Privacy Statement on the Processing of Personal Data at PTCServices Oy

PTCServices Oy has both institutional and corporate clients as well as other contacts whose personal data we process carefully and securely in accordance with data protection legislation. This privacy statement describes the procedures by which PTCS processes and stores accumulated personal data.

The privacy statement includes the description of PTCS’s customer and marketing register. It explains the processing of personal data in situations where the processing is based on PTCS’s legitimate interest and customer relationship.

The privacy statement contains information on the rights of the data subject, data security, and cookies.

The register contains identifying information on the individuals recorded in it, which is necessary for the purpose of the register. The register may include the following personal data:

  • First and last name
  • Job title, area of responsibility, decision-making level
  • Whether the person is a Cloudia user
  • Contact details: billing address, postal address, phone number, email address
  • Organization: name, Business ID, municipality/region, whether the organization is a procurement unit in special sectors, industry
  • Customer-related information: customer number, dates, commissioned assignments/services, complaints, customer feedback provided, and other customer communication
  • Customer category
  • Information provided by the data subject and inferred from the use of services, as well as interests
  • Identification information related to participation in an event or training organized by PTCS and any other information provided by the person (e.g., special dietary requirements if catering is provided)
  • Username and password for the paid Julkiset.fi information service. Users can change the system-generated password to one of their choice.
  •  Username and password for PTCS online training

Privacy Statement for the Customer and Marketing Register

Controller

PTCServices Oy
Annankatu 31-33 C 39, 00100 HELSINKI, Finland

Contact Person for Register Matters

Pauliina Karinkanta
PTCServices Oy
phone 0400 281091
Pauliina.karinkanta@ptcs.fi

Name of the Register

PTCServices Oy Customer and Marketing Register

Purpose of Processing Personal Data

The processing of personal data is based on a customer relationship (customer assignments, participation in training or events), other consent provided by the individual, or legitimate interest. The legitimate interest includes managing customer relationships, developing business, and marketing the company’s services and training to individuals working in the procurement sector. Processing personal data for these purposes can be considered necessary for the realization of legitimate interest (Recital 47 of the GDPR).

PTCS may process personal data in this register for customer relationship management, direct marketing, opinion or market research, or similar activities, including the use of electronic communication tools.

For the technical, commercial, or operational execution of tasks related to the processing of customer data, PTCS uses subcontractors who operate on behalf of PTCS as defined in Section 5 of the Finnish Personal Data Act.

Register Data Content

The register stores at least the information provided by the customer when subscribing to the newsletter, registering for and participating in training, and when the customer relationship begins, as well as information added or updated by PTCS.

The following information may be processed in the register:

  • First and last name
  • Job title, area of responsibility, decision-making level
  • Whether the person is a Cloudia user
  • Contact details: billing address, postal address, phone number, email
  • Organization: name, Business ID, municipality/region, whether the organization is a procurement unit in special sectors, industry
  • Customer-related information: customer number, dates, commissioned assignments/services, complaints, feedback provided, and other customer communication
  • Customer category (when defined)
  • Information provided by the data subject and inferred from service usage, and interests
  • Identification information related to participation in a marketing event, campaign, or training, and other information provided by the person (e.g., dietary requirements)
  • Username and password for the JulkiSet service. Users may change the system-generated password
  • Username and password for PTCS online courses

Personal data is stored for the duration of the customer relationship or newsletter subscription, or until the customer removes their email address from the newsletter distribution list (LianaMailer), requests deletion of their data from the register, or the email address becomes invalid.

For training registration data, the storage period in the event management system complies with the Accounting Act (Section 10), which requires data to be retained for at least six years after the end of the financial year during which the training took place.

Training recordings are stored for a maximum of 6 years. A one-week viewing right is provided to participants after the training, after which recordings are used for internal staff training. Recordings are stored on Vimeo and PTCS’s MS SharePoint365.

Partners whose systems or applications are used to process the data contained in the customer and marketing register: PTCServices Oy, Frendy (Microsoft products), Liana Technologies Oy (Postiviidakko) (including newsletters, event invitations, customer satisfaction surveys, and training marketing messages), Eventilla Oy (event management system), Arts & Minds Oy, Poutapilvi Oy (julkiset.fi, technical implementation), Kuuki Marketing Lab Oy (pts.fi, WordPress), Moonhill Oy (ptcs.fi, servers), Tilitiimi T & M Oy (financial administration), Caduseus Oy (customer and billing data and marketing distribution lists), Heeros Oyj (customer and billing data), Eventgarden Oy (event streaming services), Prospectum Oy (Viestiseinä and event streaming), Pinpops Oy (event name badges), Avidly (online courses), and Vimeo.com Inc (video recordings).

Regular Data Sources

Personal data may be collected from the data subject themselves, from PTCS’s partners, or from publicly available sources.

Personal data is added to and updated in the customer and marketing register based on contacts, requests for quotation, assignments, newsletter subscriptions, and registrations for training sessions and events, as well as in connection with the purchase of an online course or during agreed meetings. Data may also be collected, stored, and updated from controllers that provide address, update, or other similar services.

Disclosure and Transfer of Data

For trainings and events, participant information (name, job title, organisation) may be shared with external speakers to support the planning of their presentations. A limited participant list (name, organisation) may be shared with other training participants so that the group is aware of who else is attending the event.
PTCS may disclose personal data within the limits permitted by applicable legislation, for example to PTCS’s partners. Data is not transferred outside the EU or the EEA

Role as Processor in Customer Assignments

In customer assignments, PTCS acts as a processor of personal data. In such cases, the controller is the client, who prepares a separate privacy statement.

Other Information Related to the Register

Right to Object to Processing

The data subject may modify or correct their data by contacting info@ptcs.fi.

The controller will delete, correct, or supplement personal data that is incorrect, unnecessary, incomplete, or outdated without undue delay, either on its own initiative or at the request of the data subject.

Upon request, all data stored about the person may be delivered by email or post.

The data subject has the right to object to processing for direct marketing, profiling, or opinion/market research.

Requests can be submitted to info@ptcs.fi.

The data subject has the right to access the information stored about them in the register. A written and signed request for access must be sent to the following address:
PTCServices Oy
Annankatu 31-33 C 39, 00100 HELSINKI
With the envelope marked: Request for Access to Personal Data

The request must include:

  • Name
  • Name of the register
  • Address
  • Phone number

Register Security and Data Protection

PTCS ensures the security, confidentiality, and availability of personal data using appropriate technical and administrative measures.

Databases are protected with firewalls, passwords, and other security measures.

Personal data is processed only by individuals specifically designated by PTCS who are employed by PTCS and whose duties explicitly include the processing of personal data, as well as by third parties who maintain or develop services on behalf of PTCS.

Remote Training

We use the following systems for remote training (webinars):

  • Microsoft Teams Meetings

PTCS’s Teams training sessions are typically recorded, and participants are given one week of viewing access to the recording after the session. This allows participants to review the course content afterward. In PTCS’s training calendar, the course description indicates whether a recording will be available. By joining the Teams meeting, the participant gives their consent to the recording.
The following information about the participant may appear on the recording:

  • The name the participant uses in Teams
  • A profile picture, if one is used
  • Video image, if the participant’s webcam is on
  • Audio, if the participant’s microphone is on

At the beginning of many training sessions, we often conduct a round of introductions to increase interaction. During this, participants are invited to turn on their microphone and webcam. Participation in introductions is voluntary and entirely up to the participant. The recording of the training session begins only after the introductions have finished.

For privacy reasons, we recommend that participants use a background image when using the webcam so that their home or workplace environment is not visible. Muting the microphone prevents sounds from being heard by other participants and from being captured in the recording. Participants may also choose to keep both their webcam and microphone turned off for the entire duration of the training.

More information about the data protection of Microsoft 365 cloud services (e.g., Teams) can be found here.

The servers are located within the EU

Online Training

PTCS’s online trainings and online store are available at elearning.ptcs.fi.
PTCS stores the username as well as the billing details provided by the user at the time of purchase.
In addition, the system (WordPress) stores the following information:

  • User profile: username, enrolled courses
  • User contact details
  • User learning data: course progress, answers to assignments, and the time spent on them
  • User log data

Learning data is retained for 365 days. User profile information remains in the system until the user requests its deletion.

Right to Lodge a Complaint

Every data subject has the right to lodge a complaint with a supervisory authority (in Finland, the Data Protection Ombudsman) in the EU member state of their habitual residence, place of work, or where the alleged breach of data protection legislation has occurred.

Cookies

You can view PTCS’s cookie policy for ptcs.fi here.