Updated on 30 March 2020
- How you can contact us.
- What types of personal data we process.
- For which purposes we use personal data and what is the legal basis of processing.
- For how long we retain the personal data.
- How you can use your rights.
- Whom we may share the personal data with.
- How we ensure information security.
- When A-lehdet serves as the joint controller.
We comply with all applicable laws and the sector’s self-regulation measures when processing personal data, including the guidelines of the Data & Marketing Association of Finland and the Interactive Advertising Bureau (IAB), such as IAB’s Europe Transparency and Consent Framework.
Business ID: 1708790-7
Risto Rytin tie 33
2. Personal data we process
The scope of the personal data that we collect and process varies depending on the type of relationship between you and A-lehdet, the processing and marketing options you have accepted or rejected, and your cookie settings.
Information collected on the use of the online services: We use server logs and cookies to automatically collect information about the use of our websites. This information includes, for example:
- information about the device or application used, including browser version, device type, screen size, display resolution, operating system, IP address and an individual device and/or cookie ID;
- information about the use of our online services, including information about page loadings, time and duration of visits, navigation around the online services and the viewed advertisement or marketing content;
- information about websites accessed via customer or marketing communications.
We can identify you based on the digital identifier created for you when you register, log into your online account, place a subscription on the website or enter the online service via a customer or marketing communication, for example to choose your customer gift. In these situations, we may connect information collected about the use of our services to the information described in more detail below.
Some of our services may also be used without logging in or providing personal data that would allow us to identify you directly, such as name or email address, in which case we will not be able to identify you personally. Please note that if you have been identified in one of our services, we will be able to identify you in other parts of the A-lehdet network as well: for example, if you have created a user ID for demi.fi, we will be able to connect information pertaining to this ID to information about your visit to Apu’s website.
Information related to consumer customers and online service users: You may provide us with your personal data when subscribing to a magazine or a newsletter, ordering a product, registering to the online services or commenting on blogs, among other things. Personal data may also be collected during the validity of your customer contract or other appropriate relationship. This data includes, for example:
- basic information, such as first name and surname, email address, postal address, telephone number;
- socio-demographic information, such as date of birth, marital status, gender, language, income level;
- customer information, such as subscription and invoicing information, customer number, information about the subscription payer and recipient or changes to this information, national identification number when paying by credit;
- customer service information, such as customer feedback, communication with the customer services or chatbot, customer service or sales call records;
- permission and consent information, such as consent for direct marketing or other consents and prohibitions for the processing of personal data;
- information about responses to surveys, questionnaires, prize draws or competitions;
- information collected during registration or when creating a user ID for A-lehdet, including email address, user ID or phone number, password, username and other information the user has volunteered, such as a photo or a verbal description of the user;
- information connected to blogs or blog comments published on the A-lehdet websites, such as blog address, comment, comment leaver’s username, email address and photo or link to a public profile, e.g. a Blogger profile.
Information related to business clients’: We store the following data about the contact people of our existing business clients, such as advertisers:
- basic information, such as first name and surname, telephone number, email address;
- the employer’s information, such as name, business ID, operating sector and contact information;
- information about status, such as role or area of responsibility, board membership;
- information about the client account, such as contracts, subscriptions and invoicing information;
- customer service information, such as customer feedback, communication with a contact person, customer service or sales call records;
- information about permissions and consents, such as consent for direct marketing or other consents and prohibitions for the processing of personal data;
- information about responses to surveys, questionnaires or competitions;
- information collected during registration for the online services, such as email address, user ID or phone number, password, username.
Information related to potential customers: When it comes to potential customers, such as people who might be interested in our services or who have been our customers before, we typically process information such as their name and contact details, as well as a brief summary of their order and offer history. In addition to this, we process information about our potential business clients’ contact people regarding their duties, such as their roles and areas of responsibilities.
Information obtained from external sources: Most of the data described above we collect from you during an order, subscription, registration or the validity of your contract or other appropriate relationship. Information may be collected and updated using the personal data bases of other A-lehdet Group companies. We may also collect information from data bases on customers' payment defaults, credit history and other similar data bases maintained by various authorities. In connection to our potential customers and influencers, we also collect information from commonly available sources, such as commercial or blogging websites and social media.
Derived and combined data: In order to provide you with a better service, we refine the abovementioned data by analysing it with various statistical methods and combining data collected from different sources. We may make assumptions about consumers’ interests, gender, age group, consumer behaviour or other similar features. These assumptions are based on the data collected or provided, mentioned above. We do not make assumptions using information that is considered sensitive, and we always ensure, through technical or organisational measures, that your privacy stays protected while the analysis is taking place. Typically, we do not process data on a personal level but instead build statistical models, which allow us to generalise the data to pertain to a wider group of people.
3. The purpose and legal basis of processing personal data
We mainly process your personal data in order to manage your client account, to provide you with our products and services and to develop and market our products and services. Below is a more detailed description of the purpose and legal basis of processing personal data.
Providing products and services: We will process your data in order to deliver the service or product you have ordered or subscribed to. We cannot make an offer, fulfil our contractual obligations, including delivering magazines, enable login to your online account, issue invoices for our services, contact you in connection to your contract, provide you with customer service or conduct customer communications without processing your personal data. When collecting data, we aim to inform you about which information is mandatory and which you may share voluntarily.
Product and service development: We use the information to develop our products and services, compile reports, improve the quality of our services and product selection and personalise our services. Contact made by our customers, analyses of the use of our websites, responses to our consumer surveys or questionnaires and other similar information helps us understand what sort of features customers would like our services to have and what type of content interests you. This data processing is based on our legitimate interest. More details on the information collected through surveys and questionnaires and what it is used for are provided separately for each survey and questionnaire. Below is a description of how you can object the processing of your data.
Marketing, advertising and their targeting: We use personal data to market and advertise our products and services. Marketing messages and advertisements may be tailored based on information which you have provided or which has been collected through your use of our services. We may also disclose information for marketing purposes to some of our partners. The A-lehdet bloggers may use comment leavers’ email addresses in order to send out invitations to events or prize draws.
We use Facebook’s ‘Custom Audience’ feature, which allows us to target our Facebook ads at our existing customers. A Facebook custom audience is created by using your email address or phone number to create an encrypted identifier in the browser which is then compared to the encrypted Facebook identifiers. This way A-lehdet can target its marketing on Facebook at its existing customers, or it can create target groups that resemble the profiles of A-lehdet customers. A-lehdet will not receive information about which identifiers relayed to Facebook have been used for the final custom audience and which ones do not have counterparts on Facebook. Similarly, Facebook will not receive information about who an identifier refers to. Facebook has agreed to only use the custom audience for the advertising of A-lehdet. More information is available on Facebook.
Competitions and prize draws: We may process your data in order to arrange a competition or a prize draw, and to draw or select the winners. In these situations, the processing will be based on the consent given when entering the competition or on our legitimate interests.
Preventing and investigating misconduct: From time to time we must use personal data in order to prevent or investigate cases of misconduct. For example, the automatically collected log data helps us monitor and assess user actions within our information system and the lawfulness of use of the information, in accordance with our legitimate interest. The email addresses of those who leave comments in the blogs and the IP addresses of people writing in the forums can help us investigate any wrongdoings.
Meeting legal requirements: We may be obliged to store some of your personal data in order to comply with the Accounting Act and other binding legislation. Occasionally, we are also required to disclose information to the authorities, for example the police, for the purpose of investigating suspected crimes. In such cases, the processing is based on the fulfilment of legal obligation.
Exceptions connected to sensitive information: We take particular care when processing sensitive information or information related to special types of personal data. This includes information connected to children or a person’s health. We comply fully with the sector’s self-regulation measures, and never use sensitive information or information related to special types of personal data to target our marketing. Our services are intended for people over 18 or young people over 13, and we never deliberately process data of children who are younger than this.
If you ask a doctor a question using our terve.fi service, we will process the information in order to provide an answer. We will not connect any information provided as part of a question to any of the other information we have collected and will delete all information that would identify you personally, including your email address, once the doctor has answered your question. The processing of sensitive information requires your explicit consent.
Legitimate interest as legal basis for the processing: When we develop our services, market our products and services or take action to stop misconduct on the basis of our legitimate interest, we consider the processing to be beneficial for both A-lehdet and its service users. The processing of personal data allows us to provide increasingly better services, distribute information about our services and products to people likely to be interested in them, tailor the content and offers and keep our services safe for all users. We aim for our practices to be as transparent as possible and to provide you with choices to use your rights, as described in Section 5. We consider the processing to be in line with your basic rights and freedoms.
Automated decisions: Making you a personalised offer based on your order history requires profiling. However, none of the decisions that might have a legal impact on you or might otherwise significantly affect you are automated.
4. Retain of personal data
We will retain your personal data for as long as is required to achieve the purposes defined in Section 3. Under normal circumstances, we will process your personal data for the duration of your contract and approximately 48 months after the end of your subscription or your latest login to your online account. This enables us to send you offers based on your order history or deduced interests, to reactivate a service, to develop our services further and to reply to any complaints. Before we delete an online account due to inactivity, we will contact the user. Once this has been done, we will minimise the amount of data we process and typically transfer the information about your name, contact details and the brief summary of your order and offer history to our marketing database.
Information about a potential customer, such as someone who has taken part in a prize draw or a competition or who has ordered products from A-lehdet before, will be processed for marketing purposes for as long as you do not opt-out of marketing messages. If you no longer want to receive these messages and no other basis for the processing exist, we will store the information about the opt-out so that we can ensure we comply with it.
Public comments to a blog are retained for as long as the blog is being published on the A-lehdet platform. The email addresses and other non-public information, such as the IP addresses, of people leaving comments are normally removed from the comments within six months of a comment’s publishing. If a comment leaver has signed in to the A-lehdet online service, the information will be processed for the duration specified in the first paragraph of Section 4.
Existing legislation, such as the Accounting Act or other binding legislation, may require us to retain personal data even after a person has ceased to be our customer or another primary purpose of processing no longer applies. In these instances, the storing is done in accordance with storage times specified by applicable laws. The Accounting Act requires us to store all documents relevant to a financial period, correspondence concerning transactions and any other accounting material certifying the transactions for at least six years, starting from the end of the year in which the financial period ended.
We aim to keep the personal data we process up to date and accurate by deleting unnecessary information and updating outdated information. However, we kindly ask that you regularly check that your information is up to date by accessing your information by signing into a service or using your A-lehdet user ID to access our online customer services. You may also influence the retention of your data, as described below, e.g. by requesting that your personal data be deleted.
5. Exercising your rights
You have several options available to you when it comes to the processing of your personal data:
Right of access, rectification and deletion: You have the right to request access to your personal data we have process in connection to you. At your request, we will rectify, amend or delete any personal data that is erroneous, incomplete or outdated for the processing purposes.
Data portability: You may also request that we transmit the personal data which you have provided and which we process automatically based on your consent or contract by contacting our customer services.
The right to object direct marketing and the related profiling: You may, at any time, prohibit us from disclosing or processing your personal data for direct marketing purposes by clicking on the link at the end of a message or by contacting our customer services.
The right to oppose or restrict processing: You may object processing that is based on our legitimate interest, based on your personal circumstances. An example of such circumstances is restricting the processing while your grounds for opposing the processing are being assessed. The processing may also be restricted if you contest the accuracy of your personal data, in which case the processing will be restricted until we are able to verify the accuracy of your personal data.
Withdrawal of consent: You can withdraw a previously given consent at any time by contacting our customer services or using some other means specifically made available. A direct marketing consent can be withdrawn by clicking on the link at the end of a message or by contacting our customer services.
Exercising your rights: If you wish to exercise your right to access or delete your personal data, we kindly ask you to fill in this form (in Finnish). In matters related to your other rights described above, you can contact the A-lehdet customer services. Please be prepared to verify your identity. If you are acting on behalf of another person, please make sure you hold a power of attorney or some other form of proof that you have the right to do so.
Targeting: You can adjust cookies and other similar technologies by using our consent management tool or by visiting the websites of our advertising technology partners. If you no longer want the content recommendations, displayed ads or the marketing and advertising messages you receive to be based on the content you consume online and on your order history, you can change the settings by signing into the A-lehdet customer services with your user ID.
6. Transferring and disclosing personal data
We process personal data within the A-lehdet Group for the purposes described above in Section 3. In addition to this, we may disclose personal data to third parties, for example in the following situations:
Authorities: We may disclose your personal data required by competent authorities in a manner specified by existing legislation.
Consent: We may disclose your personal data to third parties if you have given us your consent.
Research and product development: We may disclose your personal data for research and product development purposes. Most of the data will be anonymised to prevent the identification of the people it refers to.
Business arrangements: If we merge with another business, sell our business or make other such arrangements, your personal data may be disclosed to the buyers and their advisors.
Direct marketing, surveys and market research: We may disclose your personal data for direct marketing, surveys and market research, unless you have forbidden it.
Debt collection: We may disclose your personal data to our selected partners in order to collect a debt.
Legal claims and breaches: We may disclose your personal data to third parties if it is necessary to implement a contract, to investigate a breach or to write, present or defend a legal claim.
Furthermore, third parties may process the personal data under the following circumstances:
Personal data processors: When using third-party services, we have appropriate contracts in place and instruct the third parties on data processing to ensure that all personal data is being processed in accordance with the law. These third parties will only process the data when commissioned by us and on our behalf as the processors.
We do not normally transfer or process data outside the European Union or the European Economic Area. However, if an exception is made and personal data is transferred outside the EU/EEA, we will ensure sufficient data security, in accordance with applicable law, by utilising the standard contractual clauses approved by the European Commission, for example.
7. Data security
We use appropriate data security measures to protect your personal data against loss, destruction, unauthorized access damage or unlawful disclosure. We use firewalls and other technical means, restrict access to the information and ensure that our employees and subcontractors follow the guidelines when processing information, in compliance with their access rights and contracts, in order to guarantee that personal data is being securely processed. All employees processing personal data are bound by confidentiality.
8. A-lehdet as the joint controller