www.arcticapartments.fi/tietosuojaseloste

Customer Database Privacy Statement

Arctic Apartments & Villas
Cloudberry Dreams Oy (2656717-9)
Raaniontie 3
96800 Rovaniemi
Finland
+358 40 410 9246

2 Contact Person in Matters Relating to the Personal Data File

Maria Laajanen +358 40 410 9246,

3 Data Protection Officer

The data protection officer at Arctic Apartments & Villas is Maria Laajanen +358 40 410 9246,

4 Name of the Personal Data File

Customer database privacy statement

5 Purpose of Personal Data Processing

Personal data are collected for specified, explicit and legitimate purposes. The data are collected telemetrically and with the consent of the customers and stakeholders. Consent has been obtained from the customers and stakeholders with a separate form stating their truthful and genuine consent. The data are gathered for the purposes of customer relations.

The customers have been notified of profiling and it has been made clear that they have the right to withdraw their consent, in which case profiling will cease without delay. The personal data are gathered in accordance with this privacy statement, and they will not be used, altered or transferred in ways not mentioned in this privacy statement. The personal data are collected only with means agreed to in advance, which have been communicated to customers and stakeholder prior to collecting the data and their proven consent for the collection and processing of the data has been obtained.

6 Content of the Data File

The data file contains personal data on the customers of Arctic Apartments & Villas: first name, last name, email address, telephone number, language, personal id-code, indicator data related to profiling and the use of commodities, and data provided by customers and stakeholders directly to Arctic Apartments & Villas.

7 Regular Sources of Personal Data

The personal data is collected from the customer and obtained from partners.

8 Regular Destinations of Disclosed Data

Arctic Apartments & Villas has decided not to transfer data in our possession to third parties or automatically to other Arctic Apartments & Villas partners. Data can be transferred to marketing register of Arctic Apartments & Villas. In individual cases, Arctic Apartments & Villas discloses data of a customer or stakeholder to the designated party if the data subject so requests or if a competent authority requires Arctic Apartments & Villas on legal grounds to disclose specified data in the database in our possession.

9 Data Transfer to Third Countries or International Organizations

Arctic Apartments & Villas has decided not to transfer data in our possession automatically to third countries or international organizations. In individual cases, Arctic Apartments & Villas discloses data to third countries or international organizations if the customer or stakeholder has mandated us for such a purpose and if we have together with the data protection officer and the Finnish data protection authority assessed the risks and the quality system of the actual data security level of the third country.

10 Principles of Securing the Data File

Arctic Apartments & Villas secures the personal data file referred to in this privacy statement based on the required security level derived from risk assessment. The data protection officer participates in the risk assessment process and provides an objective statement of the final decision regarding data protection, which Arctic Aparments & Villas will adhere to. In securing the personal data file, Arctic Apartments & Villas observes technical security as well as the requirements of both administrative and information technology requirements.

11 Right of Access

Data subjects have the right to inspect what data on them have been stored in the file. In addition, after a sufficiently detailed and accurate request, data subjects have the right of access to the data on them stored in the data files. The request for access must be delivered in written form and with the subject’s signature and attached with a copy of personal id-card to the Data Protection Officer.

12 Right to Rectification and Erasure

The controller must rectify inaccurate data in the personal data file indicated by the data subject. The controller is also obligated to independently verify that the data in the data file are accurate and up to date. Data subjects may also request that the controller erases data on them from the file. This procedure is managed by the data protection officer.

13 Other Rights Pertaining to Personal Data Processing

Data subjects have the right to request a restriction of processing data on them. Data subjects also have the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller. In addition, data subjects have the right to object to processing of personal data, automated decision-making, and profiling.

14 Erasure of Data and Time of Storage

Arctic Apartments & Villas removes data on a customer from the data file, when there no longer are operational grounds for their processing or if data subjects exercise their legal right to request from Arctic Apartments & Villas the erasure of data on them. The data are erased by overwriting when their processing or keeping is no longer justified. The data are not erased, however, if specific provisions have been issued by laws or regulations or if a competent authority has initiated a process that requires Arctic Apartments & Villas to keep the data or if a Finnish court of law has been requested to decide on safeguarding the data.