Register and Privacy Statement, Freia Ltd

This is the Register and Privacy Statement of Freia Ltd in accordance with the Personal Data Act (Sections 10 and 24) and the EU’s General Data Protection Regulation (GDPR). This document has been formulated 1.8.2020.

1. Registrar and data processor

Freia Ltd (business ID 3147573-8), visiting address Askonkatu 9F, 15100 Lahti (hereinafter Freia or registrar)

2. Contact person responsible for the register

Antti Äikäs, antti.aikas@freialife.com, +358 50 369 0908

3. Legal basis

The legal basis for the processing and storage of personal data under the EU’s General Data Protection Regulation is the consent between the registrar and the person, which is documented, voluntary, and individualized.

4. Name of the register and purpose of the processing of personal data

The name of the register is Customer register of Freia Ltd

Under the applicable legislation on data protection and information services, the customer or a person participating in Freia’s services agrees to the storage of personal and other information provided in the customer register of Freia Ltd. The register means a temporary customer data register, the purpose of which is the processing of personal data to communicate with customers, maintaining a customer relationship and/or implementing Freia’s research, mapping and coaching services. The registrar commits to keep personal data confidential and treats the data confidentially.

5. Information content of the register

The information stored in the register at the customer relationship level are: person’s name, position, company/organization, contact information (phone number, e-mail address, address), website addresses, IDs/profiles in social media services, information about subscribed services and their changes, billing information, other customer relationship and subscribed services related information.

The information stored in the register at the level of research, mapping and coaching services are: person’s name, position, company/organization, contact information (phone number, e-mail address, address), educational background, information on participation in Freia’s services, demographic information (e.g. age, gender, staff group, job description), biometric data (e.g. blood pressure, aerobic fitness, muscle fitness variables, body mass index) and questionnaire variables (e.g. personal assessments of health, well-being at work, working ability and organizational status).

6. Regular sources of information

The information stored in the register is obtained from the customer via e.g. messages sent via web forms, e-mail, telephone, social media services, contracts, customer meetings, surveys, personnel surveys, and other situations in which the customer discloses their information.

7. Regular transfers of data and transfers of data outside the EU or the EEA

The information is not regularly disclosed to other parties. Data may only be published or transferred within the EU to the extent agreed with the customer.

Occasional transfers of personal data may be directed to occupational health care, private health care, public health care, or another research and occupational well-being partner. For this, the person will be asked for separate permission for the data transfer, in the same context where the customer register data is collected.

8. Registry protection principles

The register shall be handled with due care and the information processed by the information systems shall be adequately protected. When registry information is stored on Internet servers, the physical and digital security of their hardware is adequately addressed. The registrar shall ensure that the data stored, as well as the access rights to the servers and other information critical to the security of personal data, are treated confidentially and only by the employees whose job description it includes.

9. Right of inspection and right to request correction of information

Every person in the register has the right to check their information stored in the register and to request the correction of any incorrect information or the completion of incomplete information. If a person wishes to check or request the correction of data stored about him or her, the request must be sent in writing to the registrar. If necessary, the controller may ask the applicant to prove his or her identity. The registrar will respond to the customer within the one-month time limit set by the EU’s General Data Protection Regulation.

10. Other rights related to the processing of personal data

A person in the register has the right to request the removal of his or her personal data from the register (“the right to be forgotten”). Data subjects also have other rights under the EU’s General Data Protection Regulation, such as restrictions on the processing of personal data in certain situations. Requests must be sent in writing to the registrar. If necessary, the registrar may ask the applicant to prove his or her identity. The registrar will respond to the customer within the one-month time limit set by the EU’s General Data Protection Regulation.