We will update the Privacy Policy as necessary. We encourage you to regularly check our website for the latest version of the Statement.
Avainmedia Lähetysjärjestö ry:n customer register privacy policy
Date: 27.3.2025
1. THE CONTROLLER
Avainmedia Lähetysjärjestö ry, Jäspilänkatu 2, 04250 Kerava.
2. CONTACT PERSON FOR REGISTRY MATTERS
Contact person: Janne Maunumäki, telephone +358 20 7414 530.
3. THE NAME OF THE REGISTER
EPH618 contact register
4. PURPOSE AND BASIS OF THE PROCESSING OF PERSONAL DATA
The legal basis for the processing of personal data under the EU General Data Protection Regulation is the customer relationship between a customer of Avainmedia Lähetysjärjestö ry (Avainmedia) (including the user of the services) and Avainmedia, the person's consent, the person's order, other legal or factual connection.
Personal data may be processed for the following purposes:
• Managing, implementing, developing and monitoring customer relations, customer service and related communications and marketing.
• Analysing, grouping and reporting on customer relationships, and other purposes related to the development of the overall customer base and Key Media's operations.
• Collecting and processing customer feedback and satisfaction data.
• Conducting market research and opinion polls.
• The profiling purposes described in more detail in section 10 of this Privacy Policy.
• Processing tasks may be outsourced to external service providers in accordance with and within the limits of data protection legislation.
5. CONTENT OF THE REGISTER
Information about the data subject may include, but is not limited to, the following:
• Name, address, telephone number, language, email address and other necessary contact information.
• Data on the use of services, as well as marketing and communication through different channels, such as online services.
• Content generated by the data subject, such as customer feedback and additional information provided by the data subject, such as customer preferences, satisfaction data, interests or similar information.
• Services requested and used by the data subject.
• Prohibitions, restrictions, consents and other choices.
• Other customer-related information, such as information collected about the use of the website that can be linked to the customer, such as the user's IP address, the time of the visit, the web pages visited, the type of browser used, the network address from which the user has accessed the website and the server from which the user has accessed the website.
• Information relating to the processing of the data, such as the date of recording and the source of the data.
6. RETENTION PERIOD OF PERSONAL DATA
Avainmedia will retain personal data in the customer register only for the time necessary to fulfil the purposes of use described in this notice. In addition, some data may be kept longer to the extent necessary to fulfil legal obligations, such as accounting and consumer responsibilities, and to demonstrate that they have been properly fulfilled.
7. REGULAR SOURCES OF INFORMATION
The main sources of data are:
• The information stored in the register is obtained from the customer through, for example, messages sent via web forms, email, telephone, social media services, contracts, customer meetings and other situations where the customer discloses their information.
• A party providing an identification, verification, addressing, updating, credit reference or similar service.
• Population Information System of the Population Register Centre, and other known systems.
• Information provided by other partners of Avainmedia, such as members of the association, may also be added to the register.
8. REGULAR DISCLOSURES AND TRANSFERS OF DATA OUTSIDE THE EUROPEAN UNION OR THE EUROPEAN ECONOMIC AREA
Data will be disclosed for the purposes described in Section 4 of this Privacy Policy and to Avainmedia's direct marketing register and any other personal data registers of Avainmedia, but always in accordance with and within the limits of data protection legislation.
Customer data will not be disclosed to parties involved in the production, development or maintenance of services and communications on behalf of Avainmedia, except as provided for in a contract, separate consent and/or explicit regulations.
Customer data may be transferred outside the European Union or the European Economic Area, in accordance with and within the limits of EU data protection legislation.
9. DESCRIPTION OF THE PRINCIPLES OF REGISTER PROTECTION
Any manual data will be kept in a locked room, accessible only to authorised persons. Access to digital material is only possible with the personal user name and password of the authorised employee or partner. Access rights shall be granted at different levels and each user shall be granted access rights which are sufficient for the task to be performed, but as limited as possible.
10. PROFILING
As part of the processing of personal data stored in the customer register, Avainmedia may also use the data for profiling purposes. Profiling is carried out by creating a customer identifier for the data subject, which allows the combination of various data relating to the data subject that are generated in connection with the use of the service. The profile created as described above can then be compared, for example, with profiles created for other data subjects.
The purpose of profiling is to identify the demand for services and customer behaviour.
11. THE DATA SUBJECT'S RIGHT TO OBJECT TO THE PROCESSING OF PERSONAL DATA AND DIRECT MARKETING (RIGHT TO OBJECT)
The data subject has the right to object, on grounds relating to his or her particular situation, to personal profiling and other processing operations concerning the data subject's personal data by Avainmedia where the processing is based on a customer relationship between Avainmedia and the data subject. The data subject may submit his or her objection in accordance with point 13 of this Privacy Policy. The data subject should identify the specific situation on the basis of which he or she objects to the processing. Key Media may refuse to comply with an objection request on the grounds provided for by law.
The data subject may give consent or prohibit direct marketing to Avainmedia on a channel-by-channel basis, including profiling for direct marketing purposes.
12 OTHER RIGHTS OF THE DATA SUBJECT IN RELATION TO THE PROCESSING OF PERSONAL DATA
12.1 Right of access (right of inspection)
The data subject has the right to inspect the data concerning him or her that are stored in the customer register of Avainmedia. The request for inspection must be made in accordance with point 13 of this Privacy Policy. The right of access may be refused on the grounds provided for by law. In principle, the exercise of the right of access is free of charge.
12.2 Right of the data subject to obtain rectification, erasure or restriction of processing
To the extent that the data subject or user is able to act on his or her own initiative, he or she shall, without undue delay, upon being informed of an error or upon discovering the error, correct, delete or complete the inaccurate, unnecessary, incomplete or outdated information contained in the register.
To the extent that the data subject is unable to correct the data himself/herself, the request for correction shall be made in accordance with point 13 of this Privacy Notice.
The data subject also has the right to require the controller to restrict the processing of his or her personal data, for example, when the data subject is waiting for a response from Avainmedia to a request to rectify or erase his or her data.
12.3 The data subject's right to data portability
To the extent that the data subject has himself/herself provided data to the customer register which are processed on the basis of the data subject's consent or on the basis of a mandate, the data subject has the right to receive such data in a machine-readable format and to transfer such data to another controller.
12.4 Right of the data subject to lodge a complaint with a supervisory authority
The data subject has the right to lodge a complaint with the competent supervisory authority if the controller has failed to comply with the applicable data protection regulation.
12.5 Other rights
Where personal data is processed on the basis of the data subject's consent, the data subject has the right to withdraw his or her consent by notifying Avainmedia in accordance with section 13 of this Privacy Policy.
13. CONTACTS
In all questions related to the processing of personal data and in situations related to the exercise of personal rights, the data subject should contact Avainmedia's customer service at tel. Avainmedia Lähetysjärjestö ry / Customer Service, Jäspilänkatu 2, 04250 Kerava. If necessary, Avainmedia may ask the data subject to specify his/her request in writing and the identity of the data subject may, if necessary, be verified before taking any further action.