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Information about LocalTapiola
Processing of personal data is an integral element of LocalTapiola Group’s business. For us, careful and safe processing of personal data is paramount. We ensure the appropriate protection of privacy, and process all personal data as required by law and in line with good data management and data processing practice.
In this section, we tell you more about the protection of privacy at our Group. Here we aim to give you an overview of the processing of personal data we carry out. This section contains also our most important privacy notices, which describe what, why and how we process personal data in each of our individual data files and registers. The privacy notices are primary over the information provided in this section.
Data protection
What personal data do we process and why and how?
Categories of data subjects and personal data
The data subjects are the customers of LocalTapiola Group companies, such as insurance and claims customers and investor customers. In the case of institutional customers, the data subjects are their affiliated persons, such as beneficial owners. Data subjects also include customers who have previously been our customers as well as potential customers and their affiliated persons. Persons related to the customer, such as guardians and attorneys-in-fact, are also data subjects.
We only process personal data that is necessary for our purposes, such as:
personal data related to identification, including name and personal identity code
contact information, including name, address, email and phone number
information related to the services and products we offer, such as the content of insurance coverage and health declaration and the amount of invested assets.
information related to the customer relationship and its management, such as language and contacts
information about choices made by the customer, such as restrictions on direct marketing
customer communications, such as call recordings, audio recordings of online meetings, chat conversations and online messages
information required by law, such as personal data used to identify the customer in accordance with the Anti-Money Laundering Act.
Purposes of processing
We process personal data only for predefined purposes, such as:
customer service and communication as well as customer relationship management, such as responding to contacts and sending out announcements about products
provision and development of our services and products, such as the performance of insurance or investment contracts and claims processing on the basis of insurance contracts
marketing of our services and products, targeted marketing and direct marketing, such as targeted online marketing and direct marketing messages
opinion and market research, such as sending out customer service feedback surveys
organising and enabling participation in promotions, raffles and competitions
monitoring, analysing and compiling statistics on the use of our services and products, such as tracking and analytics of pages visited on our website
ensuring the security of our services and risk management
detection and investigation of nonconformities, such as fraud against insurance companies
fulfilling obligations based on law and in accordance with official directions and instructions, such as collecting customer identification data and monitoring sanction lists.
Legal basis of processing
We process personal data mainly on the basis of a contractual relationship and the measures preceding it. The performance of a contract is the primary basis for processing, in cases such as when we process the policyholder's personal data for the purpose of giving an insurance quote and later when the insurance contract is in force.
The processing of personal data may also be based on the consent of the data subject or on the legal obligations or legitimate interests of the LocalTapiola Group company acting as the controller of the data. We may disclose information to our service provider partners on the basis of consent, whereas the Anti-Money Laundering Act obligates us to collect and store certain identifying personal data on our customers. Data processing is based on legitimate interest for example when we process personal data for marketing purposes, including for the purposes of targeting of advertising, targeted online marketing or direct marketing, for combating abuse and fraud or to pay a claim to a victim outside the customer relationship.
How we collect data
We mainly collect your personal data directly from you. You provide us with your data when you interact with us, such as when you enter into an insurance or investment service contract, claim compensation, log in to our online service, call our customer service or participate in our competitions. We may also collect data about you by observing how you use our services, especially through cookies. Our use of cookies is described in more detail in the section on cookies.
We also collect your data from third parties, such as parties authorised by you, registers maintained by the authorities, credit information registers, joint registers of insurance companies, medical institutions and other insurance companies. We retrieve the vehicle details from Traficom’s Transport Register.
We update addresses from Posti's address service and cross-check with the Population Information System to ensure that the information is accurate and up-to-date.
Processors of personal data
Your data will only be processed by LocalTapiola Group companies and employees who need access to the data to perform their duties. Most of our employees are bound by a statutory obligation of secrecy, and each employee must also sign a non-disclosure agreement in which they pledge to keep customer information confidential.
In producing and providing our services, we use partners to whom we transfer personal data for processing. These partners act as our sub-processors and process personal data in accordance with our instructions. We require our sub-processors to protect personal data appropriately and we inspect and audit their operations.
Disclosure of data
We disclose personal data between the LocalTapiola Group companies insofar as permitted by law. We disclose personal data to parties external to LocalTapiola Group only with your consent or when there is a legal ground or some other legitimate purpose for the disclosure of data. Based on your consent, we may disclose your data for example when issuing a medical institution an authorisation for direct billing or when sending SOK information on your premiums to accrue S Bonus. On the basis of the law, we may disclose your data for example to public authorities, including the tax, prosecution and investigating authorities, and to other insurers. In addition, we may disclose limited amounts of personal data to advertising platform service providers for our marketing purposes, including for the targeting of advertising or for implementing targeted online marketing.
To read more about how we target advertising and online marketing, see “Targeted paid online marketing and joint controllership with advertising platform service providers”. You can find this topic in the Other section at the bottom of the page.
The disclosure of personal data refers to situations where personal data is given to another controller to process. We also transfer personal data for processing purposes to our partners, who process personal data on our behalf and thus act as our sub-processors.
Data retention periods
We have defined retention periods for the personal data we collect, taking into account the requirements of legislation and the effectiveness and fluency of business operations, such as insurance and investment services. Occasionally, we may be required by law to retain data for a certain period of time. This is not always the case, in which case we retain the data for as long as it is necessary for us.
We store data necessary for the customer relationship at least for the duration of the customer relationship. In general, it is necessary for us to continue storing data even after the customer relationship has ended. The retention period of your personal data varies depending on the type of service transactions you have or have had. For example:
As a rule, the retention period for insurance and claims data is 100 years from the end of the insurance or the last date of processing of the claim in statutory CTP and accident insurance, and at least 10 years in voluntary types of insurance. Data related to non-life insurance quotes is stored for at least 18 months from the date of the quote.
Life insurance and claims data are stored for at least 10 years from the end of the insurance. Data related to life insurance quotes is stored for at least 3 years from the date of the quote.
In contracts related to investment services, the retention period of data is, as a rule, 10 years from the termination of the contract.
Recording customer communications
We record phone calls, audio recordings of online meetings, chat conversations and online messages. They are used for verifying transactions, ensuring the quality of customer service and development and training purposes.
Transfers of data outside the EU or EEA
We may transfer your personal data outside the EU and EEA within the limits of data protection legislation.
Some external service providers or other recipients of personal data may be located or process personal data outside the EU or EEA. We use the necessary transfer mechanisms and complementary safeguards permitted by law to ensure that the level of protection of personal data is not compromised in situations where the data is transferred outside the EU or EEA. Such transfer mechanisms include, for example, adequacy decisions by the European Commission and the use of standard contractual clauses with recipients of data located outside the EU or EEA.
The standard contractual clauses we use are available on the EU legislative and justice website:
You can also request a copy of the standard contractual clauses by contacting our Data Protection Officer.
Customer due diligence and prevention of money laundering and terrorist financing
We may use your customer due diligence information and other personal data for the prevention, uncovering and investigation of money laundering and the financing of terrorism as prescribed in the Anti-Money Laundering Act, and in bringing under investigation money laundering and financing of terrorism as well as the crime committed to obtain the assets or proceeds of crime involved in the financing of money laundering or the financing of terrorism.
We may use your personal data to determine whether you are subject to international sanctions we are required to comply with.
Insurance claims and fraudulent claims registers
Finnish insurance companies maintain shared registers about insurance claims and fraudulent claims. Insurance companies disclose information on claims and crimes and suspected crimes against the company to the registers. Insurance companies use the information in the registers when granting insurance and processing claims. The purpose of the registers is to prevent and detect insurance fraud and crime by sharing information between insurance companies. LocalTapiola Group’s insurance companies also disclose information to registers and use the information in the registers.
Claims register
We register information about claims reported to us in the insurance companies' joint claims register. The register collects information on the claim and the insured person. When the insurance company submits the basic information in the claim to the claims register, the company receives information about claims filed by the applicant at other insurance companies. Based on the information in the claims register, we may also exchange more detailed information about claims between other insurance companies. We use the information in the claims register to prevent fraud against insurance companies, with the purpose to prevent a person from filing false claims at several insurance companies.
Fraudulent claims register
We register information on crimes and suspected offences against our insurance operations in the insurance companies' common fraudulent claims register. The register collects information on the claim and the insured person. In addition, we check the information entered in the register. Entering information in the fraudulent claims register requires that a suspected criminal act has been reported to the police or prosecutor. Entries made on the basis of a suspected crime are erased from the register if the person in question is found innocent of the act in a court of law or the case is dropped. We use the information in the fraudulent claims register in insurance handling and claims settlement to prevent and detect crime against insurance companies.
Data security
We use the necessary and best-practice technical and organisational data security methods to safeguard personal data. We protect personal data so that it cannot be accessed without authorisation or lost, destroyed or altered without a basis.
We ensure the protection of personal data with firewalls, separation of environments and various encryption and protection technologies, among other measures. We continuously monitor our data security. We make sure that our data centres are secure and access control is at an appropriate level.
Access to personal data is restricted with suitable access rights restrictions, and we apply access rights management processes. Access rights are always based on work duties. Personal data can only be accessed by employees who have a need to do so for the performance of their duties. We monitor to ensure that access rights are necessary at all times and remove expired access rights.
We collect logs on the processing of personal data. Logs indicate what, why and when a processing activity occurred. We use logs to monitor the processing of personal data, ensure that no errors have occurred and investigate possible errors.
Our employees involved in processing personal data are regularly trained and provided with instructions.
We also require our sub-processors to safeguard the data appropriately, and inspect and audit their operations.
Data subjects’ rights
You have a number of rights related to the processing of your personal data, which are described below.
You can exercise your rights by contacting our Data Protection Officer or through other means indicated by us for this purpose. The contact details of our Data Protection Officer can be found at the bottom of this page in the contact information section. Below, under each right, we explain in more detail how you can exercise that particular right.
Please note that, to examine your rights request, we need to be able to identify you. Your exercise of rights request must include adequate identification information, such as your name, personal identity code, postal address and telephone number.
As a rule, exercising your rights is free of charge for you. However, in the case of clearly unfounded or excessive requests, we may charge a reasonable fee or refuse to comply with the request.
Withdrawal of consent
If the processing of your personal data is based on your consent, you have the right to withdraw your consent. The withdrawal of consent has no effect on past processing activities.
When requesting consent, we will also tell you how you can withdraw your consent. In matters related to the withdrawal of consent, you can also contact our Data Protection Officer.
Right of access
You have the right to know whether we process your personal data and, if so, to receive a copy of all your data and detailed information about the processing of your personal data.
Your key customer information are listed in our online service, where you can view the information at any time. If you wish to view your personal data more extensively, you can submit a separate request for access to your data. You can make a request for access from the Omat tiedot (My Information) section of our online service or using the data access request form.
You can send the form or your questions regarding the processing of your data to us using the contact details of our Data Protection Officer.
If your request for access concerns an individual claim, you can most quickly and easily request the data by contacting the party that made the claim settlement decision directly.
Contact details of the Data Protection Officer:
Email: tietosuojaj(at)lahitapiola.fi
Mailing address: LähiTapiola-ryhmä Lakiasiat ja compliance / tietosuojavastaava 02010 LÄHITAPIOLA
Right to rectification
You have the right to request the rectification (correction) of inaccurate or incomplete data.
Your key customer information is listed in our online service, where you can also manage the information. You can also update your customer information by contacting our customer service or visiting our branch office. You can also send a separate rectification request to our Data Protection Officer.
Right to erasure
Data subjects have the right to request the erasure of their personal data.
In certain situations, you have the right to demand the erasure of your data. Personal data may be erased at your request if the retention period of the data has expired or the data is otherwise deemed unnecessary or unjustified. We cannot erase data that must be stored due to a legal obligation or other justified need.
You can submit a data erasur erequest in the Omat tiedot (My information) section of our online service. You can also send the request to erase your data to our Data Protection Officer.
Other rights
You have the right to prohibit the processing of your data for direct marketing purposes and for profiling related to direct marketing.
You can manage direct marketing permissions in our online service. You can also prohibit direct marketing and related marketing activities by contacting our customer service or visiting our branch office. You can unsubscribe from direct marketing messages by clicking on the link provided in the message.
In certain situations, you have the right to request that the processing of your data be restricted or otherwise object to the processing of your data. You can also request the transfer of personal data that you have provided in a machine-readable format, where technically feasible.
You can exercise these rights by contacting us with the contact details of our Data Protection Officer.
Right not to be subject to automated decision-making
We use automated decision-making. We will notify you of this separately in connection with each service that uses automated decision-making and, if necessary, ask for your consent to its use.
Once you have received the automated decision, you have the right to appeal against and request that the matter be reviewed by a human employee.
You can exercise your right by contacting the party that issued the decision.
Privacy statements
LocalTapiola Group has several personal data files, each of which has its own privacy statement. In the privacy statement, we explain important information related to the processing of personal data, such as the controllers, types of personal data collected, purposes of processing and the legal basis for processing.
You can read the privacy statement for our Group’s common customer data file and the privacy statements of other key data files from the links below.
We reserve the right to change and update the privacy statements if necessary.
Privacy statement of the LocalTapiola Group Common customer data file (PDF)
Privacy statement of the Non-life insurance policies and claims register (PDF)
Privacy statement of the Life insurance policies and claims register (PDF)
Privacy statement of the asset management data file of Asset Management (PDF)
Privacy notice of Asset Management and Life’s joint savings-mapping data file (PDF)
Privacy notice of the investment business carried on by LocalTapiola Group’s real estate and other alternative investments (PDF)
Privacy notice for LocalTapiola Group’s letting business (PDF)
Privacy statement of LocalTapiola Finance Ltd (PDF)
Privacy statements of other data files
You can obtain other privacy statements by requesting them from our Data Protection Officer’s contact information. Alternatively, you can read the statements at our branch offices:
Customer community privacy statement
Privacy statement of LocalTapiola Group's debt collection data file
Privacy statement of LocalTapiola Group's related party transactions register
Privacy statement of the insider register of LocalTapiola Group's investment activities
Privacy statement of LocalTapiola Group's politically exposed persons’ transactions register
Privacy statement of the insider register of Asset Management
Privacy statement of the loan, collateral and guarantee and credit insurance data file
Privacy statement of the insurance and claims history system
Privacy statement of the camera surveillance data file
Privacy statement of the job applicant data file
Privacy statement of LocalTapiola Group's stakeholder register
Privacy statement of the whistleblowing channel
Automated decision-making, and profiling
Automated decision-making
We use automated decision-making. Automated decision-making means that a decision is made entirely on the basis of automated data processing, without any human involvement in the decision-making process. Automated decision-making helps us considerably improve the efficiency of, for example, our insurance processing, claims handling and the provision of other services.
We inform you about automated decision-making separately in connection with every service that uses it and, where needed, ask for your consent to its use. After receiving a decision, you have the right to request that it be reviewed and demand that your case be re-examined by an employee.
The data and rules underlying automated decision-making are examined regularly in order to ensure that the decision-making process functions as intended and does not result, for example, in any discriminatory processing of data. We use automated decision-making in claim and life insurance activities in the following contexts:
Purchase of insurance policies
We use automated decision-making for making insurance decisions. Here, separately for every service, you will find more specific information about the personal data and logic underlying an automated decision and about its consequences.
The contact details for making an administrative review request concerning an automated decision are given below separately for every service.
Motor insurance
We use automated decision-making for making an insurance decision when you apply for motor insurance on our website.
Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy.
For motor insurance, the assessment is also based on information obtained from other official sources, including Traficom’s Transport Register. The assessment takes into account not only information about the policyholder and the vehicle, but also information about the principal user and other persons attached to the vehicle’s roles.
As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing.
For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/
Home insurance
We use automated decision-making for making an insurance decision when you apply for home insurance on our website.
Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy.
As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing.
For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/
Pet insurance
We use automated decision-making for making an insurance decision when you apply for pet insurance on our website.
Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy.
As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing.
For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/
Health insurance
Accident Medical Expenses Cover
We use automated decision-making for making an insurance decision when you apply for accident insurance on our website. Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy. Furthermore, we will check guardianship information in our own systems or Suomen Asiakastieto’s register when you are taking out an insurance policy for an underage person. As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing. For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/.
Illness Medical Expenses Cover
We use automated decision-making for making an insurance decision when you apply for medical expenses insurance on our website. Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy. As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing. For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/.
Unborn child cover
We use automated decision-making for making an insurance decision when you apply for unborn child insurance on our website. Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy. As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing. For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/.
Travel insurance
We use automated decision-making for making an insurance decision when you apply for travel insurance on our website. Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy. When taking out a fixed-term travel insurance policy, your credit file will not be checked. Furthermore, we will check guardianship information in our own systems or Suomen Asiakastieto’s register when you are taking out an insurance policy for an underage person. As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing. For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/.
Life insurance
We use automated decision-making for making an insurance decision when you apply for life insurance on our website.
Automated decision-making is based on the information you provide and the customer details that we already have about you in our systems. In addition, we use the credit register maintained by Suomen Asiakastieto Oy, insurers’ joint fraudulent claims register, and international sanctions lists to carry out background checks. Automated decision-making checks whether the information you have provided and the results of background checks meet the conditions for granting an insurance policy.
As a result of automated decision-making, a policy may be granted automatically or the insurance matter may be referred for further manual processing.
For the contact details for making an administrative review request, please see our website at https://www.lahitapiola.fi/en/personal/
Handling of claims
We use automated decision-making for making claim decisions and as part of the other claim handling process. Below, separately for every service, you will find more specific information about the personal data and logic underlying an automated decision and about its consequences.
Health insurance
Illness Medical Expenses Cover
We use automated decision-making in the processing of your claim application for illness-related medical expenses when you make a claim in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details and customer details, the policy terms and information about previous claims.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Accident Medical Expenses Cover
We use automated decision-making in the processing of your claim application for accident-related medical expenses when you make a claim in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Travel insurance
Travel illness
We use automated decision-making in the processing of your claim application for travel illness-related medical expenses when you make a claim in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details and customer details, the policy terms and information about previous claims.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Travel accident
We use automated decision-making in the processing of your claim application for travel accident-related medical expenses when you make a claim in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Travel cancellation
We use automated decision-making in the processing of your travel cancellation claim application when you make a claim in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details and customer details, the policy terms and information about previous claims.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Luggage insurance
We use automated decision-making in the processing of claim applications when you make a claim on your luggage insurance cover in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, we may either pay compensation for the claim or refer the claim application for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
LocalTapiola Life’s medical expenses insurance products
We use automated decision-making in the processing of claim applications made under medical expenses insurance policies granted by LocalTapiola Life, when you make a claim in our online service on your LocalTapiola Life-granted medical expenses insurance policy.
Automated decision-making is based on the information that you provide in the claim application about your illness/injury, on the other information requested in the claim application, and on the scope of cover of your policy and your customer details.
As a result of automated decision-making, we may pay compensation for the claim or refer the claim application for manual processing.
If your claim application cannot be processed automatically, it will always be processed by a human. If we make a negative decision and you appeal against it, the appeal will also be always processed by a human.
Home insurance
Home contents, buildings and property insurance
We use automated decision-making in the processing of claim applications when you make a claim on a home contents, buildings or property insurance policy in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Pet insurance
Cat, dog and horse insurance
We use automated decision-making in the processing of veterinary expenses claim applications when you make a claim on a cat, dog or horse insurance policy in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, we may pay compensation for the claim, or we may reject the claim application. Alternatively, the claim may be referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Voluntary motor insurance
We use automated decision-making in the processing of reported voluntary motor insurance claims when you make a claim in our online service. This means that the payment of compensation may be fully automatic, without any human involvement.
Automated decision-making is based on the claim information that you provide, and on information about previous claims, your customer details and details of the insured vehicle. Furthermore, we use information in insurers’ joint claims register, information in Traficom’s Transport Register, the policy terms and information obtained from the damage inspection.
As a result of automated decision-making, you may receive a positive decision for a damage inspection, the repair cost estimate may be approved and the repair costs may be paid to the repair shop. Alternatively, the processing of your claim may be referred for further manual processing at all stages of the process.
You will always receive a written claim decision about whether the repair costs are covered or not. The decision also includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Health insurance-related direct billing authorisation
Illness Medical Expenses Cover
We use automated decision-making for granting a direct billing authorisation when you apply for a direct billing authorisation for a medical consultation in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. In addition, we use the policy terms.
The outcome of this process is that we will either grant a direct billing authorisation or, alternatively, direct you to pay the costs yourself first and claim compensation afterwards.
Please note that, if we refuse to grant a direct billing authorisation, this does not mean that no expenses at all could be covered under your policy. We will finally decide whether the costs are covered only after you make a claim for the costs in our online service. Where necessary, contact our Claims Service (+358 9 453 4600 Mon–Fri 8.00–16.00).
Accident Medical Expenses Cover
We use automated decision-making for granting a direct billing authorisation when you apply for a direct billing authorisation for a medical consultation in our online service.
Automated decision-making is based on the claim information that you provide, and on your policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
The outcome of this process is that we will either grant a direct billing authorisation or, alternatively, direct you to pay the costs yourself first and claim compensation afterwards.
Please note that, if we refuse to grant a direct billing authorisation, this does not mean that no expenses at all could be covered under your policy. We will finally decide whether the costs are covered only after you make a claim for the costs in our online service. Where necessary, contact our Claims Service (+358 9 453 4600 Mon–Fri 8.00–16.00).
Pet insurance-related direct reimbursement service
We use automated decision-making in the pet insurance-related direct reimbursement service when a partner veterinary clinic submits an invoice for a cat’s or dog’s veterinary expenses directly to LocalTapiola.
Automated decision-making is based on the information that the veterinary clinic provides about the consultation, and on the invoice details, policy details, customer details and information about previous claims. Furthermore, we use information in insurers’ joint claims register, as well as the policy terms.
As a result of automated decision-making, the invoice received for the veterinary consultation will be either paid directly to the veterinary clinic or, alternatively, referred for further manual processing.
You will always receive a written claim decision, which includes appeal instructions and the contact details for making an appeal. Appeals are always processed by a human.
Automated decision-making in the statutory insurance lines, and deployment decisions
We use automated decision-making in the processes of the statutory insurance lines. Read more about automated decision-making in the statutory insurance lines and about deployment decisions.
Profiling
We also use profiling. Profiling means any automated processing of personal data that, by combining and analysing personal data, assesses certain personal aspects relating to a person. We use profiling, for example, in:
the insurance process, when pricing an insurance policy on the basis of the risk of loss. The risk of loss will be calculated on the basis of the customer’s and the insured asset’s details;
the claim handling process, when performing a risk assessment for a claim with the aim of identifying the risk of fraud. The risk assessment is based on the details of the customer and the claim;
in the targeting of marketing efforts.
Contact details
Controllers
The following LocalTapiola Group companies belonging act as the controllers:
Our Group consists of several companies that operate in different lines of business. Each of the companies in our Group acts as the controller of personal data it collects in its own operations.
For more information on companies that belong to LocalTapiola Group, see the Companies section on our website.
Enquiries and contact details of the Data Protection Officer
In questions and matters related to the processing of personal data, you can contact our Data Protection Officer by email or post.
Contact details of the Data Protection Officer:
Email: tietosuoja(at)lahitapiola.fi
We recommend to use a secure email connection if your message contains any personal data or other confidential data. You can send a secure email message here.
Mailing address: LähiTapiola-ryhmä Lakiasiat ja compliance / tietosuojavastaava 02010 LÄHITAPIOLA
Complaints and contact details of the supervisory authority
If you feel that our processing of personal data violates the law, you have the right to lodge a complaint with the supervisory authority. In Finland, the supervisory authority is the Data Protection Ombudsman. However, we recommend that you first contact us using the contact details of our Data Protection Officer.
Contact information of the Office of the Data Protection Ombudsman:
Email: tietosuoja@om.fi
Mailing address: PO Box 800, FI-00531 Helsinki
Phone: 029 566 6700
Customer due diligence
We identify and know our owner-customers and partners. Knowing our customers also helps us provide them with even better service.
Why we ask your customer information
The first and foremost reason why we ask for your customer information is to ensure that the customer’s interests are met. In addition, as a financial sector operator, LocalTapiola is required by the law to identify and know its customers. By identifying and knowing its customers, LocalTapiola ensures that customer information is up-to-date and prevents abuse in the financial sector.
Collection of tax liability information
LocalTapiola has a legal obligation to collect information about the tax liability of its savings, investment and pension insurance customers. The purpose of collecting tax liability information is to prevent tax evasion through foreign financial institutions. LocalTapiola's obligation applies to private individuals, companies, institutions and estates that are our savings, investment and pension insurance customers.
Other
Joint controller in social media channels
LocalTapiola Group companies have a strong presence in various social media channels. Where applicable, we act as joint controllers of personal data with social media service providers (Meta, LinkedIn and Twitter) for LocalTapiola community pages, messaging services, tracking pixels and visitor data in these channels. This information applies to persons who have interacted with one of the social media community pages managed by LocalTapiola or have accepted social media cookies on the LocalTapiola website.
We process the data subject's personal data on the basis of our legitimate interest. In the case of tracking pixels, the processing is based on the consent given by the data subject. We use the data to maintain community pages, market LocalTapiola Group services, products and offers, carry out competitions and raffles, receive feedback, purchase advertising from social media channels, measure the availability of pages or advertisements, and to provide customer service on social media. We only process data for our own purposes. Social media service providers process data in accordance with their own data protection principles and are generally responsible for compliance with data protection legislation and the implementation of data security and the rights of data subjects. You can manage your privacy settings in the service in question.
We obtain information that a data subject has made public in the service, such as username and profile picture. In addition, the data subject may provide other information on their own initiative through comments, publications or messaging services. We also receive anonymised statistical data about visitors to our community pages and how visitors interact with the page content (Meta Page Insights, LinkedIn Page Analytics and Twitter Analytics). The data we store in the data file is not transferred outside the European Union or European Economic Area.
The controller determines the retention period of personal data, taking into account applicable legislation as well as the needs and efficiency of business operations. The purpose of the retention periods is to secure the rights of both the data subjects and LocalTapiola. We may process comments, posts and messages on community pages until the data subject deletes the comment or post. We may also delete a comment or post earlier if we deem it necessary to ensure the appropriateness of comments and posts, for example. Data subjects may request the deletion of a conversation in the messaging service from the owner of the community page in the service. You can also restrict the processing of your personal data by unliking and/or unfollowing the community page.
Facebook and Instagram
Where applicable, we act as joint controllers with Meta Platforms Ireland Ltd. (Meta) with respect to LocalTapiola’s community pages, messaging service, insights and tracking pixel in the service.
We have signed an addendum on joint controllership, which defines the responsibilities of both controllers regarding compliance with obligations under the EU General Data Protection Regulation (GDPR) and the joint processing of personal data. For more information, please visit: https://www.facebook.com/legal/controller_addendum.
For Facebook Insights (Page Insights), the controllers' responsibilities for complying with their obligations under the GDPR are described in the Page Insights Controller addendum. For more information, please visit: https://www.facebook.com/legal/terms/page_controller_addendum.
Meta processes personal data in accordance with its own privacy policies. For more information about the purposes, legal bases and privacy policies of Meta's processing of personal data as well as the information required by the joint controllership and Articles 13(1)(a) and (b) of the GDPR, please see Facebook's Privacy Policy at www.facebook.com/privacy/policy
LinkedIn
Where applicable, we act as joint controllers with LinkedIn Ireland Unlimited Company (LinkedIn) with respect to LocalTapiola’s community pages, messaging service, insights and tracking pixel in the service.
We have signed an addendum on joint controllership for the processing of visitor data (Page Insights), which defines the responsibilities of both controllers regarding compliance with obligations under the EU General Data Protection Regulation (GDPR) and the joint processing of personal data. For more information, please visit: https://legal.linkedin.com/pages-joint-controller-addendum.
For more information about the purposes, legal bases and privacy policies of LinkedIn's processing of personal data as well as the information required by the joint controllership and Articles 13(1)(a) and (b) of the GDPR, please see LinkedIn's Privacy Policy at https://www.linkedin.com/legal/privacy-policy.
Twitter
Where applicable, we act as joint controllers with Twitter International Unlimited Company (Twitter) with respect to LocalTapiola's community pages, messaging service, insights and tracking pixel in the service.
For more information about the purposes, legal bases and privacy policies of Twitter's processing of personal data as well as the information required by the joint controllership and Articles 13(1)(a) and (b) of the GDPR, please see Twitter's Privacy Policy at https://twitter.com/en/privacy.
Third-party links and embedded content
Our websites and services may contain links to third-party sites and services and embedded content from third parties, such as Google Maps and YouTube videos.
We use analytics and customer experience cookies to manage the visibility and use of third-party embedded third-party content on our sites and services. Embedded content from third parties will only appear on our website if you have given your consent to the use of such cookies.
Providers of embedded content may place cookies on your browser that allow them to collect data for their own use. These third parties have their own privacy policies, which you can read on their respective websites.
Cookies
See our cookie policy.
Description of document publicity
In order to implement the principle of public access, LocalTapiola maintains a description of its data reserves. This is known as the description of document publicity. The purpose of the description is to assist LocalTapiola customers who wish to make a request for information concerning LocalTapiola's documents.
Targeted paid online marketing and joint controllership with advertising platform service providers
For the purposes of this context, targeted paid online marketing means the targeted displaying of paid advertising elsewhere on the internet than on our own websites together with advertising platform service providers.
LocalTapiola Group companies purchase targeted online marketing from the service providers of various advertising platforms. As applicable, we act as joint controllers in respect of personal data together with each advertising platform service provider (Sanoma, Alma Media, Meta, Adform) when we cooperate in the processing of personal data in order to target online marketing on the advertising platform of the service provider in question. We have concluded written agreements on the processing of personal data with all entities that act as joint controllers.
The advertising platform service providers process the personal data we disclose only for targeting our advertising and for displaying it on their advertising platforms to the target groups we have determined. The service providers erase the personal data we disclose after the effecting of online marketing, but in any case not later than 6 months after this effecting. In addition Meta event data may be retained by Meta for up to two years, and Adform may retain combined aggregated data (without the possibility to re-identify the programmatic advertising ID data) for 13 months for LocalTapiola’s programmatic advertising reporting purposes.
We process the data subject’s personal data on the ground of our legitimate interest. In server-side online marketing and programmatic advertising that is based on online behaviour, data processing is, in part, also based on the data subject’s cookie consent.
Target group list-based online marketing
In target group list-based online marketing, we target advertising based on a target group listing extracted from our registers. Into a tool provided by the advertising platform service provider, we upload the target group list we have compiled. This list contains pseudonymised personal data: a hashed mobile phone number and a hashed email address. The pseudonymisation and hashing procedures we employ mean that personal data are processed into an encoded format in such a way that they are no longer directly identifiable.
The advertising platform service provider compares the pseudonymised target group we uploaded with their own customer records in order to find matching data. After a successful matching process, our and the advertising platform service provider’s combined data create custom audience lists to which our advertising is further targeted on the digital advertising platform (in the media) of the service provider in question.
In target group list-based targeting of advertising, depending on our advertising campaigns, we use solutions provided by three different advertising platform service providers: Meta, Sanoma, and Alma Media.
Server-side targeting of online marketing
In server-side online marketing that is based on online behaviour, we target advertising to users who have visited our website, on the basis of their website visit data. Server-side targeting and marketing is effected only to those users who, when asked for their consent for the use of cookies on our website, accepted the following category: Use of “Advertising” cookies.
Website visit data and the user’s pseudonymised personal data, that is a hashed telephone number and/or a hashed email address, the country indication (Finland) for the targeting of advertising, the ID detail, are disclosed, in a server-based manner, from the user’s browser to the advertising platform service provider. The ID detail will not be linked to your customer details at LocalTapiola Group. The ID detail is a unique series of numeric characters with which LocalTapiola may request advertising to be displayed in the user’s browser on the advertisement platforms we use, if the user has consented to Advertising cookies. For server-based targeting of advertising that is based on online behaviour, we use Meta.
Programmatic advertising
At the websites of LocalTapiola Group companies, in our advertising campaigns we use programmatic advertising tracking techniques provided by Adform. Programmatic advertising is one way to purchase digital advertising automatically. An Adform cookie will be placed on your device after you have given us your consent for the Advertising category of cookies.
Adform cookie ID (3rd party cookie)
Personal data are collected for the purpose of analysing and optimising advertising campaigns, and for combining IDs of Adform customers, including LocalTapiola.
The Adform cookie collects the following personal data or advertising materials: Adform cookie ID, device type/ID, website or advertising material click time, website or advertising material URL address, data automatically sent by your device (including the language setting, IP address, demographic data).
LocalTapiola ID (1st party cookie)
The LocalTapiola ID can be supplied to Adform after you have given us your consent for the Advertising category of cookies on the LocalTapiola Group websites. The LocalTapiola ID is a unique series of numeric characters with which LocalTapiola may request advertising to be displayed in the user’s browser on the advertisement platforms we use, if the user has consented to cookies. Subject to your cookie consent, we will share the LocalTapiola ID with Adform in order to optimise advertising campaigns and deliver targeted advertisements.
The following data will be processed together with the LocalTapiola ID: device type/ID, website or advertising material click time, website or advertising material URL address, data automatically sent by your device (including the language setting, IP address, demographic data).
Joint controllership
LocalTapiola and Adform (hereinafter the ‘Parties’) are joint controllers in the phases where your personal data are collected and transferred to Adform using the Adform cookie and, where necessary, in certain activities that process the LocalTapiola ID data in connection with targeted advertising, as described above. Under the contract signed between the Parties, both Parties are responsible for the implementation of your data protection rights. If you wish to exercise your rights, please contact Adform using this link and/or contact LocalTapiola at tietosuoja(at)lahitapiola.fi. You can withdraw your consent at any time by contacting Adform via this link, and for LocalTapiola you can cancel your cookie consent in the cookie settings for the ‘Advertising’ category of cookies.
When Adform processes data for its own purposes, Adform is the controller and alone responsible for the optimisation of advertising campaigns and target groups. Adform analyses the data collected through cookies in order to deliver targeted advertisement purchases on behalf of the Adform customer programme (including LocalTapiola) in accordance with the Adform data privacy policy.
The Adform cookie placed in your browser will be removed in 60 days. However, if you decide to withdraw your consent, Adform will not collect any data even if the cookie remains placed in your device. The same retention of data applies to the LocalTapiola ID, which LocalTapiola will share with Adform subject to your cookie consent or which Adform will collect from the LocalTapiola Group websites subject to your cookie consent.
Read more about the data protection policies of the advertising platform service providers we use:
Adform
Alma Media
Meta
Sanoma
How to transact safely online
We want to ensure that you can transact safely when using the LocalTapiola online services. The following instructions will help you use our online services safely:
Use a reliable and updated browser: Updates often contain important security patches, so please ensure that your browser is always up to date. Also remember to keep your computer and mobile devices updated.
Ensure website authenticity: To log in to the online services, you should write the web address of the service in the address line of your browser. Avoid using links you see in emails and search websites, as they can lead you to fraudulent websites. Use the bookmark function available in your browser.
Activate the private browsing mode: Where possible, activate your browser’s private browsing mode, which will prevent the saving of any browsing history or cookies.
End your transaction safely: - Log out of the service. - Close all tabs in your browser.
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