Auctions and sales
Data protection notice
9 February 2024
Data protection notice, VR Group Procurement
Contact persons for bidders and buyers participating in auctions and asset sales
1. Controller
VR-Group Ltd (hereinafter referred to as “VR”)
Business ID 1003521-5
Radiokatu 3
PO Box 488
FI-00101 Helsinki, Finland
tel. +35829 4343
2. Data protection officer and contact information
VR Group's Data Protection Officer: tietosuojavastaava(a)vr.fi
VR Group Procurement data protection contact: info.procurement(a)vr.fi
Data and contact requests: info.procurement(a)vr.fi
3. Purpose of the processing of personal data
The data of the contact persons and designated professionals of bidders and buyers participating in auctions and asset sales organised by VR are processed for the following purposes:
- Preparation, processing and archiving of auctions and sales and related processes and documents
- Management of cooperation and related contacts
- Statistics, reporting and planning of cooperation
- Verification of corporate responsibility
The processing of personal data of the company's contact persons and designated professionals is based on:
A contract: We process personal data of the contact persons and designated professionals to put into effect a contract to which the bidder or buyer is a party.
A legal obligation: We process the personal data of the bidder or buyer in order to fulfil our statutory obligations, for example in accordance with the obligations imposed on the procurement documents.
A legitimate interest: The processing of the personal data of a contact person may be based on the legitimate interest of the data controller when the data are used to manage and develop the customer relationship or to prevent and investigate irregularities.
4. Sources of data
As a rule, VR collects the data of contact persons and designated professionals from the company or person acting as the tenderer.
5. Data subjects and the personal data groups
Data subjects: Contact persons of bidders and buyers and designated professionals
Basic information, including:
- Basic information on bidders and buyers, such as company/association name, business ID, industry, postal address, invoicing information
- Contact details of the contact persons of bidders and buyers, as well as designated professionals, such as first name, last name, email address and telephone number.
6. Recipients of personal data
We use external actors to support the processing of personal data, including the maintenance and development of IT systems. These service providers process personal data commissioned by us and on our behalf. The data processing is in compliance with the current legislation and is always carried out in accordance with this data protection notice. This is ensured, for instance, through agreements between the various organisations.
Without statutory grounds, we will not disclose customer data to parties outside VR or parties other than those participating in the production of VR’s services.
7. Transferring or handing over data outside the EU or EEA areas
Personal data will not be disclosed outside the EU or the European Economic Area or outside countries which the European Commission considers to have an adequate level of data protection, unless the adequate level of data protection has been ensured by means of contracts or in another manner required by law.
8. The data retention period or the definition criteria for the retention period
In data retention, the controller follows its statutory obligations. The practices of the retention of the personal data of contact persons of bidders and buyers and designated professionals depend on the grounds for the processing of the data. In general, we follow the data retention periods presented here:
- Contracts and personal data contained in contracts: Retention period is ten (10) years from the termination of the contract
- Tender documents and personal data contained in documents: Retention period is ten (10) years from the termination of the contract
- In other cases where the personal data of buyers is processed: Personal data is preserved in contact person database for the length of the contractual relationship or if there is other contractual need related to the relationship with the buyer
9. Rights of the data subjects
As a partner’s contact person, you have the right to access your personal data processed by VR. You can exercise your rights by contacting VR at: [email protected]. You will receive a response to your request no later than one month after sending the request. Below, we have listed the general rights of data subjects:
1. Right to access data
A data subject shall have the right to receive confirmation regarding whether their data have been processed by VR and to receive a copy of their personal data.
2. Right to rectification
A data subject shall have the right to request that VR rectify inaccurate or incorrect data regarding the data subject. The incorrect nature of data is to be decided on a case-by-case basis by resolving whether the data are incorrect from the viewpoint of the processing thereof (unnecessary, incomplete, outdated).
3. Right to erasure ('right to be forgotten')
A data subject shall have the right to request that VR erase the data subject’s personal data. The requests will be processed on a case-by-case basis and data that VR has a legal obligation or right to store will not be erased.
4. Right to restriction of processing
Data subjects shall have the right in certain special situations stipulated by a decree to request the restriction of the processing of their personal data.
5. Right to object
A data subject shall have the right to object to the processing of their personal data if the processing is based on the controller’s legitimate interest or if the personal data are processed for direct marketing purposes.
6. Right to data portability
A data subject shall have the right to request their personal data in machine-readable file format. This right concerns data that are in electronic format and the processing of which is based on consent or a contract.
7. Right to withdraw consent
In situations in which the processing of the data subject’s personal data is based on consent, the data subject shall have the right to withdraw their consent. Once the consent has been withdrawn, the consent-based processing in question will be discontinued.
8. Right to lodge a complaint with an authority
We seek to resolve any disputes primarily directly with data subjects. If a customer finds that we have not processed personal data as stipulated by law, the customer may lodge a complaint with a data protection authority.
10. Principles of data protection
The data security of VR’s personal data and its confidentiality, integrity and accessibility is ensured with appropriate technical and organizational measures in accordance with VR’s data security principles. Personal data is protected against unauthorized access and illegal or accidental processing. Personal data is processed only by persons specifically appointed by VR to such tasks. We train and provide guidance to our employees in matters related to data protection.
