Privacy Policy
Introduction
Includia Leadership Oy (’Includia Leadership’) is a limited liability company registered in Finland that provides training and management consulting, its business focusing especially on consulting companies in creating and promoting a diverse and equal work environment. Includia Leadership complies with applicable data protection legislation for the processing of personal data, including the General Data Protection Regulation of the European Union (EU 2016/679) and the Data Protection Act (1050/2018).
In this Privacy Policy, we provide information on the processing of personal data when Includia Leadership collects and processes personal data as a data controller. In this Privacy Policy, we provide the following information, among other things, about the processing of personal data:
− Information on the data controller
− What kind of personal data Includia Leadership collects
− For what purposes the personal data is used for
− In what situations is personal information disclosed and
− What are the data subject's rights under the General Data Protection Regulation with regard to the processing of personal data.
This Privacy Policy may be updated in order to reflect possible changes in data processing practices. If you have any questions related to our processing of personal data or you wish to use your rights as a data subject, please contact us on the addresses below.
2. Data Controller
Name: Includia Leadership Oy
Business ID: 2847276-3
Address: Hiomotie 10
00380 HELSINKI
Contact person:
Jonna Louvrier
jonna.louvrier@includia.fi
3. Collection and use of personal data
For the purposes of this Privacy Policy we refer to the data we process as personal data. We primarily only collect and process personal data you provide directly to us (e.g. via the contact form on our website). We may also collect and process personal data through any personal correspondence you may have with us (e.g. phone calls, e-mails).
Examples of the data can be, but are not limited to,:
Basic information, such as:
First and last name
Contact information (e.g. e-mail)
Other information you directly provide us, such as:
Company name and title in the company.
Any other information relevant regarding the customer or business relationship
Survey data
4. The purposes and legitimate grounds of processing personal data
We process personal data for different legitimate grounds. This section describes the type of data processed as well as the legal grounds for processing it.
In a case where we process personal data based on your given consent, the consent can be withdrawn at any time by notifying us. If the processing is based on our legitimate interest, we will weigh your interest for privacy against our interest in accordance with the data protection laws.
We process personal data for different purposes:
To process contact requests and provide services
Includia Leadership processes personal data to be able to process contact requests for future partnerships. We also process data to maintain partnerships and customer relations and to be able to provide our services accordingly. Processing of this nature is based on the GDPR Article 6(1)b and 6(1)f.
To process data in relation to Diversity and Inclusion mapping surveys
Includia Leadership processes personal data to be able to execute mappings for clients. The mappings usually include surveys, which by default do not contain personally identifiable data. Includia Leadership also strives to remove any data that could make an individual identifiable. A survey participant can also opt out of collecting personal data. Processing of this nature is based on the GDPR Article 6(1)b.
For analyzing traffic on our websites and developing our services
Includia Leadership processes personal data for analytics on our websites. The analytics do not include data that could personally identify an individual, as we use aggregated data. Processing of this nature is based on the GDPR Article 6(1)a.
For complying with legal obligations
Includia Leadership processes personal data to comply with legal obligations. This could mean data is processed in order to comply with bookkeeping obligations or to provide information to authorities. Processing of this nature is based on the GDPR Article 6(1)c.
For claims handling and legal processes
Includia Leadership may process personal data to be able to respond to legal claims, such as claims handling, debt collection and other legal processes. Processing of this nature is based on the GDPR Article 6(1)c.
5. Transfer of personal data
We process personal data primarily within the EU area. However, we and/or our service providers may transfer personal data to or access it in jurisdictions outside the EU/EAA area.
We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of Personal Data to countries outside of the EEA through a series of agreements with our service providers based on the Standard Contractual Clauses.
For more information on the transfer of personal data, you can contact us by using the contact details indicated above.
6. Sharing of personal data
We only share personal data within Includia Leadership as far as reasonably necessary for the purposes of this Privacy Policy.
Includia Leadership does not disclose personal information to parties outside the company unless one of the following situations applies:
For the purposes set out in this Privacy Policy and to authorized service providers
We may provide your personal data to authorised service providers who perform services for us (e.g. data storage, accounting, sales and marketing service providers), provide the data based on your consent as well as supply data to third parties based on legal obligation or legitimate interest.
When personal data is processed by third parties as service providers on behalf of Includia Leadership, the appropriate contractual and organizational measures measures are taken to ensure that personal data is processed exclusively for the purposes specified in this Privacy Policy and in accordance with applicable laws and regulations. In addition, measures are taken to ensure personal data is treated according to our instructions and with appropriate confidentiality and security.
For legal reasons and legal process
We may share your personal data with third parties outside our organisation if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Includia Leadership, the partners or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If Includia Leadership is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all the partners concerned when the personal data are transferred or become subject to a different privacy policy.
With your excplicit consent
We may share your personal data with third parties outside Includia Leadership when we have your explicit consent to do so. You have the right to withdraw consent at all times.
7. Retention period of data
Includia Leadership does not store personal data longer than is legally permitted and necessary for the purposes of this Privacy Policy. The retention period depends on the nature of the information and on the purposes of processing, which means that the maximum period may vary.
Any data in relation to surveys executed by Includia Leadership is destroyed after the survey has been completed and the report of the survey has been accepted by the employer. By latest all survey related data is removed during six (6) months from the closure of the survey.
8. The rights of the data subjects under the General Data Protection Regulation
According to the General Data Protection Regulation, the data subject has the right to:
receive information on the processing of personal data, unless otherwise provided by law - check the personal data concerning themselves (GDPR Article 12 and 15)
rectify their personal data (GDPR Article 16)
right to erase their personal data (GDPR Article 17)
restrict the usage of their personal data (GDPR Article 18)
request the transfer of their personal data from one controller to another (GDPR Article 20)
withdraw their consent (GDPR Article 7(3))
to not be subject to automated decision-making (GDPR Article 22)
make a complaint to the Office of the Data Protection Ombudsman if the data subject considers that the processing of personal data concerning him or her has violated the applicable data protection legislation.
The data subject may exercise his or her rights by contacting Includia Leadership with the contact information referred to in this Privacy Policy. Includia Leadership also provides more information about the data subject’s rights. Includia Leadership will respond to inquiries, as a general rule, no later than one month after receipt of the request.