Shareholder and Investor Privacy Notice
Read more below.
HKScan Oyj, 0111425-3, (“HKScan”, “we”, “us”) is the data controller in relation to the processing of your personal data as a shareholder, shareholder organization’s representative or other investor.
On this page, we describe how we collect, store and share your personal data. Personal data means any information which may be used to identify an individual.
It is important to us that you feel safe with how we handle your personal data. We take measures to ensure that your personal data is protected and that the processing of your personal data is carried out in accordance with applicable data protection regulations and our internal policies and procedures.
We may collect your personal data in the following ways:
Personal data that you give to us, e.g. when you register to our annual general meeting by filling in forms, when you provide Power of Attorney to us, or when you are communicating with us in other shareholder or investor related matters.
Personal data we collect from the book-entry system maintained by Euroclear Finland, e.g. when we cross-check the personal data provided by you with the information available in the book-entry system or when we need to collect your ownership information from the book-entry system.
Personal data that we collect from other sources, e.g. from the entity that you represent in connection with our communication with your organization (for example in relation to your role) or from supervisory authorities.
We process your personal data for the following purposes:
Maintain HKScan’s shareholder register
We process your personal data, as a shareholder or a representative of a shareholder, in order to maintain up to date shareholder register on shares and their owners, including other necessary data, that are incorporated in the book-entry system in accordance with and as required by applicable legislation.
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Categories of personal data |
Legal basis |
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Legal obligation. The processing is necessary in order to fulfill our legal obligations under Finnish Limited Liability Companies Act and other regulation and guidance concerning listed companies. |
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Storage period: Personal data in the shareholder register is stored for as long as there are no changes due to a change of ownership. After changes in the ownership, the shareholder register is updated with current and up to date shareholder information. Personal data relating to payments is stored in accordance with the storage requirements of accounting and tax legislation. |
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Carry out general meetings
We process your personal data in order to carry out general meetings, e.g. in connection with collecting your registration to the general meeting, verifying your identity and eligibility to participate in the general meeting (including possible Power of Attorney), preparing voting lists and communicating with you in relation to the general meeting.
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Categories of personal data |
Legal basis |
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Legal obligation. The processing is necessary in order to fulfill our legal obligations under Finnish Limited Liability Companies Act and other regulation and guidance concerning listed companies. Legitimate interest. The processing is necessary in order to fulfil our legitimate interest in carrying out general meetings. |
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Storage period: Personal data included or attached to the general meetings’ minutes is stored permanently in order to fulfil legal obligations. Other personal data collected for this purpose is stored approximately 1 year following the general meeting in order to fulfil our legitimate interests and plan future general meetings. |
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Communicate business related information
We may process your personal data in order to communicate information on HKScan’s business operations, operational environment, strategy, targets and financial position in accordance with HKScan Corporation Disclosure Policy, e.g. in connection with disclosing information on stock releases and when responding to queries submitted by you.
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Categories of personal data |
Legal basis |
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Legitimate interest. The processing is necessary in order to fulfil our legitimate interest in communicating business related information. |
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Storage period: Personal data is stored during the subscription period and thereafter until you unsubscribe from the communication requested. After this, we will delete personal data processed for this purpose. Personal data relating to one-off queries is stored as long as necessary to provide response to you and thereafter deleted within reasonable period. |
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Carry out other events and activities
We process your personal data if you participate to other event organized by us, e.g. in connection with receiving and registering your registration to out event as well as when communicating with you in relation to such events.
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Categories of personal data |
Legal basis |
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Legitimate interest. The processing is necessary in order to fulfil our legitimate interest in carrying out other events and activities. |
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Storage period: Personal data is stored during the event and thereafter approximately 1 year after the event in order to fulfil our legitimate interest and plan possible future events. |
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Establish, exercise and defend legal claims
The processing may also be carried out for the purposes of establishing, exercising and defending legal claims where this is necessary, e.g in case of a dispute or litigation.
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Categories of personal data |
Legal basis |
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All categories of personal data that have been collected and which are necessary in order to establish, exercise and defend legal claims. |
Legitimate interest. The processing is necessary in order to fulfill our legitimate interests in establishing, exercising or defending legal claims. |
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Storage period: Personal data is stored for such period that is necessary in order to fulfil the purpose of establishing, exercising and defending legal claims. |
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Comply with legal obligations
We may process your personal data in order to fulfil other legal obligations, e.g. when we disclose the list of our shareholders to a third party based on a legal requirement or when we are obligated to disclose personal data to authorities.
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Categories of personal data |
Legal basis |
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All categories of personal data that have been collected and which are necessary in order to fulfill the legal obligation in question. |
Legal obligation. The processing is necessary in order to fulfill our legal obligations. |
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Storage period: Personal data is stored for such period that is necessary in order to fulfil each legal obligation. |
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Where necessary, we share your personal data with others. We categorize the recipients of personal data as service providers and other recipients. Service providers’ process personal data on our behalf and in accordance with our instructions only for the purposes set out in this privacy notice. Other recipients process personal data independently on their own behalf as controllers.
We share your personal data with:
Service providers
In order to fulfil the purposes of the processing of your personal data, we share personal data with service providers that we have engaged. These service providers provide us with services such as general meeting services (provided by Euroclear Finland Oy) and other IT and communications related services. The service providers may only process your personal data for these purposes and in accordance with our instructions and not for their own purposes. We are the data controller for the processing of personal data that the service providers carry out on our behalf.
Other recipients
Information regarding HKScan’s major shareholders and major shareholding notifications are published on HKScan’s website. Moreover, we are required to disclose the list of our shareholders to anyone requesting based on a legal requirements.
In addition, in certain cases we share, if necessary, your personal data with other recipients for certain purposes e.g. when fulfilling legal obligations and handling and/or defending legal claims.
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Recipient |
Purpose |
Legal basis for the transfer |
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Third party requesting a list of shareholders |
We may disclose a list of HKScan’s shareholders, including necessary personal data, to a third party requesting such list on the basis of Finnish Limited Liability Companies Act. |
Legal obligation. The processing is necessary in order to fulfill legal obligations. |
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Euroclear Finland Oy |
We share necessary personal data regarding shareholders with Euroclear Finland in order to maintain HKScan’s shareholder register as well as for Euroclear Finalnd to be able to administer the book-entry system. |
Legal obligation. The processing is necessary in order to fulfill legal obligations. |
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Public authorities |
We share necessary personal data with public authorities if we are obligated under law to disclose the information. |
Legal obligation. The processing is necessary in order to fulfill legal obligations. |
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Courts, counterparties etc. |
We may share necessary personal data with other parties in order to establish, exercise and defend legal claims. |
Legitimate interest. The processing is necessary in order to fulfil our legitimate interest in establishing, exercising and defending legal claims. |
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External advisors |
We share necessary information with external advisors, e.g. audit firms, and law firms if we are obligated under law to share the information or in order to manage and defend legal claims. |
Legal obligation and legitimate interest. The processing is necessary in order to fulfill legal obligations or, alternatively, to fulfil our legitimate interest of managing and defending legal claims. |
We always strive to store and process personal data within the EU/EEA. However, some of our service providers may be located outside the EU/EEA and in such a case, personal data will be processed outside the EU/EEA. In order to ensure that the personal data is protected we make sure that appropriate safeguards are in place in relation to the service providers which handle your personal outside the EU/EEA, e.g. by way of data transfer agreements (which include standard data protection clauses adopted by the EU Commission). If you have questions regarding the countries where your personal data is transferred and which safeguards we take to protect your personal data, or to request a copy of such safeguards and information, respectively, where they are available, please contact us at privacy@hkscan.com.
Under data protection regulations, you have certain rights in relation to the processing of your personal data. We process your personal data to the extent necessary in order to fulfill your rights. Please submit requests for exercising your rights through our data privacy website or by contacting us at privacy@hkscan.com.
You have the right to:
Access your personal data
You have the right to access personal data we process about you. You may request a copy of your personal data through our data privacy website, which can be found here. We will provide you with it unless we have lawful reasons not to share this data or if sharing the data would adversely affect the rights and freedoms of others.
Update your personal data
Furthermore, you have the right to request that incorrect or incomplete personal data is corrected or completed.
Object to the processing of personal data
You have the right to object to the processing of your personal data based on a legitimate interest for reasons which concern your particular situation. In such a situation, we will stop using your personal data where the processing is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your personal data is necessary in order to manage or defend legal claims.
Delete your personal data
Under certain circumstances you have the right to request that your personal data is deleted. However, we cannot delete your personal data if we for example are obligated under law to keep the data.
Restrict the use of your personal data
You have the right under certain circumstances to request that the processing of your personal data is restricted. If the processing of your personal data has been restricted we may only, besides storing the data, process your personal data with your consent, or in order to establish, exercise or defend legal claims or to defend rights of others.
We may occasionally update this information, e.g. if we would process personal data for new purposes, collect additional categories of personal data or share personal data with other recipients. In such a case we will notify you in an appropriate way. The latest version of the information is always published on this page.
If you have any questions regarding the processing of your personal data, please do not hesitate to contact us. See below for contact details. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant supervisory authority within your jurisdiction.
HKScan Oyj
Company registration number: 0111425-3
Lemminkäisenkatu 48, FI-20520 Turku, Finland
E-mail: privacy@hkscan.com