VILPE Oy is committed to the responsible management, use, and protection of your personal information. This text sets out VILPE Oy’s Social Media Privacy Policy, which applies if you like or follow VILPE Oy’s Facebook, Instagram, TikTok, LinkedIn or YouTube accounts or if you react to VILPE Oy’s content which has been posted on these platforms. 

Social Media Privacy Policy

1. Controller

VILPE Oy (0558172-1)
Kauppatie 9, FIN-65610 Mustasaari, Finland

2. Contact Person in Data File-Related Matters 

Communications Coordinator Essi Poropudas 
Kauppatie 9, FIN-65610 Mustasaari, Finland 
Tel. (switchboard) +358 20 123 3200 

3. The Personal Data Processor 

The personal data processors are the aforementioned social media sites and VILPE Oy. The data protection principles of these social media sites can be accessed via the following links:

Facebook, Instagram, LinkedIn, TikTok and YouTube are the main responsible parties for the data security and rights of data subjects under the General Data Protection Regulation (GDPR) associated with their services. VILPE has no influence over the processing of this data. The data privacy settings for the service in question can be managed within the service itself.  

4. Purpose of Processing Personal Data 

The purposes of processing personal data are set out in information given by the service providers in question:

The personal data collected into the registry is used to control, manage and maintain customer relationships, produce and facilitate services and communications for the customer, invoicing, billing and debt collection as well as directing marketing and advertising and providing the data to a suitable VILPE Oy representative. In addition, the feedback and data gathered from customers is used in analysing market trends, product applications and research and development.

5. Basis for Processing Personal Data 

The basis for processing personal data is the legitimate interest of the controller. 

6. Data Sources and Nature of the Personal Data Processed 

VILPE Oy receives a registered name or username from Facebook, Instagram, LinkedIn, TikTok and YouTube, a public profile picture, any other information identified by the data subject in the application as public, as well as data contained in the data subject’s own comments and instant messaging service. Data is collected even if the user is not registered for the service or is not logged in to their account.

If a person fills out the contact form in social media channels, this information, such as name, phone number, e-mail, and date of registration is transferred to VILPE Oy’s customer service management system. General identification details and basic information will be entered into VILPE Oy’s corporate information system:

  • Date and time of registration
  • Person’s name
  • Person’s phone number
  • Person’s email address
  • Person’s gender
  • Department in organisation
  • Title
  • Responsibilities within the organisation
  • Date of birth
  • Open text, focused information for suppler relationship management
  • Log of communications
  • Agreement to/refusal of agreement to direct marketing
  • Clicking and opening of emails
  • Clicking on call-to-action links

7. Storage Time of Personal Data 

The social media service provider retains personal data until it is no longer needed or until the person in question deletes their account. VILPE Oy has access to the data until the data subject removes or stops following VILPE Oy’s Facebook, Instagram, YouTube, TikTok, or LinkedIn accounts. 

Personal data is stored for as long the customer relationship exists. After the customer relationship has been terminated, the customer’s personal data is stored for a maximum of three (3) years after the date of termination. Personal information of potential customers is stored in the direct marketing register for as long as the subject of the information holds the position, to which the marketable product or service is relevant to, or until the subject of the information withdraws the consent for the use of data for direct marketing purposes. In this case the information of the withdrawal of consent will be stored. Personal information can be stored for longer periods of time, when the applicable law and regulations or the Company’s contractual obligations towards third parties require it.

8. Transfer of Data 

The data can be transferred to the register holder’s parent and daughter companies for the purposes described in this document’s article 4., for the register holder’s direct marketing purposes, or to the register holder’s personal data records. Transfers are always made in accordance with current data protection and security regulations. Service providers from other companies also handle and use personal data, and this handling of personal data is out of VILPE Oy’s control. These service providers are:

  • Providers of IT-services
  • Providers of logistic services
  • Providers of paid services
  • Providers of marketing services

9. Transfer of Data to Outside the EU or EEA 

VILPE Oy does not transfer data outside the EU or EEA. Social media providers, by contrast, share data globally.

10. Principles of Securing the Data File 

A. Manual data
The controller does not convert data to a manual format. 

B. Electronically recorded data
The controller’s employees and any external parties operating in the controller’s name who participate in the processing of data have a confidentiality obligation regarding all registered personal data. Administrator’s rights or usernames for VILPE Oy’s Facebook, Instagram, YouTube and LinkedIn accounts have been made available only to those responsible for these services.

11. Profiling 

The controller may also use data for profiling purposes. Profiling is carried out by using identifiers, with which data generated about data subjects during the use of the service can be merged. As a result, profiles can, for example, be compared with profiles of other data subjects. 

The purpose of profiling is to identify the demand for services and customer behaviour. 

12. Data Subject Right to Object to Processing of Personal Data and Direct Marketing 

The subject of the data has the right to object to customer profiling and other data handling activities which the register holder may perform using the subject’s data, when the basis for the data handling activities is the customer relationship between the subject of the data and the register holder. The subject of the data can present their objections by the means specified in this document’s article 14. (‘Contact’). The subject of the data will need to specify the particular instances which their objections are based on. The register holder can abstain from carrying out requests regarding objections on the basis of current laws and regulations. The subject of the data can at any time accept or withdraw their consent for the use of their data for direct marketing and customer profiling purposes.

13. Other Rights of the Subject of the Data

Right of Inspection 

The subject of the data has the right to check with the relevant social media service provider what information has been stored in the customer register of this provider pertaining to the subject of the data. VILPE Oy does not transfer data from social media services to its own registers.

The subject of the data has the right to inspect what data concerning them has been stored in the register holder’s register. The request for inspection must be made according to this document’s article 14. (‘Contact’). The register holder can abstain from requests to inspect the data on the basis of current laws and regulations. Data inspection requests are usually free of charge when made only once a year.

The Right to Demand Correction of Data, Removal of Data or to Restrict Its Use

The data subject may, if they have detected an error, themselves correct, delete or restrict their personal data as far as is made possible by the social media service provider. The subject of the data may also contact the social media service provider to have their personal data corrected, deleted or restricted.

The subjects of the data have the right to demand the correction of incorrect data, as well as the right to prohibit the use of their data for direct marketing or similar purposes. Such requests must be made according to this document’s article 14. (‘Contact’). The subject of the data also has the right to restrict the handling of their data: for example, during the process of requesting the removal or correction of data concerning them.

The Right to Transfer Data from the Register 

Insofar as data subjects have themselves added data to the register and this data is processed on the basis of the data subjects’ consent or assignment, data subjects have the right to have this data transferred to themselves or to another controller in a primarily machine-readable format. The provision of this information to the data subject is the responsibility of the social media service in question. VILPE Oy does not transfer data from the data subject’s social media service to its own customer registers.

The subject of the data has the right to acquire any information which they have provided to the register (which has been used with their consent or mandate) in primarily machine-readable format to themselves or to be transferred to another register holder.

The Right to Make a Complaint to a Supervisory Authority 

The subject of the data has the right to file a complaint with a supervisory authority if the controller has not complied with applicable data protection regulations in their activities. 

Other Rights 

If personal data is processed on the basis of the subject of the data’s consent, the subject of the data has the right to withdraw their consent by discontinuing their use of the social media service in question. VILPE Oy has no power to influence the use of personal data by the social media services in question.

14. Contact 

For questions related to the processing of personal data and in situations relating to the exercise of their own rights, the subject of the data must contact the social media service provider in question, whose contact details are given on the following service providers’ websites:

If the subject of the data has questions about VILPE Oy’s processing of personal data from the social media service in question, they should contact the person specified in article 2. of this document. The controller or the person specified in article 2. can then, when necessary, ask the subject of the data in writing to clarify their request. The subject of the data’s identity can also be verified, if necessary, before taking action on the request.