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Customer and Marketing Information Privacy Statement and data protection.

This Privacy Statement contains the information required for processing the statement in accordance with the European Union's Data Protection Regulation. In our company, we comply with the provisions of the Data Protection Regulation and the Data Protection Act when processing personal data.

Sunholidays Oy can   change this privacy statement by publishing a new version of it. We encourage you to familiarize yourself with our privacy policy at regular intervals.

Date of preparation: 15 August 2022

1 Registrar

Sunholidays Oy

Sturenkatu 26 LT 36

00510 Helsinki

2 Registers

   - Customer registers of guests and renters of holiday apartments

   - Weekly share registers

   - Marketing registers

   - Register of presentation reservations

   - Vacation booking and lottery registers for business customers

   - B-to-B customer base

   - Call recordings

   - Register of customers with a marketing ban

Although the registers are mentioned in these terms of use   as separate entities, they still form an entity that is not always easy to separate. Information from the forms can enter Sunholidays Oy's marketing register. We have broken them down to make the explanation easier to understand.

3 Purpose of personal data processing and legal basis for processing

​3.1 Customer registers

At Sunholidays Oy, a lot of personal data of customers is processed in different contexts. Our most important customer registers are:

1. Register maintained on the basis of the weekly share register.

2. Marketing customer registers.

In addition to the above-mentioned registers, Sunholidays Oy also has the other registers in point 2. The processing of personal data is based on a contract or an article based on the law or on Sunholidays Oy's legitimate interest.


The law regulates the processing and storage of customer data .

Sunholidays Oy's own interest is related to business objectives, such as quality control, development of services, measurement of customer satisfaction, training of personnel and provision of additional services.


The benefit granted by law is also made to protect rights and property and to maintain physical and data security. The purpose of personal data in customer registers  is to ensure that the parties act in accordance with the agreement. For example, the fact that the customer receives accommodation or another product or service purchased in accordance with the contract.

The purpose of customer registers is also the development of business related to services or shares, for example inventory management and the development of reservation systems, improving and maintaining customer relations, and taking care of the obligations and rights of Sunholidays Oy and the customer.​

Sunholidays Oy also processes personal data in connection with the recording of phone calls negotiations. Personal data can also be processed in other similar or business-related contexts.

The other registers mentioned later can be connected to Sunholidays Oy's customer register and in that connection they form a whole, although the processing of personal data below has taken place through different channels.

3.2 Marketing registers and their use

In connection with marketing, the collection of personal data takes place either for the benefit of Sunholidays Oy or the permission obtained based on the customer's consent. In the case of marketing, for Sunholidays Oy's business interests, such as customer or service development, customer satisfaction measurement, personnel training or direct marketing.

Electronic direct marketing always requires the customer's consent, which is always obtained in writing.

With regard to electronic direct marketing, permission is required, even if the customer is a customer of Sunholidays Oy on other grounds. Consent is requested in writing and can be revoked at any time. With regard to electronic direct marketing, consent is requested, for example, in connection with an agreed meeting, call or other contact, or after the customer has stayed at the destination, acquires or is about to acquire a share, or in another situation where there is contact between Sunholidays Oy and the customer.

Information from customer information systems is also used in electronic and printed letters and similar announcements, such as surveys or raffles that accompany shareholder events. Based on this, personal data from customer information systems can also be used for direct marketing by telephone.

We keep a separate register of customers who have banned direct marketing. Our system is synchronized so that the bans are certainly 99.99% correct.​

The other registers described below can be linked to Sunholidays Oy's marketing register

(mainly the matters described in the forms section) and together these form a whole, although the processing of personal data is described differently below.

3.3 Recording of calls conferences

Calls to our customer service (switchboard, customer service, and other possible phone contacts) can be recorded. The purpose of recording calls is the legitimate interest of  Sunholidays Oy. The purpose of recording the calls is to use the calls to improve the quality of customer service and develop it, for trainings and to ensure the content of the agreement of both parties. Calls recordings are not used for other purposes.


3.4 Cookies

We collect IP address and cookie data from customers when they visit Sunholidays Oy's online service. Cookie information is anonymous. The collection of cookies is based on the consent given when entering the website or on the legitimate interest of the controller.

We can use cookies to target and refine advertising.

Sunholidays Oy's online service may contain links to third-party websites where personal data may be collected. Sunholidays Oy is not responsible for third parties or their collection of personal data.

Sunholidays Oy strives to ensure that all partners whose links can be found on Sunholidays Oy's online service are reliable. Our partners can use cookies to target advertising.

3.5 Online forms

Sunholidays Oy has several different online forms in its online service, the purpose of which is clear from the form in question. Our online forms are, for example:

Customer satisfaction surveys, share value evaluation forms or other similar surveys or surveys that improve customer satisfaction, the processing of which is based on the customer's consent and at the same time the customer has the opportunity to give consent to marketing. However, these are always separate permits.

4 Data content of the register

4.1 Shareholder and share transactions

A shareholder register is kept for shareholders. According to the Housing Joint Stock Company Act, the recipient of the share is entered in the list when the necessary explanation of the ownership right has been received and a certificate of payment of the transfer tax has been received. At Sunholidays Oy, the shareholder's information is kept only as long as he owns the share. 

Em. in addition to the information based on the mentioned law, other relevant information can also be collected about the shareholders, but this processing is based on Sunholidays Oy's and the customer's key customer relationship. We have the right to retain information based on transactions made between Sunholidays Oy and the customer. Sunholidays Oy keeps the share certificates and other documents related to share trading. Information to be stored is the person's name, social security number, address, telephone number, e-mail address, customer number, date of share purchase, information on ownership, possible guardianship or guardianship information, gender, profession, form of economy and number of family members, income and wealth information and bill payment information, marital status, deed of sale information, information about rent and other payments related to the deed of sale, contact information, and other information sent by the customer.

When a financing transaction is made with a shareholder, the customer must be aware that Sunholidays Oy is only an intermediary for financing, and that the customer's information is provided to the company offering financing. With regard to this data, the financial company acts as the data controller and the data is stored in the company's own systems. 

4.2 Rental customers and other customers


Only information permitted by law is collected from customers​

Information collected and stored about customers is the person's name, address, telephone number, e-mail address, nationality, social security number or, if this is not available, date of birth, the corresponding information of the persons accompanying the passenger.

4.3 Marketing


Information collected and stored about customers is the person's name, address, phone number, e-mail address.

4.4 Presentation appointment booking register


Information collected and held by Sunholidays Oy of those invited and participating in the presentation. The information to be stored includes name, address, phone number, email address, time of presentation and customer segment. Information about canceled presentation times will also remain in the register.

4.5 Business customers

The Consumer Protection Act does not apply to business customers. Sunholidays Oy maintains a separate business customer register. Information about existing and potential business customers that Sunholidays Oy has is stored in the register. The register stores basic information about the company in question as well as the basic information of the company's contact person, such as name, address, phone number and email address. 

4.6 Call Recordings

The content of the phone conversation is automatically saved in the call  recordings. The call is recorded as an audio file. Information about when the phone conversation took place, which customer service person answered, which number the call was made and which phone number the call came from is saved from the calls.

4.7 Forms

Our company uses different forms. The purpose of use is stated in the form. We have forms such as resale order, rental agency, and request for quotation / membership application forms. The content of the form varies, but the basic information is name, address, phone number, e-mail address and information on the shares owned.

4.8 Cookies


With the help of cookies, Sunholidays Oy can collect information about how and when our services are used on our website. The information collected can be, for example, from which page the user has accessed the service, when and which sites the user has browsed, what has been clicked, which browser is used, which device's operating system and its version.


We use cookies to monitor the number of visitors to   services and to measure advertising value. We can also collect information, for example, regarding electronic forms and page visitors, e.g. by finding out the visit times, which pages have taken the most time, and thus we know how to improve our pages accordingly. 


5 Information sources

5.1 Shareholders

One source of information is the customer who provides information to Sunholidays Oy. Most of the information is collected from the customer, as a rule, when he is at a presentation or makes an appointment. Sunholidays Oy has legal customer information on the basis of which the appointment has been made.

The customer is invited to a weekly share presentation from Sunholidays Oy's various customer registers.  Customers are invited to a share presentation by phone or email. 

The customer can also participate in the presentation after booking an introductory accommodation holiday from Sunholidays Oy. Accomodation holiday includes accommodation and presentation after the holiday. When a customer books a holiday, information is taken from the customer at the time of booking and stored in the register.

We can collect and update credit and payment behavior data from Suomen Asiakastieto Oy's register. Regarding share transactions, we always check the credit and payment behavior of the person if we offer the customer financing for share transactions. If the customer acquires a share through the financing service provided by Sunholidays Oy, the financing company may have separate channels through which it collects and processes personal data.

5.2 Accommodation customers

Information about those staying during the holiday week is taken when making the accommodation reservation. Information can be collected through different booking channels, which can be Sunholidays Oy's own channels, for example Sunholidays Oy's online service, chat, phone service and email information.

5.3 Cookies

Sunholidays Oy collects cookie data from its customers when they visit the online service. The information is used for targeted marketing and service provision.

5.4 Online forms and other forms

The customer normally fills out the form himself, either online or on a paper form. Information can also be collected on the form by Sunholidays Oy's customer service representative.

6 Updating information

We update customers' information according to notifications made by customers. Regarding these, the source of information may be reports made by the person himself or an external actor. The goal is that the external information is correct. To update the data, we use, among other things, information from the population data register. We update services regarding personal data based on information received from providers, authorities and companies (for example, Fonecta and Maistraatti).


7 Data transfers and data transfer

Sunholidays Oy does not publish the personal data it collects and observes the obligation of confidentiality, unless otherwise required by law or legal obligation. 

Sunholidays Oy does not transfer information to the outside, except to such partners who produce a certain service or function of Sunholidays Oy. Sunholidays Oy has entered into data protection agreements with these partners. In data protection agreements, it has been agreed that personal data will be processed in a secure manner and only in writing.

Information is not disclosed or transferred outside the EU or the European Economic Area, neither to individuals, companies, nor organizations. The exception, of course, is contracts related to the sector, which are agreed separately.  Sunholidays Oy can hand over information to its partners outside the EEA, but in this case, templates according to EU model contracts will be made for the partner.

Marketing acquires information from an external service provider as an additional service. This additional information is not transferred to Sunholidays Oy's own customer register, but remains as information in the service provider's register. Sunholidays Oy hands over personal data to the processor for the implementation of this ancillary service.

8 Personal data retention periods

When storing personal data, we follow good practices and Finnish law.

Call and zoom recordings are kept for a maximum of six months from the time of the call.

Information from other forms is stored as long as it is necessary for the purpose of use.

9 Principles of registry protection

Access rights to Sunholidays Oy's registers are limited. Data protection and its monitoring comply with EU regulations. 

10 A person's right to check personal information about himself

Everyone has the right to find out from Sunholidays Oy whether or not personal data concerning him is being processed and what it is.

A person can also make a request for information in person or in another way in writing.

To the extent that Sunholidays Oy acts as the processor of the register , and is not the controller, Sunholidays Oy does not provide information about the person, but the request must be submitted to the controller.

We will deliver a response to the information request as soon as possible, but no later than within a month of receiving the information request.

We refuse unreasonable requests for information.

11 Correction or deletion of personal data

You can request correction of incorrect personal data. We will correct the information as soon as possible.

Notifications must be sent to the address

Everyone has the right to have their personal data removed from the register.


The person has the right to demand that Sunholidays Oy limit the processing of personal data, 

1) The processing is against the law and the person objects to the deletion of personal data and instead demands that their use be restricted

2) Sunholidays Oy no longer needs the personal data in question for processing purposes, but the person needs them to prepare a legal claim.

Personal data may only be processed with the consent of the person or to establish a legal sanction, or to protect the rights of another natural or legal person. This restriction does not apply to the retention of personal data.

12 The court objects to the processing citing a personal reason

Everyone has the right to object to processing actions directed at personal data to Sunholidays Oy, citing a special reason. 

​13 Ban on direct marketing

If personal data is used for direct marketing, the person can at any time prohibit the data from being used for marketing purposes. In this case, personal data may no longer be processed for this purpose. If the customer wants to prohibit direct marketing, it must be notified in writing to Sunholidays Oy.


The person's right to transfer data 

Everyone has the right to receive their personal data held by Sunholidays Oy and request that it be transferred to another controller.

​The customer can also submit personal data to another data controller with the permission of the inspection right

​15 The right to complain to supervisory authorities

​All legal entities have the right to complain to the competent supervisory authority (Data Protection Agency, Ratapihantie 9, PO Box 800, 00521 Helsinki or data, if in his opinion Sunholidays Oy has not complied with data protection regulations in its operations.

Contact information


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