SUNBORN GROUP | DATA PROTECTION
Last updated 25 May, 2018
This concerns websites that are operated by Sunborn Group (“Sunborn Group”, “we” or “us”), including Sunborn Saga Oy, Sunborn Oy, Saga Trade Finland Oy, Sunborn Catering Oy and Ski Unlimited Oy.
This Privacy Statement concerns our websites and the processing of personal data related to its use and personal data provided by the user.
Sunborn Group is obligated to follow the provisions of the EU General Data Protection Regulation and the Finnish Information Society Code. Sunborn Group is also dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of these fundamental obligations, Sunborn Group is committed to the appropriate protection and use of personal data. Please review this Privacy Statement to learn more about what information we may collect about you through our websites and how we use that information. Sunborn Group may also collect personal data in the course of providing our services (see below for further details).
Who is collecting your personal data?
Sunborn Group (Sunborn Saga Oy/Sunborn Oy/Saga Trade Finland Oy/Sunborn Catering Oy/Ski Unlimited Oy)
Address: Juhana Herttuan puistokatu 23, 20100 Turku
How we collect personal data
Generally we collect your personal data from you directly (for example, when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a questionnaire, form or survey, when you subscribe to our publications or when you use our websites or our social media sites). We may also collect personal data about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites.
If you do not provide us with the personal data we have requested, we may not be able to complete or fulfil the service requested. Such collection of personal data is based on your given consent to or on other legal basis for the processing of personal data under the applicable data protection legislation.
Sometimes it may be necessary for us to collect your personal data from a third party. For example, we may collect your personal data from your employer where they are our client, from your personal representative, another Sunborn Group member firm or a publicly available record. Such processing might beis necessary for example for the purposes of the legitimate interests pursued by us or a third party, such as your employer.
At times processing of your personal data may be necessary for compliance with a legal obligation to which we are subject.
The type of personal data we collect
You do not need to register your personal data in order to use our websites. In general we collect only such personal data as is provided voluntarily by visitors to our websites and is necessary in the circumstances. For example, you may provide information such as your name, title, work address and email address in order to register for certain services or to send or receive email to/from us through the site.
Some data is necessary for us to enable you to move around our websites and use its features (this includes performance and functionality cookies, which are necessary to provide services requested by you).
The types of personal data we collect include:
- names, job titles, contact and address details
- date of birth and gender
- online identifiers (IP addresses, cookies etc.)
- educational qualifications, employment details and referee reports
- interests and behaviours on our websites
If you wish to receive Sunborn Group marketing materials, we may request various contact details depending on the type of marketing materials you would like to receive. This may include name, email address, physical address, and telephone number.
If you are interested in Sunborn Group services, we will request contact details including your name, company, and email address in order that Sunborn Group can discuss your requirements with you.
Where you are invited to attend Sunborn Group-related events, we will record your response to the invitation.
If you choose to register or login to a Sunborn Group website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with Sunborn Group , we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. We don’t request sensitive personal data through our website, however, we will request voluntary information about your dietary requirements in order to cater for your needs when attending our events. By giving us this information you give your consent for Sunborn Group to process that information.
Purposes of collected personal data
We will use your personal data only for the purposes stated in this Privacy Statement, unless we obtain your specific consent to other uses.
Sunborn Group collects, holds and uses personal data for a number of purposes including:
- to provide our services
- to respond to your requests or queries
- to maintain contact with our clients and other contacts (including alumni), and keep them informed of our services and events
- to allow you to register for certain areas of our websites to verify your identity
- for recruitment purposes
- when engaging service providers, other Sunborn Group member firms, contractors or suppliers relating to the operation of our business
- to conduct surveys
- for seeking your feedback for the performance, functionality, and security of our websites
- to meet any regulatory obligations to perform internal statistical analysis, including of our databases and websites
- to profile website users based on consent to target customers with personalised marketing messages based on their usage of our websites for any other business related purposes
Sunborn Group uses a marketing automation tool that interacts with our CRM (Customer Relationship Management) database. Data used for marketing automation purposes is enriched by data on the user-specific usage of our websites (profiling). This data will only be collected based on the user’s consent. Sunborn Group uses CRM to develop our relationship with current and prospective clients and our marketing automation is used to assist with Sunborn Groups marketing campaigns – for example, when sending marketing materials or organising events.
Sunborn Group tracks recipients’ engagement with our marketing emails. By this, we mean that we monitor if emails were successfully delivered, opened, or forwarded and by which users. We do this for reporting purposes – to check if our marketing campaigns are working and providing recipients with the information they want.
You have the right object at any time to processing of your personal data for profiling and direct marketing purposes. Once you have given your consent, you can withdraw that consent by contacting us via this form.
Automatic collection of personal information
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Cookies may be placed on your computer or internet-enabled device whenever you visit us online, if you give us your consent on the usage of cookies and the processing of your personal data. Cookies allow the site to remember your computer or device and serves a number of purposes.
On our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.
Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.
Below is a list of the types of cookies used on our web sites:
Performance (i.e., User’s Browser)
Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).
If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas.
Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account.
We use several third party analytics tools to help us understand how site visitors use our web sites. This allows us to improve the quality and content on our websites for our visitors and may also be used to provide targeted communication, marketing and content creation. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites.
Site visitor feedback
We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.
We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service.
Sunborn Group uses analytics tools, such as Google Analytics. More information about how Google Analytics is used by Sunborn Group can be found here: http://www.google.com/analytics/learn/privacy.html
When you visit our websites, marketing automation cookies are placed in your browser. They help identify you as a website visitor according to your specific browser and computer combination, and you are remembered in the event that you return to our website. If the user identifies himself by volunteering personal data, e.g. by filling in a contact form or clicking on links in an e-mail the cookie’s unique user ID is linked to the personal data volunteered by the user. We may use the information provided by you during your online visits in order to tailor the content or make suggestions of similar items you may be interested in.
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Sunborn Group only uses web beacons in accordance with applicable laws.
Sunborn Group or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
Location based tools
Sunborn Group may collect and use the geographical area of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
Social media widgets and applications
Sunborn Group web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of Sunborn Group web sites (see details on ‘Social Sharing’ cookies above). Any personal data that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, Sunborn Group web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal data that you provide on any Sunborn Group social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
Sharing and transfer of personal data
We may share personal data that you submit to us via our websites to other member firms in the Sunborn Group network of firms or to suppliers or subcontractors working on our behalf (store, process or back-up your personal data) in accordance with our data protection obligations (including transfers across geographical borders).
We do not disclose your personal data to third parties (excluding those identified above) except as required and permitted by applicable law.
We do not sell your personal data or provide it to third parties for their direct marketing use.
Data security and storage
Sunborn Group has appropriate technical and organisational security policies and procedures in place to protect personal data and information from loss, misuse, alteration, or destruction. Sunborn Group holds personal data in hard copy and electronic formats.
We take security measures to protect the personal data we hold including physical (for example, security passes to enter our offices and storage of files in lockable cabinets) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes. In some cases, Sunborn Group engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.
Additionally, we aim to ensure that access to your personal data is limited to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We use all reasonable efforts to retain personal data collected from you only for so long as we need such data in accordance with the purpose for which it was collected or until we are requested to delete it (if earlier). We apply reasonable efforts to assure that inaccurate, incorrect and outdated personal data is deleted or corrected without undue delay.
Regarding the processing of your personal data, you have the following rights:
- withdraw your consent at any time, where your personal data is being processed based on your consent obtain confirmation whether or not personal data concerning you is being processed obtain a copy concerning your personal data
- obtain without undue delay the rectification of inaccurate personal data concerning you have incomplete personal data completed
- obtain the erasure of personal data concerning you without undue delay
- object at any time to processing of your personal data for profiling or direct marketing purposes
- the right to file a complaint with a supervisory authority regarding the processing of your personal data
If you wish to exercise your rights, please contact us by using this form
If you wish to unsubscribe from any Sunborn Group mailing list, please use the unsubscribe link provided in each email from us.
Links to other sites
Changes to this policy
Sunborn Group keeps this Privacy Statement under regular review and may modify or amend it from time to time at our discretion. If we make changes, we will record the date of amendment or modification in the Privacy Statement. The revised Privacy Statement will apply to you and your information from that date. We would encourage you to review this Privacy Statement periodically to check if there are any changes in how we are treating your personal data. This Privacy Statement was last updated in May 2018.
If you have questions, comments or complaints about our handling or protection of your personal data, please contact our Privacy department by using the form below
Data protection descriptions
Please review the data protection descriptions of our marketing and customer registers.
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