Privacy notice

Drafted on 22 February 2024

“Vesku the Reindeer Contest” is a contest organised by Visit Finland, the Finnish travel promotion organisation, headquartered in Helsinki. Visit Finland is part of Business Finland and fully owned by the Finnish Government. This Privacy Policy describes:

• the ways we collect personal data about the participants (including winners and their travel companions or partners) of the contest and why we do so,
• how we use your personal data, and
• the choices you have about your personal data.
   

1. CONTACT INFORMATION OF THE CONTROLLER IN DATA PROTECTION MATTERS
Name: Business Finland Oy/Visit Finland (Business ID: 2725690-3)

(hereinafter “Visit Finland”, “Controller” or “we”)

Address: Porkkalankatu 1, 00180 Helsinki, Finland

Phone: Switchboard: +358 (0)29 50 55000

Email: dataprotection@businessfinland.fi
 

2. DATA WE COLLECT
We collect following data of all participants:

Data of all participants, such as:

• Data about your participation in the Contest, such as your Instagram account, data on you following @veskuthereindeer on Instagram, your answers in the contest, data about the evaluation of the answers and selection of winners,
• Device Data, such as your device IP address, device name and ID; operating system, browser type and language, data we collect with cookies and similar technologies, general location data based on your IP address.

The purpose of processing this data is to manage the contest, and to select the winners. The legal ground for processing is Our legitimate interest to organize and run the contest and manage the participant relationship. Legal ground for processing Device Data is Your consent.

Based on the participant relationship and Our legitimate interest, We also process all data above

• to the development of Visit Finland’s services, particularly marketing campaigns. All personal data will be aggregated so that individuals are not identifiable.
• to keep the participation safe and fair and to fight fraud by analyzing and monitoring the process and taking action against fraudulent or misbehaving participants.

Additional Data on the winners and their travel companions (partners) such as:

• Announcement of the winners and other communication between the winners and Visit Finland,

• Basic information such as name, date of birth, age, gender, nationality, communication language, time-zone, contact information (email address, home address, cellphone number), person to contact in emergency situations (name email address, home address, cellphone number)
• Identity documentation, e.g., a copy of passport
• Data on the travel and accommodation arrangements
• Copies of insurance certificates
• Information necessary for taxation

The purpose of processing this data is to award and deliver the prize, i.e. arrange the prize visit. The legal ground for processing is performance of Our contractual obligation as specified in the Terms of contest, and Our compliance with taxation or other legal obligations.

Your personal data shall not be processed for automated decision-making.
 

4. WHERE DO WE COLLECT THE DATA FROM
The data is collected directly from the participants as they take part in the contest, accept the prize, and make travel arrangements, or otherwise communicate with Visit Finland.
 

5. HOW YOUR PERSONAL DATA IS SHARED
Information may be disclosed within the framework of the Act on Innovaatiorahoituskeskus Business Finland and Business Finland Oy (1146/2017) to Innovaatiorahoituskeskus Business Finland.

Data may be disclosed to Visit Finland’s co-operation partners, other companies and organizations to make the travel and accommodation arrangements and to arrange visits and activities. It may be provided to public authorities to fulfill our legal obligations and in response to lawful requests.

Processing tasks may be outsourced to third party service providers. The contest will be run on Instagram platform. In addition, ICT services and communication, may be outsourced to external suppliers. Each supplier processes personal data only on behalf of Visit Finland to the extent necessary for the performance of its services subject to confidentiality obligations. The suppliers are bound by written agreements on the processing of personal data, including confidentiality and data security obligations.

Instagram may also collect and process Your personal data in accordance with its own privacy policies as an independent controller. Visit Finland is not liable for such processing by Instagram.

Otherwise, personal data will not be disclosed to third parties without the participant’s consent unless required by law.

Personal data may be transferred for processing to a country outside of the EU/EEA. Unless the European Commission has approved the adequacy of the data protection in the processing country, we will ensure the appropriate data protection by entering into written agreements with subcontractors under the standard contractual terms approved by the European Commission. The standard terms and conditions can be found at: https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.
 

6. PROTECTING AND RETAINING PERSONAL DATA
Any material to be retained on paper will be stored in locked facilities equipped with access control. The data controller’s personnel have undertaken confidentiality obligations.

Only persons who need personal data for the performance of their work are entitled to use the personal data and are bound by confidentiality obligations. Personal data is saved in databases that are protected by firewalls and anti-virus malware software, and other technical means. The databases are located in locked and guarded premises, and the data can only be accessed by pre-defined and designated persons.

We retain participant data until all contractual and legal rights and obligations related to the Contest and price visits have been fulfilled.

The data collected by using cookies will be deleted in accordance with the retention periods specified in connection with the cookie consents. 

We assess the need for the retention of personal data on a regular basis and take reasonable measures to ensure that no incompatible, outdated or incorrect personal data is retained.
 

7. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You may:

• Request access to the Personal Data that we process about you;
• Request that we correct or delete inaccurate or incomplete Personal Data about you;
• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
• Request transfer of Personal Data to you or a third party in situations provided by law.
• Object to our use of Personal Data about you where our use is based on or our legitimate interests.
• You can always withdraw your consent.

You do not have to pay a fee for exercising your rights and we will aim to respond you within 30 days. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes

If you consider that our processing of your personal data infringes applicable law, You may lodge a complaint with the relevant supervisory authority Data Protection Ombudsman in Finland.

In all questions concerning the processing of personal data and situations related to the exercise of the data subject’s rights, you should contact dataprotection@businessfinland.fi.