Elo processes the personal data of tenants in connection with the rental and management of the flats that it owns. We ensure the protection of our tenants’ privacy and process their personal data in accordance with currently applicable legislation. This privacy statement describes in more detail the purposes for which Elo processes personal data in residential property rentals and how the information of tenants is processed.

Data controller and Data Protection Officer
The data controller for your personal data is Elo Mutual Pension Insurance Company (”Elo”), at Revontulentie 7, 02100 Espoo, p. 020 703 50 (switchboard)

Read more about data protection at Elo or get in contact with our Data Protection Officer:
Tuukka Jousi, tietosuoja@elo.fi, p. 020 703 50 (switchboard).

If you have questions about other topics related to your tenancy other than those described in this privacy statement, please get in contact with your tenancy contact person.

The personal data of residential tenants is processed for rental administration and tenancy management, as well as property management and maintenance. The processing of tenants’ personal data is based on a contractual relationship. Personal data is also processed to ensure security of the properties and tenants, which is Elo’s legitimate interest.

As part of our investment and real estate operations, we also process personal data of commercial property tenants. More information about personal data processing in our investment operations can be found here.

What personal data do we process about you?

Your personal data is any information that can be linked to you or used to identify you. The following information about tenants is processed depending on the stage of the tenancy:

• Name
• Personal identity code
• Contact details (home address, phone number, email address)
• Nationality
• Applicant’s income, assets and potential payment default entries
• Information regarding payment ability (e.g. employer, duration of employment or health information affecting payment ability)
• Information related to the tenancy relationship and contract (e.g. rent payment information, rent amount, rental period, rental guarantee)
• Information about the rental property (e.g. name of the property and parking space)
• Details of cohabitant (name, personal identity code)
• Bank account number
• Camera surveillance recordings in the property court yards and parking areas
• Information on the use of an electronic key (electric locks)

What are the sources of your personal data?

Elo receives the tenant’s information from real estate agents, who collect personal data from the tenant in the leasing application. Salary information can also be obtained from the tenant’s employer. Credit information is received from the credit information register of Suomen Asiakastieto Oy. Elo also processes personal data from camera surveillance and electric locks, that can be used to investigate suspected crimes.

To whom is your personal data transferred or disclosed?

Information is only disclosed to third parties when the recipient has the right, by law, to receive information from Elo, or in exceptional circumstances upon consent of the data subject. Elo may on these grounds disclose information to authorities, such as police or enforcement authority. Elo also discloses information to KTI Kiinteistötieto Oy for conducting market research in the real estate business.

Elo uses trusted service providers in the rental of residential flats and support tasks, which process personal data on behalf of Elo. These are real estate agents, property managers, and other contracted services providers in the real estate operations.

Will your data be transferred outside Europe?

Personal data of tenants is not disclosed outside European Union or European Economic Area.

How long do we retain your data?

We retain your personal data only as long as necessary to fulfil the purposes set out in this privacy statement or in accordance statutory retention periods, after which the data will be deleted. The tenants’ personal data is retained generally for 10 years from the end of the lease agreement, or as long as there is a valid legal basis and the personal data is necessary for the purposes of processing. The camera surveillance recordings are retained on a property-by-property basis, but as a rule for a maximum of six months. Electronic locks store a certain amount of the latest log data for a maximum of two years.

What are your rights as a data subject?

You have the rights provided by data protection law to the personal data processed at Elo.

• Right to access data: You have the right to know what information Elo is processing about you. You also have the right to receive a copy of the data that is being processed as well as the necessary information related to the data processing.

• Right to rectify information: You have the right to have inaccurate, outdated, or incomplete information about yourself rectified or supplemented.

• Right to deletion of data: You have the right to request the deletion of information concerning you under certain conditions. Personal data may be deleted, for example, if it is no longer needed for the original processing purposes or if you object to the processing of your personal data for direct marketing. Please note that despite of your request, Elo may have to continue processing your information, for example to comply with legal obligations, when it will not be possible to delete the data.

• Right to restrict processing: In certain situations, you have the right to demand that the processing of your personal data is restricted so that Elo only has the right to retain such personal data. You can for example request that the processing of your information is restricted for the period of the investigation, if you consider that the information about you is inaccurate or the accuracy needs to be further investigated.

• Right to request data to be transferred to another system: If the processing of your personal data is based on consent or contract, you have the right to have your data transferred to another data controller. The right of transfer applies to data that you have provided to Elo yourself and that is stored in an electronic information system. If technically possible, data controller must transfer your information directly to another controller.

• Right to object processing: In certain situations, you have the right to object processing of your personal data if the processing is not based on legal obligation or contract.

• Automated decisions, including profiling: You have the right not to be subject of a decision that is based solely on automated processing, such as profiling, which has legal or other significant effects on you.

If you would like to exercise your rights, please submit an identifiable written request to Elo’s Data Protection Officer via email (tietosuoja@elo.fi) or by mailing Elo Mutual Pension Insurance Company, Data Protection Officer, 00041 Elo. Please note that you will need to prove your identity before the request is fulfilled, so please include your up-to-date contact details in the request.

Elo will respond to requests without undue delay, in any case within one month of receipt of the request. The provided information and actions based on the data subjects’ requests are primarily free of charge, unless the requests are manifestly unfounded, unreasonable, or repetitive, in which case Elo may also refuse to fulfil the request on these grounds.

If you suspect that your personal data has been processed in breach of data protection law, you have the right to lodge a complaint with the data protection authority, Office of the Data Protection Ombudsman, P.O. Box 800, 00531 Helsinki or www.tietosuoja.fi.