Privacy Policy

1. Data Controller

Lapland LKV Oy
Business ID: 3474730-5
Sivulankuja 10, 99130 Sirkka, Finland
Phone: +358 40 730 2833
Email: [email protected]

Contact person for data protection matters:
Tanja Sotka
[email protected]

2. Registers

Lapland LKV Oy maintains the following registers:

• Customer register — personal data relating to real estate brokerage assignments
• Marketing register — subscribers to The List newsletter and direct marketing contacts

Data collected through the website (contact forms, analytics, cookies) is described in section 6.

3. Legal Basis and Purpose of Processing

3.1 General

Personal data is processed in accordance with the Finnish Data Protection Act and other applicable laws, regulations and regulatory guidance. Personal data means any information that can be linked to an identified or identifiable individual.

3.2 Purposes of collection

a) Contractual or customer relationship

The customer register is used for managing the contractual relationship with the client (e.g. seller or landlord), the relationship with the counterparty to a transaction (e.g. buyer or tenant), and agreements relating to valuation or other professional services. Data may also be collected from persons attending property viewings for security and potential future client relationship purposes.

Finnish legislation governing real estate brokerage — including the Act on Real Estate Agencies and Rental Property Agencies (1075/2000) and the Act on Real Estate and Rental Apartment Brokerage (1074/2000) — requires the maintenance of an assignment diary recording personal details, property information and transaction documents.

b) Statutory anti-money laundering obligations

Pursuant to Chapter 3, Section 3 of the Act on Preventing Money Laundering and Terrorist Financing (444/2017), customer identification data and other statutory personal data are stored and retained for the prevention, detection and investigation of money laundering and terrorist financing. This data is not used for any other purpose.

c) Consent-based processing

Where processing cannot be based on the statutory grounds above, the customer's separate consent is requested. Subscribing to The List newsletter is always based on freely given consent.

3.3 Purposes of use

• Managing and developing the customer relationship
• Providing, offering and improving services
• Invoicing, debt collection and transaction verification
• Customer communication, marketing and advertising
• Analysis and statistics related to services
• Fulfilling statutory obligations
• Protecting the rights of the controller and persons involved in assignments

3.4 Consequences of not providing data

If the required data referred to in sections 3.2 a) and b) is not provided, the customer relationship cannot be established or continued. If sufficient identification data cannot be obtained at a property viewing, the individual may not be permitted to attend.

4. Customer Register — Data Content

The assignment diary may contain the following categories of data:

• Basic details: full name, address, language preference
• Personal identity code and, where applicable, company registration number for reliable identification
• Invoicing and debt collection data
• Customer and contractual data: services provided, purchase offer, transaction details, brokerage commission
• Consent records and marketing opt-outs
• Areas of interest and other information provided by the customer
• Complaints and their handling
• Tenant credit information for assessing ability to pay rent

Anti-money laundering data additionally includes:

• Name, date of birth and personal identity code, and the same for any representative
• Legal entity's full name, registration number and registering authority
• Details of beneficial owners
• Details of the identity document used for verification, or a copy thereof
• Information on the customer's activities, business nature, financial standing and source of funds
• Politically Exposed Person (PEP) data where required
• Nationality and travel document details for foreign customers without a Finnish personal identity code

5. Marketing Register — Data Content

The marketing register may contain the following data:

• Basic details: name, email address, phone number
• Property preferences: property types, price range, preferred locations, and other information provided by the customer
• Marketing consents and opt-outs
• Marketing actions taken and information provided in connection with them

The List newsletter

The List is Lapland LKV's email newsletter featuring off-market properties, market insights and topical updates. Subscribing is based entirely on freely given consent. Subscribers provide their name and email address. You may unsubscribe at any time via the unsubscribe link in any newsletter, or by contacting us at [email protected]. Your details will be removed from the subscriber list promptly upon cancellation.

6. Website Data Processing

Contact forms

When you contact us via the website contact form, email or WhatsApp, we collect the information you provide: name, email address, phone number and message. This data is used solely to respond to your enquiry. The legal basis is the preparation of a contract or the legitimate interests of the controller.

Google Analytics 4

We use Google Analytics 4 to analyse site traffic. Analytics is loaded only if you have accepted analytics cookies via the cookie banner.

• IP addresses are anonymised before storage
• Data is not used for advertising
• Data is not shared with third parties
• You can prevent analytics by declining analytics cookies

You can change your cookie preferences at any time by clearing the browser's local storage key laplandlkv_cookie_consent or by using your browser's cookie management tools.

Cookies

This website uses cookies and browser local storage only to remember your cookie preferences. Analytics cookies are set only with your explicit consent.

7. Retention Periods

• Assignment diary: 10 years from the end of the assignment
• Anti-money laundering data: 5 years — longer if required for criminal investigation or legal proceedings, to the extent required by law
• Other customer data: for the duration of the active customer relationship; a relationship is considered inactive when more than one year has passed since the last contact
• The List subscriber data: for the duration of the subscription — deleted promptly upon cancellation
• Consent-based data: deleted upon withdrawal of consent, unless retention is required on another legal basis

8. Regular Sources of Data

Personal data is collected primarily from the customer themselves in connection with assignment agreements, purchase or rental offers, property viewings and other client interactions, or when the customer contacts us directly.

Data may also be collected and updated from property management companies, the Population Information System, other public registers, and credit information registers.

9. Disclosure of Data

The controller may disclose personal data within the limits permitted by applicable law and as required to fulfil agreements between the parties. Data may be disclosed to:

• The Regional State Administrative Agency and other authorities
• Banks and other parties to a transaction
• Property management companies and the National Land Survey of Finland
• Advisory service providers (law firms, industry organisations)
• The Finnish Real Estate Federation (KVKL) for transaction price data submitted to the Price Monitoring Service (HSP) — HSP privacy policy

Data is not routinely transferred outside the EU or EEA. Transfers may however occur in connection with cloud services (OneDrive, iCloud, Dropbox), in which case an adequate level of protection is ensured through contractual safeguards or a European Commission adequacy decision.

Providers of property management systems, marketing platforms and property listing portals may process data on behalf of the controller under appropriate data processing agreements.

10. Register Security

Access to the register requires a personal user account. Only those employees whose duties require it have access to personal data. Data is protected by firewalls, passwords and other technical measures. Appropriate data processing agreements are in place with all processors.

11. Your Rights

11.1 Right of access and data portability

You have the right to know what personal data we hold about you. Requests must be submitted in writing or by email to [email protected]. We will provide the information within 30 days. You also have the right to receive data you have provided in a machine-readable format for transfer to another controller.

Please note: customer identification data collected under the Anti-Money Laundering Act cannot be disclosed to the customer for inspection (Anti-Money Laundering Act, Chapter 4, Section 3), but the Data Protection Ombudsman may verify the lawfulness of its processing at your request.

11.2 Right to rectification

You have the right to request the correction of inaccurate personal data we hold about you.

11.3 Right to object, restriction and erasure

You have the right to object to the processing of your data for direct marketing, distance selling and market or opinion research purposes, to request that processing be restricted, and to request the erasure of data stored for those purposes.

11.4 Right to withdraw consent

Where processing is based on your consent, you may withdraw it at any time by contacting [email protected]. Upon withdrawal, all data that is not required to be retained under law or another basis described in this notice will be deleted.

11.5 How to exercise your rights

All access, rectification or other requests can be submitted by email: [email protected]

12. Profiling and Automated Decision-Making

Lapland LKV Oy does not use personal data for profiling or automated decision-making that produces legal or similarly significant effects.

13. Supervisory Authority

You always have the right to lodge a complaint with the supervisory authority if you consider that the processing of your personal data infringes data protection legislation. In Finland, the supervisory authority is the Data Protection Ombudsman: www.tietosuoja.fi/en

14. Changes to This Notice

This privacy notice is updated as necessary when legislation or our practices change. The current version is always available at laplandlkv.com/en/privacy.html. This notice was last updated in May 2026.