- Marketing register – Tutoris Oy
Tutoris Oy, Business ID: 1844559-3
Address: Kajaaninkatu 15, FI-90100 Oulu, Finland
Telephone: +358 40 630 3032
2 Contact Person for Matters Concerning the Data File
Arja Kangas, +358 44 560 4794, firstname.lastname@example.org
3 Name of the Data File
The name of the file is Marketing Register.
4 Purpose and Legal Basis of Processing Personal Data
Personal data are collected for a specified, explicit and legitimate purpose on the basis of the legitimate interests of the controller. The controller has the right to engage in marketing activities.
We use personal data, photos and videos in accordance with the General Data Protection Regulation (EU) 2016/679:
– To provide a good client experience
– For the purpose of marketing communication and service/product recommendations
– To develop customer service and the Tutoris Oy electronic marketplace
– Or other comparable activities
We use client photographs in our marketing communication only after obtaining photography permission. In events, we observe the constitutional freedom of speech when taking photographs in a public place and sharing them, while taking the specific wishes of our clients into consideration.
We use trusted contracting partners and may therefore transfer data and photographs to a third party, such as an advertising agency partner. The requirements of the EU Data Protection Regulation and other legislation have been observed in the agreements between all partners.
The data that we collect may be divided into data provided by the user him/herself, data observed concerning the use of online services and data derived using analytics.
Data are not used in automatic decision-making or profiling.
5 Data Contents of the Data File
Data provided by the user him/herself or data identifying the individual:
- Identification data, such as a name
- Contact data, such as an address, an e-mail address and phone number
- Payment information and other invoicing information
- Other location data, such as the Tutoris regional centre used by the client or the client’s location data when the client takes part in a Tutoris event
- Form of therapy used by the client
Data observed concerning the use of the services and derived using analytics:
- Purchase history, such as products ordered and their prices
- Delivery information, such as the selected method of delivery and delivery address
- Product reviews, site reviews
- Usage and browsing data of the electronic marketplace
- Data and identifiers used in product recommendations and other targeted content
It is mandatory to provide identifier, contact and payment information when purchasing products online from the Tutoris Oy electronic marketplace.
6 Regular Sources of Data
The personal data in the marketing register are collected from the data subject him/herself or from public sources, such as the contact details of companies on websites and address registers.
7 Regular Disclosures of Data
The controller shall not disclose data to third parties or automatically to the other partners of the controller. The controller shall, in individual cases, disclose the data of a client or an interest group to a designated party, if the data subject requests the controller to act in this manner or if a competent authority exercises its legal right to demand the controller to separately disclose identification data from the database held by the controller.
8 Transfer of Data to a Third Country or to an International Organization
Data shall not be transferred to a third country or to an international organization.
9 Right of Access
The data subject shall be entitled to access his/her data that has been saved in the data file. In addition, after submitting an adequately detailed and specified request for inspection, he/she shall be entitled to access the data relating to him/her and contained in recordings. The request for inspection must be made in writing, signed and sent to the contact person of the controller to email@example.com, and a copy of a personal identity card with photograph must be included.
10 Right to Demand the Rectification and Erasure of Data
The controller must rectify incorrect data indicated by the party concerned in the personal data file. The controller shall also be under the obligation to use its own initiative to verify the appropriateness and timeliness of data in the data file. The data subject may also demand the controller to erase data concerning him or her from the data file.
11 Other Rights Relating to the Processing of Personal Data
The data subject shall have the right to demand restriction of processing of personal data. The data subject shall also have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. In addition, the data subject shall have the right to object to processing of data, automatic decision-making and profiling.
12 Data Removal and Retention Period
The controller shall remove the data from the data file when there are no longer any commercial grounds for data processing or if the person concerned exercises his or her legal right to demand the controller to remove the data concerning him or her.
Personal data shall be destroyed when grounds no longer exist for data processing or retention. However, data shall not be removed if the law provides otherwise or if a competent authority has initiated a process that requires the controller to retain the data or if another party has applied for a decision from a Finnish court of law to safeguard the data.
13 Approval of the Information Policy
The Information Policy has been approved as continuous and revised on 24 May 2018.
We use so-called observed data that are collected using cookies and other techniques e.g. to further improve our services, to display more relevant advertising and to customize the contents of our services and marketing messages. The advertisements of Tutoris may be targeted in third-party services, such as Facebook, LinkedIn and Google, on the basis that the user has visited our service.
Our services may have the possibility to use a customer service chat. The providers of these services may save personal data on the basis of a contact under their own terms and conditions.
Our site uses share buttons to enabling sharing across various social media services. These service providers may collect data on the shares under their own terms and conditions.