Customer and marketing register of Helen Ltd
CUSTOMER AND MARKETING REGISTER, HELEN LTD
updated 18 May 2018
Controller and contact person
Business ID: 2630573-4
Street address: Kampinkuja 2, 3rd floor, Helsinki, Finland
Postal address: 00090 Helsinki, Finland
Telephone: 09 6171
Online service: www.helen.fi
Contact person in register issues: Jussi Mikkola, +358 9 6171, email@example.com
Purpose of processing personal data
Helen gathers and processes personal data of customers and potential customers, and other registered persons (data subject) related to the management of customer accounts for the following purposes:
- For implementing, maintaining and developing the customer relationship
- For identifying customer accounts and data subjects
- For analysing the use and for providing, developing and direct marketing of services produced by Helen and its partners in relation to the customer relationship
- For monitoring payments and collecting fees
- For verifying customer orders and changes
- For customer communications
- For implementing customer satisfaction surveys and other corresponding studies and questionnaires
- For the marketing, advertising and distance selling of products and services
- For statistical purposes.
Legal basis of processing
The principal basis for processing personal data is the contractual relationship between Helen and the customer or the measures in preparation for a contract. The processing of personal data is based on the customer relationship between Helen and the customer and the fulfilment of rights and obligations resulting from it.
Processing is based on the customer's or potential customer's consent once the customer has given their consent to electronic marketing and on legitimate interest with respect to direct marketing to the customer and customer surveys and questionnaires.
Processing is also based on the compliance with statutory obligations. At Helen, these obligations include especially those based on the accounting and electricity market legislation and on the regulatory guidelines issued by virtue of that legislation. The obligations concern, for example, the delivery of services related to electricity sales and the invoicing of customers.
In the processing of personal data, Helen complies with the applicable legislation, such as personal data, electricity market and energy efficiency legislation.
Data content of the register
In connection with the register, it is possible to process information obtained from customers and from potential customers who have given their consent to receiving marketing communications or to contacting them for the purposes specified in section 4. This information on its widest basis includes:
- personal identity code
- customer number
- language of communication
- contact details (e.g. telephone number and email address)
- information related to customer categorisation
- information related to the customer's use of services
- information about the place of use, such as the address, electricity consumption estimate, heating method, metering method, main fuse size, equipment information
- billing and information related to payment behaviour, such as the billing address, billing schedule, details about payments, and the method of billing
- recorded telephone conversations between customers and Helen's customer services
- other information provided by the customer, such as customer feedback and other contacts
- information detected with regard to the use of the services, such as visits to a certain website, the time, frequency and duration of the visit, interaction with communications
- customer's marketing consent
- other information received with the consent of the customer or potential customer that is necessary in order to implement the service they have requested.
Provision of information related to basic information and invoicing concerning the data subject is a prerequisite for delivering the services offered by Helen. Furthermore, statutory obligations require the collection of, for example, data concerning energy consumption with regard to the data subject. Failure to provide the required information or the prevention of its collection may complicate or prohibit Helen's service provision.
The data subject is entitled to prohibit or restrict the processing of their data as described below. For example, they are entitled to prohibit the use of their data for direct marketing purposes.
Data retention period
The personal data in electricity, heat and cooling contracts is erased at the end of the year when 10 years have passed from the termination of the contract in question. The data of other contracts is erased after three years from the termination of the contract. The data of potential customers is erased immediately if the customer so wishes. Telephone recordings are retained for 2 years after the telephone call. Customer feedback is retained for 10 years.
Regular information sources
As a rule, information concerning customers is obtained from the customers, e.g. in connection with requests for quotes, orders, contracts and other contacts, and from the information that is stored or recorded with regard to the customer's use of the services or products. Information about potential customers is obtained, e.g. in connection with competitions, prize draws and telesales. Of this information, only the data concerning potential customers who have given their consent to sending them marketing messages and contacting them shall be recorded.
All contacts by customers to Helen Ltd may be recorded. The recordings are used for verifying transactions, processing complaints and developing customer services.
Data is also collected with cookies and other similar techniques described in further detail in the cookie clause.
Personal data can also be collected, recorded and updated from the registers of the Population Register Centre, Suomen Asiakastieto Oy and other controllers offering address, updating and other similar services or brokering of electricity contracts. Data is also updated on the basis of the rules for exchanging electricity market data published by Finnish Energy and from the authorities within the framework of the applicable legislation.
Regular supply of data
In principle, information in the customer register of Helen Ltd is not disclosed to outsiders. Information may be disclosed to the authorities in an appropriate manner in compliance with the legislation in force.
Information may be transferred to partners, subsidiaries, service providers or subcontractors of Helen Ltd in accordance with the intended use of the register. Service providers and subcontractors may include, e.g. marketing companies, collection agencies, printer operators. Telephone recordings may be transferred to a research institute in order to assess the standard of customer service. In such a case, the research institute shall agree to return the recordings used in the study or to destroy them immediately at the end of the study.
Transfer of data outside the EU or the European Economic Area
As a rule, the data in the register is not transferred outside the borders of the member states of the European Union or the European Economic Area. The data may be transferred if it is necessary in view of the purposes of the above-described processing of personal data or the technical implementation of data processing. Personal data is transferred outside the European Union or the European Economic Area only in accordance with the legislation on personal data, for example, using the standard contractual clauses approved by the European Commission.
Principles of protecting the register
The information in the customer register is gathered into databases that are protected with firewalls and passwords and by other technical means. Access to the information is granted only to persons employed by Helen Ltd or to actors authorised by it and who require the information in their duties. Helen Ltd requires that its employees and partners are committed to the confidentiality of customer data. They shall use usernames and passwords. Material kept in manual form is stored in facilities, which are kept locked and under surveillance and used by Helen Ltd.
Right of inspection, the correction, removal and transfer of data, and their implementation
The customer is entitled to:
- inspect the data concerning themselves by contacting Helen's customer services, by visiting the offices of Helen Ltd in person or by updating their data themselves in Helen's online service
- demand that incorrect or inadequate information is corrected or supplemented or that outdated information is removed by contacting Helen's customer services or by visiting the offices of Helen Ltd in person
- cancel a marketing consent they have given
- move the information they have given to Helen (name, address and contact details) from one system to another by contacting Helen's customer services
- block or clear cookies from the browser settings or reset the app reference from the settings of the mobile device as described in further detail in the cookie clause
- submit a complaint to the authorities (the Data Protection Ombudsman) if they deem that the processing of their data has been in breach of this data protection clause and the personal data legislation valid at any given time.
Helen Ltd is entitled to charge fair compensation for providing the information if the customer uses their right of inspection more often than once a year.
Contact details for exercising the rights:
Helen Ltd / Customer services
Postal address: P.O.BOX 100, 00090 HELEN, Finland
Street address: Kampinkuja 2, 3rd floor, Helsinki, Finland
Customer services tel. +358 9 617 8080 Mon–Fri at 8am – 6pm.
Office of the Data Protection Ombudsman
Postal address: P.O. Box 800, 00521 Helsinki, Finland
Street address: Ratapihantie 9, 6th floor 00520 Helsinki, Finland
Switchboard: 029 56 66700
The customer is entitled to submit a complaint to the regulatory authority if they deem that data protection regulations have been breached in the processing of their personal data.
This privacy statement is also available to view at the offices of Helen Ltd at Kampinkuja 2, 3rd floor, Helsinki.