PRIVACY POLICY
1. Joint Data Controllers
This Privacy Policy applies to all Snellman Group companies in Finland that act as joint data controllers when processing personal data as part of their online services and customer service activities. The following Snellman Group companies are joint data controllers:
a)
Name: Oy Snellman Ab
Business ID: 0181676-5
Address: Kuusisaarentie 1, 68600 Pietarsaari, Finland
Phone: +358 6 7866111
Email: tietosuoja@snellman.fi
b)
Name: Snellman Petfood Oy
Business ID: 3580283-9
Address: Kuusisaarentie 1, 68600 Pietarsaari, Finland
Phone: +358 6 7866111
c)
Name: Snellman Lihanjalostus Oy – Snellmans Köttförädling Ab
Business ID: 2212340-7
Address: Kuusisaarentie 1, 68600 Pietarsaari, Finland
Phone: +358 6 7866111
d)
Name: Snellmanin Kokkikartano Oy
Business ID: 1554059-5
Address: Jäspilänkatu 27, 04250 Kerava, Finland
Phone: +358 6 7866111
e)
Name: Figen Oy
Business ID: 2126615-8
Address: Pykärintie 15, 62395 Petterinmäki, Finland
Phone: +358 6 7866111
Party a) is hereinafter referred to as the “Parent Company”, and parties b)–d) are hereinafter referred to as the “Subsidiaries”. The Parent Company and the Subsidiaries are hereinafter collectively referred to as “Snellman”.
2. Contact Details of the Snellman Group's Data Protection Officer
Company: Oy Snellman Ab
Name: Rose Lindell
Phone: +358 40 680 9020
Email: tietosuoja@snellman.fi
3. Roles of the Joint Data Controllers in the Processing of Personal Data
The Parent Company and the Subsidiaries act as joint data controllers when processing personal data as part of their online services and customer service activities. The Parent Company establishes the general policies and principles applicable to online services and customer service and oversees the operation of the websites. The Parent Company is responsible for ensuring that the processing of personal data carried out by Snellman complies with applicable data protection legislation and Snellman’s general data protection guidelines.
The Subsidiaries are responsible for processing personal data for the development and marketing of their respective operations, products and services.
4. Purposes and Legal Bases for Processing Personal Data
Snellman processes personal data to improve product safety and customer satisfaction and to develop its business operations. This includes collecting and responding to customer feedback and any complaints. The processing is based on Snellman’s legitimate interest, arising from the relationship between Snellman and the data subject when the data subject purchases products manufactured by Snellman, expresses an interest in them or otherwise interacts with Snellman.
Snellman processes personal data for direct marketing purposes when the data subject subscribes to Snellman’s newsletter or other marketing materials. When direct marketing is aimed at consumers, the processing of personal data is based on the data subject’s consent. We may carry out direct marketing to organisations (such as retail stores) unless the organisation has specifically opted out of such marketing.
In addition, we may collect personal data about how data subjects use Snellman’s online services, based on their consent. Further information about the use of cookies is provided in Section 10 below.
5. Categories of Personal Data Collected
Snellman processes only personal data that is necessary and relevant for each specific processing purpose. Snellman processes, for example, the following categories of personal data:
– Identification and contact details: The data subject’s first and last name, postal address, email address and telephone number.
– Feedback and complaints: Information about feedback and complaints submitted by the data subject, including any attached images.
– Consents and objections provided by the data subject: Consent to or objection to direct marketing, and consent to or rejection of cookies.
– Data collected through cookies: IP address, device, operating system, browser type, time of access, URL, referring website or server, time spent on the website and language preferences.
6. Data Retention Period
Snellman processes personal data only for as long as necessary for the purposes of processing and only to the extent required.
Personal data is retained as follows:
a) Customer feedback, complaints and any personal data processed in connection with them will be deleted 12 months after the feedback or complaint was submitted, unless the matter is still pending or otherwise requires further investigation.
b) Personal data used for direct marketing purposes will be processed until the data subject chooses to unsubscribe.
c) Personal data may be retained on the basis of Snellman’s legitimate interest for as long as necessary to protect that interest. In such cases, retention periods are determined by the duration of any ongoing regulatory or other legal proceedings, as well as the applicable limitation periods and statutory deadlines for bringing legal claims.
7. Regular Sources of Personal Data
Snellman collects personal data only directly from the data subjects themselves when they use Snellman’s online services (website forms) or contact Snellman by telephone or email. Telephone calls may be recorded to improve customer service.
8. Recipients of Personal Data and Regular Disclosures of Personal Data
Personal data is processed by those members of Snellman’s personnel who need access to such data in order to perform their duties. Personal data may be transferred within Snellman on the basis of legitimate interest.
In certain circumstances, Snellman may disclose personal data to third parties. For example, Snellman may use external service providers to process personal data on its behalf. In such cases, we ensure that personal data is processed in accordance with Snellman’s privacy policies and the agreements concluded with the service providers.
Snellman may disclose personal data in connection with a potential business transfer, merger or acquisition.
9. Transfers of Personal Data Outside the EU or European Economic Area (EEA)
We primarily process personal data within the EU/EEA. However, we may transfer personal data outside the EU/EEA if an external service provider used by Snellman operates wholly or partly outside these areas. In such cases, we always ensure that the transfers comply with applicable data protection legislation by using Standard Contractual Clauses approved by the European Commission and ensuring that an adequate level of data protection is maintained in the third country.
10. Use of Cookies
We use cookies on our website. A cookie is a small text file that is sent to and stored on a user’s computer. Cookies enable website operators to recognise returning visitors, make it easier for users to log in and collect aggregated information about website visitors. This information helps us continuously improve the content of our website.
Cookies do not harm users’ computers or files. We use them to provide our customers with information and services tailored to their individual needs.
Please note that cookies may be necessary for the proper functioning of some of the websites we operate and the services we provide.
We may store cookies on your device if they are strictly necessary for the operation of the website. We always ask for your consent before using any non-essential cookies. You have the right to withdraw your consent at any time.
11. Data Security
Your personal data is stored on Snellman’s own servers or on servers operated by our service providers, which are protected in accordance with generally accepted industry practices. Access to personal data is secured by firewalls, individual user accounts, access rights and passwords.
Personal data collected and processed by Snellman is kept confidential, and access is restricted to Snellman employees who need the information to perform their duties.
12. Automated Decision-Making
No automated individual decision-making, including profiling, as referred to in Article 22 of the EU General Data Protection Regulation (GDPR), is carried out.
13. Rights of the Data Subject
The data subject has the right to access their personal data and to verify what information concerning them is stored in the personal data register. The data subject has the right to request the rectification of inaccurate or outdated information and to have incomplete information completed.
The data subject may request the erasure of their personal data in accordance with Article 17 of the EU General Data Protection Regulation (GDPR) and exercise their right to data portability. They also have the right to restrict or object to the processing of their personal data in accordance with Articles 18 and 21 of the GDPR.
The data subject has the right to withdraw their previously given consent to the processing of personal data at any time. Consent to direct marketing can be withdrawn through the unsubscribe option provided in each direct marketing message.
Requests concerning the exercise of data subject rights should be submitted by email to Snellman’s Data Protection Officer at [tietosuoja@snellman.fi](mailto:tietosuoja@snellman.fi).
If the data subject believes that Snellman’s processing of personal data violates the GDPR or other applicable data protection regulations, they have the right to lodge a complaint with the relevant supervisory authority (in Finland, the Office of the Data Protection Ombudsman).
14. Other Provisions
Snellman may update this Privacy Policy as our operations evolve or legislation changes.