Privacy policy | Dilia Group Oy

Effective date: 21.11.2022

In the course of their business Dilia Group Oy, business ID 3307187-6, and its subsidiary companies (jointly “Dilia”), may process personal data relating to you. Dilia wants to ensure that your personal data is being handled adequately and in a manner that respects your privacy.

Personal data is any data which directly or indirectly relates to a natural person; e.g., name, phone number, and e-mail address.

You are not required to furnish any personal data with Dilia (except as allowed by mandatory laws), but if you do not do so, Dilia may not be able to undertake an engagement, send newsletters or invitations, process your job application and similar, and Dilia’s website’s functionalities may be limited.

It is important for Dilia to protect your personal data and to ensure that Dilia processes such data responsibly, in accordance with applicable laws. In this policy Dilia informs you, under each of the headings:

Personal data relating to assignments and projects (section A.);
Personal data relating to job applicants (section B.);
Personal data relating to contact persons of clients and Dilia’s co-operation partners (section C.);
Personal data relating to seminars and mailings (section D.);
Personal data relating to Dilia’s website’s visitors (section E.); and
Your related rights (section F.),

about, in case, the who is accountable (data controller) for the processing of personal data relating to yourself, the types of personal data Dilia may process and for which purposes and on which legitimate basis the data is collected.

Respectively Dilia informs you on the circumstances with whom the data will be shared, and how long your data may be maintained by Dilia. Dilia also informs you on the rights you have, and how to contact Dilia (the data controllers) if questions about this policy or Dilia’s processing of personal data arise.

A. Personal data relating to assignments and projects

When Dilia is appointed for an engagement, Dilia will collect, store and otherwise process personal data relating to you in accordance with this section A.

Each one of Dilia’s group companies are controllers for the processing relating to the engagements and projects carried out by its personnel, and is simultaneously processor for Dilia Group Oy and for the Dilia group companies involved in the engagement.

The personal data Dilia may process includes:

(i) On client that is a natural person: name, personal identification number or date of birth, contact information, passport copy or other identification document, as well as the engagement and previous client relationship related information.

(ii) On a legal person client (especially relating to contact person(s)): name, personal identification number or date of birth, job title, employer, contact details and passport copy or other identification document for contact person of the client, as well as of the beneficial owner(s) of the client, data in the trade register extract or similar for the client, as well as information on whether such beneficial owner a political exposed person.

(iii) On counterparty and other persons, the respective information as referred to under (i) – (ii) above, to the extent relevant.

The personal data is provided to Dilia by the client, or collected by Dilia from such persons or from private or public sources. The personal data referred to in (iii) above is collected only to the limited extent necessary for the purpose.

For which purposes and on which legal basis personal data may be processed:

For the purposes of processing conflict of interest checks and evaluating whether Dilia can undertake the engagement, and fulfilling Dilia’s legal, regulatory, and risk management obligations in general. Such processing is carried out on the basis of Dilia’s legitimate obligation to carry out such checks, and to the extent necessary for required by the Finnish legislation for prevention of money-laundering and terrorist financing and other mandatory legislation in Finland.
For the purposes of client invoicing.
For the purposes of carrying out the engagement.
For the purposes of statistics and analysing and developing of Dilia’s business.
In each case referred to above, personal data may be processed only for the purposes of executing the engagement and Dilia’s acting as legal representative and/or financial advisor of the client, and in each case only to the extent necessary for the purposes of the client’s legal or financial matters or claims.

The personal data will not be disclosed to any third parties except in the following situations:

To client’s insurer, auditor, counterparty and its counsel, an arbitral tribunal or a court of justice, a governmental entity or to a finance institution.
If instructed by client.
To Police of Finland or to finance institution to the extent Dilia is required to do so under the Finnish legislation for prevention of money-laundering and terrorist financing.
To Dilia’s professional liability insurer, auditor or accountants.
To client’s other advisors related to an assignment or project.

In general, no personal data will be transferred outside the EU/EEA. However, such transfer may take place if necessary in a specific situation for the purposes of the legal processing and project management.

Personal data will stored for as long as mandatory rules in Finland require Dilia to keep the file of the engagement, whereafter the data will be deleted. However, Dilia may store client information and counterparty information for the purposes of conflict checks.

B. Personal data relating to job applicants

When a person applies for a position with Dilia, Dilia may collect, store and otherwise process personal data relating to the applicant.

Each Dilia group company is controller for the processing relating to a job application.

The personal data Dilia may process comprises name, contact information, personal identification number or date of birth, sex, and other information related to a job application.

Personal data is provided to Dilia via e-mail or by a recruitment consultant and from private or public records and other sources.

Personal data may be processed for the purposes of carrying out the recruitment process, which is also the legal basis for such processing.

Personal data may be shared within Dilia group companies and to any recruitment consultant.

Personal data may be stored until the recruitment process is completed. If consented to, personal data may be processed for future recruitments as well.

C. Personal data relating to contact persons of clients and co-operation partners

If you are a contact person of a client or co-operation partner, or a potential client or co-operation partner of Dilia, Dilia may collect, store and otherwise process personal data relating to you in accordance with this section C.

Each Dilia group company is controller for the processing carried out by its personnel relating to its clients and co-operation partners, and is also processor for Dilia.

The personal data Dilia may process includes name, title, employer, contact details, as well as notes from meetings with you.

Personal data is provided to or collected by Dilia in connection with an assignment or project in accordance with section A. or is otherwise provided to Dilia by the client or the co-operation partner, or is collected by Dilia from such persons or from private or public records or other sources.

For which purposes and on which legal basis personal data may be processed:

In accordance with section A.
For the purposes of managing the relationship with the client or co-operation partner.
For the purposes of maintaining and developing the relationship with the client and co-operation partner, and, if you have not objected against, marketing Dilia’s services.
If you have consented thereto, your personal data may be processed for the purpose of using you as reference person for another client, co-operation partner or potential client or co-operation partner. Such processing is carried out on the basis of such consent.

The personal data may be shared within Dilia group companies.

Personal data will not be disclosed to any third parties except in the following cases:

Personal data may be disclosed in accordance with section A.
Personal data may be disclosed to a client, co-operation partner, or a potential client or co-operation partner who requests a reference about Dilia.

Personal data is stored in accordance with section A. to the extent the data is part of an assignment, and as long as the client or co-operation partner relationship is ongoing

D. Personal data relating to seminars and mailings

When you, through Dilia’s website, social media channels, by e-mail or otherwise notify Dilia of your interest of Dilia’s seminars or other events, newsletters or other mailings, or if you register for any of of those, Dilia may collect, store and otherwise process personal data relating to you in accordance with this section D.

Each Dilia group company is controller for the processing carried out by its personnel relating to mailings of newsletters or invitations etc. or relating to registration for seminars or events, and is simultaneously processor for Dilia and for Dilia group companies related to such mailings or registrations.

The personal data Dilia may process includes name, title, employer, contact details, information on areas of interest for newsletters and other mailings.

Personal data is provided to Dilia by yourself through Dilia’s website, Dilia’s social media channels, mailing system or otherwise.

For which purposes and on which legal basis personal data may be processed:

Personal data may be processed for the purpose of managing the invitations to and organizing seminars and events, as well as of newsletters and other mailings.

Personal data will in general not be disclosed to any third parties, except through a name tag of a seminar or event, or a list of attendees handed out in a seminar or event. No personal data will be transferred outside the EU/EEA.

Personal data may be stored until you unsubscribe for Dilia’s seminars, events, newsletters and other mailings.

E. Personal data relating to Dilia’s website’s visitors

When you use Dilia’s website, Dilia will collect, store and otherwise process personal data relating to you in accordance with this section E.

Each Dilia group company is controller for the processing relating to website visitors carried out by its personnel, and is also processor for Dilia and Dilia’s group companies.

The data Dilia may process includes IP address, e-mail address, webpages visited, time and duration of visit and information related to cookies.

Personal data is collected and created by cookies and respective technologies through your use of Dilia’s website. Please refer to Dilia’s cookie policy for further information on cookies and alternative browser settings.

Personal data may be processed for the purposes of analysing the use of Dilia’s website and developing it, which is also the legal basis of such processing.

Personal data will not be disclosed to any third parties, except that the personal data that is collected or generated by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States, and Google may disclose it to third parties if it is required by law or where such third parties process the information on Google’s behalf. Please refer to Dilia’s [click: cookie policy] for further information on this matter.

The data will be stored depending on by which cookie the relevant data has been collected. Please refer to Dilia’s [click: cookie policy] for further information.

F. Your related rights

You have the right to request information from Dilia regards Dilia’s use of your personal data.

You have always the right to have incorrect or incomplete personal data relating to you to be corrected by Dilia.

You have always the right to withdraw your consent to the processing of your personal data, as a whole or in part, which Dilia has collected based on Dilia’s legitimate interests, except if Dilia is entitled to processing by mandatory laws.

You have always the right to object against Dilia’s processing of your personal data for marketing purposes.

In certain situations, you have the right to request your personal data to be deleted by Dilia, e.g. where the personal data is no longer required for the purposes for which it was initially collected by Dilia.

In certain situations, you have the right to request that Dilia restricts the processing of your personal data, e.g. if you object against the accuracy of personal data, you can request Dilia to reduce processing of such data during the time it takes required to verify its correctness.

Dilia will update this policy from time to time by publishing changes on its website. If your consent is required, Dilia will make a clear respective request the next time you visit Dilia’s website.

If you have any questions relating to Dilia’s data processing policies or wish to exercise your rights, please contact privacy@dilia.fi.

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Effective date: 21.11.2022