Privacy Notice
PRIVACY NOTICE
This privacy notice describes how Lecklé processes the personal data of its clients and potential clients or their contact persons as well as the personal data of job applicants and the users of Lecklé’s website (hereinafter a “data subject”).
1. DATA CONTROLLERS AND CONTACT INFORMATION
Lecklé Oy, Lecklé Alvia Oy and Lecklé Corporate Finance Oy (hereinafter “Lecklé” or “we”)
Address: Satakunnankatu 22 E, 33210 Tampere
E-mail: info@leckle.fi
Telephone: 020 730 3890
The data controller is always the aforementioned group company the assignment or client relationship of which is in question or who is performing marketing activities or to whom a job application is directed.
2. WHICH CATEGORIES OF PERSONAL DATA DO WE PROCESS?
We process the following categories of personal data:
- Basic information
- Name and (work) contact information
- Possible organization represented and title/position in said organization
- Managing assignments
- Client number, billing information and history
- Possible other identity and other information required for managing assignments, e.g. date of birth or social security number
- Statutory customer due diligence data and information concerning the client’s financial situation and political influence in order to prevent money laundering and terrorist financing
- Marketing and events
- Direct marketing opt-ins and opt-outs
- Event registrations
- Possible information concerning food restrictions given when participating in events
- Recruitment
- CV and job application
- Possible other information collected during the recruitment process and necessary for the progress of the process
- Cookies
- IP-address and other information collected by cookies
Providing personal data is not required by law or contract, excluding the information required for handling assignments. Providing certain personal data is also required in order for us to enter into a contract with the data subject or the company/organization represented by the data subject, as well as in order to comply with our legal obligations relating to customer due diligence and anti-money laundering legislation.
3. FROM WHERE DO WE COLLECT PERSONAL DATA?
We collect personal data mainly directly from the data subject themselves or from the organization they represent.
If necessary, we also collect personal data from authorities, companies offering contact data, the public trade register, insurance companies, credit rating agencies and other similar trustworthy parties and from the websites of organizations.
4. FOR WHAT LEGAL BASES AND WHY DO WE PROCESS PERSONAL DATA?
The legal bases and purposes for the processing of personal data are the following:
- Performance of a contract to which the data subject is party
- Managing assignments and maintaining client relationships with our consumer clients (natural persons)
- Lecklé’s legitimate interest (the operation and development of our business)
- Managing assignments and maintaining client relationships with our clients (organizations)
- Marketing and organizing events
- Developing our services
- Lecklé’s legitimate interest (the transmission of a message in the communication network and ensuring information security)
- Enabling the use of our website
- Consent given by the data subject
- Responding to inquiries
- Marketing raffles
- Developing and analyzing the operation of our website and targeted advertising
- Recruitment
- Lecklé’s legal obligations
- Accounting
- Preventing money laundering and terrorist financing as well as customer and vendor due diligence
We do not use personal data for automated decision making, including profiling.
5. TO WHOM DO WE DISCLOSE PERSONAL DATA AND DO WE TRANSFER PERSONAL DATA OUTSIDE THE EU OR EEA?
We do not, as a rule, disclose your personal data to third parties. Personal data may be disclosed to authorities based on our legal obligations or an assignment.
We use external service providers, i.e. data processors, who process personal data on our behalf for the purposes described in this privacy notice. The data processors, such as our accountant or the providers of software used by us, may use the personal data only as instructed by us. The data processors do not have right to use the personal data disclosed by us for their own purposes.
We do not, as a rule, transfer personal data outside the EU or European Economic Area (“EEA”). However, some of our data processors or their sub-processors are located outside the EU or EEA. In such cases, we take care of the level of data protection by ensuring that the European Commission has adopted an adequacy decision concerning the target country in question, or by requiring the data processor to accept the Standard Contractual Clauses approved by the European Commission to be part of the data processing agreement between us and said data processor.
6. HOW DO WE USE COOKIES?
6.1. What are cookies and what do we use them for?
When you visit Lecklé’s website, cookies or cookie-like technologies may be installed on your computer or other device. They are typically small text files which can identify your device. A user cannot be personally identified through the use of cookies. Cookies do not harm the user’s devices or files.
We use cookies to enable the use of our website and to ensure its functionality. Additionally, with your consent, cookies are used to analyze website traffic and to target marketing.
6.2. What cookies do we use and how can you manage them?
The cookies we use are described in the cookie banner displayed on our website. You can always review the cookies activated via the ”Manage cookie settings” -link in the footer of our website.
You can manage the use of cookies on our website via the cookie banner displayed on the website or via the ”Manage cookie settings” -link in the footer of our website. You can change your cookie preferences or withdraw your consent via the cookie banner or via the ”Manage cookie settings” -link at any time.
Please note that we may not be able to provide certain services and you may not be able to see certain parts of the website if all cookies are not enabled.
Please note that by accepting the use of cookies relating to analytics and/or advertising, you accept the transfer of your personal data outside of the EU or EEA, which may cause risks to your privacy.
Our website contains links and embeddings to third party websites, such as social media platforms. We are not responsible for the data protection of such sites.
7. WHAT ARE THE STORAGE TIMES FOR PERSONAL DATA?
Lecklé stores personal data only as long as and to the extent that it is necessary for the aforementioned purposes:
- Managing assignments
- Information related to assignments are stored for ten (10) years from the end of an assignment
- To comply with our obligations pursuant to the Money Laundering Act, statutory customer due diligence data is stored for five (5) years after the end of a permanent customer relationship
- To comply with our obligations pursuant to the Accounting Act, personal data included in accounting materials is stored for a period of ten (10) years beginning from the end of the financial year that the accounting material concerns
- Marketing and events
- Personal data processed for marketing purposes is stored for six (6) months from the latest point of contact with us, unless the processing is based on the consent given by the data subject, in which case the personal data shall be stored until the data subject withdraws their consent
- Personal data processed for marketing raffles is deleted right after the winner/winners have been notified
- Personal data processed in order to organize events is deleted right after the event in question
- Recruitment
- Job applications and any other information collected during the recruitment process is stored until one (1) year has passed from the submission of an open application or the filling of a designated position
- Cookies
- Personal data collected via cookies is stored for as described in the cookie banner
8. WHAT RIGHTS DO YOU HAVE?
You may use your rights described in this section 8 by contacting us using the contact information stated above in the section 1. We are happy to help you exercise your rights.
We will inform you of the actions taken based on your request generally within a month. If necessary, the time period may be extended by a maximum of two further months, taking into account the complexity and number of requests.
Before taking action based on your request, we have the obligation to verify your identity. Based on the grounds set out in applicable data protection legislation, we may refuse to fulfil your request.
Using these rights is generally free of charge.
8.1. Right of Access
You have the right to receive confirmation regarding whether we process your personal data, and the right to information about the processing of your personal data. You have the right to receive a copy of your personal data being processed by us.
8.2. Right to Rectification
You have the right to request that inaccurate, incorrect or incomplete personal data concerning you is rectified or supplemented.
8.3. Right to Erasure
You have the right to request the erasure of your personal data based on the grounds set out in the GDPR. Please note that we are not in all situations able to erase your personal data, if we have a legal obligation or other lawful basis to store the data.
8.4. Right to Restriction of Processing
You have the right to restrict the processing of your personal data in certain situations, e.g. if you have contested the accuracy of your personal data and we are reviewing the accuracy of said personal data.
8.5.Right to Data Portability
If the processing of your personal data is based on your consent or the performance of a contract, you have the right to receive such personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller.
8.6.Right to Object
You have the right to object the processing of your personal data when the processing is based on our legitimate interest. In such cases, we shall no longer process the said personal data, unless we can demonstrate that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms.
You may at any time object to the processing of your personal data for direct marketing purposes.
8.7. Right to Withdraw Consent
If the processing of your personal data is based on your consent, you are entitled to withdraw your consent at any time.
8.8. Right to Lodge a Complaint with a Supervisory Authority
You have the right to lodge a complaint with your national data protection supervisory authority (in the EU region) if, in your opinion, we do not process your personal data accordingly or fulfil your data protection rights in a sufficient manner.
In Finland, you can lodge a complaint with the office of the Data Protection Ombudsman using the following link: https://tietosuoja.fi/en/notification-to-the-data-protection-ombudsman.
9. AMENDING THE PRIVACY NOTICE
This privacy notice was last updated on 14.02.2024 and it shall be updated regularly if the applicable legislation and/or Lecklé’s personal data processing activities change.
If you have any questions relating to the processing of your personal data or if you wish to exercise your rights, feel free to contact us.
