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Balancing test

Is legitimate interest the most appropriate legal basis for processing?

Direct marketing of services is partly based on legitimate interest and consent and is an essential part of our customer acquisition process. With regard to consent, this concerns subscribers to our newsletter, senders of the contact form, users of the price calculator, and persons who have otherwise given their consent to marketing. Direct marketing of our professional services requires the collection of personal data of representatives of different organisations in order to target marketing communications. However, personal data cannot be collected solely on the basis of a contract or consent if a representative of a potential client organisation has not heard of us before. The most appropriate legal bases for processing the data are a combination of legitimate interest and consent.

Do the basic requirements hold?

The basic requirements for our interest are met as follows:

  • The interest complies with applicable EU or national law.
  • The interest is clearly stated.
  • The interest represents a necessary and real need.

Is processing personal data necessary to achieve the interest?

The services we provide are not basic services nor aimed at consumer markets. Our services are tailored software development expert services for different organisations, affecting a limited number of representatives within those organisations according to their roles or job duties. Due to the nature of our services we need to use targeted marketing communications to reach representatives from different organisations who are interested in our expert services. In such cases, processing personal data is necessary for us.

Does the interest really override the rights and freedoms of the data subject?

The personal data we process about an individual targeted by marketing communications are as follows:

  • Name of the data subject
  • Contact information
  • Organisation the person represents
  • The person’s position within their organisation
  • The data subject’s contact with us

Individuals targeted by our marketing communications can reasonably expect their data to be processed for the purposes described. Our marketing is targeted and based on the organisation the person represents and their role within that organisation.

The data subject and the controller are in a balanced position. The organisations represented by the data subjects are at least comparable in size to Kvanttori Oy, or the data subject represents an organisation larger than Kvanttori Oy.

The data we process about the data subject are not sensitive in nature and are often publicly available, for example from the organisation’s website or business registers. We do not process children’s personal data and the data subjects are not in a vulnerable position.

The processing of personal data and the targeting of marketing communications are essential for Kvanttori Oy’s business and continuity. Without processing this data, Kvanttori Oy could not target marketing communications to relevant actors, which would materially affect our customer acquisition.

Additional data protection guarantees

Personal data is stored in a separate system with restricted number of processors. Access to the system requires multi-step authentication from the processors. Data stored in the system is used only for the described marketing communications activities.