ROVIO INVESTOR NEWSLETTER PRIVACY NOTICE
Last updated: November 11, 2020
This notice explains how Rovio Entertainment Corporation (referred to as “we” in this document) collects, stores, uses, or otherwise processes the personal data of investors or other relevant stakeholders (referred to as “you” in this document) entered onto the subscriber list of our investor newsletter (the “Newsletter”), and what rights you have if we are processing your personal data. It is important that you read this notice so that you are aware of how and why we may use your data.
1 Data controller
By “data controller,” we mean an entity that determines how and why personal data is processed. With regard to the activities described in this notice, we are the data controller. Our company name is Rovio Entertainment Corporation. Our address is Keilaranta 7, FI-02150 Espoo, Finland.
2 Contact information
Your point of contact in matters related to this notice is our investor relations team, which you can reach at email@example.com.
We have also designated a Data Protection Officer (“DPO”) to oversee our data protection related matters. If you have any questions or concerns about the way we use your data, you may contact our DPO by email at firstname.lastname@example.org.
3 Why do we process your data and on what basis?
We may process your data to send out the Newsletter or other related communications, to manage the Newsletter and its subscriber list, and to improve the Newsletter. We do this based on our legitimate interest to inform our investors and other relevant stakeholders about happenings at Rovio that we think may interest them.
We do not use your data to make automated decisions which significantly affect you. By an “automated decision,” we mean a decision made by an information system without any human intervention.
4 What data do we process?
We may process the following data relating to you:
- your name and contact details, including an email address,
- which communications you are subscribed to, and
- information about your engagement with our communications.
We do not expect to process any special categories of data relating to you. By special categories of data, we mean genetic, biometric or health information, information revealing racial or ethnic origin, sex life or sexual orientation, political opinions, religious or philosophical beliefs or trade union membership, or information about your criminal offences or convictions.
5 Where do we collect your data from?
We collect your data from communications you have with us (for example, emails you exchange with our investor relations team). Providing your data to us is not mandatory, unless you want to subscribe to the Newsletter.
6 Who do we share your data with?
We may share your data with third parties to achieve the purposes described in this notice. This may include sharing data with the following types of recipients:
- other companies in the Rovio group, for example where they help us administer the Newsletter’s subscription list,
- persons or companies outside of the Rovio group that provide services to us (for example, a service provider we use to send out the Newsletter),
- prospective or actual buyers (including their agents or advisors) in the context of a planned or actual acquisition, merger, or other business restructuring,
- competent courts of law or other government authorities where we believe disclosure is necessary as a matter of applicable law or regulation, or
- any person or entity where we believe disclosure is necessary to exercise, establish or defend our legal rights or to protect your or another person’s vital interests.
In connection with the processing activities described in this notice, your data may be transferred to or processed in countries outside of the European Union (“EU”) and the European Economic Area (“EEA>”). These countries may have data protection laws that differ from the laws of your country. In these cases, we will provide appropriate safeguards to protect your personal data as required by applicable laws and regulations. These safeguards may include compliance with the European Commission’s standard contractual clauses for transfers of personal data. Upon request, we can provide you a copy of the European Commission’s standard contractual clauses and further details on the applicable safeguards.
7 How long do we keep your data?
We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected. Generally, this means that your data is stored for as long as you remain subscribed to the Newsletter. If you unsubscribe, some data may be kept to ensure further communications are not inadvertently sent to you. Other than that, we will delete your data after the applicable retention period.
8 How do we keep your data secure?
We have adopted measures to provide your data a level of security appropriate for the degree of risk involved with the processing activities described in this notice. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures we employ include, for example, protecting the systems used with user credentials and limiting access to them to those who have a need to have access.
9 Your rights
If we are processing your data, you have the right to:
- access, correct, or request the deletion of your data,
- request us to restrict our processing of your data,
- object to our processing of your data to the extent our processing is based on our legitimate interests or the legitimate interests of a third party, or
- where technically feasible, request a copy of the personal data you have provided to us in machine-readable format.
To unsubscribe from the Newsletter, please use the unsubscribe link found in the footer of each Newsletter.
To exercise any of your rights, you may also contact us at email@example.com. To fulfill your request, we need to confirm your identity to verify your right to make the request, which may involve requesting additional information from you. While we will usually not do so, we reserve the right to charge an appropriate fee from you for the exercise of your rights where permitted by applicable laws and regulations.
Finally, you always have the right to lodge a complaint with your local data protection authority regarding our processing of your data. For more information, please contact your local data protection authority (for example, the Office of the Data Protection Ombudsman in Finland).
We may update this notice from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. We may also notify of changes by other means that are appropriate to the significance of the changes.