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Privacy Policy

Our privacy policy explains how we collect, process, disclose, and protect the personal data of our employees, job applicants, and customers. Personal data means any information relating to an identified or identifiable natural person, i.e., you. Such information about you includes, for example, your name, address, phone number, and photograph. We also explain your rights as a data subject. 

Survey and feedback forms that may be sent to individuals can include links to other companies' websites or services, which have their own privacy policies. We recommend that you review the privacy policies of such third parties. 

At Freshin, we comply with the European Union's (EU) General Data Protection Regulation and other applicable data protection legislation in the processing of personal data. 

Below, you will find more information about how we process your personal data. If you have any further questions, please contact us for more details.

Data controller
The controller of your personal data is Freshin Oy (hereinafter referred to as ”we” or ”the controller”), and you are an employee or job applicant of Freshin Oy.

Contact information
freshin@freshin.fi
p. 020 7303650

Data recipients
Only Fresh employees whose job duties require processing your personal data will have access to it. Such parties include, but are not limited to, payroll, HR, employees (both themselves and others), and managers as needed.

Your personal data may also be transferred to outsourced service providers based on an agreement for processing on our behalf. For example, an external service provider is responsible for maintaining the HR system and acts as a personal data processor. In addition, our contractual partners, in addition to us, will process, to the extent necessary, data from survey and feedback forms potentially sent to individuals, as well as your responses. Such subcontractors include, for example, IT service providers who, among other things, are responsible for the technical maintenance of systems or the processing of feedback. Service providers process your personal data as we have defined, and they do not have the right to use your data for their own purposes.

Purpose of processing personal data
Maintaining, managing, and statistical analysis of employment-related information, business development, and maintenance, management, and statistical analysis of registered interest information. We process our employees' personal data to manage the rights and obligations of the parties to the employment relationship, for example in relation to legal obligations or corporate arrangements concerning the employer company. In addition, we develop and maintain our operations as well as the sales and marketing of our services. We also collect and process your personal data to comply with our statutory requirements. We also process your personal data in connection with the collection, use, processing, and publication of surveys and feedback, as well as for event registration and participation. We may publish and use your feedback on our website, in newsletters, in marketing, on social media, and in internal training, as well as in the development of our operations. We will inform you in connection with the feedback survey when your answers are processed anonymously or if the feedback is not published. In addition, we process personal data in connection with recruitment.

Basis for Processing Personal Data
We are processing your personal data based on one of the following:

  • collective agreement (e.g., employment contract), 
  • your consent (e.g., electronic direct marketing). In this case, you can withdraw your consent at any time, 
  • our legitimate interests (for example, for statistics and transfer of your personal data within our group) or  
  • statutory obligation that we as a company must fulfill (for example, it is mandatory by law for us to retain your payroll information for accounting purposes or to fulfill statutory requests from authorities).

Registered groups
Employees, regardless of the duration or form of their employment. An employee also refers to apprentices, paid and unpaid trainees, etc. In addition, data of former employees will be retained in the system for the necessary retention period. Job applicants, which also refers to persons applying for apprenticeship training and work experience.
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Registered information. 
We process your personal data only to the extent necessary. The following types of information, among others, may be collected from data subjects:

  • Name, social security number and date of birth, language, photograph, address, email address, phone number
  • Next of kin's name and phone number
  • Company, Department, Office, Supervisor
  • Job title, Education, Language skills
  • Job descriptions including qualifications
  • References
  • Development discussions and goals
  • Employment details and work history
  • person number, result location
  • Salary information and bank details
  • Tax information including tax number
  • information about potential enforcement proceedings
  • Membership in a trade union (if the employee has provided the information themselves) for the purpose of paying membership fees
  • Absences and their reasons (reason codes for sick leave)
  • traffic violation notifications
  • holidays
  • Tools
  • other information added by the person themselves to the system and provided during the recruitment process, including attachments
  • Information stored from third-party registries with your consent.
  • information on participation in events and training, as well as information collected during event registration and information provided by the registered individual, such as special dietary needs and allergies
  • the interests, areas of interest, and other information you provide.
  • other information you provided and added, as well as attachments with pictures.
  • For events and training sessions, we also collect necessary information related to them, such as your dietary preferences for catering. The event registration details you provide may include your health information, such as allergy information. 
  • Marketing material created with your consent, such as videos.
  • Information you provide in your resume and job application, such as work history, educational details, qualifications, language skills, and references; information stored in third-party registers with your explicit consent; satisfaction information and comments related to the application process; and other information you provide, which may include gender.

Regular information sources
As a general rule, we obtain information either directly from you, with your explicit consent, or otherwise with your cooperation from third-party registers.  

Our primary sources of information are employment contracts, freelance contractor agreements, and the employee database. Additionally, employees can enter their own information into systems (such as Lemonsoft and Sympa) and onto survey and feedback forms. Other sources of information may include our website and information you provide or enter yourself.

Regarding your job application, our sources of information are your job application and information obtained from recruitment agencies in connection therewith, as well as other information you have provided and contacts you have made. Your information may also be collected on our website.

Regular data disclosures and data transfers within the EU and EEA outside
Information may be disclosed and transferred within the Group to perform tasks necessary for the maintenance of the employment relationship, as well as to parties who have a statutory right to receive the information (such as the tax authorities). In addition, we may disclose your personal data to the extent necessary to a third party, for example, when various mementos or rewards are sent to individuals.

We process data primarily within the EU and the European Economic Area. Therefore, data is generally not transferred or disclosed outside the EU and the European Economic Area, unless it is necessary for the processing of personal data as described above, in which case we ensure an adequate level of protection for personal data in accordance with legislation, and in particular Articles 45-46 of the EU General Data Protection Regulation. Please note that some of our partners may process your personal data outside the EU (such as Google and Facebook). 

Personal data retention period
Personal data is retained only for as long as it is necessary to fulfill obligations arising from the employment relationship. For example, the employer has an obligation to provide an employment certificate if the employee requests it within ten years of the termination of the employment relationship.

Principles of Personal Data Protection
Personal data is stored primarily using IT-based systems and protected by necessary technical measures. Appropriate technical and organizational security measures are in place for processing personal data to protect it from loss, misuse, disclosure, alteration, and destruction. Physical materials containing personal data are stored in locked premises/archive cabinets, with access restricted to designated individuals authorized for access due to their job responsibilities. Only employees, contractors, and other individuals employed by the data controller who require access to the database for their duties and are authorized to process the personal data in question are permitted to access databases and systems and use personal data. Additionally, each individual can add/edit and delete their own information in the HR system. General basic personal information (such as email address, job title) of each registered person in the HR system is visible to everyone who has access to that system.  

Registered person's rights
The registered person has the right

  • to request access to personal data concerning them from the controller, as well as the right to request the rectification or erasure of such data or the restriction of processing or to object to processing, as well as the right to data portability;
  • to the extent that the processing of personal data is based on the consent of the data subject, the right to withdraw consent at any time without prejudice to the lawfulness of the processing carried out before the withdrawal of consent based on consent.
  • to avoid being subjected to automated decision-making without a legal basis
  • Make a complaint to the supervisory authority regarding the processing of personal data.

The right to lodge a complaint with a supervisory authority
If you believe that we are not processing your personal data in accordance with data protection regulations, you may lodge a complaint with a supervisory authority in the EU Member State where you have your habitual residence or place of work, or where you believe the infringement has occurred. 

In Finland, the authority in question is the Data Protection Ombudsman.
The Office of the Data Protection Ombudsman
Street Address: Lintulahdenkuja 4
00530 Helsinki
Mailing address: PO Box 800
00531 Helsinki
Phone (switchboard): +358 29 66700
Email: tietosuoja@om.fi