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 request access, correction, deletion, restriction, objection, or withdraw consent. 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.