This privacy statement describes how Fennica Gaming Oy (“Fennica”, “we”), as the responsible data controller, processes your personal data as part of your contacts with us.
1 Personal data that we collect
As part of and in connection to the above, we may collect and process information such as the following:
- Your contact details. This includes i.e. your name, email address, phone number, date of birth, birth place, country of residence, the name of the organisation you represent, position, website and other similar information that you provide to us.
- Your user account details. This includes i.e. your name, email address, phone number, the name of the organisation you represent, position, website, information about your access rights in service to browse Fennica’s game portfolio and instructions for game development (the “Service”) and other information you provide as part of the sign-up process.
- Your contacts with us. This includes emails and other communications between us, notes from meetings, and similar information about your contacts with us.
We generally collect all this information directly from you, but sometimes we may have received, e.g., your contact details or information used for account creation from another person in your organisation, or we may have checked a contact detail from your organisation’s website or from another publicly available source (e.g., a telephone directory).
If you do not provide your contact details to us when asked, we may not be able to correspond with your or offer our services to you.
2 Purpose and legal basis for collecting the personal data
We collect and process the above information for the purposes of our legal obligations to comply with the Prime Minister Office's authority decision's conditions (to conduct due diligence), conduct sanctions screening and book keeping regulations.
We collect and process the above information for the purposes of our legitimate interest to
- manage our customer relationship
- market and sell our services
- conduct due diligence
- receive feedback on our services
- receive information about your needs in connection to our services
- track interest in our services
- manage contracts
- provide secure access to the Service and for similar customary purposes related to the management of our customer and prospective customer relationships.
We may use automated security tools to scan our logs to, e.g., detect signs of security issues in our Service. We may need to block or suspend your account if such signs are detected. We do not, however, use your account information for automated decision-making.
We also collect and process the above information for the purposes of our legal obligations, such as to comply with the Prime Minister Office's authority decision's conditions (to conduct due diligence), conduct sanctions screening and book keeping regulations.
In some cases, we may also separately have asked for your consent for certain processing of your personal data, or you may have provided such consent, e.g., on our website. In these cases, we may also process the above information based on that consent.
3 How we disclose and transfer the personal data
Generally, we do not disclose or transfer your abovementioned personal data to anyone outside our organization. There are, however, a few exceptions to this.
- In some cases, we may provide the above information to other people in your organisation (or group). If you refer us to another person in your organisation, we might, e.g., disclose to that person that you asked us to contact them and mention details of our previous interactions. If you were to leave your organisation, we may also carry on our correspondence with other people in the organisation. In other instances, we might also, e.g., in our view need to disclose pre-contractual correspondence to other members of your organisation. Also, your organisation’s administrative users may see a list of current accounts registered for the organisation to the Service and well as account information connected to them.
- Where in our view necessary, we may disclose the above information to government agencies, courts, arbitral tribunals, or private third parties when this is reasonably necessary or expedient for the establishment, exercise, or defence of legal claims or in response to lawful document or information production orders.
We may transfer your personal data to technical service providers who assist us in proving our services. We may, e.g., use outside email providers, hosting services, account management services, and the like. n production orders.
4 International transfers of personal data
We may use certain service providers who store your personal data outside the European Union or European Economic Area or who have access to data from outside this area.
In these situations, we generally enter into an agreement with the recipient in accordance with the standard contractual clauses adopted by the European Commission that ensure safe data processing in third countries as well. We also ensure safe and lawful data processing abroad by other means.
However, if it is necessary to disclose or transfer your personal data to a third country to perform an agreement that we have entered into with you or in your favour, or if some other lawful derogation applies, we may not rely on the standard contractual clauses to the extent that this derogation applies.
5 Retention period for the personal data
We generally retain your personal data for the duration of your and your organisation’s active relationship with us and for a reasonable period thereafter.
If we do not enter into any agreement regarding our services, we will seek to delete your above information within approximately two years of your last contact with us. If we enter into one or more agreements in respect of our services, we may retain the above information for the periods described in our privacy statement relevant to the agreement in question.
We may also store the above data for a longer period than set out above if we reasonably suspect that the data may be needed for a possible legal claim, dispute, investigation, or the exercise of our rights or obligations.
When the abovementioned storage period ends, your personal data will generally either be deleted or anonymised in such a way that it is no longer possible to identify an individual based on the data. Please note, however, that some of the above data also may remain stored in personal mailboxes that we cannot access or alter without the relevant person’s consent.
6 Your rights under data protection law
Pursuant to European data protection law, you have the right to ask us:
(a) for access your personal data and, in certain cases, for a copy of your data or to have it transferred to another system,
(b) to rectify incorrect or incomplete personal data about you,
(c) to erase outdated or unnecessary personal data about you,
(d) to temporarily restrict processing your personal data, e.g., until another re-quest has been resolved or as otherwise set out in law,
(e) to object to using your data for direct marketing or, on grounds relating to your particular situation, to our processing of personal data for the legitimate interests set out above.
Where we process your personal data based on your consent, you may at any time withdraw your consent. Please note, however, that this will not affect the lawfulness of any processing based on your consent before its withdrawal.
If you believe we have collected or processed your personal data unlawfully you may also lodge a complaint with a competent data protection authority. In Finland, you may contact Office of the Data Protection Ombudsman (for more information see tietosuoja.fi/en).
7 Contacting us
If you wish to contact us concerning our use of your personal data or to, e.g., exercise your rights under data protection law you may contact us via post at Fennica Gaming Oy, Privacy team, Aku Korhosen tie 2, 00440 Helsinki, Finland or via email at firstname.lastname@example.org.
We may update this privacy statement from time to time. Where necessary, we will separately notify you of any material changes to this statement.