1. Controller of the Personal Data File
Prodiags Ltd (“Prodiags”)
FI-01720 Vantaa, Finland
Tel: +41 76 395 20 66
2. Controller’s Contact Person
Telephone: +358 50 555 5998
4. To what purposes Prodiags processes personal data?
The purposes of processing customers personal data are the following (one or more purposes may apply simultaneously):
Providing products and services
Prodiags may use the customer’s personal data for providing products and services for the customer, for example when the customer uses Prodiags’ digital products or services, makes purchases on Prodiags’ webshop and subscribes to Prodiags’ newsletters. The customer’s personal data is processed for carrying out the rights and obligations related to a contract or oth-er commitment between Prodiags and the customer.
Managing and developing services
Prodiags may use the customer’s personal data to manage and develop Prodiags’ business operations.
Managing and analyzing the customer relationship
Prodiags may use the customers personal data for managing, analyzing and improving the customer relationship with the customer.
Communication with the Customer
Prodiags may use the customer’s personal data to communicate with the customer, for example to sending alerts relating to Prodiags’ products and services, to inform the customer that Prodiags’ services have changed and to ask for the customer’s feedback on Prodiags’ products and services.
Prodiags may contact the customer to inform the customer of new products, services or promotions Prodiags and its co-operation partners may offer. Prodiags may use the customer’s personal data to personalize our offering and to provide the customer with more relevant content. This means for example making recommendations and to display customized content and advertising in Prodiags’ services and in third party services.
5. What information Prodiags collects?
Content of Prodiags’ personal data file may include the following types of data and changes made to these data types:
Basic information of all data subjects
• first and last name
• contact data (postal address, e-mail address, telephone and fax numbers)
• language preferences
• user name and password
• starting and ending moment and method of the customer or comparable relationship
• direct marketing choices
• campaigns and promotions directed to the customer, as well as their use
• interests and other information provided by the customer
• information of the use of Prodiags’ digital products and services
• technical data sent to Prodiags by the customer’s digital devices (such as computers and mobile devices) as well as information related to cookies and other similar tech-nologies
• recordings of customer service telephone conversations as well as e-mail correspond-ence
In addition to the above specified basic information Prodiags may process the following subcategories of the customer’s personal data.
Information of data subjects who have made purchases, given feedback and/or made complaints related to Prodiags’ products or services
• purchase history
• billing, delivery, returns and payment collection data (excluding bank account or credit card information unless needed for reimbursement purposes)
• content, correspondence and consequences related to feedback and complaints
6. Where do Prodiags gather personal data from?
Most of the information is collected from the customer at the beginning of and during the customer relationship and from the software programs when the customer is using Prodiags’ products and services.
[The customer’s personal data and its updates are also obtained from authorities and compa-nies offering personal data updating services, social media service companies, public directo-ries and other public sources of information.]
7. Is personal data regularly shared with others?
Prodiags does not sell, lease or otherwise disclose the customer’s personal data to third parties unless otherwise stated below.
Prodiags may share the customer’s personal data based on a valid order from a court or other official body with sufficient authority.
Prodiags may share the customer’s personal data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which personal data would be transferred to another entity as a result of such a proceeding.
8. Is personal data transferred to countries outside the European Union or the European Economic Area?
Prodiags’ services may be provided using resources and servers located in various countries around the world. Therefore Prodiags may transfer the customer’s personal data outside the country where the customer uses Prodiags’ services, including to countries outside the EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases Prodiags ensures that a legal basis for such a transfer exists and that adequate protection for the personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.
9. The principles of securing the data
Prodiags has established electronic and administrative safeguards designed to make the in-formation collected secure. Manually processed documents containing the personal data are protected against unauthorized access.
Only appointed personnel of Prodiags and of organizations operating by Prodiags’ assignment or on behalf of Prodiags are entitled to use the personal data file application. All persons processing the application have a personal right of use based on the data a person needs accord-ing to his/her job description. The system is protected with a fire-wall which protects it from contacts outside of Prodiags.
All personnel of Prodiags and its subcontractors are obliged to keep the information of the personal data which they obtain in their work confidential.
10. How long does Prodiags process personal data?
Prodiags may process the customer’s personal data in this personal data file for as long as the customer relationship or other comparable relationship between the customer and Prodi-ags exists, as well as for a reasonable time thereafter. Prodiags may process the customer’s personal data for tax or legal purposes as long as necessary.
After the above specified timeframe has ended, Prodiags may process part of the customer’s personal data in its direct marketing registers according to applicable legislation.
11. Customer’s right of access, correction and prohibition
The customer has a right of access to the personal data concerning the customer in Prodiags’ personal data files. The request for right of access shall be made in writing to the contact person of the personal data file. The request for the right of access must be signed.
The customer has the right to prohibit Prodiags from processing the customer’s personal data for purposes of direct advertising, distance selling, other direct marketing and market re-search and opinion polls and the right to demand correction of an erroneous data by contact-ing the controller’s contact person. Marketing within the application cannot be prohibited as an integral part of the service.
12. Choice of law and the right to lodge a complaint to the supervisory authority and the contact details of the supervisory authority
The processing of this personal data file is governed by the laws of Finland.
In case the customer suspects a breach of data protection legislation and the matter is not solved amicably between the customer and Prodiags in negotiations, the customer may con-tact the Finnish Data Protection authority at Data Protection Ombudsman’s Office.
Updated: October 2016