PRIVACY POLICY FOR TUIJA K GLOBAL’S CUSTOMERS, POTENTIAL CUSTOMERS AND INTEREST GROUPS 

Effective on June 25, 2020

This Privacy Policy is an integral part of Tuija K Global’s Terms and Conditions.

 

1. Controller of the filing system

Controller of this filing system is the Finnish company:

Tuija K Global Oy

Business registration number in Finnish Trade Register: 2009938-6

E-mail address: tuija.kauppinen@impactqueens.com

Telephone number: +358 50 331 6702 

hereinafter referred to as ”Tuija K”.

Please do not hesitate to contact us if you have any questions, concerns or ideas related to Tuija K’s personal data procedures.

  

2. Definitions 

In the following the most essential terms used in this Privacy Policy are explained:

1. ‘Consumer customer’ means any consumer that has purchased or ordered something from Tuija K or has some other type of other relevant connection with Tuija K, such as a subscription of a newsletter or a membership of a digital club. 

2. ‘Potential consumer customer’ means any consumer that is not yet or anymore an active customer. 

3. ‘Business-to-business customer’ means any representative of a company or public body which has purchased or ordered something from Tuija K or has some other type of other relevant connection with Tuija K. 

4. ‘Potential business-to-business customer’ means any representative of a company or public body which is not yet or anymore an active customer. 

5. ‘Interest groups’ means amongst others representatives of suppliers, the press, entities offering services to Tuija K and other stakeholders. 

6. ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly. 

7. ‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. 

3. To what purposes we process your data and based on which grounds? 

This Privacy Policy covers Tuija K’s processing of personal data of both consumers and business representatives as well as representatives of different interest groups. In the following we explain the differences in each category. One or more roles and purposes may apply simultaneously. 

• Consumer customers and business-to-business customers 

• Providing products and services 

Tuija K may use your personal data for providing products and services for you, for example when you purchase our products, use our digital services, subscribe to our newsletters and participate in our trainings and other events. 

• Managing, analyzing and improving the customer relationship 

Tuija K may use your personal data for managing, analyzing and improving the customer relationship with you and the entity you represent. 

• Communication with you

Tuija K may use your personal data to communicate with you, for example to send you invitations, important alerts and other such notices relating to our products, services, consumer panels or market research and to ask for your feedback on our products and services.

• Marketing to you

Tuija K may contact you to enhance your experience with Tuija K by informing you of new products, services or promotions Tuija K may offer. Tuija K may use your personal data to personalize our offering and to provide you with more relevant content. This means for example making recommendations and to display customized content and advertising in our services (such as websites, applications and marketing e-mails) and in third party services (such as banner advertisements). 

• Managing and developing products and services 

Tuija K may use your personal data to manage and develop Tuija K’s business operations, including its products and services. 

Processing of your personal data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously): 

1. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. 

1. Processing is necessary for compliance with a legal obligation to which the controller is subject (for example the duty to keep the records based on Accounting Act). 

1. Processing is necessary for the purposes of the legitimate interests pursued by Tuija K or a third party. 

1. You have given consent to the processing of your personal data. 

The legitimate interests of Tuija K or third party referred to in point c) above may include amongst others the following matters:

• right to promote the sales of Tuija K’s products and services by way of direct marketing, including profiling for the purposes of marketing and sales
• business development
• investigation of possible malpractice 

• Potential consumer customers and potential business-to-business customers 

• Marketing to you 

Tuija K may contact you to promote its products and services or to invite you to a consumer panel. Tuija K may use your personal data to personalize our offering and to provide you with more relevant content. This means for example making recommendations and to display customized content and advertising in our services (such as websites, applications and marketing e-mails) and in third party services (such as banner advertisements). 

• Communication with you 

Tuija K may use your personal data to communicate with you, for example to ask for your feedback on our prior engagement with you.

• Managing and developing products and services 

Tuija K may use your personal data to manage and develop Tuija K’s business operations, including its products and services. 

Processing of your personal data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously): 

1. Processing is necessary for the purposes of the legitimate interests pursued by Tuija K. 

1. You have given consent to the processing of your personal data. 

The legitimate interests of Tuija K referred to in point a) above may include amongst others the following matters: 

• right to promote the sales of Tuija K’s products and services by way of direct marketing, including profiling for the purposes of marketing and sales
• customer service for potential customers
• business development 

• Interest groups

By interest groups we mean amongst others representatives of the press, representatives of entities offering services to Tuija K and representatives of other stakeholders as well as visitors of all Tuija K premises.

• Managing, analyzing and improving the relationship

Tuija K may use your personal data for managing, analyzing and improving the relationship with you and the entity you represent.

• Communication with you

Tuija K may use your personal data to communicate with you, for example to send you news, alerts and other such notices relating to our relationship. 

• Managing and developing products and services

Tuija K may use your personal data to manage and develop Tuija K’s business operations, including its products and services. 

Processing of your personal data is based on the following grounds of the EU’s General Data Protection Regulation (one or more purposes may apply simultaneously): 

1. Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. 

1. Processing is necessary for compliance with a legal obligation to which the controller is subject (for example the duty to keep the records based on Accounting Act).

1. Processing is necessary for the purposes of the legitimate interests pursued by Tuija K. 

1. You have given consent to the processing of your personal data. 

The legitimate interests of Tuija K referred to in point c) above may include amongst others the following matters: 

• right to promote the business activities of Tuija K by way of press releases
• business development 

_ _ _

In addition to the above, Tuija K uses your data in which ever role you are if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our agreements or this Privacy Policy. 

4. What types of information we may collect about you? 

Content of Tuija K’s filing system may include the following types of data and changes made to these data types: 

• Information that may be collected of all data subjects 
• first and last names
• contact data (e-mail address, telephone number and/or postal address)
• gender
• language preferences
• when your data was put into the filing system
• campaigns, promotions and other communication directed to you, as well as their use, including participation in events
• interests and other information or survey data provided by you
• direct marketing choices
• use of your rights related to your personal data
• information of the use of Tuija K’s digital services as well as digital content created by you
• payment information
• automatically collected data (such as IP Address, your device’s operating system, browser type and language)
• mobile device identifiers (such as your unique device ID and your device name)
• recordings of customer service telephone conversations as well as e-mail and chat correspondence
• Consumer customers

In addition to the list in point 4.1. Tuija K may collect the following data types:

• subscription, purchase and feedback history
• birthday
• profession
• social media user names
• activities in or related to Tuija K’s social media channels
  
  Potential consumer customers

In addition to the list in point 4.1. Tuija K may collect the following data types 

• social media user names
• activities in or related to Tuija K’s social media channels 

• Business-to-business customers 

In addition to the list in point 4.1. Tuija K may collect the following data types: 

• title and/or job description of current and previous jobs related to Tuija K’s customer relationships
• name and business information of the entity you work for currently or previously, related to Tuija K’s customer relationship
• subscription, purchase and feedback history

 

• Potential business-to-business customers 

In addition to the list in point 4.1. Tuija K may collect the following data types: 

• title and/or job description of current job
• name and business information of the entity you work for currently 

• Customers purchasing clothing consultation services 

In addition to the list in point 4.1. Tuija K may collect the following data types:

• photos of customer
• age
• education
• marital status / family info
• amount of exercise
• hobbies
• height, weight and clothing sizes as well as data related to body type
• health data (with consent, for example data of asymmetric body)
• attitude and interests towards clothing
• clothing budget data and shopping habit data
• responses to Tuija K’s background form’s general lifestyle questions 

• Interest groups 

In addition to the list in point 4.1. Tuija K may collect the following data types: 

• title and/or job description of current and previous jobs related to Tuija K’s customer relationships
• name and business information of the entity you work for currently or previously, related to Tuija K’s customer relationship 

5. Which sources we gather your personal data from? 

• Sources applicable to all data subjects 

Tuija K gathers personal data directly from you, for example from:

• physical and website forms (e.g. background data forms, online subscriptions, marketing promotions, newsletter subscriptions, competitions, feedback forms, research participation)
• mobile applications
• physical forms in events
• telephone and video meeting conversations, e-mail and instant messaging correspondence and chat services
• your social media accounts
• customer service communications 

Tuija K gathers personal data from the technical device you use in your communication with Tuija K. 

Tuija K may obtain and update the personal data in its filing system from officials and companies offering personal data services. 

• Consumer customers 

Tuija K may gather personal data from Tuija K’s online shops, and from Tuija K’s social media channels. 

Tuija K may gather personal data from the payment service providers related to Tuija K’s online shops. 

• Potential consumer customers 

Tuija K may gather personal data from Tuija K’s social media channels. 

• Business-to-business customers

Tuija K gathers personal data from Tuija K’s online shops. 

Tuija K may gather personal data from the business-to-business customer when the representative of the company gives personal data of other employees to Tuija K. 

• Potential business-to-business customers

Tuija K may gather personal data from companies’ websites, Trade Register, social media and from other public sources. 

• Interest groups 

Tuija K may gather personal data from organizations’ websites, Trade Register, social media and from other public sources.  

6. To whom we may transfer and assign your personal data? 

Tuija K does not sell, lease or otherwise disclose your personal data to third parties outside of the Tuija K Group unless otherwise stated below. 

Tuija K may share your personal data with authorized third parties that perform services for Tuija K for the purposes described in this Privacy Policy within the limits of the applicable legislation. This may include for example providing services such as customer service and software services, managing and analyzing personal data, conducting market research and managing marketing and execution of diverse campaigns. 

Tuija K may share your personal data for obtaining payment for products and services including the transfer or sale of delinquent accounts to third parties for collection. 

Because Tuija K takes the responsibility to safeguard your personal data seriously, Tuija K does not allow those companies to use it for any purpose other than to perform those services, and Tuija K requires them to protect your personal data in a way consistent with this Privacy Policy.

Tuija K may share your personal data with carefully considered third parties for joint or independent direct marketing purposes. Sharing of your data for such purposes may in principle only happen when the planned purposes of the third party are not incompatible with Tuija K’s purposes described in this Privacy Policy. Only the minimum necessary amount of your personal data is shared with third parties. 

Tuija K may share your personal data based on a valid order from a court or other official body with sufficient authority. 

Tuija K may share your personal data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your personal data would be transferred to another entity as a result of such a proceeding. 

7. Is your data transferred to countries outside the European Union? 

Tuija K’s services may be provided using resources and servers located in various countries around the world. Therefore Tuija K may transfer your personal data outside the country where you use our services, including to countries outside the EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection. 

In such cases Tuija K ensures that a legal basis for such a transfer exists and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures. 

8. How long do we process your data? 

Tuija K may process your personal data for as long as described below for each different sub-group. In addition to the below stated times, Tuija K may always process your personal data for e.g. tax or legal purposes or due to an extraordinary long-term commitment for as long as necessary and justified.

• Consumer customers 

Tuija K may process your personal data for as long as the customer relationship between you and Tuija K exists, and until the end of the calendar year following the 5^thyear thereafter. 

After the above specified timeframe has ended, Tuija K may process part of your personal data and consider you a potential consumer customer. 

• Potential consumer customers 

Tuija K may process your personal data continuously as Tuija K aims at building a customer relationship with you. Once the customer relationship has started, the duration of the processing is defined in point 8.1. above. 

• Business-to-business customers 

Tuija K may process your personal data for as long as the customer relationship between the company you represent and Tuija K exists, and until the end of the calendar year following the 3^rdyear thereafter. 

After the above specified timeframe has ended, Tuija K may process part of your personal data and consider you a representative of a potential business-to-business customer. 

• Potential business-to-business customers 

Tuija K may process your personal data continuously as Tuija K aims at building a customer relationship with the company you represent. Once the customer relationship has started, the duration of the processing is defined in point 8.3. above. 

• Interest groups 

Tuija K may process your personal data for as long as you are a member of any of Tuija K’s interest groups such as co-operation partners or press representatives. Tuija K may process personal data related to a supplier of products or services or a contractual co-operation party until the end of the calendar year following the 6^th year after the end of the contractual relationship. 

9. How can you exercise the different types of rights you have? 

All rights can be exercised by contacting Tuija K by using the contact details issued at section 1 above. The team will then give further instructions on how to exercise a specific right. Where Tuija K has reasonable doubts concerning the identity of the person making the request, Tuija K may request the provision of additional information necessary to confirm your identity.

Tuija K will provide information on action taken on a request to you within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. 

• Right of access to your personal data 

You have the right to obtain from Tuija K confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, receive information about your personal data. 

• Right to rectification 

You have the right to obtain from Tuija K without undue delay the rectification of inaccurate personal data concerning you. 

• Right to erasure (‘right to be forgotten’) 

You have the right to obtain from Tuija K the erasure of personal data concerning you without undue delay where one of the following grounds applies:

• your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 

• you withdraw consent on which the processing is based and where there is no other legal ground for the processing;

• you object to the processing and there are no overriding legitimate grounds for the processing; 

• your personal data have been unlawfully processed; 

• your personal data have to be erased for compliance with a legal obligation in Union or member state law to which Tuija K is subject; 

• the personal data have been collected in relation to the offer of information society services. 

However, you do not have the right or erasure if the processing is necessary: 

• for exercising the right of freedom of expression and information; 

• for compliance with a legal obligation which requires processing by Union or member state law to which Tuija K is subject; or

• for the establishment, exercise or defence of legal claims.

• Right to restriction of processing

You have the right to obtain from Tuija K restriction of processing where one of the following applies:

• the accuracy of the personal data is contested by you, for a period enabling Tuija K to verify the accuracy of the personal data;

• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

• Tuija K no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

• you have objected to processing pending the verification whether the legitimate grounds of Tuija K override those of you. 

• Right to object 

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests pursued by Tuija K, including profiling. Tuija K shall no longer process the personal data unless Tuija K demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms for the establishment, exercise or defence of legal claims. 

Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. 

Please be aware that you cannot opt out of receiving service messages from Tuija K, including but not limited to security and legal notices.

• Right to data portability

You have the right to receive the personal data concerning you, which you have provided to Tuija K, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where: 

• the processing is based on consent or on a contract; and 

(b) the processing is carried out by automated means. 

10. Is it mandatory for you to disclose your personal data to us? 

Where your personal data is necessary for Tuija K in order to fulfil its contractual obligations related to a contract with you, disclosing your personal data to us is mandatory. For example, you cannot make purchases from Tuija K’s online shop without disclosing the necessary personal data. 

11. How can you withdraw a consent given by you?

You may withdraw possible consent by contacting Tuija K (contact information in section 1) or using available unsubscribe mechanism. 

12. Do we make decisions affecting you based on automated means? 

Tuija K does not make decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affect you. 

13. Do we process your personal data in order to profile you?

Tuija K may target (and measures the performance of) ads to its websites’ and applications’ visitors and users as well as newsletters recipients based on profiling both on and off of Tuija K’s services through a variety of ad networks and exchanges, using the following data, whether separately or combined: 

• data from advertising technologies on and off of our services, like web beacons, pixels, ad tags, cookies, and device identifiers;
• information provided by you (e.g., contact information);
• data from your use of our services (e.g., search history, clicking on an ad, etc.);
• information from others (e.g. advertising partners and data aggregators);
• information inferred from data (e.g., using job titles to infer seniority or names to infer gender). 

14. How can you exercise your right to lodge a complaint to the supervisory authority? 

In case you suspect a breach of data protection legislation, please contact Tuija K first (contact information in section 1). In case the matter is not solved amicably between you and Tuija K, you may contact the Finnish Data Protection authority. 

15. What are our principles for securing your personal data? 

Tuija K has established electronic and administrative safeguards designed to make the information collected secure. 

Only appointed personnel of Tuija K and of organizations operating by Tuija K’s assignment or on behalf of Tuija K are entitled to use the personal data filing system. All persons processing the system have a personal right of use granted by Tuija K or its co-operation partner. Different levels of access have been created based on the data a person needs according to his/her job description. Systems are protected with a firewall that prohibits unauthorized access outside of Tuija K. 

All personnel of Tuija K and its subcontractors are obliged to keep the information of the personal data which they obtain in their work confidential. 

Manually processed documents containing personal data are protected against unauthorized access. 

16. Which law do we apply for processing personal data? 

The processing of personal data in Tuija K’s filing system is governed by the European Union’s applicable data protection legislation as well as national laws of Finland where Tuija K is established. 

17. How can we update this Privacy Policy? 

Tuija K may modify this Privacy Policy, and if we make material changes to it, we will provide notice on our website or by other means, to provide you the opportunity to review the changes before they become effective. Your continued use of Tuija K’s products and services after we publish or send a notice about our changes to this Privacy Policy means that you have become bound by the updated Privacy Policy.