3) Description of data file: Kiinko marketing data file

Data controller

The data controllers are Kiinteistöalan Koulutussäätiö and Kiinteistöalan Koulutuskeskus Oy as joint controllers (hereinafter referred to as “Kiinko”).

Malmin asematie 6, 00700 Helsinki, Finland, Telephone: +358 (0)9 3509 290, E-mail koulutus@kiinko.fi www.kiinko.fi

Name of the data file

Marketing data file

The purpose and basis for the processing of personal data

The personal data is processed and used for Kiinko’s customer communications and marketing, which enables us to engage in targeted and timely communication regarding the services we provide.

The primary basis for the processing of personal data is the data subject’s consent or a current customer relationship. The data can also be processed based on the data controller’s legitimate interest related to business promotion. We consider promoting our business and engaging in appropriate and high-quality communication with current and potential customers as our legitimate interests. The processing of personal data based on this legitimate interest is also in the data subject’s interest.

Information content of the data file

The following types of information, among others, can be recorded on data subjects:

Personal information, such as name, address, telephone numbers and e-mail addresses, job title, name of organisation, city, training and education history with Kiinko and Kiinko’s own classification of job titles and industries based on the aforementioned information. Information regarding campaigns targeted at the data subject, areas of interest as reported by the data subject. Correspondence history and notes.

Storage period of personal data

The personal data is stored until the data subject withdraws their consent to the processing of data or requests the erasure of their data. Data may also be erased by Kiinko if the continued storage of the data is not deemed necessary.

Regular sources of data

The data is primarily obtained directly from the data subjects, with their consent, through correspondence, course registrations and applications. Data can also be occasionally collected or updated from other data sources and in connection with customer events.

Regular disclosure of data

Data from the marketing data file is not disclosed to third parties unless the data subject has specifically consented to this for a particular purpose.

Transfer of data outside the European Union or the European Economic Area

The data is not transferred outside the European Union or the European Economic Area.