Privacy Policy

Version 14.3.2022

1. CONTROLLER

Solteq Plc (Company ID 0490484-0) (“Solteq”)
Karhumäentie 3
01530 Vantaa, Finland

Data Protection Officer’s contact information:
Tel: +358 (0) 20 14444
E-mail: DPO@solteq.com

2. NAME OF REGISTER

The case register of the whistleblowing channel of Solteq Plc.

3. PURPOSE OF PROCESSING AND LEGAL BASIS

The purpose of processing of personal data is to maintain a whistleblowing channel within the Solteq Group, to process any reports filed through the channel and to undertake any measures caused by such reports.

The legal basis for the processing is the necessity to comply with the legal and statutory obligations of the controller, namely the EU Directive on the Protection of Persons Who Report Breaches of Union Law (2019/1937) and national laws based on the directive.

Furthermore, processing is based on the legitimate interest of the controller to investigate and act upon reported illegal, corrupt or unethical activities, as well as to ensure compliance with binding stock exchange rules.

4. PROCESSED PERSONAL DATA

The following personal data may be processed:

• The name, contact information and job title of the person filing the report
• The names, contact information and job titles of the persons identified in the report, including subjects, witnesses and persons involved
• The filing date and place of the report
• Any material filed in connection with the report as well as discovered during the course of an investigation initiated based on the report
• Information on measures undertaken and caused by the report and the investigation
• Information on any consequences, including legal consequences, caused by the report

5. REGULAR DATA SOURCES

The primary data source of the register are reports filed through the controller’s whistleblowing channel.

Further data sources include information obtained from the persons involved in a reported matter, as well as information discovered as a part of an investigation caused by a report.

6. DURATION OF PROCESSING ACTIVITIES

The collected personal data will be stored and processed for as long as is necessary for the purposes to which it has been collected, taking into account possible investigations that may be triggered by a filed report.

Personal data will, however, be deleted from the register after two (2) years from its collection if a longer storage period is not required by a legal process or a similar compelling reason related to the information.

7. REGULAR DISCLORURES OF PERSONAL DATA

Personal data contained in the register will primarily be used in the controller’s internal investigations.
Personal data may be disclosed to public officials (such as the police) or governing bodies as is necessary during the course of investigations and possible legal processes, as well as to comply with and demonstrate compliance with applicable laws and regulations.

The whistleblowing channel used by Solteq is maintained by an external service provider, an independent Finnish company, Plan Brothers Oy. The Plan Brothers Oy has confirmed by a written agreement that it has undertaken to keep all data confidential and secure, and process personal data obtained through the whistleblowing system in accordance with the applicable data protection legislation.

8. TRANSFER OF DATA OUTSIDE THE EEA

The personal data contained in the register will not be transferred outside the EEA.

9. DATA SECURITY

The data contained in the register is protected in accordance with Solteq’s applicable data security policies, including the use of appropriate user credential control, passwords, firewalls and other technical and organizational measures. Any physical copies of the data are stored in locked and supervised spaces and are disposed of in accordance with Solteq’s policies concerning the disposal of sensitive information.

10. RIGHTS OF DATA SUBJECTS

As a data subject, you have the following rights.

If we are processing your personal data based on your consent, you have the right to withdraw you consent partially or completely at any time. Withdrawing your consent will not affect the processing of your personal data that took place prior to the withdrawal.

You have a right to receive confirmation from us on whether or not we process your personal data as well as to be informed about how we process your data, such as the purpose of processing and the categories of personal data that are being processed. You also have the right to receive a copy of the personal data concerning you that we are processing. If you request more than one copy, we may charge you a reasonable sum based on administrative expenses.

You have a right to have your inaccurate personal data rectified without delay as well as to have your incomplete personal data completed by providing additional data.
We will erase your personal data at your request provided that we have no obligation to retain the data based on obligations between the parties or based on applicable laws or regulations.

In certain situations, specified by the applicable data protection legislation you also have the right to request restriction of the processing of their personal data, the right to object to the processing of their personal data as well as the right to have your data transmitted from one system to another.

You have the right to lodge a complaint with a supervisory authority (without it having an effect on other administrative redress procedures or judicial remedies). This kind of complaint is lodged with a supervisory authority in the EU/EEA Member State where you are habitually resident, where you work or whose applicable data protection laws and regulations have been infringed according to the complaint. Solteq Plc’s head office is located in Finland, where the competent supervisory authority is the Office of the Data Protection Ombudsman.