Privacy

PRIVACY POLICY – CLIENTS AND SUPPLIERS

Controller

Name: Dottir Attorneys Ltd (“Dottir” or “we”)
Company ID: 2733840-7

Correspondence address:
Pohjoisesplanadi 35 Aa,
00100 Helsinki, Finland

E-mail address: hello@dottirlaw.com
www.dottirlaw.com

Contact person:
Attorney, Managing Partner Daniel Stranius
daniel.stranius@dottirlaw.com
+358 44 333 0535

General information regarding our processing activities

This Privacy Policy is applicable to Dottir’s database of Dottir's clients and suppliers as well as our marketing database.

We mainly process personal data subject to this Privacy Policy when offering or promoting our legal services to our existing and potential clients or when maintaining the customer relationships with our clients as well as other business relationships with our suppliers and other relevant interest groups.

All of our processing activities are conducted in accordance with the General Data Protection Regulation (2016/679) ("GDPR") and other applicable national data protection laws.

This Privacy Policy describes how we process personal data concerning the representatives and owners of our clients, potential clients, suppliers and other business partners. The word “you” refers to all the aforementioned individuals whose personal data is processed in accordance with this Privacy Policy.

We may update this Privacy Policy if it is necessary in order to reflect the changes in data processing practices or otherwise.

Please note that this Privacy Policy applies to processing of personal data carried out by Dottir as data controller.

Personal data processed and sources of data

We may process the following personal data relating to you:

Typically we receive the personal data directly from you, from other representatives of your employer or from your employer’s counterparts, in the course of an engagement with your employer.

In addition, personal data may be collected and updated from public sources, such as public search engines, other public websites and social media as well as public registers (e.g. information relating to your contact details).

Some of the personal data may also be generated by us. This information includes correspondence between you and our representatives as well as information relating to meetings between you and our representatives.

Purposes and legitimate grounds for processing of personal data

Personal data is processed by us for the following purposes:

To provide our services and to run our business and carry out our contractual obligations:

We process personal data in the first place to be able to offer our legal services to our customers and to run, maintain, promote and develop our business. Personal data may be processed in order to carry out our contractual obligations towards you, if you are a private indivual.

For our legal obligations:

We may process your personal data to enable us to administer and fulfil our obligations under the law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities. The customer's representatives' and beneficial owners' identification information and other KYC data may be used for the prevention, detection, and investigation of money laundering and terrorist financing, as well as for the investigation and prosecution of the crime from which the assets or proceeds involved in money laundering or terrorist financing have been obtained (Act on Preventing Money Laundering and Terrorist Financing, Section 3:3.4).

For claims handling and legal processes:

We may process your personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud and money laundering, misuse of our services and for data, system and network security.

For communication and marketing:

Personal data may be processed in order to correspond with you via email and other communication channels. We may also process your personal data for the purpose of marketing our services to you e.g. by sending newsletters and event invites.

Legitimate grounds for processing

We process your personal data mainly to pursue our legitimate interest to maintain and develop customer and business relationships and to run and develop our business. In some cases we process personal data to comply with our contractual obligations towards you. Furthermore, we process personal data to comply with legal obligations, such as know-your-customer and anti-money laundering procedures and other procedures based on applicable law or set out by the Finnish Bar Association.

When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.

You may be requested to grant your consent for the processing of personal data. When the processing of personal data is based on a consent, you may withdraw your consent at any time.

Transfer to countries outside Europe

We store your personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or your domicile.

If we transfer your personal data outside the European Economic Area or to a country that does not provide adequate protection of personal data according to the European Commission, we will provide adequate protection for such transfers through a series of agreements with our service providers and technical and organisational means.

Personal data recipients

We do not share personal data with third parties outside of our organization unless one of the following circumstances applies:

For legal reasons and legal processes:

We may share personal data with third parties outside Dottir’s organization if access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; or (ii) detect, prevent, or otherwise address crime or security issues.

To authorized service providers:

We may share personal data to authorized service providers who perform services for us (including data storage, legal, accounting, sales and marketing services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Statement.

For other legitimate reasons:

If Dottir is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give you notice when the personal data are transferred or become subject to a different Privacy Statement as soon as reasonably possible provided that the transfer concerns your personal data.

With explicit consent:

We may share personal data with third parties outside Dottir’s organization for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

Storage period

We do not store personal data longer than is legally permitted and necessary for the purposes set out in this Privacy Policy. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.

When the storage of personal data is no longer necessary for the purpose for which it was initially collected, we may continue storing the data only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting, reconciliation purposes and direct marketing.

The customer's representatives' and beneficial owners' identification information and other KYC data must be stored for a period of five years from the expiry or termination of the relevant client relationship with us.

Your rights

You have the right to access your personal data processed by us and to request a copy of your personal data undergoing processing. In case the processing is based on a consent, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed. You may also ask us to erase the your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

You may object to the processing of personal data on grounds relating to your particular situation if such data are processed for our legitimate interest. You also have the right to prohibit us from using your personal data for direct marketing purposes. You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data.

In case the processing is based on a consent or agreement, you have the right to receive your personal data that you have provided us with in a structured and commonly used format.

The above mentioned rights may be used by contacting us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

Lodging a complaint

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman www.tietosuoja.fi

PRIVACY POLICY – APPLICANTS

About this policy

Dottir Attorneys Ltd. (“Dottir”) respects your privacy and is committed to processing, maintaining, and using your personal data responsibly. This privacy policy applies to personal data that you provide to us directly during the job application process or when you submit an open application to us, as well as other information we receive from you or third parties, such as recruitment service providers in connection with recruitment process.

Please note that this Privacy Policy only applies to the processing of personal data carried out by Dottir as a data controller and only in the context of recruitment.

This Privacy Policy may be updated from time to time. We will not make substantial changes without prior notice.

Contact details of data controller

Name: Dottir Attorneys Ltd

Business ID: 2733840-7

Correspondence address: Pohjoisesplanadi 35 Aa, FI-00100 Helsinki

Contact: pihla.knaapila@dottirlaw.com

The purpose and legal grounds of the processing

The processing of personal data is based on the legitimate interest of Dottir to process personal data as necessary for the recruitment process. In certain situations, the processing of personal data is also necessary for the performance of pre-contractual measures between Dottir and the job applicant and for the implementation of the employment contract.

In addition, Dottir may, where required by national law, request the job applicant's consent to the collection of certain types of personal data or to the processing of certain types of personal data. For example, consent may be requested if an aptitude assessment is carried out as part of the recruitment process.

Personal data is processed for the purposes of receiving and handling job applications, assessing and selecting job applicants and meeting the needs of the recruitment process. If a job applicant does not wish to disclose their data to Dottir, they may not be considered in the recruitment process.

Personal data processed

Dottir processes personal and contact data of job applicants, and other data necessary to assess the suitability of the job applicant for the position applied for. The processed data varies from case to case and may include, for example:

We only collect information that is relevant for filling in the position in question.

Sources of personal data

As a rule, Dottir receives data from job applicants themselves through job applications and job interviews. With the applicant’s consent, personal data can also be collected from third parties, such as the service provider carrying out the recruitment process or aptitude assessment.

During a recruitment process we may, with your consent, contact a referee you have provided us with, such as your former employer. In such case we may get some information about you from such referee.

Regular disclosures of data and categories of recipients

As a rule, Dottir does not disclose any data to third parties. However, Dottir uses service providers to process personal data on our behalf. Dottir will ensure through contracts that these parties do not process personal data in a way that is not in accordance with Dottir's instructions and this Privacy Policy.

International data transfers

Personal data may be transferred outside the European Union or the European Economic Area in accordance with data protection legislation and within the limits set by it. We have ensured an adequate level of data protection, in accordance with the conditions of the EU General Data Protection Regulation, including in situations where data is transferred outside the EU or the EEA in accordance with the adequacy decisions set by the European Commission and using, where appropriate, standard contractual clauses adopted by the European Commission and, where appropriate, supplementary safeguards.

Storage period of personal data

Dottir processes job applicants’ personal data during the recruitment process. After the recruitment process has been completed, personal data will be stored for as long as necessary for implementing the rights and obligations of Dottir and responding to potential claims, however, no more than one year after the recruitment decision has been made. The one-year storage period may be waived if the claims lead to litigation. Open applications are stored, with the consent of the job applicant, for up to one year for potential recruitment.

Your rights

Right to access

You have the right to access your personal data processed by us and to request a copy of your personal data undergoing processing.

Right to withdraw consent

In case the processing is based on a consent granted by you, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to correct

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.

Right to deletion

You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. Please note that during the term of employment personal data is processed primarily due to legal obligations and therefore we may not be able to delete it.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data.

Right to object

You may object to the processing of personal data on grounds relating to your particular situation if such data are processed for our legitimate interest. In case we do not have compelling legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.

Right to data portability

You have the right to receive some of the personal data you have provided us with in a structured and commonly used format.

How to use your rights

If you want to use your rights, please contact us via letter or e-mail.

We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.

Lodging a complaint

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, you have a right lodge a complaint with the local supervisory authority for data protection.

In Finland, the competent authority is the Data Protection Ombudsman (www.tietosuoja.fi).