Privacy Statement / Information Document – EU General Data Protection Regulation, 2016/679
Summary
In this summary, we explain how Spark Traineeships Oy processes the personal data of individuals in its communication and marketing target groups. Detailed information about the processing activities
can be found in the information and marketing register’s privacy statement below.
We process your personal data with your consent
The processing of your personal data at Spark Traineeships is based on your consent, our mutual
agreement, or you have given us marketing permission in another context, for example, by subscribing
to our newsletter.
What information do we collect about you?
We only collect information about you that is necessary for the communication between Spark
Traineeships Oy and you, related to our company. This information includes, for example:
• your email address, name, phone number, position in the company, and social media address. We do not process your data for any other purposes than these.
Where did we collect your data from?
The personal data we have stored was obtained when you expressed interest in our services, sent a
contact request or other message, subscribed to our newsletter, participated in our events, or
responded to our campaign. Personal data may also be collected from public sources or from
companies that provide personal data services. We process your data only for the necessary time,
after which we will delete the data from our registry.
How long do we keep you personal data?
Spark Traineeships will not retain your personal data longer than is strictly necessary to achieve the
purposes for which it is collected. After this period, the data will be deleted or anonymized.
Cookies and Similar Technologies
Spark Traineeships uses only technical and functional cookies, as well as analytical cookies that do
not compromise your privacy. A cookie is a small text file stored on your computer, tablet, or
smartphone when you visit our website. The cookies we use are essential for the proper technical
functioning of the site and to enhance your user experience. They help ensure that the website
operates correctly and remember your preferences, such as language settings. In addition, they
enable us to improve and optimize our website. You can disable cookies at any time by adjusting your
browser settings to prevent their storage. You may also delete cookies that have already been saved
through your browser settings.
To whom do we disclose your data?
We only disclose your data to our communication and marketing tool providers solely for the purpose
of implementing the service. With all parties to whom your data may be legitimately disclosed, lawful
data processing agreements have been made, and your data is always treated as confidential.
How do we protect your data?
We use methods and systems for processing personal data in which your data is protected in the best
possible way. We have restricted access to your data with access rights and appropriate technical
protection methods. Our staff involved in the processing of your data adheres to a duty of
confidentiality and takes all measures to protect your privacy.
Spark Traineeships Oy Information and Marketing Register 20.8.2025
1. Data controller
Spark Traineeships Oy
Business ID: 3520898-7
Satutytönpolku 3, 15210 Lahti
2. Contact person responsible for the register
info@sparktraineeships.com
3. Name of the Register
Spark Traineeships Oy Information and Marketing Register.
4. Purpose and Legal Basis for the Processing of Personal Data
The legal basis for the processing of personal data in accordance with the EU General Data Protection
Regulation is:
• Performance of a contract: the individual’s customer or employee relationship with Spark
Traineeships Oy.
• The individual’s consent (for example, marketing consent given through contact via the web
service, phone, or email).
• The legitimate interest of Spark Traineeships Oy to offer its services to company contacts
whose contact information is available from publicly available data sources or from
companies that provide personal data services.
The purpose of processing personal data is to inform about information related to Spark Traineeships
Oy and to market services in the form of the group’s newsletter or targeted marketing campaigns.
Personal data is not used for automated decision-making or profiling.
5. Categories of Data Subjects
Contact persons of Spark Traineeships Oy’s customers and potential customers, Spark Traineeships
Oy’s employees and trainees, and individuals who have subscribed to electronic marketing messages
from Spark Traineeships Oy.
6. Data Content of the Register – Categories of Personal Data
The information stored in the Spark Traineeships Oy information and marketing register includes:
• the individual’s name, position, company/organization, contact information (phone number,
email address, address).
• website addresses, IP address of the network connection, identifiers/profiles in social media
services.
• information about ordered services and their changes.
• information obtained based on cookie policy acceptance about visits to Spark Traineeships
Oy’s websites and areas of interest.
7. Recipients and Categories of Recipients of Personal Data
Spark Traineeships Oy uses subcontractors who process personal data on its behalf. Subcontractors
act as Spark Traineeships Oy’s system and service providers. Appropriate personal data processing
agreements have been made with the subcontractors, which, in addition to the terms of processing,
include a commitment to confidentiality.
8. Transfer of Data outside the European Union or European Economic Area
Personal data is primarily processed only within the EU/EEA area. In certain cases, personal data may
also be technically processed outside the EU/EEA area. In such cases, Spark Traineeships Oy ensures
a sufficient level of data protection as required by law.
9. Personal Data Retention Period
Data is stored in the register for a necessary period or until the data subject withdraws their consent
for the processing of their data. After the withdrawal of consent or the expiration of the retention
period, the controller will properly destroy all data related to the data subject, regardless of the storage
format.
10. Data Subject’s Rights and How to Use Them
For all matters related to data protection and the processing of personal data, contact the Spark
Traineeships Oy data protection officer at the email address info@sparktraineeships.com.
If the Data Subject wishes to check their personal data or receive other information about the
processing of their data, the Data Subject must prove their identity in connection with the request,
either with strong electronic identification or by presenting an official identity document.
Right to access data – right of inspection
Data subjects have the right to inspect the data concerning them in the register. To check their own
data, the data subject must submit a written request, personally signed or verified in a
corresponding manner, to the controller, or present the request in person at the controller’s office.
The data subject must also prove their identity in connection with the request. The controller will
provide the data requested by the data subject without undue delay:
o Electronically, if the data subject has requested it and if it is securely possible.
o Or by arranging an opportunity to review the stored data about them at one of the
Controller’s offices.
Right to rectification, erasure, and restriction of processing
The data subject has the right to request the rectification or erasure of incorrect or inaccurate data
in the register, or the restriction of its processing.
Right to object to processing
The data subject has the right to object to the processing of their personal data.
Right to data portability
The data subject has the right to request the transfer of the data they have provided in a machine-
readable format.
11. Withdrawal of Consent
The data subject has the right to withdraw their consent for the processing of their personal data at any
time. The data subject can withdraw their consent to receive information and marketing messages by
using the channel-specific unsubscribe function or by sending a request for data deletion to the
controller. After the withdrawal of consent, the controller will no longer process the data subject’s
information for these purposes.
12. Right to lodge a complaint with a supervisory authority
If the data subject believes that the processing of personal data is not lawful, they have the right to file
a complaint with the supervisory authority.
13. Data Sources, Regular Data Sources
The data stored in the register is obtained from our customer relationship management system
(existing or potential customers who have been in contact with us) or from the individual, for example,
through messages sent via web forms, email, phone, social media services, and at events where the
person provides their information. In addition, personal data may also be collected from public
sources or from companies that provide personal data services.
14. Automated Decision-making Including Profiling
Personal data is not used for automated decision-making or profiling.
15. Principles of Register Protection
Care is taken in the processing of the register, and the data processed with the help of information
systems is properly protected. When register data is stored on Internet servers, the physical and digital
data security of their hardware is taken care of appropriately. The controller ensures that the stored
data, server access rights, and other information critical to the security of personal data are handled
confidentially and only by those employees whose job description includes it.