Privacy Policy
1. General
This Privacy Policy describes how personal data is processed by Termex-Eriste Oy and its subsidiary Vintit Kuntoon Oy. This Privacy Policy applies to the controller’s and its subsidiary’s websites, the delivery of products and services, customer relationship management, and marketing. This Privacy Policy also applies to subcontracting and other stakeholder cooperation. In addition to consumer customers, this Privacy Policy also applies to the processing of personal data relating to business customers.
We comply with applicable data protection legislation when processing personal data. Data protection legislation refers to the applicable data protection laws, such as the European Union General Data Protection Regulation (2016/679) (“GDPR”) and the Finnish Data Protection Act (1050/2018). Any data protection-related terms not defined in this Privacy Policy shall be interpreted in accordance with applicable data protection legislation. Personal data means any information relating to an identified or identifiable natural person (“data subject”), as more specifically defined in the GDPR. Information from which a data subject cannot be identified directly or indirectly does not constitute personal data.
2. Controllers and Contact Information
For the purposes of this Privacy Policy, Termex-Eriste Oy acts as the data controller.
Depending on the processing situation, the subsidiary Vintit Kuntoon Oy may also act as a data controller.
Data Controller: Termex-Eriste Oy
Business ID: 0711231-2
Address: Ilolantie 14, FI-43100 SAARIJÄRVI, Finland
Email: termex@termex.fi
Telephone: +358 207 809 880
Subsidiary: Vintit Kuntoon Oy
Business ID: 2275894-7
Address: Ilolantie 14, FI-43100 SAARIJÄRVI, Finland
Telephone: +358 207 809 880
3. Data Subjects
The categories of data subjects whose personal data may be processed include:
- Representatives of customer companies and consumer customers
- Individuals who have submitted contact requests
- Potential customers (consumer customers and representatives of business customers)
- Suppliers, service providers, other business partners, and their representatives
- Website visitors and users of other electronic services
Responses provided through the chat service may be generated using artificial intelligence. Conversations are stored for the purposes of providing customer service, handling inquiries, and improving our services. Users are requested not to enter sensitive personal data into the chat, such as personal identity numbers, health information, or payment card details.
4. Purposes and Legal Bases for Processing Personal Data
We process only such personal data as is necessary for the relevant purpose. The main purposes are described below:
- Delivery of products and services, entering into customer agreements, processing orders, and verifying business transactions.
- Customer service and communication, customer satisfaction surveys, and prize draws.
- Invoicing, credit decisions, and debt collection.
- Marketing (including market research), other promotional activities and event organization, marketing references, analyses, statistical reporting, and measuring marketing effectiveness.
- Direct marketing, including electronic direct marketing and telemarketing, planning and measuring the effectiveness of advertising and marketing, and combining and updating personal data for direct marketing purposes.
- Managing stakeholder relationships and cooperation with subcontractors and service providers.
- Improving the user experience of our website and other services, monitoring website traffic, and targeting marketing through cookies and similar tracking technologies.
- Compliance with legal obligations (for example, accounting and tax legislation).
- Internal and group reporting and other administrative measures, business planning, and the training of personnel and stakeholders.
- Handling warranty claims and liability for defects, processing complaints, and managing legal and regulatory proceedings.
- Prevention and investigation of misuse, ensuring information security, and safeguarding the security of individuals, property, and occupational safety.
- Where we process personal data to deliver products and services, enter into customer agreements, and fulfil orders and related obligations, the legal basis for processing is the performance of a contract or the preparation of a contract.
- Processing may also be based on the legitimate interests of the controller or a third party. Legitimate interests include, for example, customer relationship management, customer communications, marketing (including direct marketing), reporting, business development, training, complaint handling, and legal proceedings. When relying on legitimate interests, we balance the benefits of processing against any potential impact on the data subject and conclude that the rights and interests of data subjects do not override those legitimate interests. Further information regarding processing based on legitimate interests is available upon request.
- Where personal data is processed to comply with legal requirements, the legal basis is compliance with a legal obligation.
- Processing personal data required for sending newsletters and other electronic direct marketing is based on the data subject’s consent, as required by law.
5. Categories of Personal Data and Sources of Data
The personal data we process may include:
- Identification and contact information, such as the name and contact details of the customer or the customer’s representative.
- Information relating to products and services and related orders, such as order records, delivery schedules, and information relating to agreements, financing, customer communications, and complaints.
- Information relating to marketing (including direct marketing) and events, as well as consents and objections provided by the data subject. Examples include contact details of customers and prospective customers for marketing purposes, information collected in connection with events, materials made available on our website, newsletter subscriptions, and direct marketing consents and opt-outs.
- Information relating to the use of websites and other electronic services (IP address, device, browser and operating system information, and registration details).
Personal data is necessary, for example, for fulfilling orders, providing services, managing customer relationships, communications and sales activities, organizing events, and complying with legal obligations. Information collected through cookies is voluntary insofar as it concerns data collected through non-essential cookies.
We collect personal data when, for example, you interact with us, purchase or order our products or services either personally or on behalf of an organization you represent, visit our websites or other electronic services, subscribe to our newsletter or other materials available on our websites, respond to customer satisfaction surveys, or otherwise contact us.
We also receive personal data from external sources, such as public registers maintained by authorities and, for direct marketing purposes, from private register service providers.
Personal data may also be received from Vintit Kuntoon Oy or from our contractual partners, such as authorized Termex Insulation Service Entrepreneurs.
Website chatbot and contact forms: When you use our website chat service or fill in a contact form, we process the contact information you provide as well as the content of the conversation or form. Chat responses are generated using artificial intelligence, and conversations are stored for the purpose of handling inquiries and improving service quality. We also inform users of this in the chat window before a conversation begins.
6. Retention of Personal Data
We retain personal data for as long as necessary to fulfil the purposes described in this Privacy Policy and at least for the period required by law (for example, obligations relating to accounting or reporting requirements), or for the purpose of handling litigation or similar disputes. When personal data is no longer needed for the purposes for which it was collected or otherwise processed, it will be deleted or anonymized within a reasonable period, and no later than 10 years after the customer’s last contact.
Personal data obtained from external register service providers is retained in accordance with the agreement concluded with the party providing such personal data.
Notwithstanding the above, personal data may be retained for as long as necessary if needed for investigating complaints, disputes, litigation, or similar matters.
Further information regarding retention periods and retention criteria is available upon request.
Chat conversation content is deleted after 90 days. After that, only statistical information, such as the number of messages and the language used, is retained, and such data cannot be used to identify an individual. If the conversation results in a contact request, the related information is retained in accordance with the retention periods applicable to customer data.
7. Recipients of Personal Data
Personal data may be disclosed, combined, or otherwise processed between companies belonging to the same group of companies and companies involved in the delivery of insulation products and services, such as authorized Termex Insulation Service Companies, for the purposes described in this Privacy Policy and in accordance with applicable data protection legislation.
We may also use various service providers and other third parties for the processing of personal data, including providers of technical solutions, hosting services, accounting services, debt collection services, and financial administration services. Group companies may also process personal data on behalf of another group company.
We ensure that all parties processing personal data on our behalf are bound by the data processing agreements required under applicable data protection legislation.
Personal data may be disclosed to third parties when required by law, by a competent authority, for the investigation of misuse, or for ensuring security. Personal data may also be disclosed in connection with legal proceedings or similar legal processes.
If the controller or its subsidiary is involved in a merger, acquisition, business transfer, or other corporate restructuring arrangement, personal data may be disclosed to the parties involved in the transaction and their advisers.
Additional information regarding recipients of personal data is available upon request.
8. Joint Controllership with Vintit Kuntoon Oy
Vintit Kuntoon Oy, a company belonging to the same group as Termex-Eriste Oy, may act as a joint controller within the meaning of applicable data protection legislation when processing personal data for shared purposes.
As joint controllers, the companies jointly determine the purposes and means of processing personal data.
The group companies have agreed that Termex-Eriste Oy shall be responsible for fulfilling the obligations imposed on joint controllers under applicable data protection legislation. Data subjects may contact Termex-Eriste Oy regarding any matters related to joint controllership.
9. Joint Controllership Related to Meta Services
When we operate Meta Business Pages on Facebook and Instagram, Meta Platforms Ireland Limited and the controller identified in this Privacy Policy may act as joint controllers, where applicable, with respect to the personal data of visitors to those pages.
Meta processes personal data in accordance with its own Privacy Policy, available at:
https://www.facebook.com/privacy/policy
Meta is responsible for complying with its obligations under applicable data protection legislation and for enabling the exercise of data subject rights within its services.
The controller referred to in this Privacy Policy processes personal data collected through Facebook and Instagram business pages in accordance with this Privacy Policy.
Further information regarding the processing of personal data by Meta and page administrators, as well as the allocation of responsibilities between joint controllers, is available at:
https://www.facebook.com/legal/terms/page_controller_addendum
You can manage your privacy settings through your Facebook or Instagram account. You may also contact Meta directly if you wish to exercise your rights as a data subject. In addition, you may always contact the controller identified in this Privacy Policy for further information or assistance regarding your rights.
10. User Tracking
We use user tracking and analytics technologies on our website to understand how visitors use our website and services and to improve user experience, marketing effectiveness, and service performance.
Tracking technologies may collect information about:
- Website visits and browsing behaviour
- Pages viewed and navigation paths
- Device and browser information
- Traffic sources
- Interactions with website features, forms, and chat services
Where required by law, non-essential tracking technologies are used only with the user’s consent. More information about cookies and tracking technologies may be provided through our cookie banner and cookie settings tool.
11. Transfer of Personal Data Outside the European Economic Area
As a rule, personal data is processed within the European Economic Area (“EEA”). However, personal data may also be processed outside the EEA.
Where personal data is transferred outside the EEA, we ensure that the transfer is carried out lawfully and subject to appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms.
Further information about international data transfers and the safeguards applied is available upon request.
12. Protection of Personal Data
Personal data is stored on appropriately protected servers and systems using technical and organisational security measures designed to safeguard personal data against unauthorised access, disclosure, alteration, or destruction.
Access to personal data is restricted through role-based access controls and other access management measures.
Any physical records containing personal data are stored in secure facilities and are accessible only to authorised personnel.
All persons processing personal data are bound by confidentiality obligations.
13. Automated Decision-Making and Profiling
We do not use personal data for automated decision-making or profiling that produces legal effects or similarly significant effects on data subjects.
14. Rights of the Data Subject
Under applicable data protection legislation, data subjects have the following rights. The availability of individual rights depends on the purpose and legal basis of the processing concerned.
Right of Access
You have the right to obtain confirmation as to whether we process your personal data and to receive the information required by data protection legislation regarding such processing. You also have the right to receive a copy of your personal data.
Right to Rectification
You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data.
Right to Erasure
You have the right to request the deletion of your personal data in accordance with applicable data protection legislation. We will delete personal data unless we are required by law to retain it or another lawful basis for retention applies.
Right to Restriction of Processing
You have the right to request the restriction of processing in situations provided for by applicable data protection legislation.
Right to Data Portability
You have the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format and, where technically feasible, to have such data transferred to another controller.
Right to Object
You have the right to object to the processing of your personal data based on legitimate interests, including profiling based on such interests. However, we may continue processing where compelling legitimate grounds exist.
You always have the right to object to the processing of your personal data for direct marketing purposes and any profiling related to direct marketing.
Right to Withdraw Consent
Where processing is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
15. Exercising Your Rights
Requests concerning data subject rights must be submitted in writing or electronically to the controller using the contact details provided in Section 2.
We may need to verify your identity before providing information or carrying out your request and may therefore request additional information.
If we are unable to comply with a request, we will provide a written explanation.
We generally respond to requests concerning data subject rights within one (1) month of receiving the request, in accordance with the GDPR.
16. Right to Lodge a Complaint with a Supervisory Authority
We encourage you to contact us first if you have any questions regarding the processing of your personal data.
You have the right to lodge a complaint with a competent data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection legislation.
In Finland, the competent supervisory authority is:
Office of the Data Protection Ombudsman
https://tietosuoja.fi/en
17. Changes to This Privacy Policy
We may amend this Privacy Policy from time to time. Changes may result from developments in our services, business operations, or applicable data protection legislation.
We encourage users to review this Privacy Policy regularly to stay informed of any updates.
The latest version of this Privacy Policy is always available on our website.
Originally published: 17 December 2022
Last updated: 31 August 2026