Toyota Finance Finland – Privacy Policy
1. Data file name
Toyota Finance Finland Oy’s customer register
2. Controller
Toyota Finance Finland Oy
Korpivaarantie 1, P.O. Box 49
FI-01451 Vantaa
Telephone: +358 (0)9 851 81
3. Contact person for the data file
Tuomo Juslin
Korpivaarantie 1, P.O. Box 49
FI-01451 Vantaa
Telephone: +358 (0)9 851 81
E-mail: turvapostiasiakaspalvelu@toyotarahoitus.fi
My Finance service: myfinance.toyota.fi (Opens in new window)
4. Data protection officer
Markku Harmaala
Korpivaarantie 1, P.O. Box 49
FI-01451 Vantaa
Telephone: +358 (0)9 851 81
5. Purpose and legal basis for processing personal data
Making a credit decision
The personal details of credit applicants are processed to make credit decisions and to change the terms of the contracts. Credit decisions are made based on information that the customer provides in the credit application, payment method details of any prior credit agreements and customer information obtained from Suomen Asiakastieto Oy and from Positive Credit Register (which is maintained by Finnish Tax Administration). The information is also used to make automated credit decisions in the context of assessing the preconditions for granting credit and making a rental agreement. The legal basis for processing personal data in the context of a credit decision is fulfilling the agreement.
The creditor has the right and obligation to verify the buyer’s personal or corporate information and to obtain the necessary credit and income data in the manner specified in the Credit Information Act and the Positive Credit Register Act. The creditor reports the up-to-date credit-related information required by law to the Positive Credit Register maintained by the Finnish Tax Administration.
Managing the customer relationship
Managing the customer relationship requires processing the credit customer’s personal data. The personal data is processed to activate the credit agreement and manage the credit (e.g. registering payment transactions, making any changes to the agreement and terminating the agreement). The legal basis for processing personal data to manage the customer relationship is fulfilling the agreement.
Customer communications, direct marketing and online marketing
Toyota Finance Finland Oy may use the customers’ personal data for customer communications upon sending bulletins and notification regarding financial products and services to its customers. The personal details of customers are also used to market products related to vehicle financing. Toyota retailers can be used for assistance in direct marketing. In these cases, the retailers act as processors on behalf of Toyota Finance Finland Oy.
Toyota Finance Finland Oy conducts online advertising through external advertisement networks. Advertising is aimed at target groups defined by the company and third parties. Ads can also be targeted based on website access data provided by cookies, if the customer in question has provided consent for using cookies.
Personal data processing for customer communications and direct marketing is based on the legitimate interest of the controller. Electronic direct marketing and online marketing using cookie data require the separate consent of each respective customer.
Call Recording
Toyota Finance Finland Oy may record customer calls to ensure the quality of customer service and to manage and verify the customer and contractual relationship. The recording will always be announced separately at the beginning of the call. The recording of customer calls is based on the data controller’s legitimate interest. Please note that your current customer and contract information can be found in the My Finance service at https://myfinance.toyota.fi (Opens in new window).
Statistics and reporting
Personal data is processed to develop products and processes, and to monitor and steer business operations. Data processing for these purposes is based on the legitimate interest of the controller.
Complying with statutory obligations
Toyota Finance Finland Oy processes personal data in order to handle statutory obligations and comply with official decisions. These include obligations imposed by credit legislation, the statutory obligation to keep records and any obligations related to taxation, for example. Data can also be processed to fulfil obligations related to legislation concerning the prevention of money laundering or terrorism.
6. Information content of the data file
The data file includes the following groups of customer details:
Personal details:
- first names and last names,
- personal identity code,
- address information,
- telephone number,
- e-mail address,
- credit information,
- profession,
- job details, nature and duration of employment,
- bank account details in cases of refunds,
- driving licence/passport details in relation to customer identification,
- possible residence permit details,
- call recordings,
- other additional customer relationship details (information recorded in the context of customer service, for example),
- marketing permissions and prohibitions,
- online identification data, such as IP addresses, data collected through cookies and other technologies, if the customer has provided consent for processing such data.
Credit agreement details:
- details of the applied and granted credit,
- details related to invoicing and collection,
- type and registration number of the financed car.
Other details regarding the customer’s agreement (possible leasing arrangements and other rental agreements)
The personal identity code is used in compliance with the Data Protection Act to identify the customer and fulfill the rights and obligations of the customer and Toyota Finance Finland Oy
7. Regular data sources
Personal details are collected from the data subjects themselves. The details are usually obtained from the credit applications submitted by the customers.
Customers are identified using the Digital and Population Data Services Agency’s service based on the information they provide. Personal details can also be updated in this context. The address details of customers are updated through Posti’s address service.
The creditworthiness of customers is confirmed with Suomen Asiakastieto Oy and Positive Credit Register maintained by Finnish Tax Administration.
8. Processing of personal data
Henkilötietoja käsittelevät vain henkilöt, joilla on työtehtäviensä vuoksi tarve käsitellä niitä. Tietoja käsittelevä henkilöstö on saanut tietosuojakoulutuksen ja sillä on käytössään henkilötietojen käsittelyä koskeva kirjallinen ohjeistus.
Henkilötietoja voidaan myös siirtää sopimukseen perustuen ulkoisille palveluntarjoajille. Palveluntarjoajat käsittelevät henkilötietoja Toyota Finance Finland Oy:n määrittelemin tavoin, eikä heillä ole oikeutta käyttää tietoja omiin tarkoituksiinsa. Ulkoisia palveluntarjoajia käytetään mm. tietojärjestelmien toimittamiseen ja ylläpitoon, perintään sekä tutkimusten suorittamiseen.
9. Regular disclosure and transfer of information outside the EU or EEC
The disclosure of personal data refers to situations where personal data is provided to another controller for independent use. The effective data protection legislation is observed in cases of disclosing personal data.
Toyota Finance Finland Oy discloses details regarding credit decisions to the Toyota retailer or repair shop that submitted the credit application for the purpose of making the planned agreement.
The personal details of customers are disclosed for direct marketing purposes to Toyota Auto Finland Oy, the retailer that made the agreement and AXA (repayment security) based on legitimate interest. With the consent of the customer in question, personal details can also be disclosed to Toyota companies specified in the context of the consent.
The personal details of customer can also be disclosed to authorities and, in cases of payment defaults, credit information companies in accordance with the effective legislation.
The personal details of customers are primarily not transferred outside the EU/EEC area. However, in the context of using the customer service chat functionality, it is possible for personal data to end up outside the EU/EEC area in some cases. Efforts have been made to reduce this risk by minimising the amount of personal data used for the chat functionality. If you would like more information about the protection measures used for international data transfer, please contact turvapostiasiakaspalvelu@toyotarahoitus.fi.
10. Data file protection principles
Databases, database backups and documents are situated in locked, guarded and access-controlled rooms.
The data stored in databases are protected by means of firewalls, passwords and other technical means. As a general rule, only the personnel of Toyota Finance Finland Oy have access to the information in the data file. Furthermore, retailers authorised by Toyota Finance Finland Oy have limited access to the information in the data file.
11. Storage period of personal data
Pursuant to the requirements of the Act on Preventing Money Laundering and Terrorist Financing, personal data will be retained for five years following the end of a customer relationship, after which the data will be erased or anonymised.
For marketing purposes, personal data will be used for no more than one year after the end of the agreement.
Call recordings are retained for 90 days.
If it is necessary to retain personal data for the purpose of completing a pending or intimidating legal action or proceeding, the data will be retained until the legal action has been concluded, as well as for the duration of the applicable statutory limitation period. Such legal actions or proceedings may include, for example, an official investigation and any related appeals process.
12. Data subject’s rights
Data subjects have the right to check what details on them have been stored in the data file. By request of a data subject, we will rectify and supplement information or erase erroneous, unnecessary, deficient or obsolete information.
Data subjects have the right to restrict and object to the processing of their data, under certain conditions.
Data subjects have the right to transfer their personal data to another controller, under certain conditions.
Data subjects have the right to prohibit the use and disclosure of their data for direct marketing purposes.
To the extent that the data processing is based on consent, the data subjects are entitled to withdraw their consent.
Requests regarding the rights listed above must be submitted electronically by registering for the MyFinance service at https://myfinance.toyota.fi or by lodging a written and signed request to the contact person for the data file (see Section 3).
Data subjects are entitled to refuse bulletins and other communications by notifying the contact person for the data file (see Section 3).
Data subjects have the right not to be subject to a decision based solely on automated processing. By notifying the contact person for the data file (see Section 3), data subjects may demand that the details impacting the credit decision are processed on behalf the controller by a natural person.
Data subjects have the right to submit a complaint on the processing of their personal data to the Data Protection Ombudsman.
Data Protection Ombudsman’s Office
P.O. Box 800,
FI-00531 Helsinki
Tel. +358 (0)29 566 6700
tietosuoja@om.fi