Helsinki Fashion Week’s mission is to develop a method for building sustainable online cyber environments
and to provide individual users with personalized user experience of the currently available version of our
Digital Village platform while creating digital sustainability standards by comparing physical events and
activities with digital ones conducted on our platform as well as to provide sustainable designers an opportunity
to promote their digital design items to users.
Central to this objective is the compliance with applicable data protection laws and regulations as well as
transparency about the collection, use and sharing of personal data related to the provision of our services.
“our”) relating to the visitors, registered users and/or their authorized representatives, initial designers as well
as other stakeholders and business partners of HFW (aforementioned data subjects are hereinafter collectively
referred to as “User” or “you”) of or related to our digitalvillage.io website, browser and/or mobile application
enabled HFW Digital Village platform, associated intermediary e-commerce shop for purchasing services as
well as any other related online or off-site services provided by us (hereinafter collectively referred to as
may be private individuals, authorized representatives of initial designers and/or authorized representatives of
our customer organizations or business partners.
data in accordance with the information obligations set in Articles 13 and 14 of the General Data Protection
Regulation 2016/679/EU (“GDPR”).
data, including collecting, handling, storing, accessing, using, transferring and disposing of information.
responsible for, the privacy and data processing practices of any third parties.
otherwise. The current version can be found on our website digitalvillage.io. We will not make substantial
Name: Helsinki Fashion Week Oy
Business ID: 3016184-1
Correspondence address: c/o Nordic Fashion Week ry, Myyrmäenraitti 2, 01600 Vantaa, Finland
PERSONAL DATA PROCESSED AND SOURCES OF DATA
We collect five types of information concerning the Users: (i) User data; (ii) Transaction data; and (iii) Analytics
User data is received directly from the Users in connection with the registration to and use of the Services.
This refers to all personal data about you generated through your use of the Services, including our voice
recognition functionality embedded with interactive 3D object that will morph/change according your words
spoken through your internal device microphone, provided you have granted us access to your internal device
microphone as part of the provision of the Services. User data further includes personal data processed by us
in relation to representatives of initial designers and/or our other stakeholders or business partners use of the
Furthermore, our Services automatically utilize an external blockchain process available through
https://universalprofile.cloud and operated by our partner Lukso Blockchain GmbH. The purpose of the
blockchain process is to create a smart contract based account for each individual user interested in
purchasing digital clothing items from the initial designers through the Services as well as to validate the User’s
claim for such digital clothing item. Likewise, a smart contract based account shall be created in the blockchain
process for initial designers for the purposes of authenticating the issuance of digital clothing items from the
initial designer to the individual User.
Even though the smart contract based blockchain accounts are primarily based on anonymity with no
identifiable information attached related to the User it may, however, in certain situations be possible to identify
individuals holders of smart contract based blockchain accounts by combining or linking other data hold by the
Users and/or Lukso Blockchain GmbH. In such situations, blockchain-related data shall also be considered to
be personal data under applicable laws and we will treat the combined data as personal data, and process
available at https://universalprofile.cloud/privacy.
Transaction data concerning payment transactions and credit card information is received directly from the
User via third party payment service provider, whenever Users are placing orders and executing payments for
services associated with digital design items available through the Services.
Analytics data is collected automatically as you use the Services. Analytics data is primarily collected in an
aggregated form meaning that the identification of single individual from the aggregated data sets is not usually
possible. However, in certain situations it may be possible to recognize individuals from analytics data, either
alone or when combined or linked with user data. In such situations, analytics data shall also be considered to
be personal data under applicable laws and we will treat the combined data as personal data, and process
HFW may process the following categories of personal data:
– full name;
– e-mail address;
– voice data (where applicable);
– feedback and ratings concerning the Services;
– data related to blockchain accounts, such as private keys associated with smart contracts or
ownership status of digital clothing items (where applicable);
– city and postal code; – marketing consent and/or prohibition; – records of your interaction with our customer service, such as phone records; and – other information you choose to provide us through our correspondence concerning the Services.
– payment method and payment card number (depending on the payment method);
– transaction time;
– delivery address;
– account number (depending on the payment method);
– billing details;
– details for successful or interrupted purchases (order number, merchant, price); and
– details for possible return payment (where applicable).
– IP address;
– device type, number and model (computer, phone or tablet);
– advertisement and visitor identifier for your device;
– operating system;
– time of visit and time zone;
– browser type and version;
– language settings and preferences; and
– metadata relating to the use of the Services.
The use of our Services does not depend on the provision of any special categories of personal data under
GDPR article 9(1). To the extent that the User voluntarily decides to provide such data to the Services, we
shall in addition to our legitimate interest primarily rely on articles 9(2)(a), 9(2)(e) and/or 9(2)(f) of the GDPR.
Your personal information shall not be processed for the purposes of automated decision-making, including
COOKIES AND ANALYTICS TOOLS
We use various technologies to collect and store Analytics Data and other information when Users visit our
Services, including cookies.
Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites
and facilitate the use of our Services and to create aggregate information of our visitors. This helps us to
improve our Services and better serve our Users. The cookies will not harm your device or files. We use
cookies to tailor our Services and the information we provide in accordance with the individual interests of our
Information collected by cookies is not, in principle, associated with personally identifiable information but some
information collected by Cookies may be indirectly associated with personally identifiable information relating
to identifiable person. Such information includes User’s IP address and unique device ID.
What cookies do we use and how are they used
Necessary cookies are essential to ensure the availability of our Services. For example, necessary cookies
pre-load certain procedures of our Services in order to speed up the website’s loading and register a unique
ID for the website’s visitor in order to recognize them again later.
We use analytics cookies to improve the operation of the Services. Analytics cookies collect information,
among other things, on how Users use the Services and how Users navigate between the various tabs on the
Services. In addition, analytics cookies are used to collect statistics and technical information about Users’
devices and to maintain a session when a User visits another website during the session.
We use marketing cookies in our Services. These cookies help us customize our marketing and provide Users
with more personalized services in the future. We use marketing Cookies to collect information about for
example User behavior and preferences on our Services. We use this information to optimize our Services
and to better target content and advertising to Users. In addition, third-party advertisers can for example use
marketing cookies to target Users with more relevant and real-time ads.
First and Third-Party Cookies
The Cookies we use can also be divided into first party cookies and third-party cookies. First-party cookies are
provided by HFW and we manage them ourselves – their functionalities cannot be influenced by third parties.
Third-party cookies are provided and managed through the Services by the service providers we use.
We use session cookies and persistent cookies. Session cookies last only for the duration of the session on
our Services and are deleted automatically when the browser is closed. Persistent cookies stay in your browser
until they are removed, or until they expire. Therefore, persistent cookies are not deleted automatically when
you close the browser or leave the Services.
How do you control cookies
If you do not wish to have cookies stored on your device, you may choose to set your web browser to refuse
cookies or delete the cookies stored by the Services. Most web browsers allow you to block cookies by default
and disabling cookies does not prevent you from accessing our website. However, you must have enabled
cookies when you log into our Services. You can re-enable cookies at any time.
For example, the following links provide information on how to adjust the cookie setting on some popular
We also use Google Analytics to compile Analytics Data and reports on visitor usage. For an overview of
Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following
browser add-on tool: Google Analytics opt-out add-on.
PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING
Purposes of processing
To provide our Services and carry out our contractual obligations (legal ground: performance of a contract and
We process personal data to be able to offer the Services to our Users and to run and maintain our business.
Personal data may be processed in order to carry out our contractual obligations towards the User or towards
the organization the User represents. We may use the data for example to offer essential functionalities of the
Services and to provide access to the Services.
For our legal obligations (legal ground: compliance with a legal obligation)
We process personal data to enable us to administer and fulfil our obligations under law. This includes data
processed for complying with our bookkeeping obligations and providing information to relevant authorities,
such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling and legal processes. We may also process data
for the prevention of fraud, misuse of our Services and for data, system and network security.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Services and for
informing Users of changes in our Services. We may also process personal data to market our Services, for
example in the form of sending newsletters.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding the use of the Services to improve the quality of our service, for
example by analysing any trends in the use of our Services. Where possible, we will do this using only
aggregated, non-personally identifiable data.
Legitimate grounds for processing
We primarily process personal data of Users on a contractual basis. For Users acting as representatives of
our initial designers and/or customer or partner organizations, personal data is primarily processed based on
our legitimate interest whilst fulfilling our contractual obligations towards the organisations they represent.
We may also process personal data based on our legitimate interests, for example in connection with analytics
and marketing. When choosing to use your data on the basis of our legitimate interests, we weigh our own
interests against your right to privacy.
In certain cases Users may be requested to grant their consent for the processing of personal data. In this
event, the legal ground for such processing is your consent. You may withdraw your consent at any time free
of charge and without providing a reason.
HFW stores Users’ personal data primarily within the European Economic Area. However, we have service
providers in several geographical locations. As such, we, and our service providers may transfer personal data
to, or access it in, jurisdictions outside the European Economic Area or outside of the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the
jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to
countries outside of the European Economic Area through a series of agreements with our service providers
based on the Standard Contractual Clauses or other similar arrangements.
You may receive further information on international transfers by contacting us using the above-mentioned
PERSONAL DATA RECIPIENTS
We do not share personal data with third parties outside of our organization unless one of the following
To the extent that third parties need access to personal data to perform the Services, we have taken
appropriate contractual and organisational measures to ensure that personal data are processed exclusively
and regulations, including but not limited to appropriate confidentiality undertakings.
For legal reasons
We may share personal data with third parties outside our organization if we have a good-faith belief that
access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation,
and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii)
protect the interests, properties or safety of HFW, our Users or the public in accordance with the law. When
possible, we will inform Users about such transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services for us (including facilities
responsible for manufacturing your order, logistics providers responsible for the delivery of your order as well
as providers of other relevant data storage, sales, marketing and support services).
Further we may share your personal data with authorized providers of bookkeeping and/or payment services.
Our agreements with our authorized service providers include commitments that the service providers agree
to limit their use of personal data and to comply with privacy and security standards at least as stringent as the
For other legitimate reasons
If HFW is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party
involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all
soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside of our organization for other reasons than the ones
mentioned before, when we have the User’s explicit consent to do so. You have the right to withdraw this
consent at all times free of charge and without providing a reason.
Anonymous and aggregate data
Please note that the above principles regarding disclosure of data apply to personal data. We may disclose
aggregate data to third parties, but solely to the extent such aggregate data is in anonymous format and does
not include any personal data.
HFW does not store personal data longer than is legally permitted and necessary for the purposes of providing
the Services or the relevant parts thereof. The storage period depends on the nature of the information and
the purposes of processing. The maximum period may therefore vary per use.
The majority of Registration and/or User Data shall be deleted within sixty (60) days following the removal of
a User’s account to the Services. We may, however, retain such User Data for longer period provided we are
subject to a legal requirement to retain such data or we have a legal mandate in doing so, such as for the
purposes of establishment, exercise or defence of legal claims or in relation to our bookkeeping obligations.
Transaction Data shall be stored in accordance with the applicable bookkeeping and limited liability company
legislation, in most cases between six (6) to ten (10) years following the respective transaction.
We will store Analytics Data relating to the Service no longer than reasonably necessary and in any case no
longer than twelve (12) months.
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what
personal data we have collected and what personal data we process regarding you.
Right to withdraw consent
In case the processing of your personal data is based on a consent you have granted to us, you may withdraw
the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use our
Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or
completed by contacting us. You may also directly update some of your User Data through your Service
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless
we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data are processed for other purposes
than necessary for the performance of the Services or for compliance with a legal obligation. If you object to
the further processing of your personal data, this may lead to fewer possibilities to use the our Service.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification
or objection requests are pending and/or when we do not have legitimate grounds to process your data. This
may however lead to fewer possibilities to use our Service.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to
independently transmit those data to a third party.
How to use the rights
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out
above. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to
prohibit us from using your personal data for direct marketing purposes, market research and profiling made
for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe
possibility offered in connection with any direct marketing messages.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we
collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality,
integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for
Should despite of the security measures, a security breach occur that is likely to have negative effects on your
privacy, we will inform you and other affected parties, as well as relevant authorities when required by
applicable data protection laws, about the breach as soon as possible.
LODGING A COMPLAINT
In case you consider our processing of personal data to be inconsistent with the applicable data protection
laws, a complaint may be lodged with the local supervisory authority for data protection.
In Finland, the local supervisory authority is the Data Protection Ombudsman (www.tietosuoja.fi).