Updated 02 January 2024

The purpose of this Privacy Notice (“Privacy Notice“) is to inform Users on how and why Havator Oy collects and uses their personal data to manage the customer relationship, promote Havator products and services, and provide the website www.havator.com (“Website”). Users may include representatives of Havator Oy client companies, representatives of potential client companies, or people visiting the Website (“User”).

1. Controller

Havator Oy (“Havator”) acts as the controller under data protection legislation. Havator is responsible for personal data being processed in accordance with this Privacy Notice and valid data protection legislation.

The primary contact person in data protection issues is:

Lari Niemi

2. Legal basis and purpose of personal data processing

Havator processes the personal data of Users for several purposes described below.

2.1 Customer relationship

Havator processes personal data for the purposes of managing and maintaining customer relationships and processing customer communications and contacts. The supply of Havator products and services and the management and delivery of orders require us to process personal data. In this respect, the processing of personal data is primarily based on a contract between the client company and Havator, also including the implementation of measures preceding the contract and the related processing of personal data.

2.2 Marketing and the Website

The personal data of Users may be processed for marketing purposes and in order to provide the Website. The personal data of Users may be collected and processed when the User contacts the customer service, subscribes to a newsletter, takes part in competitions or otherwise shows interest in Havator’s operations at fairs or events, for example. The personal data of Users may be used for sending electronic marketing communications. In this respect, the processing of personal data is based on Havator’s legitimate interest in promoting Havator products and services and providing the Users with essential information about the services and products as a part of the Website.

2.3 Product and service development

Havator’s objective is to provide high-quality products and services. Therefore, Havator may use the personal data of Users to analyze the market, user groups, the Website, products and services in order to develop the quality of products and services and improve the customer experience. This processing of personal data is based on Havator’s legitimate interest in developing its business operations and providing improved products and services.

Havator uses cookies and other similar technologies for statistical purposes, to provide Website functionality, develop its quality and improve the user experience. Read more about cookies here.

2.4 Data security

Havator may process personal data to ensure the data security of the Website and information systems. Havator maintains data security measures to secure business-related data, including personal data, to ensure the availability of business-related services and to prevent and detect criminal activity. The implementation of data security measures requires limited processing of the Users’ personal data. In this respect, the processing of personal data is based on Havator’s legitimate interest in securing the information systems and data essential to the business, including the personal data of Users.

2.5 Processing of personal data within the Group

The personal data of Users may be processed within the Havator Group by another group company. Here, the processing of personal data is based on Havator’s legitimate interest in organizing and managing customer relationships, marketing and data security measures in an appropriate and practical manner within the Group.

3. Collected personal data

3.1 Customer relationship

Havator may process the personal data of Users in order to manage the customer relationship. Havator regularly receives the personal data it processes from the Users themselves in connection with an order and/or delivery, including the following personal data

• User’s name, position/title, and contact details;
• client company data, such as client company name, Business ID, and customer number;
• data related to the contractual relationship with the client, such as information about an order, starting and expiry date, and invoicing data; and
• customer communication and other contacts related to the order and delivery.

3.2 Marketing

Havator may process the personal data of potential clients and their representatives for marketing purposes when the User contacts the customer service, subscribes to a newsletter or takes part in competitions at fairs or other events. Havator receives the personal data it processes regularly from the Users themselves. Havator may collect the following personal data

• User’s name, position/title, and contact details;
• client company data, such as client company name and line of business;
• purpose of contact and related data; and
• the newsletters the User has subscribed to and/or events they have taken part in.

3.3 Use of the Website

In the context of using the Website, Havator may automatically process technical data when the User moves around the Website, including among other things the following personal data

• IP address, device ID, device model, operating system and settings; and
• timestamps and log information related to the use of the Website

Havator may also collect data about visits, number of visits and moving around the Website using cookies and similar technologies for statistical purposes to compile anonymous statistics that help us understand how the Users use the Website and to make it more user-friendly. Read more about cookies here.

3.4 Other sources

At times, Havator may collect personal data of Users from other sources, such as publicly available sources and third parties including marketing companies or social media.

4. Disclosure of data

Havator may disclose the personal data of Users to third parties in the following situations:

• to other Havator Group companies for the above-mentioned purposes;
• to trusted service providers working on behalf of Havator and who have no independent right to use the personal data disclosed by Havator. For example, Havator may use IT providers for information system maintenance, marketing companies for promotional purposes, or collection agencies for pursuing payments;
• when required under legislation, for example in reply to appeals or in connection with legal proceedings;
• if Havator is involved in a merger or asset deal;
• when we sincerely believe that the disclosure of data is necessary for securing our rights, securing you and others, investigating crimes, or responding to requests from authorities.

5. International data transfers

Havator or its Group companies or service providers may process personal data outside the EEA. In this case, we use appropriate and established protection mechanisms, such as standard clauses approved by the European Commission, that make it possible to transfer personal data to service providers in third countries. Our service providers located in the United States are committed to the Privacy Shield framework between the EU and the United States. Further information about the Privacy Shield framework developed by the U.S. Department of Commerce and the European Commission and related principles on personal data processing is available here.

6. Storage of data

Havator will store the personal data of Users only as long as necessary for the implementation of purposes defined in this Privacy Policy, and thereafter the personal data will be destroyed unless legislation or contractual rights or obligations require us to store the personal data for longer.

Main storage periods are as follows:

• Personal data related to a customer relationship are stored for the duration of the customer relationship and thereafter for as long as the contractual rights and responsibilities, such as invoicing purposes, require, or for as long as legislation, such as the Accounting Act, require.
• Personal data collected for marketing purposes are removed after two years of the last contact of parties, unless contractual rights and responsibilities or legislation require the storage of personal data. The User’s rights in the context of marketing are described in Section 7 of this Privacy Notice.

7. Rights

The User shall have the right of access to personal data concerning him or her, the right to correct and update personal data, and the right to request the restriction of processing under applicable data protection legislation. Furthermore, the User may request the erasure of their personal data. Please note that the erasure of all personal data may not necessarily be possible during the contractual relationship due to obligations arising from legislation or the contractual relationship.

The User has the right to object to processing based on a legitimate interest. The User has the right to deny the use of their personal data for direct marketing purposes.

The User shall have the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and to transmit those data to another controller under and in accordance with applicable data protection legislation. This right applies to personal data provided by the User collected based on the User’s consent or the contractual customer relationship. The right to transmit does not apply to personal data processed based on a legal obligation.

The above-mentioned requests may be sent by email to: tietosuoja@havator.com.

The User has the right to lodge a complaint with the national data protection supervisory authority if they consider that the processing of personal data is in breach of data protection legislation. In Finland, this complaint is lodged with the Office of the Data Protection Ombudsman: www.tietosuoja.fi

8. Protection of data

Havator implements the appropriate technical and organizational data protection measures to protect personal data against loss, destruction, abuse or unauthorized access. Havator restricts access to personal data to employees and contractors that need the data in question for their work and to service providers who may only process the data in accordance with Havator’s instructions. People with access to personal data are bound by secrecy.

9. Changes

We reserve the right to amend and update the Privacy Notice. If we make changes to this Privacy Notice, we will inform you about it on the Website which will also provide you with the latest version of the Privacy Notice.

10. Contact information

In questions regarding the Privacy Notice or personal data of Users stored by Havator, please contact Havator’s contact person by email at lari.niemi@havator.com.