This privacy statement applies to processing of personal data of users of the Spotgate service. Spotgate system is owned by Suomen Kaupallisten Televisioiden Liitto ry / Screenforce. TV commercial producers and media companies use the system to transfer their digital commercials to Finnish TV channels. Please read this statement carefully before using the service.
1. Controller
Suomen Kaupallisten Televisioiden liitto Ry / Screenforce
Address: Mannerheimintie 15bB, 00260 Helsinki
Business ID: 1799117-0
Contact person: Executive Director Anna Lujanen
Telephone: +358 40 5274734
Email: anna.lujanen@screenforce.fi
2. Purpose and legal basis for processing of personal data
We process personal data to:
- fulfill our contractual obligations, such as:
- authenticate and authorize users;
- invoice users by the number of transferred commercials;
- serve customers in customers service situations to identify user and organization; and
- provide reports to users.
- improve the services and correct errors on the basis of our legitimate interest, such as:
- process log files if there are problems in processing of commercial.
- fulfill our legal accounting obligations.
3. Types of personal data
We process the following categories of personal data:
- Name and title
- Email address and password
- Contact details, such as phone number, address and country location (e.g. Finland)
- Any other information necessary for invoicing purposes
- Personal data is given by persons themselves when they register as users of the service.
4. Transfers and disclosures of personal data
Personal data is disclosed to following partners:
- TV channels receiving commercial spots
- Finnish music rights owner association, Teosto TV channels and Teosto receive metadata of the TV commercials including names, email addresses and telephone/mobile phone numbers.
Otherwise, no personal data is disclosed to third parties unless Screenforce is legally required to do so or unless Screenforce has the data subject’s consent.
In addition, Screenforce uses subcontractors to process the data in which case it guarantees through contractual arrangements that the data will be processed in accordance with applicable data protection legislation. Some of Screenforce’s or its subcontractors’ partners may located outside the EU or the EEA. In such a case, Screenforce will ensure the adequate level of protection of personal data by agreeing on matters related to the confidentiality and processing of personal data as required by legislation, e.g. by using Standard Contractual Clauses approved by the European Commission.
5. Retention period of the personal data
All assets, metadata and transactional/activity logs shall be kept indefinitely for audit and historic reporting purposes. There is legitimate interest to hold data that may be personal data to allow companies to view historical records of their files and who processed them.
Data including personal data shall be removed as follows:
- If data subjects delete their own data in the platform, data are stored in a backup and all such data will be permanently removed within 30 days.
- If a company for which the data subject belongs to, no longer uses the system for a period of 2 years, the data will be archived and made unavailable to all users. Permanent deletion will occur after 7 years.
Data subject may also request for a deletion of data as set out below.
6. Rights of the data subjects
Data subjects have the following rights:
- Right of access, correction and erasure of personal data: Data subject has a right to access personal data processed by Screenforce. Data subject has a right to request to correct, complete or delete erroneous, insufficient or outdated personal data. However, data is not deleted if personal data is needed for legal obligation or establishment or responding a legal claim or the data is needed to fulfill agreement between data subject and Screenforce.
- Right to data portability: Data subject may request to transfer his/her personal data that is processed automatically on the basis of his/her consent or contract.
- Right to withdraw consent: If processing of personal data is based on data subject’s consent, it may be withdrawn at any time. Right to object and limit processing: Data subject may object processing based on legitimate interest. For example, in this situation processing is limited for the time period that is needed to evaluate the grounds for objecting the processing. Processing may also be limited if person claims the personal data being incorrect. Limitation applies for the time period needed to ensure the correctness of personal data.
- Right to lodge a complaint: Data subject has a right to lodge a complaint to data protection authorities (www.tietosuoja.fi), if the person thinks that his/her personal data has been processed against applicable law.
If a data subject wants to use the rights described above, he/she is advised to contact Screenforce (please see contact details on section 1). Screenforce may ask data subject to verify his/her identity when using the rights.
7. Cookies
Spotgate sets technical cookies. Cookies hold session information like session id and language parameter of the user. These cookies are necessary for the service to function properly.
8. Changes to privacy statement
Screenforce may change this privacy statement and its information. It is recommended that you read this privacy statement on a regular basis to see if there are any changes done.
This privacy statement was updated on 22.4.2022.