The Registrar

Plowing Group
Voimakatu 14
15170 Lahti Finland
Jyrki.kuisma@plowing.fi
+358405411177

Plowing Group (hereinafter Plowing Group) comprises the following subsidiaries and co-ownership companies:

• Plowing Oy (business ID: 1081691-9)
– www.plowing.fi
– www.smartox.fi
– www.smartox.eu

• Hämeen Kalustemekaniikka Oy (business ID: 0951042–9)
– www.h-km.fi

2. Contact person for register matters

Data Protection Officer
Jyrki Kuisma
Tel: +358405411177
Jyrki.kuisma@plowing.fi

Or by mail to

Plowing Oy
Voimakatu 14
15170 Lahti
Finland

3. Name of the register

Plowing Group’s customer and user register

4. Purpose and legal bases for the processing of personal data

Personal information is collected from customers and stakeholders for specific, explicit and legitimate purposes in order to fulfill their contractual obligations under the customer relationship. Without certain personal information, Plowing Group may not offer its products and services as requested by the customer, process orders, log in to a customer account, verify customer transactions, contact the customer in connection with the contract, provide technical support, technical brochures or invoice for its products and services.

Personal information will not be used, modified or transferred in any way other than as set forth in this Privacy Statement. The processing of personal data is based on Article 6 (1a) of the EU Data Protection Regulation (EU) 2016/679 the consent of the data subject and / or the legitimate interest of the controller in the processing of personal data in accordance with paragraph (1f).

5. Personal data to be processed

• Basic information (name, address, phone number, email address, etc.)
• The IP address, and cookies of the person visiting the website
• Billing, payment and collection information
• Online service login information, event and user analysis data
• Interests and other information provided by the registrant him- or herself
• Allocation data based on data from the Trade Register, Population Information System and other registers

6. Source of information

The personal data of the customer register is mostly obtained directly from the registrant him- or herself, when registrant:

• Register online or place an order for any of our products or services on our website
• Voluntarily complete a contact form on our website or provide feedback via email
• Use or view our website via his or her browser’s cookies or other similar technologies

The personal data is also collected from other sources such as:

• Publicly reliable sources such as (corporate websites, trade registers, credit registers, and other public and private registers, etc.)

7. Regular data releases

Plowing Group will not disclose any personal information in its possession to any third parties or automatically to other parties of Plowing Group. Plowing Group will disclose customer or stakeholder information to a designated party in an individual case if that party requests Plowing Group to do so or Plowing Group is required to retain some of the customer’s personal information in order to comply with accounting or other mandatory legislation. In this case, the retention of data is based on compliance with Plowing Group’s statutory obligation.

8. Disclosure and transfer of data outside the EU / EEA

Plowing Group will not automatically transfer the personal information in its possession to third countries or organizations. In an individual case, Plowing Group discloses the information to third countries or international organizations if the customer or stakeholder has required Plowing Group to do so mandatorily, and together with the Data Protection Officer and the Finnish Data Protection Authority, has assessed the risk and quality system of the third country or / and the international organization.

9. Data protection

Personal information that collected by Plowing Group is protected by firewalls, passwords and other technical means. Plowing Group shall take the necessary technical and organizational measures to protect personal data against unauthorized access and against accidental or unlawful destruction, alteration, disclosure, transfer or other unlawful processing. These measures will be reviewed and updated as necessary.

10. Rights of data subjects

Plowing Group would like to make sure that customers are fully aware of their data protection rights:

• The right to information: Customer has the right to be informed of the collection and processing of his or her personal data.
• The right to access: Customer has the right to request for copies of his or her personal data. We will charge a small fee for this service.
• The right to rectification: Customer has the right to request Plowing Group to correct any information that customer believes is inaccurate or incomplete.
• The right to erasure: Customer has the right to request that Plowing Group erase his or her personal data, under certain conditions.
• The right to restricting processing: Customer has the right to request that Plowing Group restrict the processing of his or her personal data, under certain conditions.
• The right to object to processing: Customer has the right to object Plowing Group’s processing of his or her personal data.
• The right to data portability: Customer has the right to request that Plowing Group transfer the personal data to another organization, or directly to the customer under certain conditions.
• The right to avoid automated decision making: Customer has the right not to be subject to a decision based solely on automated processing.

11. Data deletion and retention

Plowing Group deletes the personal data from the register when there is no business case for processing the data. Personal data is processed during the term of the customer relationship and thereafter for the time necessary to handle warranty and defect liabilities.

12. Approval of Privacy Statement and Cookie policy

Plowing Group reserves the right to change this Privacy Statement and cookie policy. The updated version of the privacy statement and cookie policy is published on Plowing Group websites. Customer accepts the amended terms and conditions by continuing to use Plowing Group’s services, therefore dose not require a signature or other active action from the customer.

Cookies:
• Plowing Group websites use cookies that recognize and remember user’s previous selected preferences. These could include customer’s language selection, location, etc. A mixed of first-party and third-party cookies are used.

• Plowing Group websites use cookies to collect information about user visit, the content user viewed, the links user followed and information about user’s browser, device, and IP address.