Fazer Privacy Statement



Updated 9.12.2019. Click here to see recent changes to this Policy.

This Privacy Statement describes how the personal data of consumers and the contact people of companies, other organisations and stakeholders is processed by Fazer Group companies in the context of their business.

In the general section we go through the processing of data and your rights in general. You can quickly and easily see from the service-specific information how we process your personal data in the services you are using.

Our key values include customer focus and quality: we process your data responsibly, and we want to be worthy of your trust. You can influence the way in which your data is processed. In this Privacy Statement, we tell you about your rights and how to exercise them.

Your data will be stored when you make an agreement or otherwise use our services, for instance, when you register as a user of our service, give us your consent to send you marketing messages, purchase products from an online store, use web or mobile services, participate in a marketing campaign or survey, provide feedback or contact our customer service.

We process your data in the course of fulfilling an agreement or implementing our services, in our marketing and customer communication, as well as in our customer services. In addition, we use the data to target our marketing and communication so that it fits your interests. In the future, we want to create increasingly better experiences, and the data we collect will help us understand our customers better.

1. From where do we collect data?

We collect data about you, among other occasions, when you:
• register as a user of our services,
• give us a marketing permission and receive messages from us;
• make purchases at our online store or use our other web or mobile services,
• take part in one of our marketing campaigns or a marketing survey or an opinion poll we organise,
• give us feedback, leave us a message to contact you or otherwise get in touch with Fazer;
• sign up for an event organized by Fazer,
• are a contact person of one of our corporate customers or partners or contact us as a representative of your organisation; or
• share, publish, comment on something or send a message in Fazer’s social media channels when you wish to get customer service. We also carry out social media monitoring on a general level to better understand our customers and to get a better picture of what is said about Fazer and the industry.

We can also collect data about you from other registers of companies belonging to the Fazer Group, for example, in conjunction with a business purchase or another business transaction.

2. What kind of data do we collect?

The data we process may vary depending on which of our services you use and how you use them. You can influence the type of data we collect. We get some of the data directly from you, for instance, when you do business in our online store or participate in one of our campaigns. We get some of the data through cookies and other similar technologies. This way we learn, for instance, how our services are used, and we can offer the best service experience possible. To check how we process your data in the different services you use, go to the section on service-specific details.

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Depending on which services you use, we collect the following data concerning you:

Name and contact details:

We collect your first and last name, address, email address, telephone number and other similar contact details.

Demographic data:

We collect other descriptive data, such as age and/or date of birth, language and country.

Identification data:

We collect registration information for online services, such as user ID and password and other similar security information.

Customer relationship data:

We collect data, for example, on any purchases, reservations, used benefits or other activities you have made or placed in the online store, any newsletters you have received (e.g. whether or not you have opened the message) or other activities. We also collect information on customer feedback and other customer contacts. In certain complaint situations, we may process health-related data to investigate our legal liability.

Payment data:

To be able to process your payments, we collect the necessary information for the payment of your purchases. Among other things, we collect information about the means of payment you use and on invoicing details, in the event that you choose an invoice as the means of payment.

Data on representation:

We collect information about your position in the company or other organisation you represent, as well as the name and contact details of the company or organisation in question, when you interact with us as a representative of your company or other organisation or stakeholder group. We also collect other information necessary for the management of the relationship between Fazer and the company or organisation you represent.

Campaign data:

When you participate in one of our marketing campaigns, such as a prize draw or competition, we collect the data provided in this connection, as well as the data on participation in the campaign.

Market surveys and opinion polls:

When we carry out market surveys and opinion polls, we collect data through which we can learn to develop our services, business operations and product.

Data on interests and profiling data:

We collect data on your interests. In addition to expressly provided data, your interests can be deduced or derived from other data we collect.

Marketing permissions and prohibitions:

We collect data on opt-ins and opt-outs with regard to marketing.

Changes to data:

If the aforementioned data changes, our systems may record details of the changes so that we can ensure that the data is accurate.

Visual recordings:

We may take photographs or record video at Fazer events. If we photograph you in particular and not the whole audience, we will ask for your content to publishing the image. Your picture may also be recorded by our security cameras for security reasons when you visit Fazer facilities.

Health-related data:

We collect data concerning your health in the context of some services, such as Fazer Brainhow. Such information includes data on your activeness, diet and sleep. When we collect health-related data, we will ask for your express consent for its processing, unless we have some other legal grounds for processing it. Such legal grounds include an investigation concerning legal liability in complaint situations.

You can influence the type of data we collect. You can use most of our services without giving us the above information. However, the use of certain services, such as participation in a campaign, processing a complaint, or purchasing products or services through an online service, requires that you submit your personal data. If you decide not to submit your personal data to us, we may be unable to provide all the offers or content to you, or provide as targeted and personal a service as we could if we had access to your data. You can quickly and easily see from the service-specific information how we process your personal data in each service.

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3. Cookies

We collect data on the use of our online services with the help of cookies, for example.

A cookie is a small file that a website stores in the visitor’s browser, which sends data to the website’s administrator when the visitor revisits the website. We use cookies that work as intended on our website – they improve the user experience or monitor traffic on the Fazer website. We may also use cookies to target, personalise and advertise our webpages. You can disable cookies or set an alarm for cookies in the browser settings.

Read more about our cookies here.

4. What is the data used for?

We process your data for business purposes, such as to deliver any products you have ordered, produce the service you have purchased or to fulfil some other contract. We also process your data if it is necessary for the realisation of Fazer’s legitimate interests. In some cases, we may ask you for your consent for the processing of your data. We combine the data we collect to be able to offer you as good service as possible.

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We process your data for the following purposes, among others:

Web and mobile services:

We process your data so that you can use our online services and mobile apps. Your data allows us to identify you, offer our digital services to you and fulfil a contract, by delivering an order, for example.

Customer service and communication:

We process your data for the purpose of providing customer services, such as responding to any feedback or complaint you have sent us, carrying out customer communication and resolving disputes.

Direct marketing as well as marketing surveys and opinion polls:

We process your data to be able to market our products and services. We can also process your data in marketing surveys and opinion polls to gain a better understanding of our customers and thereby provide them with better services.

Targeting communication, marketing and services:

We process your data to target communication and marketing. This allows us to provide you with information about our products and services that is as relevant as possible. The targeting of content is based on interests the customer has indicated or information we have learned about the customer with the help of recorded data. Such data consists of information on which campaigns you have participated in and your activities in our online services. We use this data to form groups at which we target our marketing, and do not therefore target marketing specifically at any individual person.

Analysis, compilation of statistics, and the development of business, products and services:

We process the data for analysis, for compiling statistics and reporting, as well as for developing our business, products and services, and improving the user experience.

We process the data in the aforementioned ways on the basis of the fulfilment of contractual obligations or Fazer’s legitimate interest. We can also request your consent for the processing of your data for the realisation of particular purposes. For example, our direct marketing aimed at consumers is always based on your consent given in advance, which you can withdraw at any time.

“Legitimate interest” refers to an interest that is legal and the realisation of which is important for Fazer’s operations. Fazer may act on the grounds of legitimate interest where a significant and pertinent relationship exists between the user of the service, i.e. the data subject, and Fazer. When assessing legitimate interest, the interests of the data subject and Fazer are evaluated, including the realisation of fundamental rights, the nature and purpose of use of the data collected, and data security. The data subject has the right to object to processing that occurs on the basis of a legitimate interest. You can find more information about your rights under the section 8. How can you influence the processing of your personal data?

You can read more about the data we collect in various services and about service-specific purposes of use and grounds under section 1. From where do we collect data?

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5. How long do we store your data?

We do not store your data for any longer than is necessary for the purposes described in this Privacy Statement and to comply with any mandatory legislation, such as accounting laws. The retention period of your data is also affected by the connection in which and the purpose for which your data has been collected. You can read more on how the retention periods are determined below.

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You can check the grounds for the retention periods of personal data by service from the table below. When the grounds for retaining your data comes to an end, a process which removes your data from our registers in a secure manner begins.

The services or functions subject to retention periods What do we use your data for in this particular service, for example? How long do we store your data?
One-time purchase or recurring order in our online store The delivery of an order and the reception of any possible complaints Until such time as the order (or the final delivery of a recurring order) has been delivered, the complaint period has expired, the data is no longer needed for the monitoring of product quality and we have no reason to assume that you would get in touch with us in relation to the order.
Booking systems (e.g. Fazer’s visitor centre, Meetings & Parties service) The production of a service or event Until such a service or event has been delivered, the complaint period has expired, the data is no longer needed for the monitoring of service or product quality and we have no reason to assume that you would get in touch with us in relation to the service or event. The data of registered customers is retained for the duration of the customer account.
Participation in a campaign The realisation of a campaign (such as the delivery of a prize) Until such time as the campaign has ended and the measures following the campaign (such as the delivery of prizes) has been carried out and we have no reason to assume that you would get in touch with us in relation to the campaign.
Marketing communication For the marketing of new products and offers Until the consent for marketing and/or the subscription concerning a newsletter has been cancelled.
Feedback, new idea, complaint or other customer service The processing of feedback, the improvement of services and investigating legal liability Until the complaint period has expired, the requirements of food safety self-monitoring have been fulfilled, the complaint has been processed and Fazer’s legal liability has been investigated and the matter concluded.
Order For service implementation Until such time as the order has been delivered/picked up, the complaint period has expired or the data is no longer needed for the monitoring of product quality and we have no reason to assume that you would get in touch with us in relation to the order.
Responding to an opinion poll or survey For the improvement of our services Until the opinion poll has closed or the survey has concluded and the purpose of the research or survey has been fulfilled.
For the use of a mobile app (e.g. Fazer Brainhow) For service implementation Until the application’s use has ended and the related account has been terminated.
Fazer card For service implementation Until the card agreement has expired.
For the use of the MyFazer loyalty program For service implementation Until you end the My Fazer loyalty program membership.
Processing the personal data of the representatives of companies or other organisations or a stakeholder group The implementation of services and communication Until we no longer need your data for the purpose it was collected for, or until you no longer manage the tasks in the company or organisation on the basis of which your personal data is processed. We will nevertheless continue to process your data, if your new job description gives grounds for such processing.
Video surveillance systems Two weeks to three months, as applicable country-by-country.
Access control systems Three years. If access rights have not been granted, the application data will be erased within three months of entering the application in the system.

Please note that regardless of the above criteria, we may have an obligation due to mandatory legislation to process certain data concerning you (such as transaction data for the online store in order to comply with accounting legislation) for a longer time, in which case we will only process the data for the purpose of complying with the legislation in question. We may also make an exception in retention periods when a legal claim is made against Fazer or when the handling of matters related to such a claim is incomplete.

In addition, regardless of what is stated above, we may process the data in an anonymised format, among other things, for analysis and statistical purposes and to improve our business, products and services.

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6. Who can process your data and do we disclose it to third parties?

Your data is processed within Fazer Group. We may disclose your data to the authorities, for example, if the law requires us to do so. In addition, we may disclose your data in the context of any disposal of business or some other corporate transaction to the buyer of the business or another relevant party related to the corporate transaction.

To fulfil the agreement, we may disclose personal data to third parties. Such third parties include our partners offering payment agency or transportation services in our online stores or sales outlets; these partners may also act as the controller in terms of personal data needed for the payment and transportation. Each online store provides information on the partners it uses. We advise you read the data protection policies of such third parties.

We use services provided by third parties in the processing of personal data, but we do not, as a rule, disclose your data to them in such a manner that they would be able to use it for other purposes than those defined by Fazer.

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We use subcontractors and service providers for the processing of your data, such as for technical maintenance or the implementation of campaigns and direct marketing. In such cases, we obligate our subcontractors and service providers with appropriate contractual means to maintain a level of information security that is adequate to protect your data and to comply with the valid personal data legislation. The subcontractors and service providers we use only use your data for the purposes defined by Fazer, described above. We do not disclose your data to them in a format that would allow them to use it for other purposes.

7. Do we transfer your data beyond the borders of the EU or EEA (“third countries”)?

If we use your data for electronic communications, your data may be transferred to our service provider located in the United States. Your data may also be transferred to the US and Canada when you complete transactions in our online Fazer Store offered by Fazer Confectionery Ltd. According to a decision by the EU Commission, the level of data protection in Canada is sufficient. Our service providers in the United States, on the other hand, comply with rules based on the Privacy Shield agreement between the EU and the United States. We may also transfer your data to other third countries, provided that the requirements set in the EU’s General Data Protection Regulation are met.

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We use the digital tool of our service provider in the United States to implement digital marketing and customer communication, due to which your data may be transferred to the United States when we use the data for digital communication. We also use an inventory and shipping management service provider in the United States which uses subcontractors located in other third countries, due to which your data may be transferred to other third countries when we use the data for inventory management and shipping purposes.

The service provider which offers the platform for the online Fazer Store operating under Fazer Confectionery Ltd is located in Canada, and data may be transferred to the Unites States in connection with the data processing of this service provider. Therefore, when you make purchases in the online Fazer Store, your personal data may be transferred to the United States and Canada to enable your online transaction.

According to a decision by the EU Commission, the level of data protection in Canada is sufficient, which secures the transfer of personal data to Canada. Our service providers in the United States, on the other hand, have undertaken to abide by rules based on the Privacy Shield agreement between the EU and the United States, which ensure an adequate level of data protection. You can read more about the Privacy Shield agreement between the EU and the United States on the website of the European Commission.

We can also transfer your data outside the EU or EEA in cases other than those mentioned above if this is necessary for the purposes of use stated above, for inventory management and shipping purposes or the technical maintenance of the data, provided that the requirements set in the EU’s General Data Protection Regulation are met, such as by carrying out the transfer by applying the model clauses approved by the European Commission.

8. How can you influence the processing of your personal data?

You can control how Fazer collects and uses your data. Because your rights are important for us, we have established several means by which you can influence the processing of your data. Below, you can read about your rights and the methods you can use to exercise them.

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You are entitled to influence the processing of your data in the following ways:

• You have the right to forbid the processing of your personal data for the purposes of direct marketing at any time (right to object). Please note that if you unsubscribe from a newsletter you earlier subscribed to through the link in a newsletter but have given us general marketing permission, you may continue to receive marketing communication from us. In such cases, you can withdraw the consent you have given by filling in the form found on our website or contacting our customer service. Please note that even if you opt out of direct marketing, you may still see our advertisements in online services external to Fazer and receive customer communication from us, such as confirmation of an order you made through our online store. In addition, you may receive marketing communication like this from Fazer in relation to your work or area of responsibility. The easiest way to opt out is to unsubscribe via the link at the end of the message you receive.

• In some situations, you may have the right, for reasons related to special personal circumstances, to object to the processing of your personal data beyond the purposes of direct marketing. In such cases, your right only pertains to your data that we process by virtue of Fazer’s legitimate interests. When you ask us to stop processing your personal data on these grounds, you must tell us what the special personal reason is due to which the processing of your data should be stopped.

• You have the right to request access to the data concerning you or to receive confirmation that we do not process data concerning you (right of access). The easiest way to make such a request is to fill in the relevant form found on our website. In certain situations, you also have the right to receive the personal data you provided to us in digital format so that you can transfer it to another controller (right to data portability).

• You have the right to have data rectified (right to rectification). This means that if your data is incorrect, inaccurate or deficient, you are entitled to ask us to rectify or complete the data. In certain situations, you may have the right to restrict the processing (right to restriction of processing). This means that if you dispute the accuracy of your data, you have the right to restrict its processing for a period of time that allows us to ensure that your data is accurate.

• You have the right to have your data erased in certain situations, including situations where the processing of your personal data is no longer necessary for the purposes for which it was collected, or if the processing of your personal data was based on your consent and you wish to withdraw your consent, and there are no other grounds for processing your personal data (right to be forgotten). Please note that if the processing of your personal data is necessary for the purpose of, for instance, delivering an online store order you have made or complying with your desire to opt out of direct marketing, we cannot remove your data.

You can exercise your rights related to the processing of your personal data by contacting us via the form found on our website.

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9. Who can you turn to if you have questions concerning the processing of your data?

You can read more about our data protection policies at www.fazergroup.com/privacy , where you can contact us, for example, or exercise your rights related to the processing of your data.

If you think that we, despite the principles mentioned in this Privacy Statement, have infringed upon your rights based on personal data legislation, you can also file a complaint with your local data protection authority. We nevertheless recommend that you first get in touch with our customer service to clear up the matter.

10. Controllers:

Oy Karl Fazer Ab, together with the companies belonging to the same Group, which are the controllers in respect of their own operations.

Fazer is an international family-owned company offering quality bakery, confectionery, biscuit and grain products as well as café services. Fazer operates in eight countries and exports to around 40 countries.

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Oy Karl Fazer Ab
Fazerintie 6, 01230 Vantaa, Finland
P.O. Box 4, 00941 Helsinki, Finland

Finland

Fazer Food Services Oy
Laulukuja 6, 00420 Helsinki, Finland
P.O. Box 37, 00421 Helsinki, Finland

Fazer Ravintolat Oy
Fazerintie 6, 01230 Vantaa, Finland
P.O. Box 4, 00941 Helsinki, Finland

Fazer Confectionery Ltd
Fazerintie 6, 01230 Vantaa, Finland
P.O. Box 4, 00941 Helsinki, Finland

Oy NIS- Nordic Industrial Sales Ab
P.O. Box 4, 00941 Helsinki, Finland

Fazer Bakeries Ltd
Fazerintie 6, 01230 Vantaa, Finland
P.O. Box 17, 00941 Helsinki, Finland

Fazer Finland Oy, Fazer Mills
P.O. Box 4, 00941 Helsinki, Finland

Kaslink Aito Oy
y-tunnus 2950143-1
Tanssilavantie 10, 45610 Koria, Finland

Kaslink Foods Oy
y-tunnus 2950142-3
Tanssilanvantie 10, 45610 Koria

Kaslink Oy
y-tunnus: 1730025-3
Tanssilavantie 10, 45610 Koria

Sweden

Fazer Food Services AB
Lindhagensgatan 120
P.O. Box 30170
104 25 Stockholm, Sweden

Fazer Konfektyr AB
Lindhagensgatan 120
P.O. Box 30170
104 25 Stockholm, Sweden

Fazer Bageri AB
Lindhagensgatan 120
P.O. Box 30170
104 25 Stockholm, Sweden

Fazer Sweden AB
Hallgränd 3
121 62 Johanneshov, Sweden

Norway

Fazer Food Services AS
Filipstad Brygge 1
Box 1375, Brygge 1
0252 Oslo, Norway

Fazer Norway AS
Karl Johans Gate 2
0154 Oslo, Norway

Denmark

Fazer Denmark ApS
Lindgreens Allé 12
DK-2300 Copenhagen, Denmark

Fazer Food Services A/S
Skibhusvej 52 A, 1.
5000 Odense C, Denmark

Estonia

Fazer Eesti AS
Veerenni 24
10135 Tallinn, Estonia

Fazer Food OÜ
Jälgimäe tee 14
76404 Saku vald, Harjumaa, Estonia

Latvia

Fazer Latvija SIA
Druvas iela 2
Ogre, 5001, Latvia

Lithuania

Fazer Lietuva UAB
Raudondvario pl. 129A
47188 Kaunas, Lithuania

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Service-specific details

The service-specific details provide you with information on where we collect data from and on the way in which we process your data in the various services you use.

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Online stores

Our online stores let you order our products or services. We process your personal data to fulfil the agreement and to manage the customer relationship. In connection with orders, we will ask for details such as your name and contact information, your customer relationship information, change data and identification data, which allow us to deliver the order. We also collect your payment data, such as the selected means of payment and invoicing details, if the means of payment is an invoice. If you wish, you can grant us marketing permission.

To fulfil the agreement, we may disclose personal data to third parties. Such third parties include our partners offering payment agency or transportation services in our online stores; these partners may also act as the controller in terms of personal data needed for the payment and transportation. Each online store provides information on the partners it uses. We advise you read the data protection policies of such third parties.

Fazer Store online store, which is offered by Fazer Confectionary Ltd, includes a functionality which reminds the user of an abandoned shopping cart. If you have placed a product in the online store's cart, filled in the contact information and clicked "Continue to shipping", but reject the cart's contents without making a payment, Fazer will process your personal data in order to send a service message, i.e. a reminder of the uncompleted purchase.

When you make purchases in the online Fazer Store provided by Fazer Confectionery Ltd, your personal data may be transferred to our service providers in the United States and Canada. According to a decision by the EU Commission, the level of data protection in Canada is sufficient. Our service providers in the United States, on the other hand, comply with rules based on the Privacy Shield agreement between the EU and the United States. For more information on transferring data to third countries, read section 7. Do we transfer your data beyond the borders of the EU or EEA (“third countries”)?

Booking systems

You can use our booking systems to make a reservation for a space or event or a table at one of our restaurants or cafés. In order to fulfil the agreement, we will ask for details when you make the booking. These details include your name and contact information, and your customer relationship data, so that we can complete the booking under your name, confirm the booking and get in touch with you in connection with any cancellations, for example. We may also request other information necessary to carry out the reservation in question. This information includes special diets, any possible need for accessible spaces or the first name and age of the person celebrating their birthday in connection to any invitations to birthday parties. Based on the customer relationship, we also collect other data on your interests and changes. If you wish, you can grant us marketing permission.

Orders

You can place an order for cake, bread or other food with us. In order to fulfil the agreement, we will ask for details in connection with such orders. These details include your name and contact information, which allow us to confirm the order and get in touch with you if necessary. We can also collect data about special diets which is necessary to prepare your food order.

Campaigns

In campaigns, we market a particular product, service or offer for a fixed period of time. In connection with a campaign, we may offer you a chance to participate in a prize drawing or competition or ask your consent to marketing. In such cases, we will ask you to provide personal data, such as your name and contact information. We need this information to implement the campaign and to send you any possible prize you have won and, if you have given your consent to marketing, to send you offers, newsletters or news via email also after the campaign has ended.

Marketing communication

Marketing communication aimed at consumers

Newsletters allow us to send you information about offers or new products and services digitally. We will ask your consent before sending you newsletters. If you have given us general permission for marketing, we can send you news and newsletters which we think might interest you on the basis of the services you have used. You can unsubscribe for a newsletter sent to you through a link at the end of the email in question. Please note that despite the cancellation of an individual newsletter, you may still receive other marketing communication from Fazer Group if you have not cancelled the general consent to marketing you have given to Fazer Group.

You can cancel a general consent to marketing either in the contacting our customer service or with a form available on our website. The cancellation of a general consent to marketing stops all marketing communication aimed at consumers, including any newsletters you may have subscribed to.

Marketing communication aimed at the representatives of companies and other stakeholders

You may receive marketing communication related to your work or area of responsibility from Fazer when, for example, your company is our customer, you have shown interest in Fazer’s services or products as a representative of your company, you belong in some other stakeholder group or if you have subscribed to one of our newsletters. We do this on the basis of the customer relationship or Fazer’s legitimate interests. When the local legislation so requires, we will ask for your consent to such marketing. If you receive marketing communication like this from Fazer in relation to your work or area of responsibility, the easiest way to opt out is to unsubscribe via the link at the end of the message you receive.

Feedback, complaints and other customer service

You can give us feedback, make a complaint concerning a product or service of ours or send us an idea through our customer service aimed at consumers. In this context, we will collect data such as your name, your contact information and possible data on representation, based on the customer relationship. This data facilitates the processing of the idea or complaint and allow us to respond. We may also collect health-related data if this is necessary for the processing of compensation or an investigation concerning legal liability. We will do this in cases where our products have caused you health-related symptoms of some kind.

Opinion polls and surveys

Opinion polls and surveys allow us to collect information important for our operations. It is voluntary to answer to them, and we will process your data on your consent. When you participate in a poll or a survey, we may ask personal details that are necessary for carrying out the poll or survey or if the poll or survey involves a prize draw, in which case we need the personal data to send you your prize.

Mobile applications

We provide our customers with mobile apps, through which you can place orders or receive benefits when you visit our cafés or restaurants. For you to be able to use an app, we will collect personal data from you (such as your contact information, change data and customer relationship data, as well as information on your interests, such as information on the use of the app, so that we can send you offers suitable for you.

MyFazerCafé

MyFazerCafé is a customer loyalty programme which includes a mobile card you can charge on your smart phone. The card allows you to use benefits in all Fazer Cafés. For you to be able to use an app, we will collect your name and contact information, customer relationship data, change data and information on your interests, based on your customer relationship. If you wish, you can grant us marketing permission.

The Fazer Brainhow service

Fazer Brainhow is a well-being service offered by Oy Karl Fazer Ab. In this Privacy Statement, we describe how Fazer, in its capacity as the controller, processes your data in the service.

The service is produced on the platform of Wellmo Mobile Wellness Solutions MWS Oy (hereinafter “Wellmo”) and it employs the services of Wellness Foundry Holding Oy (hereinafter “MealLogger”) which allow the monitoring of meal data. Wellmo and MealLogger process part of the data entered in the service by a user as independent controllers. We also recommend that you read the data protection policies of Wellmo and a MealLogger before taking the service into use.

Fazer collects and processes your personal data related to the Fazer Brainhow service so that we can help you improve your well-being and find peer support and so that you can keep notes on the development of your well-being. For this purpose, we will ask your name and contact information, step count, weight, height, details of your memberships in the service groups and communities and information on your diet. You can select to provide information about your gender, how you sleep and how active you are, which you may choose to complement with any data added by yourself, which can help you along journey towards better well-being. Such data can include information on your outdoor activities or stress level. You can also upload pictures in the service.

You decide the data we may collect on you, and you can remove your data from our service at any time. Given that the information concerns health-related sensitive personal data, we will request your express consent for the collection and processing of this data.

If the service is offered to you by your employer, your collected data can be used in compiling the anonymous statistics of your workplace. The data will not be disclosed to your employer in any other form than as anonymous statistical data. In addition, your data can, if you so wish, be used in various comparisons with the other users at your workplace. If you want to share your data with other users, you can do so in the settings of the service.

Fazer card

A Fazer card allows you to pay for your purchases at certain Fazer restaurants. Once you have received the card you will be instructed to create a profile which allows you to keep an eye on your purchases. When you create the profile, we will ask you, on the basis of your customer relationship, to provide us with your personal data, such as name, contact information and date of birth, so that we are able to identify you as the user of your card.

The MyFazer loyalty progreamme

MyFazer is the loyalty programme of Fazer Group. The loyalty programme includes a variety of services, benefits and offers, as well as an opportunity to participate in the development of Fazer’s products and services. The loyalty programme can be joined through Fazer’s online and mobile services. A member can terminate their membership at any time in the MyFazer service.

The processing of data related to the MyFazer loyalty programme is based on the loyalty agreement you have signed. We ask for your name and contact information to administer the MyFazer loyalty programme. You can modify and manage your own data in the MyFazer service.

In addition, we use cookies to collect data on the online service browsing, purchases, and product and service evaluations of the members of the MyFazer loyalty programme as well as information provided by the members themselves, such as feedback and answers given in different surveys and studies. We may combine the collected data with other customer information and use the data to provide interesting, targeted benefits, services and contents to the members of the MyFazer loyalty programme and for the programme’s analytics, statistics and development.

The MyFazer loyalty programme includes marketing communication, and when you join the programme, you will receive Fazer’s newsletters, benefits and offers via e-mail and possibly by other electronic means, if you so wish. You can manage your message settings in the MyFazer service. The push messages of mobile applications related to the loyalty programme can be managed in the relevant application.

We use the services of third parties for the implementation of the loyalty programme, which means your data may be transferred to the United States. You can find further information on the transfer of data to third countries in 7. Do we transfer your data beyond the borders of the EU or EEA (i.e. to "third countries")?

Video surveillance systems

Video surveillance enables us to ensure the personal safety, protection of property and food safety of our employees, customers and other persons staying at or visiting our facilities as well as to prevent and resolve situations that jeopardise safety, property and production processes.

Video surveillance stores data on persons who are within the range of the cameras at any given time. Surveillance may target, among other things, public spaces, loading docks, factory areas and, under certain conditions, areas where money is handled. This will enable us to ensure safety and protect people and property from harm. If Fazer uses video surveillance systems in the premises, the covered area is marked with clear notice tags (for example with camera images or with a notice reading “video surveillance” or other similar notification).

Fazer processes the data based on the legitimate interest of the controller. The retention period of the data is defined based on requirements of local legislation and/or supervisory authority recommendations and the initial retention time ranges from two weeks to three months, as applicable country-by-country. The data may be retained for longer if required by presenting, resolving or defending a legal claim; in other words, until the judgment is legally valid or the matter has been finally settled. Surveillance has been outsourced to a security company whose security guards monitor events on the property through a TV monitor. The security guards have technical access to the video surveillance material and they are allowed to access the material if necessary on prior consent from Fazer security manager. The security system is maintained on premise by Fazer itself.

Data can be disclosed to the authorities on the basis of the statutory right to obtain information. Such authorities include the police.

Access control systems

Access control enables us to ensure the personal safety, protection of property and food safety of our employees, customers and other persons staying at or visiting our facilities as well as to prevent and resolve situations that jeopardise safety, property and production processes.

The access control register stores data on persons who have applied for access rights and who at any given time have entered or exited through doors or gates included in the system or used the facilities included in the system. The information to be stored in the system includes the person's background information, such as name, role, employer and possibly their personal identity code, date of birth and picture, as well as the date and time of access and the vehicle’s registration number and picture. The background information is usually obtained from the person themselves or their representative when the access right is applied for, and the other information is obtained from the access control systems.

Fazer processes the data based on the legitimate interest of the controller. Processing the personal identity code is required for unambiguous identification of the person in question in order to ensure the safety of persons, among other things. The data is retained for a maximum of three years or longer, if required by presenting, resolving or defending a legal claim; in other words, until the judgment is legally valid or the matter has been finally settled. If access rights have not been granted, the data will be erased within three months of entering the application in the system.

Data can be disclosed to the authorities on the basis of the statutory right to obtain information. Such authorities include the police.

Processing the personal data of company contact people and other stakeholders

Fazer processes the data of its corporate customers and potential corporate customers, suppliers and subcontractors as well as other stakeholders in the course of its business operations. We process your data in these contexts when you are in contact with us as a representative of your company, other organisation or a stakeholder group. In such cases, we typically process the data on the basis of the fulfilment of contractual obligations or Fazer’s legitimate interest. Read more about legitimate interest in section 4. How is the data used? We can also request your consent to the processing of your personal data when, for instance, the applicable legislation requires your consent for marketing communication related to your work or area of responsibility.

We process your data to be able to make an agreement with you or provide services to you, for customer communication and service as well as for the analysis, statistics, reporting and development of our business operations. We also use your data for the marketing of our products and services and can, on the basis of any work-related interests you have informed us of, target the marketing we send to you in such a way that it benefits you in your work as much as possible. If you receive marketing communication like this from Fazer in relation to your work or area of responsibility, you can opt out at any time by unsubscribing via the link at the end of the message you receive.

When you deal with us as a representative of a company or other organisation or stakeholder group, the data we collect from you includes your name, contact details, position and job and/or title in the company or other organisation you represent. In some situations, we can also collect information about your interests and possibly other data necessary for the management of the relationship between Fazer and the company or organisation you represent. In addition, we collect information from generally available sources, such as the websites of companies, social media services and directories and contact databases maintained by the authorities or service providers.

Facebook pages maintained by Fazer

Fazer maintains several Facebook pages. If you like any of Fazer’s Facebook pages, comment on posts or otherwise interact with one of Fazer’s Facebook pages, we will receive your public profile details visible to all Facebook users, such as your user name and profile picture. We process your data in order to tell you about new products and services as well as benefits or offers, to carry out marketing campaigns, such as competitions and draws, to receive feedback, purchase advertising from Facebook and to measure the performance of our advertising. If you have provided feedback or filed a complaint on our Facebook pages, we may direct the processing of the feedback or complaint to a party outside of Facebook, in which case we will process your data in the same manner as in other customer service situations.

We also obtain visitor data from Facebook collected by Facebook when users visit Fazer’s Facebook pages or interact with the page or its contents. Such statistics help us understand how our users interact with Fazer’s Facebook pages.

Fazer processes the data on Fazer’s Facebook pages on the basis of Fazer’s legitimate interest.

Facebook Ireland Limited and the Fazer company maintaining the Fazer Facebook page are joint controllers of the visitor data of Fazer’s Facebook pages, as applicable. Facebook bears the primary responsibility for compliance with data protection legislation as well as fulfilling the information security requirements and data subject requests. Facebook processes personal data in accordance with its own data policy: www.facebook.com/policy/. You can manage your own Facebook settings in Facebook. If you want to exercise your privacy rights related to your Facebook visitor data, you can contact Facebook.

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