Privacy policy
PRIVACY POLICY
1. General
This privacy policy (“Privacy Policy”) describes how personal data is processed and protected at Properta Attorneys Ltd (“Properta”) in accordance with the applicable legislation and good data processing practices.
Properta processes personal data when we are contacted regarding an assignment, when preparing and making clearances for potential assignments, when a person takes part in our events, marketing campaigns or survey polls, or when we receive contact information through a company, organization, interest group or any other cooperation. We also have obligations regarding the processing of personal data as attorneys which are based on laws, regulations, regulatory provisions or the instructions of the Finnish Bar Association.
Personal data is also processed in carrying out and developing Properta’s services, like in marketing, in client communications, and customer service.
2. Data file controller and contact information
Properta Attorneys Ltd
Bulevardi 6 C 22, FI-00120 Helsinki, Finland
Business ID: 2798639-1
tel.: +358 10 274 0190
email: mail@properta.fi
3. Personal data that Properta processes
Properta processes personal data when necessary for the purposes described below. The purpose of use determines what type of data Properta collects and processes. Additionally, the data that Properta processes may vary depending on which services are utilized and the manner in which they are utilized. Thus, an individual may also influence the way their personal data is processed.
The data may consist, among others, of the following:
Name, represented entity and contact details, such as given name and surname, address, phone number, email, and organisation/company/authority and title.
Information required for the prevention of money laundering and terrorist financing, such as nationality, ownership interest, information on exercising independent control, political exposure, relationship to a politically exposed person, and name, number, or other identifying details of the identity verification document.
Other demographic information, such as a social security/identification number of a private individual.
Client/co-operation relationship information, such as any information on assignments, invoicing and payment information, client feedback, communication and cancellation information, as well as other information concerning communication and cooperation.
Interest and profiling information, such as information received from the person themself about their professional interests.
Marketing bans.
Visual recordings, such as photos taken at events organised by Properta.
Job applications and other information received along with recruitment processes including LinkedIn-information, educational background, special expertise and language proficiency, current and previous positions, employers, job titles and job descriptions, referees, interview recordings, and other information provided by the job applicant, including copies of certificates.
Other information collected based on consent.
Properta may also process the following data: name, title/profession, age/date of birth, contact details and other similar identifiers, such as object of interest after the termination of an assignment or data received through a company, an organization, interest group or any other cooperation.
4. Sources of information
Personal data is provided to us by or on behalf of our clients or from a third party related to an assignment when Properta is preparing for or handling an assignment of legal services. Data is collected, among others, during preparations and clearances for assignments and during discharging an assignment while preparing or providing legal services, signing up for and attending to our events, from feedback or contacts, or later during customer-relationship or cooperation.
Personal data may also be collected and updated from our partners’ registers, companies’ online services and applications, as well as from authorities and companies offering services related to personal data.
5. The purposes and legal basis for processing personal data
Properta processes its clients’ personal data to prepare for, manage, develop and administer client accounts. Properta processes personal data to prepare for and execute the contractual relationship with the client, e.g. for the handling of assignments and for customer service purposes. In addition, personal data is processed for purposes related to communication within stakeholder and cooperation relationships.
In addition, Properta processes personal data based on a legitimate interest for marketing and developing our services, such as in connection with preparations for new clients or opinion surveys.
Properta may also process personal data based on consent when necessary and when there is a legal obligation to process personal data, such as for the prevention, investigation and detection of money laundering and terrorist financing.
The personal data of job applicants are processed in connection with the recruitment process, including the processing of job applications, the assessment of applicants’ suitability for the positions applied for, measures preceding the conclusion of a possible employment contract, and the performance of the employment contract.
6. Regular data disclosures and transfers
Properta may disclose and transfer personal data only when it is an obligatory requirement under applicable law (e.g. disclosures to the statutory authorities). In addition, in the case of a possible merger and acquisition transaction, Properta may disclose and transfer data to a third party related to the merger and acquisition transaction.
Properta may use subcontractors and service providers for the processing of personal data, as well as, for the technical maintenance of its IT-systems. The data Properta discloses or transfers to such partners is only to be used for purposes determined by Properta. In addition, Properta has ensured that, in accordance with all applicable agreements that are in place, all of its contractual partners are required to implement appropriate measures for the protection of the personal data and otherwise comply with applicable data protection legislation.
Properta stores personal data in the European Economic Area (EEA) or in countries with a level of data protection required by the authorities. If the handling of the assignment requires us to disclose data outside of the EEA, we will only use co-operation partners that process the personal data on the same basis that we do. In that case, we will ensure an adequate level of data protection and other necessary measures (such as contractual mechanisms) that are required by legislation.
7. Retention time policies
Properta stores personal data for as long as it is necessary for the fulfilment of the defined purposes under the applicable legislation, regulations, regulatory provisions, and the Rules of the Finnish Bar Association.
Among others, Properta may store information related to assignments for 10 years after the termination of the assignment. In accordance with the Finnish Bar Association’s Guidelines for the Prevention of Money Laundering and Terrorist Financing, we store information that is necessary to prevent money laundering and terrorist financing for 5 years after the end of the client relationship, unless any other obligation requires us to retain the information longer.
8. The rights of a data subject
The data subject has the statutory rights available to them, which include, for example:
Right of Access to Personal Data
The data subject has the right to request access to personal data concerning them (right of access) to verify whether personal data relating to them are being processed in a personal data register or not. Pursuant to the General Data Protection Regulation, the data subject’s right of access may be restricted or refused where the provision of such information would adversely affect the rights and freedoms of others. Such protected rights include, among others, the controller’s trade secrets or the personal data of another individual. The right of access may also be restricted under national legislation (Data Protection Act).
Right to Rectification and Erasure
The data subject has the right to request that the controller rectify inaccurate or incorrect personal data concerning them without undue delay. At the request of the data subject, the controller shall erase personal data relating to the data subject unless the personal data must be retained where processing is necessary, for example, to comply with a legal obligation applicable to the controller or for the establishment, exercise, or defence of legal claims.
Right to Object to Processing or to Request Restriction of Processing
The data subject has the right to object to the processing of their personal data on grounds relating to their particular, personal situation where the processing is based on the legitimate interests of the controller. The data subject does not have the right to object to the processing of personal data where the processing is based on a contract between the controller and the data subject. Where the data subject objects to the processing on grounds relating to their particular, personal situation, the data subject must specify the particular circumstances on which the objection is based. The controller may continue processing despite the objection if there are compelling and legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject or if the processing is necessary for the establishment, exercise, or defence of legal claims.
At the request of the data subject, the controller shall restrict the active processing of personal data, for example, where the data subject contests the accuracy of the personal data, in which case the processing shall be restricted for a period enabling the controller to verify the accuracy of the data. During the period of restriction, personal data shall, as a rule, only be stored. The data may also be processed for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest. The data subject shall be informed before the restriction of processing is lifted.
The data subject has the right to obtain access to their personal data within one month of submitting a written request. The request for access shall be submitted in writing to Properta using the postal or email address provided above.
The controller shall, without undue delay, rectify or erase personal data contained in the register that are inaccurate, unnecessary, incomplete, or outdated in relation to the purposes of processing, either on its own initiative or at the request of the data subject.
The data subject also has the right to cancel the consent he/she has given, to opt-out from future marketing, and, in certain situations, the right to have his/her data transferred to himself/herself or to a third party. In addition, a data file subject has the right to make a complaint regarding the processing of personal data to the supervising authority, the Data Protection Ombudsman (www.tietosuoja.fi/en/home).
Questions and requests concerning the rights of a data subject shall be sent to Properta’s email address: mail@properta.fi or by mail to the following address: Properta Attorneys Ltd / Privacy Policy, Bulevardi 6 C 22, FI-00120 Helsinki, Finland.
9. Protecting personal data
Properta uses necessary technical and organisational measures to protect personal data from illegal access, disclosure, destroying or any other unjust handling. These measures include, among others, firewalls, cryptography, using safe equipment bay, due access control, controlled granting of usage rights , and controlling the use of such rights, briefing staff that is involved in processing personal data and careful selecting of subcontractors, contracts and instructions.
10. Changing the privacy policy
Properta constantly develops its services and practices concerning data privacy and reserves the right to revise and update this Privacy Policy when necessary. In addition, the changes in legislation and its interpretation may cause a need for changing the policy.
The updated Privacy Policy is available on Properta’s website.