We process personal data about you when you visit Kielo’s website, are a tenant, have a parking space or another right of use in one of the properties owned by Kielo’s subsidiaries, in connection with use of Kielo’s whistleblower function or otherwise are in contact with Kielo. More information about Kielo’s whistleblower function can be found here. Kielo is committed to your privacy and to protecting the personal data we process about you. All processing of personal data takes place in accordance with the General Data Protection Regulation (EU) 2016/679 and other applicable privacy protection law.
Your privacy is important to Kielo and you are therefore encouraged to read the information that concerns you about the processing of your personal data.
The parent company of Nyfosa Finland AB, reg. no. 559313-6327 (“Kielo”) is Nyfosa AB, reg. no. 559131-0833 (the “Kielo Parent“), which is the data controller for the processing of your personal data as described in this privacy notice.
If you have entered into, or applied to enter into, a lease agreement with one of Kielo Parent’s subsidiaries (a real estate company) (the “Landlord“), Kielo Parent and the Landlord are joint data controllers for the processing of your personal data. This also applies if you enter into another type of agreement (such as agreements for a parking space or another type of right of use, or other forms of agreements) with one of Kielo Parent’s subsidiaries (the “Subsidiary). The Subsidiary/Landlord and Kielo Parent have agreed on the allocation of responsibility for the processing of your personal data. If you want to know more about the Subsidiary’s/Landlord’s and Kielo Parent’s division of responsibility, you can contact Kielo and/or Kielo Parent via the contact details stated below under Section ”Contact us”.
Personal data is any information that can be directly, or indirectly together with other data, linked to a living natural person. Processing of personal data means any activity performed on your personal data, such as the collection, management, storage, use, transfer, or erasure of your personal data.
The personal data that is processed about you is partly data that you yourself provide to Kielo Parent or the Subsidiary/Landlord, partly data Kielo Parent or the Subsidiary/Landlord creates itself, and partly data that is obtained from other sources, for example from public registers or through Kielo’s whistleblower function.
Processors of personal data who process personal data on behalf of Kielo Parent/Subsidiaries
In order to fulfil the purposes of the processing of your personal data as set out above under Section under “If you represent a company/You as a private individual” Kielo Parent/the Subsidiary/the Landlord will share personal data with service providers and other actors who will process your personal data on behalf of Kielo Parent/the Subsidiary/the Landlord in the capacity of data processor. Such data processors may be, for example, asset managers that provide property and tenant relationship management services, a contractor who will repair something on your premises, a company that provides internet or electricity, or a supplier of IT systems (e.g., ERP system provider). Such processors are located mainly in EEA and more specifically in Finland. Kielo Parent/the Subsidiary/the Landlord always enters into agreements with data processors to ensure that they only process your personal data in accordance with the instructions and purposes communicated by Kielo Parent/the Subsidiary/the Landlord.
Disclosure of personal data to other data controllers
Purpose
Comply with legal obligations and respond to the interest of public authorities in the processing.
To establish, defend or exercise legal claims.
Categories of recipients
Legal basis
Legal obligation. The disclosure of your personal data is necessary for Kielo Parent/the Subsidiary/the Landlord to fulfil our legal obligations.
Legitimate interest. The disclosure is necessary to meet our legitimate interest in the processing in question (e.g., right to establish, defend or exercise legal claims).
Legitimate interest. The disclosure is necessary to enable Kielo Parent/the Subsidiary/the Landlord to satisfy the legitimate interest of being able to establish, defend or exercise legal claims.
Transfer of personal data outside the EU/EEA
Generally, your personal data is only processed within the EU/EEA. Should Kielo Parent/the Subsidiary/the Landlord in any situation have a service provider that provides services from a country outside the EU/EEA and if this would mean that your personal data is processed in a country outside the EU/EEA, Kielo Parent/the Subsidiary/the Landlord ensures that there is a legal basis for such transfer as provided in Chapter V of the EU’s General Data Protection Regulation (2016/679) (“GDPR”), including where the European Commission have deemed the country to provide an adequate level of protection for personal data; or by use of specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data essentially equivalent protection as it has in Europe.
Kielo Parent/the Subsidiary/the Landlord also ensures, when necessary, that additional technical and organizational measures are taken to further protect the personal data that is the subject of the transfer.
If you require further information about on our current data processors established outside the EU/EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by using the contact details provided below in Section Contact Us.
You have several rights in relation to the processing of your personal data. You may at any time submit a request to exercise these rights by contacting Kielo Parent at the contact details set out below.
When Kielo Parent/the Landlord/the Subsidiary receives a request to exercise a right, Kielo Parent/the Landlord/the Subsidiary will investigate your request and assess whether the conditions are fulfilled to grant the request. Kielo Parent/the Landlord/the Subsidiary will notify you by email if Kielo Parent/the Landlord/the Subsidiary (i) needs additional information, (ii) if your request is rejected (and why), or (iii) grants your request.
If you would like to exercise any of these rights, please contact Kielo Parent at [email protected].
Kielo may change or update this privacy notice from time to time. The latest version of the privacy notice is always available on Kielo’s website www.kielotoimitilat.fi. In case of changes that are significant and require your consent, Kielo will inform you of this and ask for your consent.
If you have any questions regarding the processing of your personal data, please send an email to [email protected].
If the company you represent is in the queue for renting premises or submits an expression of interest, the Landlord and Kielo Parent process personal data about you as a contact person in order to administer your place in the queue or your expression of interest.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent have a legitimate interest in being able to administer and manage expressions of interest and the queuing system.
Retention period: Your personal data is processed for this purpose as long as the registered interest remains or until the company you represent is offered a premises. However, when you stop acting as a representative of the company, your personal data is deleted.
When a company that you represent is offered to rent premises, the Landlord and Kielo Parent need to process personal data about you as a representative of the company. Your personal data is processed in order to ensure that you and the company meet the requirements that the Landlord and Kielo Parent impose on tenants in order to enter into a lease agreement, e.g. regarding creditworthiness.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent need to process your personal data in order to evaluate that the company you represent is a suitable tenant to enter into an agreement with.
Legal basis for storing credit information
Legitimate interest: If you have been refused a lease agreement, Kielo Parent has a legitimate interest in saving credit information, information from debt collection companies and authorities in order to be able to defend any legal claims.
Retention period: Your personal data which is processed for this purpose is retained as long as the data is up to date and relevant for the lease process i.e., until it is ensured that the tenant prerequisites are met and a lease agreement is concluded. Credit information and information from debt collection companies and authorities are not stored. However, when you stop acting as a representative of the company, your personal data is deleted.
During the time that the company you represent is renting premises, the Landlord and Kielo Parent will process personal data about you as a representative in order to administer the lease agreement.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent process personal data about you as a representative of a company in order to fulfil and administer the agreement entered into with the company you represent.
Retention period: Your personal data is processed for this purpose for the duration of the lease agreement and for a maximum of 24 months after the tenant has left the rented premises in order to establish, defend or exercise any legal claims. However, when you stop acting as a representative of the company, your personal data is deleted.
The Landlord and Kielo Parent may process personal data about you if you have received keys in electronic key systems to gain access to the common areas of the property.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent process personal data based on our legitimate interest to manage access to premises or common areas.
Retention period: Your personal data is processed for this purpose until you return the key.
If the company you represent is in a queue for a parking space or for another right of use or makes an expression of interest for a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent process personal data about you as a contact person in order to administer your place in the queue or expression of interest.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent has a legitimate interest in being able to administer and manage expressions of interest and the queuing system.
Retention period: Your personal data processed for this purpose as long as the registered interest remains or the company you represent has been offered a parking space or another right of use. However, when you stop acting as a representative of the company, your personal data is deleted.
When a company that you represent is offered a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent need to process personal data about you as a representative of the company. Your personal data is processed to ensure that the company you represent meets the requirements set by the Subsidiary/Landlord and Kielo Parent in order to enter into a parking space or another right of use agreement.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent need to process your personal data in order to evaluate that the company you represent is suitable to enter into an agreement with.
Retention period: Your personal data processed for this purpose will be retained for as long as it is up to date and relevant for the purpose of ensuring that the agreement prerequisites are met and concluding a parking space or another right of use agreement. However, when you stop acting as a representative of the company, your personal data is deleted.
During the time that the company you represent has a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent will process personal data about you as a representative in order to administer the agreement.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent process personal data about you as a representative of a company in order to fulfil and administer the agreement entered into with the company that you represent.
Retention period: Your personal data is processed for this purpose for the duration of the contractual relationship and for a maximum of 24 months after the tenant has left the rented object in order to establish, defend or exercise any legal claims. However, when you stop acting as a representative of the company, your personal data is deleted.
In exceptional cases, Kielo Parent or the Subsidiary/Landlord uses camera surveillance on the property and/or the premises. When camera surveillance is being used, this is indicated by signs inside and/or outside the property. Camera surveillance is used to provide security by preventing crime and other disturbances.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent process personal data about you as a result of camera surveillance for the legitimate purpose of being able to prevent and deter crime and other disturbances in connection with premises.
Retention period: The recorded material is stored for a maximum of 72 hours. In some cases, the material may be stored for a longer period in order to establish, defend or exercise any legal claims if there are reasons to suspect that the recorded material has captured e.g., crimes, vandalism or other disturbances.
If Kielo Parent sells the real estate company which is the Landlord of the company that you represent or which the company you represent has previously had a lease or another right of use agreement with, personal data may be processed and transferred to the buyer. Kielo Parent also continues to process your personal data for some time after the sale has been completed.
Categories of personal data
Legal basis
Legitimate interest. Kielo Parent processes your personal data to manage the sale and transfer of your agreement from the seller to the buyer.
Retention period: Your personal data is processed for this purpose for up to 18 months after the sale is completed to ensure that the transfer of your agreement is duly managed and completed. Your personal data may also be stored in order for Kielo Parent to be able to establish, defend or exercise any legal claims in connection with the sale for a maximum of 24 months from the sale. However, when you stop acting as a representative of the company, your personal data is deleted.
When you are in contact with Kielo or Kielo Parent by phone or email and thereby provide personal data, your personal data is processed in order to handle your requests and offer you adequate service.
Categories of personal data
Legal basis
Legitimate interest. Kielo and Kielo Parent processes your data to be able to offer adequate service when you contact Kielo or Kielo Parent and to be able to process requests as needed.
Retention period: Your personal data is processed for this purpose for a maximum period of twelve (12) months.
Kielo processes personal data about you if you, during your visit at Kielo, connect to the network in Kielo’s premises.
Categories of personal data
Legal basis
Legitimate interest. Kielo processes your data to be able to offer adequate service and to be able to process requests as needed when you visit our premises.
Retention period: Your IP address and location information are stored for three (3) months.
Kielo processes personal data when you contact Kielo via our digital channels (e.g. our website or our social media platforms such as LinkedIn and X (former Twitter)) in order to be able to handle your inquiries and offer you adequate service. Depending on your choices and settings regarding cookies when you visit Kielo’s website, some personal data may be collected for statistical purposes. Read more about Kielo’s use of cookies in Kielo’s cookie-policy.
Categories of personal data
Legal basis
Legitimate interest. Kielo processes your data to be able to offer adequate service when you contact Kielo and to be able to process requests as needed.
Retention period: Your personal data processed for this purpose is deleted annually. Your IP address and location information are stored for up to 14 months.
Kielo Parent and the Subsidiary process personal data about you if you enter into an agreement with Kielo Parent and/or the Subsidiary as a representative of a supplier or partner or if you are a contact person for such a supplier or partner.
Categories of personal data
Legal basis
Legitimate interest. Kielo Parent and the Subsidiary process your personal data for the legitimate interest of being able to administer and fulfil the agreement with the supplier or partner that you represent or are a contact person for.
Retention period: Your personal data is processed for this purpose for the duration of the contractual relationship and also after the contractual period to the extent necessary for Kielo Parent’s/the Subsidiary’s legitimate interest in retaining contractual history and for a maximum of 10 years after the end of the validity of the agreement.
When you submit your personal data, or when someone else submits information that contains your personal data or that can indirectly identify you, in Kielo’s whistleblower function, Kielo Parent processes your personal data in order to handle the submission and investigate a potential misconduct or malpractice. Information submitted to the function may also include personal data of third parties and during the investigation, Kielo Parent may process personal data of other persons who are linked to the potential misconduct or malpractice. More information about Kielo’s whistleblower function can be found here.
Categories of personal data
Legal basis
Legal obligation. If the subject of the reported matter falls under the Finnish Act on the Protection of Persons Reporting Infringements of European Union and National Law (the “Whistleblower Act”) (1171/2022), personal data is processed to comply with the provisions of the Whistleblower Act.
Legitimate interest. If the subject of the report does not fall under the Whistleblower Act, Kielo has a legitimate interest to process personal data to ensure that Kielo’s and Kielo Parent’s business is carried out in compliance with applicable laws and Kielo Parent’s ethical guidelines and to handle any HR related implications.
Legal basis for sensitive personal data
The establishment, exercise or defence of legal claims. If Kielo processes sensitive personal data about you in connection with a whistleblower case, e.g. health data or criminal data, Kielo does so, depending on the situation, because the processing is necessary for reasons of substantial public interest, or is necessary for the purposes of carrying out the obligations and exercising specific rights in the field of employment, or is necessary in order to establish, defend or exercise a legal claim.
Retention period: Personal data will normally be stored for 30 days from the completion of the investigation but in no case longer than two years unless further storage is necessary due to the Whistleblower Act or other legislation, or if storage is necessary to establish, defend or exercise legal claims. Personal data that is not relevant for the investigation will be deleted without undue delay.
Kielo, Kielo Parent and/or Landlord/Subsidiary process your personal data in order for them to fulfil legal storage obligations under e.g., the Finnish Accounting Act (1336/1997).
Categories of personal data
All personal data described above that may be relevant to the legal obligation.
Legal basis
Legal obligation. Kielo, Kielo Parent and Landlord/Subsidiary process your personal data to the extent required to fulfil our legal obligations concerning e.g., accounting.
Retention period: Your personal data is processed for this purpose as long as Kielo, Kielo Parent and/or Landlord/Subsidiary have a legal storage obligation to process it for e.g., accounting purposes: according to the Finnish Accounting Act, documents that may include your personal data must be stored for accounting and tax purposes for 6 full fiscal years after the expiry of the year in which the transaction relates.
If you are in a queue to rent a residence or make an expression of interest in renting a residence, the Landlord and Kielo Parent process your personal data in order to administer your place in the queue or your expression of interest.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent has a legitimate interest in being able to administer and manage expressions of interest and the queuing system.
Retention period: Your personal data is processed for this purpose as long as your registered interest remains, or you have been offered to rent a residence.
When you are offered to rent a residence, the Landlord and Kielo Parent need to process personal data about you to be able to assess whether you meet the requirements that the Landlord and Kielo Parent impose on tenants in order to enter into a lease agreement.
Categories of personal data
Legal basis
Agreement. The Landlord and Kielo Parent need to process your personal data to be able to evaluate that you are a suitable tenant to enter into an agreement with.
Legal basis for storing credit information
Legitimate interest: If you have been refused a lease agreement, Kielo Parent has a legitimate interest in saving credit information, information from debt collection companies and authorities in order to be able to defend any legal claims.
Retention period: Your personal data processed for this purpose is retained as long as it is up to date and relevant for the lease process i.e., until it is ensured that the tenant prerequisites are met and a lease agreement is concluded. Credit information and information from debt collection companies and authorities are not stored.
While you are renting a residence as a private individual, the Landlord and Kielo Parent will process personal data about you in order to be able to administer the lease agreement, administrative matters and any disturbance cases concerning you or other tenants.
Categories of personal data
Legal basis
Agreement. The Landlord and Kielo Parent process your personal data in order to fulfil and administer the lease agreement with you as a tenant.
Legal basis for sensitive personal data
Legal claims: If Kielo Parent processes sensitive personal data about you in connection with a disruption case, e.g. health data, Kielo Parent does so because the processing is necessary to establish, defend or exercise legal claims.
Retention period: Your personal data is processed for this purpose for the duration of the lease agreement and for a maximum of 24 months thereafter in order to establish, defend or exercise any legal claims.
The Landlord and Kielo Parent may process personal data about you if you have received keys in an electronic key system to gain access to the common areas of the property.
Categories of personal data
Legal basis
Legitimate interest. The Landlord and Kielo Parent process personal data based on our legitimate interest to manage access to properties or common areas.
Retention period: Your personal data is processed for this purpose until you return the key.
If you are in a queue for a parking space or for another right of use or make an expression of interest for a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent process personal data about you in order to be able to administer your place in the queue or your expression of interest.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent have a legitimate interest in being able to administer and manage expressions of interest and the queuing system.
Retention period: Your personal data is processed for this purpose as long as your registered interest remains, or until you have been offered a parking space or another right of use.
When you are offered a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent need to process personal data about you in order to assess whether you meet the requirements set by the Subsidiary/Landlord and Kielo Parent in order to enter into an agreement for a parking space or another right of use.
Categories of personal data
Legal basis
Agreement. The Subsidiary/Landlord and Kielo Parent need to process your personal data in order to evaluate your suitability to enter into an agreement.
Legal basis for storing credit information
Legitimate interest: If you have been refused a lease agreement, Kielo Parent has a legitimate interest in saving credit information, information from debt collection companies and authorities in order to be able to defend any legal claims.
Retention period: Your personal data processed for this purpose is stored for as long as it is up to date and relevant in order to ensure that agreement prerequisites are met and enter into an agreement on a parking space or another right of use. Credit information and information from debt collection companies and authorities are not stored.
While you as a private individual rents a parking space or another right of use, the Subsidiary/Landlord and Kielo Parent will process personal data about you in order to administer the agreement.
Categories of personal data
Legal basis
Agreement. The Landlord and Kielo Parent process your personal data to be able to fulfil and administer the agreement with you.
Legal basis for storing data
Legitimate interest: Kielo Parent has a legitimate interest to store data in order to establish, defend or exercise any legal claims.
Retention period: Your personal data is processed for this purpose for the duration of the agreement and for a maximum of 24 months thereafter in order to establish, defend or exercise any legal claims.
In exceptional cases, Kielo Parent or the Subsidiary/Landlord uses camera surveillance to monitor premises. Where camera surveillance can be used, this is indicated by signs inside and/or outside the property. Camera surveillance is used to provide security by preventing crime and other disturbances.
Categories of personal data
Legal basis
Legitimate interest. The Subsidiary/Landlord and Kielo Parent process personal data about you as a result of camera surveillance for the legitimate purpose of being able to prevent and deter crime and other disturbances in connection with properties.
Retention period: The recorded material is stored for a maximum of 72 hours. In some cases, the data may be stored for a longer period in order to establish, defend or exercise any legal claims, if there are reasons to suspect that the recorded material has captured e.g., crimes, vandalism or other disturbances.
If Kielo Parent sells the real estate company that is your Landlord or which you previously have had a lease or another right of use agreement with, personal data may be processed and transferred to the buyer. Kielo Parent also continues to process your personal data for some time after the sale has been completed.
Categories of personal data
Legal basis
Legitimate interest. Kielo Parent processes your personal data to manage the sale and transfer of your agreement from the seller to the buyer.
Retention period: Your personal data is processed for this purpose for up to 18 months after the sale is completed to ensure that the transfer of your agreement is duly managed and completed. Your personal data may also be stored in order for Kielo Parent to be able to establish, defend or exercise any legal claims in connection with the sale for a maximum of 24 months from the sale.
When you are in contact with Kielo or Kielo Parent by phone or email and thereby provide personal data, your personal data is processed in order to handle your requests and offer you a satisfactory service.
Categories of personal data
Legal basis
Legitimate interest. Kielo or Kielo Parent processes your data to be able to offer an adequate service when you contact Kielo or Kielo Parent and to be able to process requests as needed.
Retention period: Your personal data is processed for this purpose for a maximum period of twelve (12) months.
Kielo processes personal data about you if you connect to the network in Kielo’s premises during your visit to Kielo.
Categories of personal data
Legal basis
Legitimate interest. Kielo processes your data to be able to offer an adequate service and to be able to process requests as needed when you visit our premises.
Storage period: Your IP address and location information are stored for three (3) months.
Kielo processes personal data when you contact Kielo via our digital channels (e.g. our website or our social media platforms such as LinkedIn and X (former Twitter)) in order to be able to handle your inquiries and offer you an adequate service. Depending on your choices and settings regarding cookies when you visit Kielo’s website, personal data may be collected for statistical purposes. Read more about Kielo’s use of cookies in Kielo’s cookie-policy.
Categories of personal data
Legal basis
Legitimate interest. Kielo processes your data to be able to offer an adequate service when you contact Kielo to be able to process requests as needed.
Retention period: Your personal data is processed for this purpose is deleted annually. Your IP address and location information are stored for up to 14 months.
When you submit your personal data, or when someone else submits information that contains your personal data or that can indirectly identify you, in Kielo’s whistleblower function, Kielo Parent processes your personal data in order to handle the submission and investigate the potential misconduct or malpractice. Information submitted to the function may also include personal data of third parties and during the investigation, Kielo Parent may process personal data of other persons who are linked to the potential misconduct or malpractice.
More information about Kielo’s whistleblower function can be found here.
Categories of personal data
Legal basis
Legal obligation. If the subject of the reported matter falls under the Finnish Act on the Protection of Persons Reporting Infringements of European Union and National Law (the Whistleblower Act) (1171/2022), personal data is processed to comply with the provisions of the Whistleblower Act.
Legitimate interest. If the subject of the report does not fall under the Whistleblower Act, Kielo has a legitimate interest to process personal data to ensure that Kielo’s and Kielo Parent’s business is carried out in compliance with applicable laws and Kielo Parent’s ethical guidelines and to handle HR related implications.
Legal basis for sensitive personal data
The establishment, exercise or defence of legal claims. If Kielo processes sensitive personal data about you in connection with a whistleblower case, e.g. health data or criminal data, Kielo does so, depending on the situation, because the processing is necessary for reasons of substantial public interest, or is necessary for the purposes of carrying out the obligations and exercising specific rights in the field of employment, or is necessary in order to establish, defend or exercise a legal claim.
Retention period: Personal data will normally be stored for 30 days from the completion of the investigation but in no case longer than two years unless further storage is necessary due to the Whistleblower Act or other legislation, or if storage is necessary to establish, defend or exercise legal claims. Personal data that is not relevant for the investigation will be deleted without undue delay.
Kielo, Kielo Parent and/or the Landlord/Subsidiary process your personal data in order for them to fulfil legal storage obligations under e.g., the Finnish Accounting Act (1336/1997).
Categories of personal data
All personal data described above that may be relevant to the legal obligation.
Legal basis
Legal obligation. Kielo, Kielo Parent and/or the Landlord/Subsidiary process your personal data to the extent required to fulfil our legal storage obligations concerning e.g., accounting.
Retention period: Your personal data is processed for this purpose as long as Kielo, Kielo Parent and/or the Landlord/Subsidiary have a legal storage obligation to process it for e.g., accounting purposes: according to the Finnish Accounting Act, documents that may include your personal data must be stored for accounting and tax purposes for 6 full fiscal years after the expiry of the year in which the transaction relates.
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