Email conversation register

Privacy policy
Last updated


Oy Duell Bike-Center Ab (2464132-0)
Kauppatie 19
65610 Mustasaari

Contact person in matters concerning the register

Sami Ilvonen sami.ilvonen (at)

Legal basis for processing

Legitimate interest

Purpose of personal data processing

The purpose of the register is to enable the controller organisation to communicate by e-mail. The information obtained (e-mail address and any contact details or other personal data contained in the messages themselves and their attachments) is used to establish and maintain customer relations and for other communication needs of the controller.

Basis of legitimate interest

Direct marketing is a legitimate interest of the controller under the EU General Data Protection Regulation. The controller needs to process personal data in order to carry out its business tasks. The processing of personal data in this context cannot necessarily be justified by a legal obligation or a contract with an individual. In the balancing test, the controller has identified legitimate interest as the most appropriate ground for processing in view of the nature and scope of the processing and the exercise of the rights and freedoms of data subjects. The controller has assessed that the legitimate interest will not cause serious harm to the rights and freedoms of the individuals concerned (data subjects). Translated with (free version)

The personal data groups in question

Electronic contact details.

Recipients and recipient groups

The controller's staff and outsourcing partners, where applicable (financial management, IT management, etc.) and communication partners.

Data content of the register

The personal register contains the following information: - First name and surname of the person - First name and surname - E-mail address - Mailing address - Telephone number - Details of previous subscriptions - Conversation information between communicators - Other personal data contained in any attachments

Regular sources of information

This information is obtained from the emails received from the customer. Information may be obtained from other stakeholders, e.g. through mass media, newsgroups, referrals, etc. The information will not be disclosed outside the organisation holding the register or to its partners, except for matters related to credit application, collection or billing and where required by law. The personal data of the data subject will be deleted at the request of the user, unless the deletion of the data is prevented by law, the manageability of the customer relationship, outstanding invoices or collection operations.

Personal data retention period

The data will be kept for 10 years.

Regular transfers of information

Mailing list data are used solely by the company, except when an external service provider is used either to provide added value services or to support credit-related decision-making. Data will not be disclosed to external parties or to the company’s partners except for purposes related to credit applications, debt collection or invoicing as well as in situations required by law. A data subject’s personal data will be removed upon the data subject’s request unless such removal is prohibited by legislation, matters related to the management of the customer relationship, outstanding invoices, or debt collection.

Data transfer outside the EU or EEA

The data in the register will be transferred outside the EU or EEA to the UK. It is also possible that service providers outside the EU/EEA are used for processing or that the clouds of service providers are located outside the EU/EEA, in which case SCC standard clauses are used as the basis for data transfer and additional safeguards are implemented for data transfers, such as internal guidelines (on pseudonymisation of personal data and the like) and possibly TIA analysis where appropriate.

Principles of register protection A: Manual material

Manually processed documents containing customer data (e.g. printed emails or their attachments) are, after initial processing, stored in a locked and fireproof space. Only specific employees who have signed confidentiality agreements have the right to process manually stored customer data.

Principles of register protection B: Electronic material

Only specific employees working for or on behalf of the company have the right to use the mailing list and maintain its data. Each specific user has his or her personal
username and password. Each user has signed a confidentiality agreement.
The system is protected by a firewall to prevent external
attacks on the system. System security is ascertained with regular S.T.A. audits.


We use cookies on our website. A cookie is a small text file that is sent to and stored on the user’s computer. Cookies do not cause any harm to the user’s computer of files. The primary purpose for the use of cookies is to improve and personalise a visitor’s user experience on our website as well as to analyse and improve the functionality and content of our site. Data collected with cookies can also be used in targeted communication and marketing as well as optimising marketing activities. Visitors cannot be identified based solely on cookies. However, data collected with cookies can be linked with possible data received from the user in other situations, for example when the user fills in a form on our website. The following types of data are collected using cookies: - visitor’s IP-address - time of visit - browsed pages and time of browsing - visitor’s browser - other? Your rights A user visiting our website has the right to prohibit the use of cookies at any time by changing his or her browser settings. Most browser software give the option of disabling cookies and of removing cookies that have already been saved. Disabling cookies may affect the functionality of the website.

Automatic processing and profiling

The data will not be processed automatically.

Inspection right, i.e. the right to get access to personal data.

The data subject has the right to check what information about him or her is in the register. The request for inspection must be made in writing or by means of a verifiable e-mail address. Data subjects have the right to object to the processing and disclosure of their data for the purposes of direct marketing, distance and direct selling, market research and opinion polling by contacting the controller's customer service desk.

The right to transfer data from one system to another

Where a legitimate interest is used as a ground for processing, the data subject does not have the right to transfer his or her data from one system to another.

The right to demand correction of information

Taking into account the purposes of processing, any data stored in the filing system that is inaccurate, unnecessary, incomplete, or outdated must be erased or rectified. A written request for rectification, signed by hand, should be sent to the company’s customer service or the personal data filing system’s administrator. The request should specify what information should be rectified and on what grounds. Rectification shall be carried out without delay. Notification of rectification will be sent to the party who provided the inaccurate data or to whom the data were disclosed. If a request for rectification is denied, the responsible person of the filing system will provide a written document stating the grounds for the denial of the request for rectification. The data subject concerned may then pass the matter along to the Data Protection Ombudsman.

Right of limitation

The data subject has the right to request restriction of processing, for example if the personal data in the register are inaccurate. Contact the person responsible for the register.

Right to object

The data subject has the right to request personal data concerning him or her and the right to request the rectification or erasure of personal data. Such requests may be addressed to the contact person of the register. If you are the contact person of a company or organisation, your data cannot be deleted during this period.

The right to file a complaint with the supervisory authority

If you consider that an infringement of the General Data Protection Regulation has occurred in the processing of your personal data, you have the right to lodge a complaint with a supervisory authority. The complaint can also be lodged in a member state where you are a permanent resident or where you are employed. Contact information for the Finnish national supervisory authority: Office of the Data Protection Ombudsman PL 800, Lintulahdenkuja 4, 00530 Helsinki tel. +358 29 566 6700

Other rights related to the processing of personal data

Data subjects have the right to object to the disclosure and processing of their data for direct marketing and other marketing purposes, to request that their data be made anonymous where applicable, and to be completely forgotten.