Processing of personal data
We value our customers and their privacy! As a company specialized in telemarketing, when you entrust your personal data to us, we will honor that, and take good care of your data.
Who Are We?
Pro Elinvoima is an auxiliary business name of Suomen Terveysravinto Oy (VAT number FI23421641). Our address is Sarkiantie 409, 38200 Sastamala, Finland.
Contact us: firstname.lastname@example.org
What Do We Do?
We hope to enrich your life with quality products, mostly cosmetics and dietary supplements. In order to do that, we need to contact people to tell them about our products, to keep a database of our customers, and to send products to the customers. All that requires the handling of personal data.
Where Do We Get the Information?
We do not get new phone numbers from people in Estonia. We have agreed with a call center that they call people and tell about our products. The call center acquires the phone numbers by itself, and it has agreed to use only phone numbers that have been acquired legally.
Once you have made a purchase, we will receive your personal data.
What Information Do We Have of You?
When you are called, we actually do not have your information. The information is the property of the call center, and we do not have access to it unless the call center reveals it.
When you have ordered a product from us, we will have your name, phone number, customer number, possibly your age, sex, and email address. After you have been established as our customer, we will have your order history, as well as possible email and call history with you if you have contacted our customer service.
You have the right to contact us and ask to see your information.
If need be, we will have access to the recordings of the marketing calls done to our own customers (for a limited time, see below), as well as to the information when you have been called in the past.
Our call center subcontractor will record all marketing calls in order to be able to settle possible disputes over what had been agreed upon.
How Long Do We Store Your Information?
If our subcontractor calls you, we will not get your information. If you have questions at that point, please contact the call center that called you. But if you have bought the product from the call center, we will have your information. As you have ordered something from us, you are a part of our Customer Program and we will provide you changing benefits during that time. The Customer Program lasts three years from the time of the last purchase. Once that time is reached, we will remove and anonymize your information.
If you want us to remove your information, you have the right to do so; in that situation, please contact us.
How Do We Use Your Information?
When we have received your personal data, we will use it first to deliver the products to you that you have ordered. We will also use your personal data to tell you about other products and generally to keep in touch with you. We will also use the information to make statistics and for general profiling.
There is no automatic profiling that has legal consequences for you.
Why Can We Contact You?
According to the General Data Protection Regulation (GDPR), if we have acquired your personal data legally, we can call you and offer you our products. This is what GDPR calls “legitimate interest”.
When you have ordered from us, we will – with decent time intervals – contact you and offer you products we believe you will like. GDPR calls this right the “legitimate interest.” We will stop contacting you if you tell our customer service that you do not wish future marketing calls.
Why Can We Do the Other Things We Do?
When we send you the products you have bought, we will need to use your personal information. That is done to fulfill the contract.
When we help you via our customer service, we can do it based on the “legitimate interest.” The same is true for compiling statistics, system development, and profiling, as well as marketing to the existing customers.
To Whom Do We Give Your Information?
We want to take good care of your information. We do not give it to outsiders for their own marketing.
We give your information to the subcontractor so that they can send the goods to you. Not surprisingly, they need your name, address, and possibly your phone number. We give your data to our subcontractors who are responsible for calling you.
Your data may be accessible to our technical subcontractors, as we sometimes need their help with the maintenance of our system. We also store your data to programs used for statistical purposes and other programs we use to store and handle the data.
None of the subcontractors we use are allowed to use your data for their own purposes.
Your data is never moved outside ETA countries.
How Do We Protect Your Information?
Your information is in our system only in electronic form. The register has been protected with passwords, and we have implemented necessary procedural and legal actions to protect the data. All the persons processing the data have signed a non-disclosure agreement. Those subcontractors responsible for the system and the calls have taken care of the necessary technical and organizational actions that guarantee the physical and technical protection of the register.
What is the Loyalty Program?
When you order a product, you are awarded a place in our Loyalty Program. You are always eligible to receive products for our Loyalty Program prices and will receive other changing benefits. Everyone in the Loyalty Program is considered as a customer as long as they are in the program. A customer is considered to be part of the Loyalty Program until three years after the last order.
When Will We Remove Your Information?
If you want us to remove your information, we will do that. However, there are some exceptions. First, if you have unpaid bills, we can remove the information only after you have paid them. Secondly, if you have sued us and want us to remove our information about you so that we would not be able to answer before the court of law, we will keep the information until the court case has been settled. Finally, some information needs to be retained for the sake of accounting and other activities that are prescribed by the law. The information will be stored and used only for the purposes prescribed by the law.
As mentioned above, if you have not made an order during the last three years, your data will automatically be removed.
Your data can be processed by and shared between all the companies belonging to Suomen Terveysravinto group, as basically many of the processes are shared between the individual brands, owned by Suomen Terveysravinto group. However, we will not use your data in any way that is against what we have stated in this data processing policy.
What Rights Do You Have?
You have the right to see all the information that we have of you, and if we have wrong information, we will change the information as soon as we are notified. You can also demand that your information should not be processed. Also, if you happen to want to have your information in machine-readable format, we will provide it to you.
You have the right to forbid us from marketing you (marketing calls, emails, printed ads, etc.) Also, as stated above, you have the right to ask us to remove your information.
Also, you have the right to receive answers to your questions regarding your personal data within a month – though we plan to answer much earlier.
If you feel that we have wronged your rights, you can also report us to the data security authorities.