Finnair Plc, Global Internet newsletter subscriber register
PURPOSE OF THE REGISTER
The register is used to communicate offers and product information of Finnair and its partners. The communication is done in form of an e-mail newsletter. Newsletter is sent out 1-3 times a month and it does not obligate the subscriber to any actions.
Registered information shall be used for creating subscriber profiles. Profiles assist Finnair in targeting the regionalized marketing messages. Finnair's Internet marketing communication message/offers varies according to markets.
Finnair has the right to cancel a newsletter subscription by removing the subscriber's email address and the profile markings directed to it, provided that the email address is no longer valid, or the email box has not been opened for the past 6 months. The subscriber has the option of renewing his/her Finnair newsletter subscription by registering himself/herself as a subscriber on Finnair's internet pages.
DATA CONTAINED IN THE REGISTER
When entering into a subscription, the subscriber's e-mail address and first name will be recorded in the register. In addition, the country from which the subscriber wishes to receive offers, and the language of the newsletter, will also be registered.
Additional information that may be collected, such as last name, street address, postcode, town, country code, telephone number and birth date will be stored in the register for the duration of possible online contest only, so that the winner may be drawn and notified.
In case the subscriber later chooses to provide supplemental information on himself/herself, the user-specific content in the register may vary according to the actions taken by the user.
Right of refusal
In case the contest participant chooses not to activate the newsletter subscription himself/herself, the information given shall be stored only temporarily.
The newsletter subscription may be cancelled at any point. A cancellation may be entered at www.finnair.com, or by registering the refusal via the link provided at the end of each newsletter.
REGULAR SOURCES OF INFORMATION
Information shall be collected from the subscriber only as he/she selects options or newsletters available via the service, or otherwise participates in an activity, which requires information, and which has been implemented via the newsletter.
TRANSFER OF INFORMATION
Information may be transferred to parties belonging to the same group of companies as the register owner, as permitted by law. Servers and other technical auxiliary devices used for data processing may be owned and controlled by the third party service provider providing services to the register owner. The register owner may acquire services needed for the use of such devices from an outside service provider.
Data may be transferred outside of the European Union and the European Economic Area, should that be necessary in order to technically implement the service requested by the user, or in cases where it is otherwise necessary based on § 23, Sections 2-5 of the Personal Data Act. Partners outside the EU are required to belong to the Safe Harbor arrangement and to comply with the Safe Harbor privacy principles.
The European Commission has stated that the Safe Harbor arrangement fulfils the minimum level of data protection outlined in the EU directive on the protection of personal data. It is also commensurate with the Finnish Personal Data Act.
UTILISATION OF RIGHTS
The subscriber has the right to know what information about him/her has been recorded in Finnair's Internet Service newsletter subscriber register.
The data can be inspected once in a calendar year, with no charge. The request for data inspection must be submitted in writing to the person in charge of register-related matters, whose name appears at the end of this register document. The request must include the email address given by the subscriber at the time of registration. The person submitting the request must sign it by hand. Data to be transferred as a result of an inspection request shall be transmitted via email to the email address given in the request.
In case there is an error in the data concerning the subscriber, he/she has the right to have the error corrected. The request to correct the error should be submitted to the following address: Finnair SRD/92, 01053 Finnair.
PROTECTION OF THE REGISTER
Manually processed data
Those documents that contain personal data, which are processed manually, are properly destroyed after processing.
Data recorded through automatic data processing
Only certain employees of Finnair, or employees assigned by or acting on behalf of Finnair, shall have the right to use the Finnair Internet Service newsletter subscriber application.
In protecting the electronic register, the following principles are followed: (i) The use of the register is guided, (ii) the data contained in the register can be accessed only by persons designated to do so in advance, in connection with their work assignments, (iii) the data is collected in electronic databases protected by real-time technical methods, (iv) the servers are located in locked rooms accessible only to persons with permission to enter, and (v) a written agreement exists between Finnair and any outside service providers, where the confidentiality of data processing and protections fulfilling the criteria defined above in this item are a pre-condition.
PERSON IN CHARGE OF THE REGISTER; CONTACT INFORMATION