Data File Description


Description of file as referred to in section 10 of the Personal Data Act (523/1999).

Data Controller


PL 10, Finland
01044 DNA

Läkkisepäntie 21
FI-00620 Helsinki

Business ID 0592509-6
Tel. switchboard: +358 44 0440
Customer Service: +358 44 144 044

Contact person in matters related to the register

Jyrki Kinnunen
tel. +358 44 0440 (DNA Ltd switchboard)

Name of register

DNA's customer register

Grounds for keeping the register

Customer relationship

Purpose of use

The data stored in the register can be used for the management, maintenance and development of the customer relationships of DNA Ltd and companies belonging to the same group (hereinafter jointly referred to as DNA), the targeting and analysis of DNA's offering, the production, provision and development of services, and for market research and other statistical purposes. Data stored in the register can be used for marketing from DNA to its customers (including electronic direct marketing) and for targeting such marketing within the limits permitted by legislation. Such marketing can also concern the products or services of DNA's partners. Customers are entitled to prohibit the use of their personal data for purposes of direct marketing.

When a customer contacts DNA's customer service, the call can be recorded or other communications such as e-mails or text messages saved. Recorded or otherwise stored communications can be used for verification of customer service events and the training of customer service personnel. The recordings will be destroyed when they are no longer required for the above-mentioned purposes. Recorded communications are only processed by personnel with the right to process customer information.

Data contained in the register

The following data on DNA's customers and service users may be stored in the register:

  • Basic customer data such as name, address, telephone number, e-mail address, language, personal identity code and customer ID(s)
  • Names, addresses and dates of birth of potential users
  • For corporate clients, the details of the company's contact person and users (name, address, telephone number and e-mail address, as well as job description and position in the company)
  • Information related to customer and contractual relationships, such as subscriptions, services, devices, start and end dates of agreements, opening and closing dates of subscriptions and services, order values, order and delivery dates, cancellation and refund information, registrations with any bonus agreements, user ID for the DNA TV application, SIM card number, IMEI code or other identifiers of terminal devices, and service use and availability addresses.
  • Customer history such as service changes, customer communications, and offer, order and agreement information.
  • Direct marketing consents and prohibitions.
  • Recording of customer calls and other communications related to customer service situations
  • Invoicing method information, invoicing addresses and other information related to invoicing and debt collection
  • Directory information disclosure prohibitions
  • Additional information provided by customers or collected with their consent (e.g. feedback from customer surveys, areas of interest)
  • Use and service information regarding communications and service and content use through various services and channels (e.g. the use, search and browsing information of service features)
  • Customer information compiled from data contained in the register, where such information is relevant with regard to the purpose of the register

Source of register data

Personal data is collected in connection with registration or service use, or directly from the data subjects or with their consent (e.g. through cookies). Personal data can be collected and updated from the Population Information System, the prohibition registry maintained by the Finnish Direct Marketing Association and other third-party registers.

Information disclosure

DNA can disclose data from the register where permitted or obligated to do so under currently valid legislation. Register data can be regularly disclosed for publication in subscriber lists or telephone directories unless the customer has prohibited such disclosure.

A part of the data can be stored by DNA's subcontractors due to reasons related to the technical or operative implementation of data processing, and data may also be otherwise processed through technical interfaces. DNA may also employ subcontractors in the processing of the data. The data may be transferred outside the European Union or the European Economic Area. In such cases, DNA will nevertheless ensure the level of data protection required by law.

Customer register confidentiality

All DNA staff and persons representing DNA are required to maintain confidentiality regarding all customer data. The use of the register is protected by user-specific usernames, passwords and access rights.

Upon termination of the customer relationship, the customer's data will be deleted from the register immediately when further processing will no longer be required.

Right of access

Pursuant to section 26 of the Personal Data Act, data subjects have the right to inspect what data has been saved on them in the personal data register. A signed right of access request should be submitted in writing to:

PL 10, Finland
01044 DNA

On your right of access request, please mention that the request concerns data in DNA's customer register.