Description of the processing of personal data of customers and customer representatives of Bulevardi Jewellery (“Bulevardi”), updated 23.02.2023
1.
Diamor Oy
Eestinkallio 5F , 02280 Espoo
1.
Diamor Oy
E-mail: info@bulevardijewellery.com
Address: eestinkallio 5F , 02280 espoo
2. Personal data to be processed
BULEVARDI processes the following data necessary for BULEVARDI to operate and provide services to all BULEVARDI consumer customers:
– first name and surname
– First name and surname (first name and first name), first name and surname (first name and surname), contact details (postal address, telephone number, e-mail address).
– direct marketing authorisations and prohibitions.
– marketing and promotional information, such as marketing activities and participation in marketing activities targeted at the data subject (e.g. participation in promotional sweepstakes, contests and events)
– data relating to the management and communication of customer and other business relationships (e.g. purchase and cancellation of products and services, delivery information, feedback and complaints)
– changes to the information identified above
3. Purposes of processing of personal data
Personal data may be processed for the following purposes:
– Customer relationship management and administration, analysis and development, such as:
o servicing, repairing, making, delivering or otherwise performing a contract for a product
o to provide the services of the Boulevard
– to communicate with the customer, including customer communications;
– providing direct marketing by Boulevard;
– other similar uses that do not conflict with the uses described above.
4. Legal grounds for processing
4.1.
We process your personal data for the performance of a contract to which you are a party or for the performance of pre-contractual measures at your request. A contract arises when you purchase a service or product from Bulevardi.
4.2. Legitimate interest
Bulevardi’s right to process your personal data is partly based on the legitimate interest created by the customer relationship. Legitimate interest is the processing ground for the processing of personal data for marketing and communication purposes.
We have carried out a balancing of interests, on the basis of which we have concluded that the fundamental rights and freedoms of data subjects do not override the legitimate interest of Bulevardi to process personal data based on the customer relationship. You have the right to object at any time, on grounds relating to a particular personal situation, to processing of personal data based on a legitimate interest pursued by Boulevard. In such cases, we will assess whether there are substantial and legitimate grounds for continuing to process the personal data which override your rights and interests.
5. Recipients or categories of recipients of personal data
Personal data will be disclosed within the limits permitted and required by applicable law. As a rule, data will be disclosed to the competent authority, such as the tax authority.
Personal data are not regularly disclosed for purposes other than those mentioned above. However, Bulevardi is entitled, to the extent permitted by law, to disclose personal data, for example in situations related to the sale of business.
The processing of personal data is outsourced to the following service providers, who process personal data on behalf of Bulevardi:
– IT software systems provider
– Accounting firm
6. Transfer of personal data to third countries
Personal data are not transferred outside the EU and EEA.
7. Retention periods for personal data
Personal data will be kept for as long as necessary for the purposes for which the personal data are processed or for compliance with legal obligations.
– Bulevardi will retain the personal data of the consumer-customer for as long as the customer’s relationship with Bulevardi continues and for 20 years after the purchase of the service or product. The retention period is based on the typically long lifetime of Bulevardi’s products. The data is retained in order to provide the highest possible quality of customer service.
– Bulevardi will retain personal data processed for direct marketing purposes until the data subject explicitly declines to receive direct marketing. At that time, Bulevardi will retain information about the marketing ban unless the data subject objects to such processing.
– Bulevardi will retain all accounting information for 6 years from the end of the calendar year in which the accounting period ends.
8. Rights of the data subject
You can exercise your rights described below by contacting us either by e-mail:
info@bulevardijewellery.com
or by post to Data Protection, eestinkallio 5f , 02280 espoo
Please note that we may, if necessary, ask you to provide additional information to confirm your identity.
8.1. Right of access to data
You have the right to obtain confirmation from Boulevard whether we are processing personal data concerning you. You also have the right to access personal data concerning you and to be informed about the processing of your personal data in accordance with the GDPR.
We will not give you access to information that is a trade secret or confidential information of Bulevard or information that could violate the privacy of another person.
When you exercise your right of access, we will provide you with a copy of the personal data we process about you. If you request more than one copy, we may charge a reasonable fee based on administrative costs. If you make a request electronically, we will provide you with the information in a commonly used electronic format, unless you request delivery orally or on paper.
8.2 Right to rectification
You have the right to ask us to correct or complete inaccurate or incorrect information about you without undue delay. We may ask you to provide further clarification if we need additional information, for example, to verify your identity or to confirm the accuracy of new information you have provided.
8.3. Right to erasure
You have the right to have Bulevardi delete personal data concerning you without undue delay if:
– the personal data is no longer needed for the purposes for which it was collected or otherwise processed (for example, if you are no longer a customer);
– you object to the processing of your personal data on grounds relating to your particular personal situation and there are no legitimate grounds for the processing or you object to the processing of your personal data for direct marketing purposes;
– Bulevardi has unlawfully processed the personal data; or
– the personal data must be erased in order for Bulevardi to comply with an applicable legal obligation.
– We will assess your rights and our ability to erase on a case-by-case basis. We will endeavour to respect your wishes and your right to erasure to the extent permitted by law.
8.4. Right to restriction of processing
You have the right to request that we restrict the processing of your personal data so that, in addition to storage, the personal data may only be processed with your consent or for the establishment, exercise or defence of legal claims or the protection of another person’s rights where:
– you contest the accuracy of your personal data, in which case we will restrict processing for the time necessary to verify the accuracy of the data;
– we are processing your personal data unlawfully and you object to the erasure of the personal data and instead request the restriction of the use of the personal data;
– Bulevardi no longer needs the personal data for processing purposes and we would otherwise delete your data, but you need it to establish, exercise or defend a legal claim; or
– you have objected to the processing of your personal data on grounds relating to your particular personal situation and are awaiting a determination as to whether the legitimate interests of Bulevardi override the grounds for your objection.
8.5. Right to data portability
If you have provided your personal data to us by becoming a customer, you have the right to receive such personal data in a structured, commonly used and machine-readable format and the right to transfer such data to another controller, to the extent that:
– we carry out the processing automatically; and
– the processing is either based on your consent (as in the case of a subscription to a newsletter, if any) or the processing of your personal data is necessary for the performance of a contract.
The right to data portability is limited to a procedure that does not adversely affect the rights or freedoms of others. We will not provide or transfer to you or to another controller personal data of other persons or information that is a trade secret of Boulevard.
You do not have the right to transfer information from one system to another where such personal information is processed for the legitimate interests of Boulevard.
8.6. Right to object to the processing of personal data
You have the right to object to the processing of your personal data on grounds relating to your particular situation, provided that our processing is based on a legitimate interest and there is no compelling legitimate ground for our processing which overrides your rights and freedoms.
9. the right to lodge a complaint with a supervisory authority
The data subject has the right to lodge a complaint with the Data Protection Supervisor if the data subject considers that Bulevardi has infringed the applicable data protection legislation in the processing of personal data and that the processing of personal data infringes the data subject’s rights under the GDPR.
10. Where was the personal data obtained (if not from the data subject)?
Bulevardi collects personal data only from the data subject.
11. Security of processing of personal data
Personal data in electronic form is protected by technical means generally accepted in the information security industry, such as firewalls and passwords.
Manual files containing personal data are kept in locked premises, which are inaccessible to unauthorised persons.
Only identified employees of Bulevardi and companies acting on its behalf and for its account have access to personal data.