Customer Privacy Policy

CUSTOMER PRIVACY POLICY OF MARKETING

Controller
EnerKey Enegia Solutions Oy
Lutakonaukio 7
40100 Jyväskylä
e-mail helpdesk@enerkey.com
Tel. +358 (0)20 741 4110
Fax +358 (0)20 741 4118

Name of the Customer Privacy Policy
EnerKey’s marketing Customer Privacy Policy

Contact person
Iiro Kuntsi
Digital Marketing Specialist
e-mail: iiro.kuntsi@enerkey.com

Purpose of personal data processing
We process personal data in communications and marketing, based on a customer relationship, for existing business customers, or if the product or service marketed is related to the person’s duties or area of responsibility at the company. We also conduct marketing communications with the person’s consent.

Personal data processors
A customer’s personal data is processed by those representatives of Enegia’s personnel who need to process the personal data in order to perform their duties successfully.

Description of the categories of data subjects and the categories of personal data
The data subjects include EnerKey’s customers, their contact persons, and the users of EnerKey’s services.

Regular data sources
User data is obtained with the user’s consent from the user and/or from events related to the user on our website.

Software used by EnerKey:

• Active Campaign
• Webropol
• WordPress
• Google Analytics
• Google Data Studio
• Google Adwords

Regular disclosure of data and transfer of data outside the EU or the European Economic Area
Data is not disclosed to third parties. Data is not disclosed or transferred outside the EU or the European Economic Area.

Principles of Customer Privacy Policy
Personal data is kept confidential. The data in the user Customer Privacy Policy is saved in the controller’s own system or in the system of a service provider that provides the controller with IT services. The servers of the controller’s system are located in a dedicated, locked space, and the service provider’s servers are located in well-protected and monitored data centres. The data is protected from the public Internet with a firewall, and access to the Customer Privacy Policy requires a user ID and password. User IDs and access rights are managed by the controller’s information management.

Rights of a data subject
A data subject can easily manage or block electronic communications targeted at them in connection with received communications. Personal data is erased from or rectified or checked in the personal Customer Privacy Policy of marketing at the data subject’s request, provided that an active customer relationship does not require its storing. We maintain our personal data Customer Privacy Policy of marketing on a regular basis, erasing any contact information that no longer works and updating the contact information of our active customer relationships both on our own initiative and at the customers’ requests. When the personal data processing is based on the data subject’s consent, the data subject has the right to cancel their consent.

Cookies
Our website uses cookies to improve user experience and to collect statistics about the site’s use. By using the website, you accept the use of cookies.

What are cookies?
A cookie is a small text file which your browser installs on your computer. Cookies are used, for example, when it is necessary to transfer your details as you move from one page to another within the service. Cookies cannot be used against your permission. To read more about cookies, go to the Finnish Communications Regulatory Authority’s website.

Cookies used on our website

Google Analytics
We use Google Analytics, a common tool, to find out the number of visitors to our site and how they found their way on our site. Google Analytics is very commonly used, on practically all websites today.

Hotjar
Hotjar is a service with which the website manager can follow users’ movements on the site. Hotjar uses cookies to prevent the re-recording of users’ movements on the site. Read more about Hotjar cookies in their documentation.

Cookie notification
Our cookie notification uses cookies to check whether the user has accepted the use of cookies on our site.

How are cookies managed and how are they deleted?
Use your browser settings to manage your cookies. You may, for example, prevent new cookies from being recorded, delete existing cookies or request a notification whenever new cookies are recorded. You can find more information on cookie management here.

Content of the Customer Privacy Policy
The Customer Privacy Policy can include the following data on a user:

• Name
• Phone number
• Email address
• Organisation
• Language
• Level of education and profession
• IP address
• Location
• Web browser
• Behaviour on the website

EnerKey’s partners:

• EnerKey’s Finnish partners
• Third parties providing cloud services
• Third parties providing marketing and auditing services
• Third parties that help EnerKey to meet its statutory obligations

CUSTOMER PRIVACY POLICY OF ENERKEY

Controller
Enegia Energy Management Services Ltd
Lutakonaukio 7
40100 Jyväskylä
e-mail helpdesk@enerkey.com
Tel. +358 (0)20 741 4110
Fax +358 (0)20 741 4118

Name of the Customer Privacy Policy
EnerKey user Customer Privacy Policy

Contact person
Kari Iltola
Product Manager
e-mail: kari.iltola@enerkey.com

Content of the Customer Privacy Policy

The Customer Privacy Policy includes the following data on a user:

• Name
• Phone number
• Email address
• Organisation
• Language
• Information on the service use (e.g. times of visit)

Personal data processors
A customer’s personal data is processed by those representatives of Enegia’s personnel who need to process the personal data in order to perform their duties successfully.

Description of the categories of data subjects and the categories of personal data
The data subjects include Enegia’s customers, their contact persons, and the service users.

Regular data sources
User data is obtained with the user’s consent from the user and/or from events related to the user.

Regular disclosure of data and transfer of data outside the EU or the European Economic Area
Data is not disclosed to third parties. Data is not disclosed or transferred outside the EU or the European Economic Area.

Principles of Customer Privacy Policy
Personal data is kept confidential. The data in the user Customer Privacy Policy is saved in the controller’s own system or in the system of a service provider that provides the controller with IT services. The servers of the controller’s system are located in a dedicated, locked space, and the service provider’s servers are located in well-protected and monitored data centres. The data is protected from the public Internet with a firewall, and access to the Customer Privacy Policy requires a user ID and password. User IDs and access rights are managed by the controller’s information management.

Rectification of data
Personal data can be rectified free of charge by filing a sufficiently detailed request for rectification with the user support of the EnerKey service: Helpdesk, tel. +358 20 799 2101 helpdesk@enerkey.com

Erasure of data and any other rights
Erasure of a person’s data from the Customer Privacy Policy terminates the person’s access right to the service.
A person’s data is anonymised in the Customer Privacy Policy six months after the termination of the access right.

CUSTOMER PRIVACY POLICY OF ENEGIA PORTFOLIO SERVICES OY

In addition to Enegia’s personal data Customer Privacy Policy, the following terms and conditions are applied to this Customer Privacy Policy.

Controller
Enegia Portfolio Services Oy (hereafter EPS)
Ohjelmakaari 10
FI-40500 Jyväskylä
e-mail info@enegia.com
Tel. +358 (0)20 741 4110
Fax +358 (0)20 741 4118

Name of the Customer Privacy Policy
EPS customer data Customer Privacy Policy

Contact person
Lasse Pollari, Compliance Officer
e-mail lasse.pollari@enegia.com
tel. +358 (0)40 579 7845

Purpose of personal data processing
EPS collects data in order to obtain customer knowledge. Customer knowledge is based on the obligations of an investment service company to know its customers in order to prevent money laundering and supporting terrorism and to find out about the customer’s knowledge of financial instruments.

Content of the Customer Privacy Policy
The Customer Privacy Policy can include the following data on a user:

• Personal identity code
• Copy of a passport, driving licence or ID card
• Address

Personal data processors
EPS’s sensitive personal data can be processed by the EPS personnel, the customers’ customer leads, portfolio management assistants, financial management officers, and the Compliance Officer.

Regular disclosure of data and transfer of data outside the EU or the European Economic Area
EPS discloses personal data to tied agents for the provision of services. Personal data can also be disclosed to the authorities if EPS is obliged to do so. Data is not disclosed or transferred outside the EU or the European Economic Area.

Principles of Customer Privacy Policy
Personal data is kept confidential. The data in the user Customer Privacy Policy is saved in the controller’s own system or in the system of a service provider that provides the controller with IT services. The servers of the controller’s system are located in a dedicated, locked space, and the service provider’s servers are located in well-protected and monitored data centres. The data is protected from the public Internet with a firewall, and access to the Customer Privacy Policy requires a user ID and password. User IDs and access rights are managed by the controller’s information management.

Erasure of data and any other rights
As an investment service company, EPS may store personal data longer than would be necessary for the customer relationship if so required by legislation.