Name: Bell Rock Advisors Ltd (“Bell Rock” or “we”)
Company ID: 3103307-5
Pursimiehenkatu 26 C,
00150 Helsinki, Finland
E-mail address: firstname.lastname@example.org
Managing Director, Juuso Lehto
+358 45 678 4090
This Privacy Statement is applicable to Bell Rock’s database of customers and suppliers, users of our website bellrock.fi (“Website”) as well as our marketing database. We mainly process personal data subject to this Privacy Statement when offering or promoting our 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 Statement describes how we process personal data concerning the representatives of our clients, potential clients, suppliers and other business partners as well as the users of the Website. The word “you” refers to all the aforementioned individuals whose personal data is processed in accordance with this Privacy Statement.
We may update this Privacy Statement if it is necessary in order to reflect the changes in data processing practices or otherwise.
Please note that this Privacy Statement applies to processing of personal data carried out by Bell Rock as data controller.
The personal data collected and processed by us in accordance with this Privacy Statement can be divided into two general data categories: a) Company and Contact Data and b) Analytics Data.
We may process the following Company and Contact Data relating to you:
Typically we receive the Company and Contact 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, Company and Contact 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 Company and Contact 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.
The logging systems on our Website automatically log certain Analytics Data when you visit the Website. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with Company and Contact Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.
We may automatically collect the following Analytics Data when you visit or interact with the Website:
We collect the following information relating to the technical device you use when using the Website:
We collect information on your use of the Website, such as:
We use various technologies to collect and store Analytics Data and other information when you visit our Website, including cookies.
Our Website uses Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve our Website. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
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 services to our customers and to run, maintain, promote and develop our business.
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. For quality improvement and trend analysis: We may process information regarding the use of the Website to improve its quality e.g. by analysing any trends in the use of our Website. When possible, we will do this using only aggregated, non-personally identifiable data.
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.
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.
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, we provide adequate protection for such transfers through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
We do not share personal data with third parties outside of our organization unless one of the following circumstances applies:
We may share personal data with third parties outside Bell Rock’s organization if access to and use of the personal data is reasonably necessary to: a) meet any applicable law, regulation, and/or court order; or b) detect, prevent, or otherwise address crime or security issues.
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.
If Bell Rock 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.
We may share personal data with third parties outside Bell Rock’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.
We do not store personal data longer than is legally permitted and necessary for the purposes set out in this Privacy Statement. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
For instance, Company and Contact Data relating to you is typically stored as long as we have an ongoing service or business relationship with the organisation you represent. Information relating to your participation to our events is stored until the end of the event in question.
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.
We will store Analytics Data relating to the Website for a period of six (6) months.
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, 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 rectify: You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.
Right to erasure: 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.
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 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 data portability: You have the right to receive some of your personal data that you have provided us with in a structured and commonly used format.
How to use the rights: The above mentioned rights may be used by sending a letter or an e-mail to 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.
You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or the unsubscribe possibility offered in connection with any direct marketing messages.
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
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data.
Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you as well as relevant authorities about the breach as soon as possible in accordance with law.