Privacy Policy Statement of Investment Research Finland Ltd

1. Registry holder

Investment Research Finland Ltd (”Investment Research Finland”, or “IRF”, or ”Company”) uses personal information it its operations relating to Client relationships, marketing, communication, and internal analytics.

Investment Research Finland provides consolidated reporting services, performance measurement services and fund visibility services. Investment Research Finland can also undertake direct marketing to individuals and organizations.

IRF utilizes and stores personal data in order to provide services, under take customer communications and fulfill client agreement obligations, as well as marketing. IRF also utilizes analytics regarding traffic on the Company website.

Investment Research Finland provides part of its services based on partner providers mostly in asset management and information technology services,  and may utilize partner representatives’ contact or personal information in providing services.

Investment Research Finland utilizes and stores any client or personal data in a profession manner. Please note that this privacy police applies only to personal information of individuals (rather than organizations) and only to Investment Research Finland Ltd.

Our group company Suomen Sijoituskumppani Oy offers domestic institutional investors the advisory services of our partner Söderberg & Partners Wealth Management AB as a tied agent.

2. Contact information for data controllers

Finnish Investment Research Ltd, Business ID: 1640202-0

Suomen Sijoitussuunnittelu Oy, Business ID: 2370749-8

Suomen Sijoittajapalvelut Oy, Business ID: 2360622-4

Address: Vuorikatu 14 A, 00100 Helsinki

Telephone number: +358 9 6227 8770

www.investmentresearch.fi

Person in charge of the register: Kalle Kauppila, tel: +358 9 6227 8771

Investment Academy Ltd, Business ID: 2309376-4

Address: Vuorikatu 14 A, 00100 Helsinki

Telephone number: +358 45 317 6363

www.sijoitusakatemia.fi

Person incharge of the register: Juha Paukku, tel. +358 45 317 6363

Suomen Sijoituskumppani Oy, Business ID: 3280156-6

Address: Vuorikatu 14 A, 00100 Helsinki
https://soderbergpartners.fi/wealth-management/

3. Collected Personal Information

General Contact Data

• First and Last Name

•Professional title

•Represented institutions’ name

•Institutions' organizational structure and individual positions within

• Contact information (email, physical address, billing address and phone number)

• Industry classification

• Contact type and role  (for example: reporting client, performance measurement client, data provider etc.)

• Contacthistory

Website Analytics

•IP-address

•URL-address

• Time of visit

• Broweser type and version

• Hardware type

Website is hosted within European Economic Area by and in Amazon GmbH server facility. The server stores all items listed above in text.

Company website also incorporates Google Analytics-tracker, allowing Google companies access to items listed above.

4. The source of information

By default, client or client approved partners provide the General Contact Data directly to Investment Research Finland, upon entering a service agreement.  

General Contact Data can also be collected from public sources such as client public websites, media news items or interviews published in general media.

Website Analytics Data is stored by accessing the website.

5. Purpose of the usage of information

Personal information may be used to legal or contract-based usages:

Providing a service or fulfilling a contract

Client communication and Client relationship management

In case of direct inquiries to Investment Research Finland, IRF may use the given contact information to provide answers

Electronic Marketing

Electronic marketing such as e-mail newsletters may be cancelled or prohibited by providing a direct notification to Investment Research Finland, and any individual always has a right to be excluded from direct marketing measures.

6. Holding period of information

Investment Research Finland holds personal information as long as the Company is legally required or it is necessary to maintain contractual obligations, or provide services to the client. Faulty or expired personal information will be updated or deleted from the registry.

7. Transferring personal information outside European Economic Area

IRF uses information technology providers that are active globally, and it is possible that by provider choice the personal information listed in this policy may be transferred outside the European Economic Area.  All relevant IRF information technology service agreements include common Privacy Policy statutes for cross-border sharing.

8. Recipients of personal information

Investment Research Finland does not give personal information to third parties excluding the following situations:

Legal reasons or obligations

Investment Research Finland may provide personal information to third parties if access to these information is considered reasonably necessary (i) to oblige with law, or court orders (ii) to prevent fraud, money laundering, financing terrorist organizations or information security concerns (iii) to protect Investment Research Finland assets or to ensure common good required by the law.

InvestmentResearch Finland may also provide personal information to other third partiesby the consent of the individual or a client organization.

9. Individual rights to personal data

Right to access the personal information

Right to review the personal information

Right to update or correct the personal information

Right to delete information.

Individual may request Investment Research Finland to delete personal information, unless Investment Research Finland has a specific right or legal or contractual obligation to keep the information

Right to exclude or resist the usage of information with respect to direct marketing purposes Right to transfer information in are adable and commonly used form to a third party by request

Individual can exercise  rights by contacting Investment Research Finland representatives by email, mail or calling

Investment Research Finland may deny requests that are repeated too often, are excessive or clearly unreasonable

In order to access the information please contact representative of Investment Research Finland

10. General Security

Investment Research Finland stores and utilizes personal information in a professional manner. IRF undertakes common reasonable data security measures, such as restricting internal use to relevant personnel, and requiring username and password information for any access.

11. Right for Complain

IRF does not by any means, contract or otherwise, limit or discourage individual rights to inform the supervising authorities, should an individual have reasonable doubts that IRF does not treat personal information in the way compliant to Finnish and European Law.