Combined register statement and information document (Finnish Personal Data Act (523/99) Sections 10 and 24)

Last modified September 7th, 2016

This Register Statement is prepared by Dream Broker Ltd with business ID 2092227-2 (”Dream Broker”) regarding personal data. All subsidiaries of Dream Broker also apply the principles and policies described herein.

This Register Statement covers Dream Broker’s personal data collection, processing and usage practices. This Register Statement does not apply to treatment of personal data, which is handled on behalf of Dream Broker’s customers subject to customer agreements and which Dream Broker may use to provide, maintain, protect, develop, and improve products and services, or to the products and services provided by third parties.

1. Controller Dream Broker Ltd.
Business ID 2092227-2

Tel. +358 10 232 7771
Energiakuja 3
FI-00180 Helsinki

2. Name of the register Dream Broker Customer and Contact register
3. Purpose of collection of personal data Dream Broker collects information for:

1)    Customership

  • providing the services and products;
  • developing existing customership, customer management and care;
  • managing customer data and providing technical and user support;
  • operational and contract management, administration, analysis and categorisation;
  • informing of changes, informing upon critical alerts and other such notices relating to our products and/or services;
  • targeting of customer communication and marketing;
  • communicating about Dream Broker’s services, enhancing sales and conducting market research;
  • registration to Dream Broker events; and
  • direct marketing.

2)    Dream Broker’s internal purposes and product development

  • analysis, reporting, development and personalisation of Dream Broker’s operations, services and products;
  • improving and developing security, services and products;
  • ensuring the quality and safety of the services and products;
  • statistical analyses; and
  • development and reporting related to the business operations.

3)    Other general objectives

  • preventing fraudulent activities;
  • fulfilling the obligations based on law and orders from authorities; and
  • removing or prohibiting sharing of illegal or infringing material.
4. Legal basis of collection of personal data Personal data is collected and processed based on the Finnish Personal Data Act Section 8 Paragraph (1)(2) and (1)(5), due to a contract to which the data subject is a party, or a relevant customer connection between the data subject and the operations of Dream Broker. Processing may also be based on data subject’s consent.
5. Content of the register Dream Broker will only collect personal data, which is needed for the purposes mentioned in section 3. At least the following information may be collected:

  • Basic information such as name, company/organisation, title, position and profession, address, e-mail address, phone number, language, username and password;
  • Records of purchases and downloads;
  • All created, shared, imported or posted content in video, audio, text and images and other media and related meta information;
  • Information regarding the use of the products and services;
  • Records of person’s consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data;
  • Records automatically created when a person visits online products or websites, such as IP-address, traffic source, pages visited, the links and features used, interactions, the content viewed or requested, device information, browser or application type and access times; and
  • Records of person’s participation in Dream Broker events.
6. Regular sources of personal data Dream Broker may collect personal data when data subject interacts with us or our business partners pursuant to our business, websites, services or products, buys our services or products, participates in a survey or campaigns, submits information through a web solution, by e-mail or by any other way.

Personal Data is received and gathered:

  • directly from the data subjects and customers (i.e. organisation represented by the data subject) when purchasing or using services or products, visiting our websites and otherwise interacting with Dream Broker;
  • from Dream Broker’s affiliates and distribution partners from whom a data subject (or organisation represented by the data subject) has purchased the services or products;
  • by using cookies and related technology or third party analytical software; and
  • from public sources such as Population Information System or other similar external sources or from Dream Broker’s customer database and third party contact information providers.
7. Regular destinations of disclosed data and whether the data is transferred to countries outside the European Union or the European Economic Area Dream Broker does not share, sell, rent or trade personal data with third parties for their promotional purposes.

Dream Broker may share personal data with third parties, which contribute to providing the services or products and with contracted service providers, so that these service providers can provide services on our behalf. Personal data may also be shared with and between Dream Broker’s affiliates.

Personal data may be disclosed to a third party during a negotiation of any merger or acquisition and the receiving party has undertaken to follow non-disclosure liabilities with respect to the disclosed information. Only the necessary personal data is shared with such third parties. In addition, personal data may be disclosed to authorities in cases required by mandatory local legislation or a court order. Data may also be disclosed if the disclosure is permitted by applicable law, regulation or agreement or consented by the data subject.

In addition, Dream Broker may also share general, demographic or aggregated information with third parties about data subject and the usage of websites, services and products, but that information will not include or be linked to any personal information without data subject’s consent.

Personal data may be transferred within the European Union or a country or organisation with guaranteed adequate level of protection as defined by the EU Data Protection Directive (95/46/EC), Finnish personal data Act (1999/523) or the European Commission.

8. Data Protection Principles The information security of personal data processing and confidentiality, integrity and usability are ensured with appropriate technical and administrative measures in accordance with Dream Broker’s information security principles.

Only designated employees and the employees and agents of companies operating on behalf of Dream Broker are entitled to handle the register and to maintain the data in it. Each designated user has his/her own personal user ID and password. Each employee of Dream Broker is under a duty of confidentiality for the information obtained by him or her.

9. Inspection right and correction of information Data subject has in accordance with Sections 26-28 of the Finnish Personal Data Act the right to verify what information about him/her has been recorded into the Dream Broker customer and contact register. Data subject may, in accordance with Section 29 of the Finnish Personal Data Act, request for correction of incorrect, unnecessary, incomplete or outdated data. Data subject must in the verification request specify the information to be corrected. The verification or correction request is to be signed and sent in writing to the Helpdesk described above.
10. Permissions or bans Data subject may forbid using information concerning him/her for direct marketing, distance selling or market and opinion surveys in writing to the Helpdesk.
11. Changes to Register Statement Dream Broker may change or update this Register Statement at any time. We recommend that you read the Register Statement from time to time.