Last update: [22.02.2022]
This Privacy Statement describes the principles according to which Tower Media Oy (hereinafter also Tower Media) collects and processes personal data. Personal data is any information related to an identified or identifiable person, such as name, email address, photo, or job title. Personal data is collected and processed in connection with, for example, Tower Media's employees and customers.
Tower Media processes personal data in accordance with this Privacy Statement and applicable data protection laws. The Privacy Statement may be updated as business or applicable laws change. The changes will take effect when Tower Media publishes an updated privacy statement on this site. The aim is to inform about other material changes in other ways as well.
Tower Media Oy
Business ID: 2181563-9
02130 Espoo, Finland
Contact in privacy matters:
As a data controller, Tower Media mainly collects and processes the following personal data for the purposes mentioned in this privacy statement:
Personal information about customers and potential customers, such as:
Name of the employer
As user information for customers using Tower Media's cNow system: name, e-mail, telephone, job title and employer company name
Personal information about employees, such as:
Employment contract and information contained therein
Information required for payroll and taxation
Personal information about shareholders, such as:
Information on shareholders required to maintain the statutory list of shares and shareholders
Tower Media processes personal data on lawful grounds only for pre-defined purposes. The main purposes and legal grounds for processing of personal data are:
Information on shareholders required to maintain the statutory list of shares and shareholders
Tower Media collects and processes personal information in order to provide and deliver its services and to fulfill its contractual obligations.
This includes, but is not limited to, normal customer management and communication, billing, collection, and customer support.
In these respects, the lawful basis for the processing of personal data is, in particular, the agreement between Tower Media and the customer, as well as the steps involved in preparing the agreement as well as Tower Media's legitimate interest.
Tower Media may also process the personal information of customer contacts that it deems potential for prospecting purposes..
Tower Media may also process personal information for customer communications.
In addition, Tower Media may process personal information for marketing purposes (including direct and digital marketing), to personalize advertising and content, and to form customer or user segments or profiles.
In these respects, the legal basis in the processing of personal data is, in particular, the legitimate interest of Tower Media and possibly also consent.
Based on a legitimate interest, Tower Media may send email marketing to the contacts of its customers or potential customers. In particular, where required by law, electronic direct marketing may also be based on consent. The marketing consent may be revoked at any time. Even if marketing does not require consent, a person can always forbid direct marketing to him-/herself.
Tower Media is constantly striving to develop products and services related to the provision of digital communication systems. This requires analyzing and monitoring the use of the services. Personal data may also be collected and processed for these purposes.
Personal data may also be processed to improve the quality of the service and to resolve technical problems.
In these respects, the legitimate basis for the processing of personal data is, in particular, the fulfillment of legal obligations and the legitimate interest of Tower Media.
Tower Media may also process personal information in order to fulfill legal obligations (including accounting, taxation, employment contract law), to respond to or prepare legal claims, or as required by a court or authority.
In this respect, the lawful basis for the processing of personal data is the fulfillment of a contract (employment contract) and the fulfillment of legal obligations related to the employment relationship, sometimes also the consent of the employee.
The provision of personal data is a prerequisite, in particular, for the conclusion of a contract and the fulfillment of legal obligations. In an employment relationship, Tower Media needs personal information to the extent that it is able to fulfill its obligations under employment contracts and the law. For potential clients and job seekers, the provision of personal information is largely voluntary. However, incomplete information may affect how Tower Media can handle a contact request, for example.
Profiling refers to any automatic processing of personal data in which, for example, a person's interests are assessed using personal data. Tower Media may use profiling primarily to target digital advertising. Profiling aims to make content and marketing more relevant and personal. However, a person has the right to object to the processing of personal data on the basis of a legitimate interest (including profiling for marketing purposes). Profiling in the context of Tower Media marketing does not include automatic decision-making that would have legal or other similar effects on the individual.
Tower Media obtains personal information about customers and potential customers mainly from the person him-/herself, including in connection with contacts, contracts, customer meetings and other situations in which the customer discloses their information. Information about potential customers may also be obtained from service providers that provide marketing registers, such as Posti. In the context of digital marketing, personal information may also be collected and processed, for example, from website visitors.
Information about employees is obtained primarily from the individual and, with his or her consent, from others, such as recruitment agencies or referrers.
Information about shareholders is obtained from the shareholders themselves.
Personal information will be processed by Tower Media personnel and Tower Media's subcontractors (eg, cloud service and server capacity providers) for the purposes set forth in this Privacy Statement. The data is maintained primarily in electronic form on the servers of third-party service providers. Tower Media may also use subcontractors in other areas such as digital marketing, CRM systems, financial management and invoicing. Subcontractors are contractual partners of Tower Media and are not entitled to use Tower Media's personal data for their own purposes. All personal information will be treated as confidential.
Otherwise, Tower Media may disclose personal information when required to do so by law, court or competent authority, in response to or in preparation for a legal claim, or if the person has consented to the disclosure. Tower Media may also disclose personal information if it is involved in a corporate or business transaction or other business or corporate arrangement.
Personal data may be transferred outside the EU, especially if the service provider used by Tower Media to store and process the data is located in a non-EU country. However, Tower Media will always ensure that the transfer of personal data outside the EU takes place using adequate safeguards as required by data protection law. This may mean, for instance, transferring personal data to a country approved by the EU Commission with adequate data protection or by concluding standard contractual clauses on the transfer of personal data published by the EU Commission.
Personal data is stored almost exclusively in electronic form and is protected in accordance with general industry standards. Tower Media will not use the personal information for any other purpose or disclose the information other than as described in this privacy statement. Tower Media's physical premises are also well protected and locked.
Tower Media will not retain personal information for longer than is necessary for its purpose or as required by contract or law. Personal data may also be deleted in the event that a person withdraws his/her consent or requests the deletion of his/her data (and Tower Media has no other legal basis for processing). Retention periods may also be governed by legislation (eg accounting, employment contract law) and the expiry of time limits for bringing legal actions. If necessary, Tower Media may also update or delete outdated or incorrect information.
Users can log in to the service and view and, in some cases, update or change their own information.
If Tower Media processes data on the basis of consent, the person may withdraw the consent at any time by giving notice, for example by contacting us using the contact details mentioned above.
A person has the right to receive confirmation from Tower Media whether it processes personal data about him or her and to find out what personal data Tower Media processes about him or her. In addition, the person has the right to receive additional information on the grounds for processing his or her personal data.
The person has the right to request that Tower Media correct any incorrect or outdated or otherwise incomplete personal data in this regard.
Even if Tower Media does not process personal information for direct marketing purposes on the basis of consent, a person may at any time refuse to process his or her personal information for direct marketing purposes, for example by contacting us using the contact information mentioned above.
If Tower Media processes personal data on the basis of a public interest or a legitimate interest, the person has the right to object to the processing of personal data to the extent that there is no compelling reason to suppress the person's rights or the processing is not necessary to meet a legal claim.
In certain circumstances, a person has the right to demand that Tower Media restrict the processing of personal data in this regard.
If Tower Media has processed the data on the basis of consent or in order to fulfill the agreement, the person has the right to receive the data provided electronically in one of the commonly used electronic formats so that the data can be transferred to another service provider.
A person may exercise the rights described above by contacting Tower Media using the contact information mentioned above. At the same time, Tower Media must use reasonable means to ensure identity so that information is not disclosed to outsiders. If a person considers that the processing of Tower Media's personal data is not lawful, he or she may also prepare a complaint to the competent supervisory authority (Office of the Data Protection Ombudsman / https://tietosuoja.fi/ ).