Customer Data Protection Notice


This notice provides you with information on how Sampo Rosenlew Ltd., Konepajanranta 2, P.O.Box 50, FIN-28101 Pori, Finland („we“) will process your personal data.


  1. 1.        Purposes for which we process your data

We will process your personal data (as set out in point 2 below) for the following purposes:

a)      The performance of sales and distribution processes, including billing and invoicing as well as the compliance with sanctions (e.g., trade sanctions) and other regulatory requirements

b)      The management of our relationships with (potential) customers, including the analysis of customers’ business needs and how they use our products and services, including after-sales services

c)      Making available certain online services to customers and further optimizing and developing such services; recognizing, preventing and investigate attacks against such services; and analyzing the usage of such services and generating access statistics

d)      Business analytics and statistical analysis, including the aggregation of data in order to analyze market trends and anticipate customer demand

e)      Analyzing and forecasting customer demand

f)       Performing direct marketing via electronic and non-electronic means as well as advertising

g)      Documenting interactions (e.g., meetings, phone calls, e-mail conversations) with customers

h)      Management of the entire sales process

i)        Business opportunity management and tracking of opportunities

j)        Analysis of customer satisfaction

k)      Administration of any on-site visits at our premises


We collect this data either directly from you, from our distribution partners, or your employer.


The provision of personal data is voluntary. However, if you do not provide your personal data, we may not be able to perform relevant business processes, including sales and distribution processes.


  1. 2.        Processed data categories and legal basis of the processing

We process the following categories of your personal data exclusively on the basis of your consent according to Article 6(1)(a) of the General Data Protection Regulation (“GDPR“):

a)      email address and telephone number to the extent that they are used for direct marketing purposes.


We may process the following categories of your personal data on the basis of our prevailing legitimate interest (according to Article 6(1)(f) GDPR), which lies in achieving the purposes as set out in point 1 above:

a)      Master data

-        Name

-        Academic Title

-        Salutation/sex

-        Language

-        Picture

-        Birth date

-        Associated customer (employer)

-        Company address, e-mail address, phone number, fax, and other contact information

-        Roles/functions at customer

-        Department


b)      Customer relationship data

-        Professional and personal interests

-        Career information

-        Meeting notes

-        Receipt of and reaction to marketing and business development initiatives

-        History of previous interactions with us or any affiliated group company

-        Information on the use of any online services provided by us or any affiliated group company, including IP address, authentication data (e.g., username and password), URLs visited, time and date of the use of an online service or a particular feature thereof, name and version of the client software used, location data, and the webpage (URL) visited before accessing the online service

-        History of orders placed

-        History of inquiries made

-        Customer category

-        Correspondence


c)      Commercial information

-        Scope of power of attorney for the customer

-        History of commercial transactions with us or any affiliated group company

-        Contracts entered into on behalf of the customer

-        Contractual documentation

-        Information about contract performance and instances of non-performance

-        Information about the expiration and termination of the contract


  1. 3.        Transfer of your personal data

For the purposes set out above, we will transfer some of your personal data to the following recipients:

  • IT service providers that we use
  • Group entities
  • Our distribution and business partners if they are involved in the product/service delivery


Some of the recipients referred to above are located or process personal data outside of your country. The level of data protection in another country may not be equivalent to the one in your country. Therefore, we take measures to guarantee that all recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC). Such agreements are accessible upon request from


  1. 4.        Retention periods

Your personal data will only be kept for as long as we reasonably consider necessary for achieving the purposes set out in point 1 above and as is permissible under applicable laws. We will, in any case, retain your personal data for as long as there are statutory retention obligations or potential legal claims are not yet time-barred.


  1. 5.        Your rights in connection with your personal data

Under applicable law, you have, among others, the rights (under the conditions set out in applicable law): (i) to check whether and what kind of personal data we hold about you and to request copies of such data, (ii) to request correction, supplementation or deletion of your personal data that is inaccurate or processed in non-compliance with applicable requirements, and (iii) to request us to restrict the processing of your personal data, (iv) in certain circumstances, to object for legitimate reasons to the processing of your personal data or to revoke consent previously granted for the processing, (v) to request data portability, (vi) to know the identities of third parties to which your personal data are transferred and (vii) to lodge a complaint with the competent authority (in Finland: Tietosuojavaltuutetun toimisto, Ratapihantie 9, 6. krs, 00520 Helsinki, Withdrawing your consent does not affect the lawfulness of processing based on your consent before your withdrawal.


  1. 6.        Our contact details

Please address your requests and any other questions concerning this notice to:


Sampo Rosenlew Ltd.

Konepajanranta 2

P.O.Box 50

FIN-28101 Pori






If there are no requests or questions concerning this notice, no further action is required from your side.