Privacy and cookie policy

This Privacy and Cookie Policy (”Privacy Policy”) applies to www.energiasuomi.fi/ (”the Website”), which is owned and operated by Energia Myynti Suomi Oy, Teknobulevardi 3-5, 01530 Vantaa Finland, business ID 2116967-3 (”EMS”). EMS belongs to the same group as Energi Danmark A/S (“Energi Danmark”), who maintains this Website as a service for EMS.

EMS is the data controller of and is responsible for the processing of the personal data, which we process about you. Contact details of EMS can be found below.

In addition, where Energi Danmark accesses personal data processed though the Website, or where EMS transfers or discloses any personal data between Energi Danmark affiliates, such Energi Danmark affiliate is also a data controller of your personal data. Information and contact details of all Energi Danmark group companies and affiliates (and their locations) can be found here.

1. What personal data is collected?

EMS mostly collects and processes personal data that you yourself provide on the Website (e.g. by submitting your contact details via a contact form or subscribing to a newsletter), or personal information that is recorded using cookies. EMS may also process information about you that it receives from associated companies (such as its group companies) or information that is publicly available. Personal information we collect on you may include the following categories of data:

• Name, address, e-mail address and telephone number;
• Company you work for;
• Other information, such as CVR numbers, that you submit when using the Website;
• Information that you provide when contacting EMS (e.g. by filling out a contact form);
• Information about your visits to the Website, including but not limited to data traffic, location data and other communication data; and
• Information about your smartphone, tablet or computer, including IP address, operating system and browser type.

2. What are the legal basis for processing personal data?

We always ensure that we have appropriate legal basis for processing any personal data. For the most part, we rely on our legitimate interests in our processing. These legitimate interests of our include e.g. realization of your customer relationship with us, as well as business and service development and optimization. In some instances we may also process your personal data based on performance of a contract to which you are a party to or the company you are representing is a party to.

We do not in general rely on you consent as the basis for processing. However, where consent is the legal basis for our processing (e.g. direct marketing or collection of location data), your consent will be separately requested.

3. What is the collected data used for?

We process the above mentioned personal data for the following purposes:

• To ensure that the content of the Website is presented to you in the most efficient manner possible;
• To contact you with news, information, products or services that may be of interest to you, and where you have consented to being contacted for such purposes, or where legislation allows for EMS to contact you without your consent;
• To carry out surveys for the purpose of improving your interaction with the Website;
• To provide you with an overview of billing information and similar;
• To communicate with you;
• For system administration; or
• To measure traffic on the Website.

See further below section 6 for processing purposes in relation to cookies used on the Website.

4. Where and how is your personal data stored?

EMS has taken the necessary technical and organisational security measures to prevent accidental or illegal destruction, loss or degradation of data, and to prevent data from being disclosed to third parties, misused or otherwise processed in a manner that contravenes the Privacy and Cookie Policy. These measures may include, inter alia, use of firewalls, virus and malware protection, access management systems (both physical and technical), personnel and service provider training and vetting, and contractual arrangements.

All information received by EMS is stored on a secure server. Your personal data is therefore saved on servers with limited access located in controlled facilities, and which are regularly checked to determine whether our personal data is managed in a proper manner.

Only such persons from EMS, that need to access your personal data, are granted access to any personal data. EMS trains and instructs all personnel, who are granted access to any personal data, on the appropriate, lawful and secure processing of data.

We do not store or process your personal data for longer than is necessary for the purposes such data was collected. Typically we process personal data collected via our Website between 12 to 24 months. Newsletter subscription information is stored as long as your subscription is still valid. Where our processing is based on performance of a contract or your customer relationship, we process your personal data as long as we deliver services or products based on such contract or as long as you still have a customer relationship with us. In addition, we are obligated to maintain certain personal data for a number of years due to binding legal obligations (e.g. for taxation or accounting purposes). You can find more information on how long cookie data is retained below.

5. How is your personal data shared or disclosed?

Your personal data is never shared with or sold to a third party without your express consent. However, we may share, disclose or allow access to your personal data with our service providers and subcontractors, who e.g. participate in the performance of our services or maintain our Website. All such disclosures or access grants are always done on need-to-know basis, and we ensure that such third parties are bound by appropriate security obligations and may not process your personal data for any other purposes than what has been stated herein.

In addition, EMS may disclose your personal data to associated companies (such as our group companies) in accordance with legislation and this Privacy and Cookie Policy. In certain situations, your personal data may be disclosed to competent authorities due to requirements of applicable laws.
While EMS mostly processes your personal data within the European Economic Area (EEA), we do use some service providers and third parties in connection with the Website and our services (such as MailChimp and Google), who operate from countries outside the EEA and may therefore access your personal data from such countries. These non-EEA countries may include countries (such as the USA), where the level of data protection has not been deemed adequate by the European Commission. Where we transfer or allow access to your personal data from such non-EEA countries, we always ensure the security and confidentiality of personal data by taking appropriate legal security measures either by entering into the EU Commission Standard Contractual Clauses (SCCs) with the service provider, or though the EU-US Privacy Shield arrangement. The SCCs can be found here and information on the EU-US Privacy Shield can be found here.

6. Use of cookies

As stated above, our Website uses cookies and some of the cookies used also collect personal data on you. A cookie is a small text file that is stored in your browser and enables your computer to be recognized on subsequent visits.

We use cookies on our Website for the following purposes:

How long the cookies can be saved for may vary, but they are generally automatically deleted after 12-24 months. However, some cookies, e.g. opt-out/deselection cookies, may also be stored for up to ten years provided the user does not delete them. Please note that cookies are renewed after each visit.

You have the right to delete or block cookies via your browser settings. However, please note that deletion or blocking cookies may affect your ability to use certain features of our Website or services. To delete or block cookies, please follow these guidelines: https://cookiecontroller.com/

If you wish to block cookies relating to Google Analytics, you can do so here: http://tools.google.com/dlpage/gaoptout

7. Your rights

You have many rights in relation to your personal data under applicable laws, which EMS is committed to implement where requested. Under applicable laws and subject to certain restrictions, you have the following rights:

• You are entitled to find out which personal data EMS processes about you, gain access to them, and receive a copy of such personal data. In connection with this right, you also have the right to receive certain additional information concerning the processed data.
• You have the right to have incorrect information about you corrected.
• In special cases, you have the right to have information about you deleted before the date on which our ordinary general deletion enters into force. These cases include e.g. situations where our processing has been based on your consent and you withdraw such consent, or where you object to our processing and we do not have a compelling legitimate interest to process your data.
• In certain cases, you have the right to have the processing of your personal data restricted. These cases include e.g. situations, where we no longer have a legal basis for our processing but you object to us deleting your personal data and wish to only restrict its use.
• In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred from one controller to another without hindrance. This right nevertheless only concerns such situations, where our processing has been based on your consent or the performance of a contract.
• Where our processing is based on your consent, you have the right at any time to withdraw your consent. If you choose to withdraw your consent, this does not affect the lawfulness of our processing of your personal data on the basis of your previous consent up to the time of withdrawal. If you withdraw your consent, this will only take effect from the time at which consent is withdrawn.
• You are entitled to lodge a complaint to your local data protection supervisory authority (e.g. in Finland, the Finnish Data Protection Ombudsman at www.tietosuoja.fi) if you are dissatisfied with the way in which we process your personal data or realize your rights listed hereunder. Contact information of all EU member states’ data protection supervisory authorities can be found here.

If you wish to exercise any of your above mentioned rights, you may do so by contacting us using the contact information given below in section 9.

You can read more about your rights on your local data protection supervisory authority’s homepage. For example, in Finland the data protection authority is the Finnish Data Protection Ombudsman, whose homepage is at www.tietosuoja.fi.

8. Changes to the Privacy and Cookie Policy

EMS updates its Privacy and Cookie Policy on an ongoing basis. All changes are published on the Website.

9. Contact us

If you have any questions relating to our processing of your personal data, this Privacy and Cookie Policy or use of the Website, please do not hesitate to contact us via the following contact details:

Energia Myynti Suomi Oy
Address: Teknobulevardi 3-5, 01530 Vantaa, Finland
Tel: +358 20 765 9970
Email: gdpr@energiasuomi.fi