1. The Controller

Customer Interaction Management CIM Oy
Vitikka 2, 02630 Espoo
Tel. +358 (0) 400 433 048

  1. Contact persons

Jarkko Oksa

The DPO:

Jarkko Oksa

  1. Name of registry

Customer Interaction Management CIM Oy’s customer and marketing registry

  1. Purpose of filing system

Personal data is used for orders, credits, billing, recovery, contacts, transactions, customer enquiries, service development, reporting, marketing, and other customer relationship management measures.

Purchasing, transaction and location information in the filing system can also be used for profiling and targeting marketing activities and customer communications to make them more interesting to the registered. Personal information is also used when sending newsletters, or when people attend events and other marketing activities.

  1. Data content and information categories of the filing system

Data that can be used includes contact persons of the controller’s current or past customer organisations, persons with connections to the controller, participants of marketing events, or persons who approved the marketing.

The registry may contain data from following information categories relevant to the purpose of the use of the registry:

a) Basic information such as name and contact details (address, email address, telephone number) of the controller’s current or past customer organisations as well as their contact persons’ name and contact details

b) Information relating to the customer relationship between the controller and the registered persons, such as information on orders or appointments, possible direct marketing permits and prohibitions, and other communications between the parties, and related information

c) Data, including the first and last name, address, contact details, date of birth, position, employer, gender, mother tongue, username and password of a person registered in the controller’s service or its ancillary service, or information obtained through the application and the various functions contained therein, such as location and information the user has provided in the application

d) Transaction information from the controller’s website on different websites, information on behaviour on websites and other related category information, participation in events, information entered for events, contacts made with customer service, contacts made with employees and services, and information related to subscribing to the newsletter.

e) First and last name of the person registered for the event, as well as possible contact details and information provided on the event. Registration information provided by the person may include the following: email address, phone number, address, birth date, allergy information, passport number or personal ID.

  1. Regular sources of information

Information provided by the customer, customer data system and billing database, user and transaction information on websites, blogs and newsletters, information on customer relationship management and customer service systems, information collected from public sources, partners and companies and authorities offering personal information services.

  1. Regular disclosure of information

Filing system information can be shared within Customer Interaction Management CIM Oy and their dealers or subcontractors.

Customer Interaction Management CIM Oy can also outsource the processing of your personal data to companies outside the enterprise which may also be in countries outside the European Union and the European Economic Area, such as the United States of America. These companies can process personal data to provide, for example, infrastructure and IT services, or other services. In such cases, sufficient data security and the handling of the filing system are taken care of by an EU-U.S. – Privacy Shield arrangement, or by contract using templates approved by the EU Commission.

  1. Principles of filing system protection

The information is technically protected. Physical access to data is blocked by access control, as well as other security measures. Access to information requires adequate rights and multi-stage identification. Unauthorised access is also prevented by firewalls and technical protection. The filing system information can only be accessed by the controller and by specially designated technical persons. Only designated persons have the right to process and maintain the filing system information. Users are bound by professional secrecy. The filing system is backed up safely and can be restored as needed. The level of secrecy is audited at recurring intervals either by external or internal auditing.

  1. The right to check and amend the filing system information

A person on the filing system has the right to check what information there is on him or her on the filing system The request must be made in writing to the controller A data subject has the right to amend any incorrect information on the filing system.