to transfer Customer Contact Data outside EU and/or EEA (incl. Switzerland). Should such international transfer occur, it would only be executed as allowed by and in accordance with applicable laws. Due to limited coverage of EU Commission adequacy decisions, EU Commission standard contractual clauses (e.g. of type controller to processor, EU Commission decision 2010/87/EU) would typically be used as appropriate safeguards for these international personal data transfers. In some cases, also US/EU Privacy Shield arrangement would be relied on. Copies of the standard contractual clauses would be available through the contact details mentioned above.
Security Principles of the Data File
Customer Contact Data are protected by technical and organisational measures against accidental and/or unlawful access, alteration, and destruction or other processing including unauthorized disclosure and transfer of Customer Contact Data.
Such measures include (but are not limited to) proper firewall arrangements, virus and malware detection, encryption of telecommunication and messages as well as use of secure and monitored equipment and server rooms. Data security is a special focus area when third parties (e.g. data processing subcontractors) providing and implementing IT systems and services are retained.
Data security requirements are observed in IT system access management and monitoring of access to IT systems. Priceff personnel involved in processing of Customer Contact Data as part of their tasks is trained and instructed in data protection and data security matters.
Right to Object Processing of Customer Contact Data
In accordance with the law the data subject has at any time the right to object the processing of Customer Contact Data:
- On the grounds of the lawfulness of Priceff data processing being based on Priceff legitimate interests; and
- For direct marketing purposes (unsubscribe from Priceff direct marketing, if any).
In order to use these rights, the data subject has to contact the above-mentioned contact point in writing (incl. email). However, the request of a data subject may be declined or limited where allowed or required under the law.
Other Rights of Data Subject
In accordance with the law the data subject has at any time the right to:
- Access the Customer Contact Data and based on request, receive a copy of it and related other supplementary information concerning Customer Contact Data processing as specified in the law;
- Request, purposes of Customer Contact Data processing allowing:
- Inaccurate Customer Contact Data to be corrected;
- Incomplete Customer Contact Data to be amended; and
- Obsolete or outdated Customer Contact Data to be deleted;
- Be forgotten by Priceff, if:
- Customer Contact Data are no longer necessary in relation to the Priceff data processing purposes;
- The Customer Contact Data have been unlawfully processed by Priceff;
- The processing has been based solely on legitimate interests of Priceff which the data subject has objected and no overriding legitimate grounds for the processing have been established; or
- The data subject has objected processing for direct marketing (concerns only such Customer Contact Data that is solely used for direct marketing and for no other purpose).
- Restrict the processing of the Customer Contact Data if:
- The data subject contests the accuracy of the Customer Contact Data;
- The processing is unlawful, and the data subject opposes the deletion of such Customer Contact Data;
- The data subject has objected to processing of Customer Contact Data on the sole lawful basis of Priceff legitimate interests and pending the investigation whether the legitimate interests of Priceff override those of the data subject; or
- Priceff no longer needs the Customer Contact Data for its purposes of uses, but Customer Contact Data are required by the data subject for the establishment, exercise or defense of legal claims;
- Lodge a complaint with a supervisory authority (in Finland: Data Protection Ombudsman);
In order to use these rights, the data subject shall contact the above-mentioned contact point in writing (incl. e-mail). However, the request may be declined or restricted where allowed or required under the law.
Retention period of Customer Contact Data
Generally, Priceff retains the Customer Contact Data for ten years from the last business activity completed between Priceff and customer contact person.
This general retention rule is based on i.a. laws regulating expiration of debts, possible long warranty periods related to Priceff services and products as well as traditionally long-lasting business relationships between Priceff and Customer Companies. Also, possible needs related to litigation purposes justify such retention of the Customer Contact Data.
Notwithstanding the above, the retention of Customer Contact Data may always be extended due to existing or imminent need of Priceff to establish or exercise legal claims or defend itself against legal claims related to Customer Contact Data.
Provision of Customer Contact Data
Provision of Customer Contact Data is voluntary but necessary to commit to and continue any business activity between Priceff and customer contact person and/or Customer.
Failing to provide Customer Contact Data prevents or may prevent Priceff from committing to an/or continuing the mentioned business activity.