Privacy Notice – RELEX Surveys

Last updated on August 29, 2024

In brief

This privacy notice explains the data processing related to RELEX customer surveys. The content is summarized as follows:

On occasion, RELEX uses surveys to gather feedback from customers, partners, and other business relations.

All information gathered through these surveys is treated confidentially and used strictly for purposes of getting insights to RELEX operations (see more in section ‘Legal basis’) and for purposes potentially set out in the survey invite.

In full

This privacy notice (“privacy notice”) informs you about how Retail Logistics Excellence – RELEX Oy (“RELEX Oy”) and its affiliated companies globally (jointly “RELEX”) process the information they collect from respondents to RELEX surveys.

In this privacy notice, “personal data” or “data” herein refers to data that can be associated with an identifiable individual. “You” refers to the respondent of a RELEX survey whose personal data is processed.

What types of data does RELEX process and what is done with it?

Information processed

In most cases, we use our pre-existing information about you (typically your name and contact information) to approach you with the request to participate in our survey and to connect the survey results to the correct entity / individual / interaction.

In the course of responding to a survey, you may be asked – in addition to actual survey questions – to provide further information such as country, company name, and role information. This information is used for results segmentation.

Information collected via surveys may be combined with both information relating to past collaboration with you and/or your employer, and with follow-up activities.

Depending on the used survey tools, we may also track your interaction and progress with the survey invite and survey itself.

Whose data is processed?

RELEX may send surveys to different audiences, including but not limited to RELEX prospective and current business partners, customers, contractors, and their employees.

Legal basis

Survey data

RELEX pursues the following legitimate interests when processing your data in relation to surveys.

Your data is processed based on the legitimate interest of RELEX to measure our marketing activities, enhance and maintain good relationships with our business partners, customers, and contractors, and measuring satisfaction with and collecting feedback on our operations, products and services, related activities, and other mutual cooperation and/or implementation approaches so we could improve.

Analytics

Depending on technologies used, survey analytics are based either on legitimate interest or consent.

Data storage and duration

How long will your personal data be stored and processed?

The survey responses shall be stored without a set time limit. Directly-identifying respondent information will be deleted from survey raw data after twelve (12) months from completion of the survey analysis. Support ticketing surveys are stored for as long as the original incident information is stored.

If your response, including your contact information, leads to subsequent communications/remedial actions, such information may be stored for a longer period, depending on the need at hand.

Data movement

Data sources

In case of customer satisfaction surveys, RELEX has previously collected your email address or other associated data either directly from you or in relation to your use of our training, support tools, solutions, or customer registry.

In case of marketing surveys, we typically have your contact information from our customer registry, event participant list, or your other point of interaction with RELEX.

Transfers of data to processors

Your data may be made accessible to RELEX’s service providers in a limited context. While doing so, such third-party service provider personnel may process, store, or incidentally access your data when undertaking their contracted activities.

The processors which are provided with your data include:

ProcessorService ProvidedProcessor corporate location
Momentive Europe UCSurvey platform titled “Survey Monkey”Ireland
Microsoft GroupSurvey platform titled “Microsoft Forms”USA, Ireland
Atlassian IncAutomated survey tool “JIRA Service Desk”USA
Qualtrics LLCSurvey platform titled “Qualtrics”Ireland

RELEX may also occasionally use other tools not mentioned herein for undertaking the surveys. You will notice the use of other third-party tools when interacting with the survey.

A full list of RELEX sub-processors which may process your personal data can be found on our processor page.

Data processing locations and transfers of personal data outside the European Economic Area (EEA)

Survey response data is by default stored in the European Union. Some RELEX affiliates are located outside the European Union or the EEA, and employees of such affiliates may process data for the purposes specified in this privacy notice. We may use service providers (see above) that are located outside the European Union or the EEA.

Global or cross-border data transfers are conducted after an assessment of potential privacy risks. Data transfers outside the European Union or the EEA are limited to those countries that the European Commission identifies as having adequate levels of data protection. We ensure that the transfer is legal and safe by concluding an agreement based on the EU Commission’s standard contractual clauses (the fixed content of such clauses is available here) or by taking other measures (such as requiring registration under the EU-US Data Privacy Framework) that are required under applicable legislation.

Upon request, RELEX will provide additional details relating to data transfers, the safeguards that we have put in place, or a copy of any related documents.

Other

Where RELEX takes steps to sell, buy, merge, or otherwise reorganize its businesses in certain countries, this may involve disclosing data to prospective or actual purchasers, sellers, or partners and their advisors. In such circumstances, RELEX takes all reasonable steps to ensure that the appropriate measures to protect personal data are taken by such prospective or actual purchasers, sellers, or partners and their advisors.

There may also be circumstances not covered by this notice where processing or disclosure of your data may be justified or permitted. One such example includes complying with a court order, or a warrant issued by the authorities, where we are compelled to produce such information.

Other circumstances in which there may be a justifiable legitimate interest to disclose your data to a third party are where such disclosure is necessary to address an ongoing problem, or where we need to meet the legitimate information requirements of our third parties. In any such action, we act according to the applicable laws.

Security

Access to your personal data is restricted to RELEX employees responsible for the survey in question. Beyond this, RELEX has also implemented appropriate technical and organizational measures to ensure data security to prevent unauthorized access to your personal data and any unauthorized manipulation of said data. Such measures include restricting access to your data and hosting it with service providers that can demonstrate an adequate level of data security.

Exercising your rights

You have the following rights to your personal data that we have gathered:

  • You have the right to access and obtain a copy of such data that we can identify as pertaining to you.
  • Should you find any errors in your data, those errors will be corrected at your request.
  • You have the right to object to the collection and use of your data, where our use of your data infringes on your rights more extensively than what can objectively be deemed as permissible.
  • You may request we cease storing your personal data when we no longer have a defensible need to store it or as otherwise allowed by applicable data protection law.
  • If you establish that the data we have pertaining to you is incorrect or we have no legal right to use it, you may request we cease any further processing of your personal data, or only store it until the issue is resolved.
  • Where our collection of data is based on user consent, you may also i) withdraw your consent via the appropriate settings, and ii) ask for your data in interoperable format.

If you have questions on the data processing that RELEX performs for our own purposes or if you want to exercise your rights relating to applicable data protection laws, please do not hesitate to contact us. If you feel that RELEX is not fulfilling your statutory rights, you have the right to lodge a complaint with the Finnish Data Protection Ombudsman.

RELEX contact information

RELEX Oy acts as the data controller for personal data covered by this privacy notice:

Retail Logistics Excellence – RELEX Oy
Business ID FI 1963444-1
Address: Postintaival 7, FI-00230 Helsinki, Finland
Website: www.relexsolutions.com

The contact person relating to this Privacy Policy is:

Privacy Director Hannes Saarinen
privacy@relexsolutions.com

Changes

To keep this notice up-to-date, we make changes and additions from time to time. We will publish the revised notice on our website or on any other channel where this privacy notice has previously been made available. We recommend that you revisit this privacy notice from time to time to review any possible changes. Any changes apply from the date that we publish the revised notice.

September 2023