UPM SOS – Privacy Policy

  1. Data Controller

UPM-Kymmene Oyj

Alvar Aallon katu 1

00101 Helsinki, Finland

Phone: +358 204 15 111

Website: https://www.upm.com

Email for privacy matters: privacy@upm.com

UPM acts as the data controller and determines the purposes and legal basis for processing personal data collected through the UPM SOS application.

  1. Use of External Data Processors

UPM may use external service providers to process personal data on its behalf. These processors act solely according to UPM’s documented instructions and do not process data for independent purposes.

  1. Purpose and Legal Basis for Processing Personal Data

Personal data is processed for employee and contractor safety, lone-worker monitoring, SOS emergency alerts, monitoring connection status, maintaining application functionality, fulfilling legal obligations, and improving service quality.

Limited usage statistics are also processed to understand general application usage and improve performance.

  1. Categories of Personal Data Processed

Identification data, location data (only latest location retained), SOS event data, technical data (device & network status), and limited usage statistics (app opens, key feature usage).

  1. Background Location Collection

Location is collected continuously while monitoring is active. Only the latest location is retained. If an SOS alert is triggered, the location at that moment is stored. No movement history is stored.

  1. Retention of Personal Data

Latest location is overwritten continuously. SOS alerts are retained per UPM requirements. Identification and contract-related data follow statutory retention. Usage statistics are stored only as long as needed.

  1. Disclosure of Personal Data

Data may be disclosed to authorized UPM personnel, emergency responders, and authorities when required by law. No marketing disclosure.

  1. Transfers Outside EU/EEA

If transfers occur, UPM ensures GDPR-compliant safeguards.

  1. Protection of Personal Data

UPM uses appropriate technical and organizational measures. Only authorized personnel have access.

  1. Rights of the Data Subject

Users may exercise their rights under applicable data protection legislation, including rights of access, rectification, restriction, objection, and other applicable rights.

Contact: privacy@upm.com

  1. Complaints

Complaints may be filed with the Office of the Data Protection Ombudsman.

  1. Cookies

UPM’s general cookie practices apply: https://privacy.upm.com

  1. Marketing

The UPM SOS application is not used for advertising.