Privacy policy regarding rental management

1. Controller

Principal of Premico Management Oy
c/o Premico Management
Aleksanterinkatu 11, 00100 Helsinki
info@premico.fi
(hereinafter referred to as “we” or “Premico”)

2. Contact person

c/o Premico Management / Data Protection Officer
Aleksanterinkatu 11, 00100 Helsinki
info@premico.fi

3. About this privacy policy

Premico provides rental and property management services to housing companies and landlords who are its clients. These services include tasks related to establishing, managing, and administering tenant rental relationships, as well as maintaining and managing properties.

When processing tenants’ personal data, the relevant housing company or landlord is generally considered the data controller responsible for the processing of personal data, and the service provider, such as Premico, is considered the data processor. This privacy statement explains how personal data is generally processed in the rental management and property management services provided by Premico on behalf of its clients. More detailed information on the processing of personal data is available from the relevant landlord and housing company.

4. What are the grounds for processing and what purposes do we process personal data for?

The purpose of processing personal data in Premico’s operations is to provide rental management and property management services. Personal data may be processed to handle tasks related to establishing, managing, administering, and developing tenant rental relationships and arranging services acquired for the housing company. Personal data may also be processed, for example, for arranging parking, tenant communication, customer communication, customer service implementation, measuring tenant satisfaction, and ensuring the quality of customer service. Personal data is also processed to provide tenants with the digital services they have ordered through the KomuHomes application.

The lawful basis for processing personal data may include fulfilling contractual rights and obligations, the legitimate interest of the data controller or a third party, compliance with legal obligations, or the individual’s consent.

5. What data do we process?

We may process the following data in connection with rental management and property management services:

  • Basic information of the data subject: first and last name; personal identification number; date of birth; customer number; information related to the apartment and move; information related to rent, its payment, receivables, and collection of receivables;
  • Contact information of the data subject: street address; postal code; city; phone number; email;
  • Identifying information of the data subject: gender and language of communication, if unambiguous identification of the data subject
    is important for the rights and obligations of the data subject or the data controller; information related to the vehicle;
  • When it is a company apartment, information related to the company and its contact persons is collected: business ID; contact person; contact person’s phone number; contact person’s email; signatory / procurator; billing address; postal code; city; country;
  • Other information provided by the data subject on the rental apartment application: pets (number / type); number and dates of birth of children; reasons for moving; smoking; yes / no; employment information for all applicants (employer; profession / job; employment, permanent / part-time; start date of employment; gross income / month) or study information (educational institution; study program; start date of studies; estimated graduation date; gross income / month) or pension information (pension / month); referee (name; phone number; email); consent to check credit information;
  • When the rented apartment is an ARA target, the following is also asked: phone for work; marital status; personal identification numbers of any other applicants; pregnancy certificate if pregnant; information on possible homelessness; relocation obligation; possible information on moving to the area for work (employer; start date of work; workplace address; postal code; city); information on a possible owner-occupied apartment remaining in another area (owner-occupied apartment remaining in the area will be rented sold / is for sale); information on moving for another reason; living space (number of residents; apartment area in m2; building type; apartment type; condition of the apartment; tenure); housing costs (rent / maintenance or company fee; separate heating costs; separate water charges; year of moving in; other factors affecting the need for housing; applicant’s income (current gross monthly income; capital income per year; other income per year; total income to be considered per year); assets, fair value of property; student loan; housing loan; other loans; total assets to be considered); spouse’s / partner’s income (current gross monthly income; capital income per year; other income per year; total income to be considered per year); other applicants (current gross monthly income; capital income per year; other income per year; total income to be considered per year); information on a possible owner-occupied apartment (type; owner’s name; property (company name; property address and municipality; acquisition time; property size; apartment size, apartment use; current market value of the share apartment / property); explanation of other assets (publicly traded shares in total; other, what?); application attachments (pay certificates of all working persons moving into the apartment for gross monthly earnings from the employer; tax certificates from all persons over 18 years old moving into the apartment; certificate of possible pension amount; possible pregnancy certificate; student certificate from all students over 18 years old moving into the apartment; explanation of the fair value of assets; creditor’s certificate of debts; explanation from immigrants of the right to reside in the country (copy of passport); certificate of unemployment benefit;
  • Camera surveillance: In connection with camera surveillance, information (image, sound, and recording time) may be collected about
    persons moving in the areas of housing companies.

Providing personal data marked with an asterisk (*) on the application form is a prerequisite for the establishment of our contractual and/or customer relationship. Without the necessary personal data, we cannot provide the service.

6. Where do we collect the data from?

Personal data is mainly collected from the data subjects themselves during the move-in process, either directly or indirectly through various communication channels such as phone, mail, email, or similar means. Additionally, information related to the person may be collected when logging into and using the housing company websites.

Personal data may be collected and updated within the limits of applicable legislation for the purposes described in this privacy statement from publicly available sources and authorities (such as KELA and the Population Register Centre) or other third parties (such as Suomen Asiakastieto Oy) using services provided by third parties that utilize publicly available sources. Such data collection may relate to checking credit information, identifying data subjects, identifying politically exposed persons, and fulfilling obligations related to the prevention of money laundering and terrorist financing. Data collection and updating are carried out manually or by automated means. Information processed in connection with camera surveillance is collected in locations where camera surveillance is in use. Camera surveillance is indicated by signs.

7. To Whom Do We Disclose and Transfer Data, and Do We Transfer Data Outside the EU or EEA?

We may transfer personal data collected through our websites and services to our parent company Premico Group Oy or its subsidiaries and/or associated companies within the same group, or to consultants or other contractual partners of Premico and its subsidiaries in situations where fulfilling contractual obligations or other legal basis for processing personal data requires it. Personal data may also be transferred to representatives of the housing company to perform these tasks and to service providers possibly used by the housing company, such as maintenance companies, security companies, parking service partners, and locksmiths. Additionally, data may be disclosed to the resident, shareholder, or authority in accordance with applicable legislation. Recordings collected through camera surveillance may be disclosed to investigate crime, misuse, damage, and accident situations in accordance with applicable legislation and the requirements of competent authorities. We may also transfer personal data to service providers to handle assignments related to the collection of receivables and to implement rental management and property management services, rental agreement management, and tenant relationship management.

We also utilize subcontractors acting on our behalf in the processing of personal data, and we have outsourced IT management to an external service provider, whose managed and protected server stores personal data.

We do not otherwise disclose tenants’ personal data to third parties except as required by law or as necessary for the services provided by Premico Group Oy and its subsidiaries for purposes that are not inconsistent with the aforementioned purposes of processing personal data.

Personal data may be transferred outside the European Union or the European Economic Area if it is necessary for the purposes of processing personal data or for the technical implementation of data processing. We have made appropriate agreements with the relevant service providers to ensure that the transferred personal data is processed lawfully. These agreements include the standard contractual clauses based on the applicable decision of the European Commission.

8. How do we protect the data and how long do we store the data?

We have implemented and maintain appropriate technical and organisational security measures to protect personal data from accidental or unlawful destruction, loss, damage, or alteration, as well as unauthorised disclosure, misuse, or other unlawful processing. Our data protection practices cover physical security measures and procedures, access control (e.g., user IDs, firewalls, and digital encryption technologies), logging, antivirus protection, denial-of-service attack prevention, and other necessary data security measures. Personal data is processed confidentially in Premico’s operations, and the right to process personal data is limited to individuals who need to process personal data for their tasks. Databases and their backups are located in locked premises, and only certain pre-named individuals have access to the data.

We process personal data only as long as necessary for the applicable purpose and considering the retention periods defined by law and ARA. We regularly assess the necessity of retaining data. More detailed information on the retention periods of personal data is available from the relevant landlord and housing company. For example, the retention period of data collected through camera surveillance depends on the solution used in the location, but recordings are retained for a maximum of one year unless a possible legal claim or other crime, misuse, damage, or accident investigation requires a longer retention period.

Additionally, we take reasonable measures to ensure that no incompatible, outdated, or incorrect personal data is retained for the purposes of processing. We promptly correct or delete such data.

9. What rights do you have as a data subject?

As a data subject, you have the right to:

  • Obtain confirmation of whether we process your personal data, and if such personal data is processed, the right to access the personal data and the information required by law about the processing of personal data;
  • Request that we correct inaccurate and incorrect personal data concerning you and the right to have incomplete personal data completed;
  • Have your personal data deleted in situations prescribed by law (e.g., when the data is no longer needed and there is no legal basis for retaining it);
  • Withdraw your consent to the processing of your personal data or change it;
  • Request the restriction of the processing of your data, for example, while waiting for the data controller’s response to your request to correct your data;
  • Object to profiling and other processing of your personal data to the extent that the basis for processing is the legitimate interest of the data controller;
  • Have your data transferred from one system to another if there is a legal basis for this.

As a data subject, you also have the right to lodge a complaint with the competent supervisory authority if the data controller has not complied with the applicable data protection regulations in its operations. In Finland, the Data Protection Ombudsman supervises compliance with data protection legislation. If you wish to bring the processing of personal data in Premico’s operations to the attention of the Data Protection Ombudsman, you can contact the Data Protection Ombudsman by following the instructions provided at www.tietosuoja.fi.

10. Contact information

Contacts and requests regarding the processing of personal data in Premico’s operations and this statement should be addressed to the contact person named in section two (2).

11. Changes to the privacy policy

If we change this statement, we will make the changes visible in the statement with the date. If the changes are significant, we may also inform you in other ways, such as by email or by posting a notice on our website. We recommend that you regularly visit our website and take note of any changes to the statement.

Changes:

8.12.2020; Premico’s address changed to the new address.
2.3.2023; The structure of the statement has been modified to a more readable format, and the contact details of the data protection officer have been updated.
16.05.2023; The basis for processing data has been added to include measuring tenant satisfaction and ensuring the quality of customer service.
14.12.2023; The basis for processing data has been added to include the possibility of offering digital services produced by the KomuHomes application to tenants.
27.12.2023: Examples added to section 6. Changed: 12.6.2024: Basic information of the data subject added to section 5, example added to section 7, and mention of collection removed.
12.6.2024: Added basic information about the data subject to section 5, added an example to section 7 and removed mention of debt collection.
24.6.2024: Information on personal data processed in connection with Premico’s property management services has been combined into the same privacy statement.
3.2.2025: The privacy statement has been updated to include rental management and property management services, rental agreement management, and tenant relationship management as purposes for disclosing personal data.