Privacy policy


1 Registrar

The registrar of the register is XENONIT Oy (business ID 3245833-1)

The contact person for registry matters is Juha Kilpinen

Address: Köynnöskuja 8, 01360 Vantaa, Finland
Phone: 040 2453067


2 Name of the registry

The name of the register is the XENONIT customer register.


3 Purpose of the processing of personal data

Personal data is processed for purposes related to the management, administration and development of the customer relationship, the provision and delivery of services, and the development and invoicing of services. Personal data is also processed for the purposes required to clarify possible complaints and other claims.

In addition, personal data are processed in communications to customers, such as for information and news purposes and in marketing, as part of which personal data are also processed for purposes related to direct marketing and electronic direct marketing.

The customer has the right to prohibit direct marketing directed at him.

The data controller processes the data itself and utilizes subcontractors acting on behalf and for the account of the data controller in the processing of personal data.


4 Legal bases of the proceedings

The legal bases for the processing of personal data are the following in accordance with the General EU Data Protection Regulation (hereinafter also the “GDPR”):

  • the data subject has consented to the processing of his or her personal data for one or more specific purposes (Article 6 1.a of the GDPR);
  • processing is necessary for the execution of a contract to which the data subject is a party or for taking pre-contractual measures at the request of the data subject (Article 6 (1b) GDPR);
  • treatment is necessary to achieve the legitimate controller or a third party's interests (6 GDPR art. 1.f).

The data subject's legitimate interest referred to above is based on a relevant and appropriate relationship between the data subject and the data controller as a result of the data subject's processing and processing for purposes which the data subject could reasonably have expected at the time and in the appropriate relationship.


5 Data content of the register (categories of personal data to be processed)

The register contains, in principle, the following personal data on all registered persons:

  • basic information and contact details of the person: [first name, surname, address, telephone number, e-mail address];
  • information related to the person's company or other organization and the person's position or job title in question. in a company or organization;
  • person's direct marketing permits and prohibitions.

6 Regular sources of information

Personal information is collected from the registered person himself.

Personal data shall also be collected and updated, within the limits of the applicable law, from publicly available sources related to the implementation of the customer relationship between the controller and the data subject and through which the controller fulfills its customer relationship responsibilities.


7 Retention period of personal data

The data collected in the register shall be kept only for as long and to the extent necessary in relation to the original or compatible purposes for which the personal data were collected.

The need to retain personal data shall be assessed every five years and in any case the data of the data subject shall be deleted from the register five years after the end of that data subject's customer relationship with the controller and the end of the customer relationship obligations and measures. For example, accounting documents are kept for six years from the end of the financial year.

The controller shall regularly assess the need for data retention in accordance with its internal code of conduct. In addition, the controller shall take all reasonable steps to ensure that personal data which are inaccurate, incorrect or out of date for the purposes of processing are deleted or rectified without delay.


8 Recipients (groups of recipients) of personal data and regular disclosures of data

Personal data will not be disclosed to third parties.


9 Data transfer outside the EU or the EEA

Personal data contained in the register will not be transferred outside the EU or the EEA.


10 Registry security principles

Materials containing personal data shall be kept in locked premises to which only designated and authorized persons have access.

The database containing personal data is on a server, which is stored in a locked state, which can only be accessed by designated and authorized persons. The server is protected by an appropriate firewall and technical protection.

Access to databases and systems is only possible with separately issued personal usernames and passwords. The controller has limited the access rights and authorizations to information systems and other storage media so that the data can be viewed and processed only by persons who are necessary for their lawful processing. In addition, database and system access transactions are recorded in the log data of the registrar's IT system.

The controller's employees and other persons have undertaken to observe professional secrecy and to keep confidential the information they receive in connection with the processing of personal data.


11 Rights of the data subject

The data subject has the following rights under the EU General Data Protection Regulation:

  • the right to obtain from the controller confirmation that personal data concerning him or her are being processed or not to be processed and, if such personal data are being processed, the right to have access to the personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data concerned; (iii) the recipients or groups of recipients to whom the personal data have been or are to be disclosed; (iv) where applicable, the intended period of retention of the personal data or, if that is not possible, the criteria for determining that period; (v) the right of the data subject to request the controller to rectify or erase personal data concerning him or her or to restrict or object to the processing of personal data; (vi) the right to lodge a complaint with the supervisory authority; (vii) if personal data are not collected from the data subject, all available information on the origin of the data (Article 15 GDPR). This described basic information (i) - (vii) will be provided to the registrant on this form;
  • the right to withdraw consent at any time without prejudice to the lawfulness of the processing carried out prior to the withdrawal (Article 7 GDPR);
  • the right to have inaccurate and erroneous personal data concerning the data subject rectified by the controller without undue delay and the right to have incomplete personal data supplemented, inter alia by providing additional clarification taking into account the purposes for which the data were processed (Article 16 GDPR);
  • the right to have the controller delete personal data concerning the data subject without undue delay, provided that (i) the personal data are no longer needed for the purposes for which they were collected or for which they were otherwise processed; (ii) the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing; (iii) the data subject objects to the processing on the basis of his or her specific personal situation and there is no valid reason for the processing or the data subject objects to the processing for direct marketing purposes; (iv) personal data have been processed unlawfully; or (v) personal data must be deleted in order to comply with a legal obligation to which the controller is subject under Union law or national law (Article 17 of the GDPR);
  • the right to have the controller restrict the processing if (i) the data subject contests the accuracy of the personal data, in which case the processing shall be limited to the period during which the controller can verify their accuracy; (ii) the processing is unlawful and the data subject opposes the deletion of personal data and instead requests that their use be restricted; (iii) the controller no longer needs such personal data for the purposes of processing, but the data subject needs them in order to establish, present or defend a legal claim; or (iv) the data subject has objected to the processing of personal data on the basis of his or her specific personal situation pending verification that the data subject's legitimate grounds override the data subject's grounds (Article 18 GDPR);
  • the right to have personal data concerning him or her provided by the data subject to the controller in a structured, commonly used and machine-readable form, and the right to transfer such data to another controller without prejudice to the controller to whom the personal data have been transmitted, subject to the consent of the Regulation art.);
  • the right to complain to the supervisory authority if the data subject considers that the processing of personal data concerning him or her infringes the general EU data protection regulation (Article 77 GDPR).

Requests for the exercise of the data subject's rights shall be addressed to the controller's contact person referred to in paragraph 1.