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Privacy Notice

This is the privacy notice of YES-EU Ltd in accordance with the EU General Data Protection Regulation (EU) 2016/679 regarding the processing of personal data.

This notice describes how YES-EU Oy processes personal data relating to contact persons of its customers, suppliers, business partners and other stakeholders, as well as individuals participating in marketing campaigns and prize draws.

YES-EU Ltd operates in the import, sales, installation, and maintenance of electric buses, commercial vehicles, and related electrification equipment.

Prepared: 10 May 2023. Last updated: 4 September 2026.

1. Controller

YES-EU Oy
Address: Perintötie 8 C, 01510 Vantaa
Business ID: FI31985228

2. Contact details for data protection matters

Contact: infosuomi@YES-EU.com

3. Purpose of processing and legal basis

The controller processes personal data of data subjects for the following purposes:

a) Customer relationship management and maintenance

Processing of contact details of current and potential customers’ representatives for handling offers, contracts, orders, deliveries, invoicing, and maintaining customer relationships. The legal basis for processing is a contract (Art. 6(1)(b)), a legal obligation for certain records such as accounting-related information (Art. 6(1)(c)), and legitimate interest (Art. 6(1)(f)).

b) Supplier and procurement management

Processing of contact details of suppliers and subcontractors’ representatives for procurement activities, contract management, and cooperation. The legal basis is a contract (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)).

c) Stakeholder and partner communication

Processing of contact details of stakeholders (e.g. authorities, financiers, industry associations) and partners for cooperation and communication purposes. The legal basis is legitimate interest (Art. 6(1)(f)).

d) Direct marketing, marketing campaigns and prize draws

Sending newsletters, product information, event invitations and communications related to marketing campaigns and prize draws by e-mail or through other electronic channels. The legal basis for processing personal data is the data subject’s consent (Art. 6(1)(a)) or the controller’s legitimate interest (Art. 6(1)(f)).

Where processing is based on consent, the data subject has the right to withdraw their consent at any time, without affecting the lawfulness of processing carried out before the withdrawal. Where processing is based on legitimate interest, the data subject has the right at any time to object to the use of their personal data for direct marketing purposes. In connection with prize draws, personal data may also be used for contacting winners and delivering prizes.

e) Website technical functionality and security

IP addresses of website visitors and cookies necessary for the functioning of the service are processed to ensure information security. The legal basis is legitimate interest (Art. 6(1)(f)). If analytics or third-party cookies are used, consent is requested separately.

4. Legitimate interest of the controller

The controller has a legitimate interest in maintaining customer, supplier, stakeholder, and partner relationships, ensuring the technical security of its website, and marketing its services.

Processing is necessary for the purposes described above, and these objectives cannot be achieved by other means. The data processed is limited to professional contact details and organizational roles.

The scope of processing is limited, does not involve special categories of personal data, and has minimal impact on data subjects’ rights and freedoms.

Data subjects can reasonably expect their contact details to be used in a professional context, and the processing does not exceed what is typical in a business relationship.

Data subjects have the right to object to processing based on legitimate interest at any time and to object to direct marketing unconditionally.

Personal data is not used for automated decision-making with significant legal effects. Profiling used for marketing does not have significant impact.

In the overall assessment, the controller’s legitimate interest is not overridden by the rights and freedoms of data subjects.

5. Categories of personal data

The personal data processed includes:

– Name and position in the organization
– Contact details (phone number, email address, business address)
– Information related to services and products ordered, changes, invoicing details, and other data related to customer, supplier, or stakeholder relationships
– Data collected via cookies (such as IP address)
– Data relating to prize draws and marketing campaigns, such as participation details, responses provided by the participant, winner information, and contact details required for delivering a prize

6. Sources of personal data

Personal data is primarily collected directly from the data subject, e.g. via website forms, email, phone, social media services, contracts, meetings, and other situations where the data subject provides their information.

Contact details may also be collected from public sources such as websites, directories, and other companies.

7. Disclosure and transfer of data

Personal data is not regularly disclosed to third parties. Data may be published if agreed with the customer.

The controller may use trusted subcontractors (e.g. IT service providers and CRM providers) for processing personal data, and appropriate data processing agreements have been concluded with them.

Data may be transferred outside the EU/EEA where necessary for business operations, maintaining customer or stakeholder relationships, or fulfilling contracts. Such transfers are carried out using European Commission standard contractual clauses or another lawful safeguard.

8. Principles of data protection

Personal data is protected through appropriate technical and organisational measures. Information systems are protected by access controls, user accounts, and other appropriate information security measures. Personal data and related records are stored and disposed of securely.

Access to personal data is restricted to employees and other authorised persons who require such access for the performance of their duties. Personal data is processed confidentially. Where necessary, data processing agreements are concluded with external service providers.

9. Retention periods

Personal data is retained only for as long as necessary to fulfil the purposes described in this notice or to comply with applicable legal obligations.

Contract-related data is generally retained for 6 years after the end of the contractual relationship due to accounting requirements.

Stakeholder and partner contact details are retained as long as the relationship is active or the data is necessary, with necessity reviewed every two years.

Data used for direct marketing is retained for a maximum of two years from the last active contact or the giving of consent, unless the data subject objects to direct marketing or withdraws consent earlier.

Data collected via website cookies is generally processed only for the duration of the session.

Personal data relating to prize draw participants is retained for the administration of the prize draw and delivery of prizes, and thereafter only for as long as necessary to fulfil obligations relating to the prize draw, address potential claims, or comply with statutory retention obligations. Personal data processed separately for direct marketing is retained in accordance with the retention period applicable to direct marketing.

10. Data subject rights

You have the following rights regarding the processing of your personal data:

– Right of access
– Right to rectification
– Right to erasure
– Right to restriction of processing
– Right to object to processing
– Right to withdraw consent
– Right to data portability

Requests should be submitted in writing to the e-mail address mentioned in section 2. We will respond within the time limits required by applicable legislation, generally within one month. Additional information may be requested to verify identity.

Data subjects also have the right to lodge a complaint with the supervisory authority if they believe their rights have been violated. The contact details of the Data Protection Ombudsman can be found here: Contact information | Data Protection Ombudsman’s Office