Tenant’s data processing
In this privacy notice, we describe or provide our contact details, the categories of data subjects and personal data (hereafter referred to as “data”), sources of the data, the purposes and legal basis of the processing, storage periods of the data, disclosure of the data, data protection measures, rights of the data subject, etc.
NAME OF FILING SYSTEM
Asuntosalkku Suomi tenant data base
Asuntosalkku Suomi Oy
Business ID 2939840-3
Ilmalankuja 2 L
Person in charge of processing activities:
phone 040 1810 325
PURPOSES AND LEGAL BASIS OF THE PROCESSING
Contractual relationship: the data subject is or has been a party to a contract with the controller, or the processing precedes the parties entering into a contract. The data subject can be a tenant, guarantor, resident, a representative of aforementioned, or other equivalent person. The processing is necessary for the performance of this contract. The purposes of the processing are management, maintenance, development and marketing in the customer relationship.
Consent: the data subject has applied to become a tenant or resident of an apartment owned by the controller and thus has given his/her consent to the controller for the processing of his/her data to process the application and perform a contract. When the processing concerns special categories of personal data, the data subject has given explicit consent to the processing of special categories of personal data.
Legitimate interests of the controller: the data is also processed to make or defend against legal claims or lawsuits and for internal purposes of the controller and its fund manager, including but not limited to development of business processes. These purposes are essential to our business, justified based on the relationship between the controller and the data subject and thus in the controller’s legitimate interest. The data subject can object to this processing in ways described below.
CATEGORIES OF PERSONAL DATA
The following categories of personal data are processed regarding all aforementioned data subjects:
- Basic information of the data subject, such as name and address
- Contact information of the data subject, such as phone number, email address and possible contact person or representative
- Permissions and limitations such as direct marketing permissions or opt outs
- Other information provided by the data subject
- Event information
- Personal identity code for purposes of reliable identification
In addition the following categories of personal data are processed regarding data subjects that are tenants or guarantors:
- Billing and debt collection information, the tenant’s rent payment details including the name of the payer, account information
- Details of a paid collateral including the name of the payer
- Information concerning the customer and contractual relationship, including but not limited to goods and services bought, their usage dates, service representative for the goods and services, language of contract, commencement, termination and details about the object of contract.
In addition the following categories of personal data are processed based on consent regarding data subjects that are applicants to become tenants:
- Work information such as job title, employer, time of commencement of employment, permanent or fixed-term contract and contact information of employer
- Study information such as institution and degree programme, if the applicant is a student
- Information about income related to paying the rent
- Name of spouse who applies together with the applicant, where applicable
- Information about the applicant’s needs related to housing
- Information concerning upkeep of the apartment such as smoking and pets
- Credit information and payment default entries
- Other information provided by the data subject
In addition to the aforementioned we process other information voluntarily provided by the data subject in communication with the controller or by other equivalent means.
REGULAR SOURCES OF THE DATA
The data are collected from the contract between the data subject and the controller, the application of the data subject, during use of the services provided, from payments to the controller, or by other means directly from the data subject. When consented to, data is also collected from the credit information register of Suomen Asiakastieto Oy. Data can also be collected from or updated based on the Finnish Population Information System per the law about the Population Information System and the Population Register Centre’s certificate service, from the opt out register of Suomen Suoramarkkinointiliitto and other equivalent registers.
FAILURE TO PROVIDE DATA
The provision of data is a necessary requirement for entering into a rental agreement. Data that does not apply to the data subject can be left unprovided without consequences to entering into a rental agreement. For example, a data subject that doesn’t have an email address doesn’t need to provide an email address.
Failure to provide data in a rental application or withdrawing consent for the processing of a rental application before the signing of a rental agreement will result in the non-formation of a rental agreement.
PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA
We process special categories of or sensitive personal data to manage the rental relationship when the data subject or his/her legal representative provides us with said data and requests the processing. This can include, but is not limited to, a request from a tenant to consider their health in a matter related to the rental relationship, a notification from a tenant that their spouse is moving in to the same apartment, or another issue related to the management of a rental relationship.
DATA DISCLOSURES AND TRANSFERS
- The manager of the alternative investment fund: the data subject’s information is processed by Asuntosalkku toimilupa Oy, which is the alternative investment fund manager of the controller, in conjunction with data of other funds managed by the same manager.
- Enterprise group: the data subject’s data is processed by the controller’s enterprise group. The group head is Asuntosalkku Oy.
- Government agencies: data can be disclosed to government agencies or other parties as required by law, statue or equivalent.
- Corporate actions: if the controller is part of a corporate action such as divestment, merger, or equivalent, data can be disclosed to other parties in the corporate action and their advisors.
- Debt collection, legal claims and claim resolution: data can be disclosed to third parties when this is necessary for the performance of a contract, investigating a possible breach and to make or defend against legal claims or lawsuits. Data can also be disclosed to other arbitration or resolution bodies, including but not limited to The Consumer Disputes Board or consumer advisory services. Data can be disclosed to a debt collector, if a third party performs debt collection on behalf of or in place of the controller.
- Apartment maintenance: data can be disclosed to third parties, when this is appropriate for apartment maintenance or repair. Typical third parties that are data recipients include a housing company, its manager, its maintenance provider, a renovation partner, a damage inspector and other equivalent parties.
- Billing management and bookkeeping: data can be disclosed to third parties for billing management and bookkeeping, if the controller uses a third party for these services.
- Apartment renting: data can be disclosed to third parties for the purposes of renting or selling the apartment. Third parties that are data recipients include real estate agencies and realtors.
The information system used by the controller is shared between the controller, its manager and other funds managed by the same manager. In these companies and our IT-service provider including the provider’s company group personnel have access to the data subject’s personal data as it is necessary for the duties of the personnel. We use contracts to ensure that our service providers process the data subject’s personal data in accordance with the law and this privacy notice.
Data is not transferred outside the European union or European Economic Area.
STORAGE PERIOD OF THE DATA
We store the data for three calendar years after the conclusion of the rental agreement. However we store data from denied tenant applications including possible appendixes for only one calendar year. However, our realtor partner(s) always store the rental agreement, rent debt and rent prepayment data and end of rental agreement information for at least the legally required five years.
We can store data concerning an open case, such as a lawsuit or claim, for a longer period if this is appropriate for the management of the case. This storage contains personal data.
The data subject can influence the storage period in ways described below under the heading “rights of the data subject”.
Manual files are stored in locked and guarded premises. Access to this data is restricted to specific personnel.
Electronic files are stored in an environment, the use of which requires a personal user identification and permission provided by an administrator or main user. The administrator or main user also defines the access level. The electronic environment requires a personal password to use. Use is monitored with logs.
Electronic storages are protected with firewalls, passwords and other technical means. Servers, back-up disks and other electronic storage mediums are located in locked and guarded premises, and access is restricted to specific personnel.
RIGHTS OF THE DATA SUBJECT
Access, rectification, portability and erasure: The data subject has the right to access data concerning him/her. Upon the data subjects request we rectify errors in the data, supplement incomplete data and erase data that is inaccurate, incomplete or outdated for its purpose. The data subject has the right to receive his/her personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, when we process the data automatically and based on a contract or consent. The data subject can use this right by contacting our customer service. Contact details can be found below.
Right to object: The data subject can at any time object to the processing of his/her personal data for the use of direct marketing. The data subject can object on grounds related to their particular situation to processing that is based on the legitimate interest of the controller or a third party. The data subject can use this right by contacting our customer service. Contact details can be found below.
Right to restriction of processing: The data subject can demand the restriction of processing under specific circumstances including, but not limited to, when the data subject denies the accuracy of the data. Processing is restricted while the accuracy is verified or corrected.
Right to withdraw consent: The data subject can withdraw his/her consent at any time. The data subject can use this right by contacting our customer service. Contact details can be found below.
Right to lodge a complaint: The data subject has the right to lodge a complaint with a supervisory authority, if he/she believes that his/her data has been processed in a manner that is contrary to the law or this privacy notice. The contact details of the supervisory authority can be found at www.tietosuoja.fi. If the data subject has a permanent residence or place of work in another EU member state, he/she can also lodge a complaint with the supervisory authority in that country.
CONTACT DETAILS FOR CUSTOMER SERVICE
We request that data subjects contact our customer service for more information if they wish to exercise their rights. Customer service can be contacted by email, phone or mail. A written and signed request or demand must be submitted by email or mail. The contact details are
Asuntosalkku Suomi Oy
Ilmalankuja 2 L
UPDATING THIS PRIVACY NOTICE
The controller updates this privacy notice as needed to keep it up to date.