Privacy Policy
Data Protection Description
In accordance with EU General Data Protection Regulation (2016/679, “GDPR”). Version 1.0, dated 21 December 2022.
This information may be subject to changes from time to time due to i.a. technical reasons and/or change of services providers, applicable legislation and legal interpretations.
1. Object of the processing
MedPhab marketing and customer register
2. Controllers, data protection officers and contact information
Contact information concerning the register for purpose of establishing the data subject’s rights:
Email: jussi.hiltunen@vtt.fi
Controllers:
VTT Technical Research Centre of Finland Ltd. (”VTT”), Business ID: 2647375-4
Address: Tekniikantie 21, 02150 Espoo, Finland
Data Protection Officer
Address: VTT Technical Research Centre of Finland Ltd., P.O. Box 1000, 02044 VTT, Finland
Email: dataprotection@vtt.fi (DPO, cybersecurity manager and legal counsel)
3. Categories of the personal data
The categories of the personal data contained in the register are i.a.:
Name details
E-mail address
Organisation
Contact request message
The data subjects represent current or potential customers of the Controller(s) concerning MedPhab related services and other interest groups of MedPhab.
4. Purposes of the processing and the legal basis for the processing
The personal data is primarily processed for the following purposes:
Replying contact request
Business development, other development and reporting
The personal data is processed on the basis of legitimate interest of the Controller(s). The legitimate interest applicable is a right to conduct well-grounded marketing and communication and thereto related direct marketing.
Every person has the right to refuse to allow the use of their personal data for direct marketing purposes. If the registrant wishes to opt-out, he or she should inform jussi.hiltunen@vtt.fi.
5. Regular sources of information
Personal data are either received from the data subject or filled in on the basis of public sources.
6. Recipients or categories of recipients of the personal data
The Controller(s) may provide third parties with such personal data which is needed by a third party (i) in order to provide the Controller(s) with marketing and/or technical services related to the object of the processing or other similar processing purposes and/or (ii) for collaboration with the Controller(s) which requires joint efforts in marketing and communication.
VTT acts as a temporary controller until Finland-based MedPhab Non-Profit Association is established in 2023. When MedPhab NPA becomes a new controller, VTT transfers the collected data to MedPhab NPA and deletes the collected data from VTT’s database.
Each provision of data is done in accordance with requirements of GDPR and applicable legislation.
7. Transfer of data outside the European Union or the European Economic Area
The personal data is not regularly, but may be, transferred outside the EU or EEA if this is necessary to ensure appropriate and cost-effective implementation of the processing purpose, such as in case of technical reasons related to service provider or processing. In such cases, the transfer is done in accordance with requirements of GDPR and applicable legislation.
In case of absence of European Commission (“EC”) adequacy decisions, EC standard contractual clauses are used as appropriate or suitable safeguards for these data transfers. Whenever EC adequacy decisions are applicable, the Controller(s) may rely on them.
8. The existence of automated decision-making, including profiling
No automated decision-making or profiling which produces legal effects or has similar material effects concerning the data subject is made.
9. The period for which the personal data is stored or the criteria used to determine that period
The personal data is processed as long as it is needed for the purpose of any processing purpose set forth above. After this the data subject’s personal data are either anonymised or deleted, unless other applicable legal basis for processing remains.
10. Principles of protection of the register
Personal data is stored in a technically secure location. Physical access to the data is restricted by means of access control and other security measures. Access is also prevented by means of e.g. firewalls and other technical protection measures. Only named employees of the Controllers have the right to process personal data contained in the register. These persons are bound by confidentiality obligations.
Rights of the data subject
The data subjects have the following rights that the data subject may establish by contacting the Controllers in writing, preferably by email, or as detailed below. Some of the rights may be subject to limitations, in accordance with GDPR and applicable legislation.
The data subject is requested to contact the Controllers from an email address which the Controllers presumably has in its register(s). The Controller(s) may also request further information or documentation in order to verify person’s identity.
Right of access
The data subjects have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed and access to his or her personal data and information concerning the processing.
Right to rectification
The data subjects have the right to obtain from the controller rectification of inaccurate personal data concerning him or her, and the right to have incomplete personal data completed.
Right to erasure
The data subjects have the right to obtain from the controller the erasure of personal data concerning him or her, to the extent permitted by law.
Right to restriction of processing
The data subjects have the right to obtain from the controller restriction of processing, as set forth in GPDR.
Right to data portability
Where the processing is based on the data subject’s contractual relationship and is carried out by automated means, the data subjects have the right to receive the personal data concerning him or her, which he or she has provided to the controller and have the right to transmit those data to another controller.
Right to object
Where the personal data is processed on the basis of legitimate interest of the controller, the data subjects have the right to object at any time to processing of personal data concerning him or her for such purpose.
Right to lodge a complaint with a supervisory authority
The data subjects have a right to lodge a complaint with a supervisory authority (e.g. Finnish Data Protection Ombudsman) if the data subject considers that the processing of personal data breaches the data subject’s rights pursuant to GDPR.