S-Group's co-op member and customer register

Updated 28.5.2024 with the following changes:

  • Specified personal data processing based on a legitimate interest in section 4.
    • The storage period for purchase data is the year of the purchase + 10 years as of 28 May 2024 
    • Customer data is utilised for creating customer categories and profiles for a maximum of the year of entry + 10 years 
  • Added information to chapter 6 regarding service providers that process personal data on our behalf 
  • Clarified the structure of the privacy notice to be easier to understand 

S GROUP’S CO-OP MEMBER AND CUSTOMER REGISTER PRIVACY NOTICE (28 May 2024 onwards)  

1. Data controller 

SOK Corporation 
P.O. Box 1, FI-00088 S-RYHMÄ, Finland 
S Group’s co-op member service: +358 10 76 5858 
Street address: Fleminginkatu 34, FI-00510 Helsinki, Finland 
Business ID 0116323–1 

2. Contact details of the data protection officer 

3. The personal data processed 

We process your personal data if your belong to any of the following customer groups:  

  • Co-op members: persons who are or have been members of a cooperative 
  • Members of a co-op member household: persons who belong to or have belonged to a co-op member household but are not necessarily members of the cooperative themselves. 
  • Other customers: people who are not co-op members or members of a co-op member household. 

We process the types of data listed in the table below. The types are specified in more detail below the table.  

 Co-op member Member of a co-op member household Other customer  
Basic data 
Contact us 
Employee information   
Cooperatives’ membership information  
Invoicing Bonus partners  
Information about the co-op member household  
Deposit account for benefits payable in cash  
S-Etukortti card  
Credentials 
Customer groups 
Customer categorisation and profiling information XXX
Subscriptions, services used and data concerning the use of services 
Authorisations and prohibitions, i.e., your consents and objections to personal data processing 
Data on paid benefits and received discounts X
Detailed purchase data XXX
Customer’s digital footprint 
Information regarding customer belonging to a target group XXX
Online shopping information 
Customer feedback 
Survey responses based on consent 

Information used for the provision of co-op member benefits:  

  • basic information 
  • contact information 
  • cooperative’s membership information 
  • co-op member household information 
  • deposit account for benefits payable in cash 
  • S-Etukortti card 
  • invoicing Bonus partners 
  • data on paid benefits and received discounts 

Basic information:  

  • first and last name, social security code, date of birth, gender, language, order of non-disclosure of information for personal safety reasons  
  • starting date and validity period of customer relationship  
  • information of prohibitions and updates from the Population Information System and service providers  

Contact information:  

  • permanent postal address, temporary postal address, domicile, mobile phone, other phone number, email  

Employee information:  

  • information about S Group employee discount entitlement  

Cooperatives’ membership information:  

  • membership cooperative, member identification number, member status, starting and ending date of membership, place of affiliation  
  • status of co-op contribution, paid co-op contribution, date of completing co-op contribution and payment transactions  
  • information on interest paid on the contribution, information on the return of the surplus paid  

Invoicing Bonus partners:  

  • registrations at Bonus partner companies, validity periods  

Information about the co-op member household:  

  • main member of the co-op member household, persons belonging to the same co-op member household as the main member  

Deposit account for benefits payable in cash:  

  • account number, validity period and account type for the payment account for benefits  

S-Etukortti cards, S-Bank Private Visa cards:  

  • card number, card type, validity period, reason for cancellation  
  • information on to which co-op member household the Bonus purchases are connected  
  • information on the membership of which cooperative the card subscription is based  
  • information on a card being added to Apple Wallet 

User identification:  

  • S User Account, customer code  

Customer groups:  

  • customer groupings of the customer (such as groupings connected to the use of digital services, main Sokos store and customer class, grocery store and ABC store segment)  
  • information about the customer’s participation in support groups of associations or other groups  

Customer categorisation and profiling information: 

  • categories and profiles linked to the customer 
  • student status 

Subscriptions, services in use and information concerning the use of services:  

  • information on services subscribed to / in use (e.g. S User Account, S-mobiili)  
  • information entered by the customer, data produced by the use of services  
  • information of the data controller’s communication with the customer aimed at maintaining the customer relationship  

Authorisations and prohibitions, i.e., your consents and objections to personal data processing:  

  • email marketing permit, mobile device marketing permit (mobile phones)  
  • authorisations and prohibitions, such as notification permits, administered in S-mobiili and ABC-mobiili mobile apps.  
  • cookie choices  
  • direct marketing ban, phone marketing ban, Puhelin-Robinson phone ban, Posti-Robinson mail ban, prohibition of surveys  
  • prohibition on separate direct mail, prohibition to send notifications  
  • prohibition of processing purchase data in more detail than the total sum of the receipt, prohibition of analytics and customer grouping, prohibition of targeted advertising on channels outside S Group  

Data on paid benefits and data on received discounts:  

  • number of the S-Etukortti card used for purchases entitling one to co-op member benefits or the member/customer number, date of purchase, time, place of purchase, manner in which the card was used, purchase data in the receipt sum level 
  • paid Bonus, Tankkausbonus refuelling bonus and payment method benefits  
  • co-op price benefits received, personnel discounts received  
  • online warranty receipts and online receipts  

Detailed purchase data 

  • information about purchases at the product level   

Customer’s digital footprint  

  • website user data and mobile service user data   
  • information of the identified use of digital services (e.g., online and mobile services)  

Information regarding customer belonging to a target group 

  • information regarding customer belonging to a target group for electronic direct marketing messages or mobile services 

Online shopping information  

  • data concerning shopping carts as well as order and delivery data, such as order number, payment information, delivery method and destination; however, more detailed information on deliveries from online grocery stores, such as additional delivery information, is only included in the order and delivery register of the co-operative that delivers the order, and not a part of S Group’s Co-op Member and Customer Register.  
  • information provided by the user about their preferences  
  • products marked as favourites by the customer  
  • contact history and phone call recordings concerning online store service, orders and deliveries  

Customer feedback  

  • feedback provided on a feedback form and the feedback functionality in the S-mobiili app.  

Survey responses based on consent  

  • responses given in a survey when the respondent has given their explicit consent to the processing of responses as personal data  

4. Bases for the processing of personal data, purposes of use and storage periods 

S Group’s co-op member scheme requires us to process the personal data of co-op members and other people belonging to co-op member households. Personal data is required for purposes such as the provision of services and benefits in the co-op member scheme, managing customer relationships and maintaining the membership lists of cooperatives. Customer data allows us to also offer S Group’s customers relevant services and benefits that meet their individual needs as closely as possible, as well as produce targeted and personalised content and advertising. 

Some of our services, such as S User Accounts and online stores, can also be used without co-op membership or belonging to a co-op member household. The data of such customers is processed for purposes such as the provision of the online store service or other digital service used by the customer, processing customer feedback and other management of customer relationships. 

We also utilise customer data in the planning and development of S Group’s business operations. For this purpose, we may use personal data for purposes such as analysis and profiling, or to carry out surveys or market studies. We may also process personal data for marketing purposes of our partners and organisations that belong to S Group at any given time. The term “S Group” refers to the cooperatives and the SOK Group together with its subsidiaries and associated companies. The term “partner”, meanwhile, refers to companies that grant Bonus and/or benefits to co-op members, for example, and companies that cooperate with S Group, implement joint marketing or buy media visibility from S Group. 

The storage periods of data vary based on the purpose for their use. The storage of an individual data item in the register lasts until the end of the longest storage period set for said data item, but the data may be used for each purpose only for the time indicated in the table below. Certain data related to the management of customer relationships are stored for the entire duration of the co-op membership or membership in a co-op member household. Meanwhile, detailed purchase data is stored for a maximum period consisting of the year of the purchase and the ten years following it. 

Personal data is generally erased within six months of the termination of a customer relationship. However, we store some data for a longer period of time. This includes data related to membership in a cooperative and data related to the payment of membership fees. This information is stored for a period consisting of the year of the monetary transaction and six years following it. A customer relationship may end due to resignation or termination, or when the customer leaves a co-op member household. 

Data related to the S User Account is deleted when the customer relationship ends. S User Account customer relationship is considered to end when the customer requests the account to be deleted. 

The tables below provide more detailed information regarding what purposes the personal data in the register are used for, and how long the data is stored. 

4.1 Basis for processing: contract 

When joining as a co-op member or joining a co-op member household, you must accept the rules of the co-op membership scheme. Co-op members must also accept the bylaws of the co-op when joining. Customers using our digital services must accept the terms and conditions of the services, such as the S User Account, Collect and Scan service or online stores.   

The provision of the co-op membership scheme and digital services requires us to process our customers’ personal data for the purposes indicated below. 

Purpose of use: Data processed: Processing period: 
Member administration of the cooperative - Basic data 
- Contact information 
- Cooperatives’ membership information 
- Deposit account for benefits payable in cash 
End of the calendar year during which the co-op membership was terminated + 6 years 
Organisation of elections- Basic data 
- Contact information 
- Cooperatives’ membership information 
- Permissions and prohibitions 
Throughout the validity of the membership 
Information on interest paid on the membership fee, information on the return of the surplus paid - Basic data 
- Cooperatives’ membership information 
- Deposit account for benefits payable in cash 
End of the calendar year of the last payment transaction after the co-op membership was terminated + 6 years 
Calculation and payment of co-op member benefits such as Bonus, payment method-related benefit and Refuelling Bonus - Information used for the provision of co-op member benefits 
- Purchase data 
5 years 
Provision of services and benefits (such as S-mobiili, My Purchases, online stores) 
- Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Product-level purchase data 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
Throughout the customer relationship + 6 years after the termination of the customer relationship. For S User Account agreements, throughout the validity of the agreement. Detailed purchase data: year of the purchase + 10 years 
Electronic cash receipt, warranty receipts - Image of the receipt Electronic cash receipt: 10 years from the purchase transaction Warranty receipt: 10 years from the purchase transaction or upon request by the customer 
Co-op member and customer communication - Basic data 
- Contact information 
- Purchase data 
Throughout the customer relationship + 6 years after the termination of the customer relationship. For S User Account agreements, throughout the validity of the agreement. 
Targeted advertising, mail - Basic data 
- Contact information 
Validity of the co-op membership agreement + 6 months after the termination of the agreement 
Maintenance of user data for digital services - S User Account data 
- Basic data 
- Contact information (confirmations) 
- Permissions and prohibitions 
- Customer’s digital footprint 
Throughout the validity of the S User Account agreement 
Defence against legal claims - Data required to defend against claims The data is stored until the matter has been settled 
Collect and Scan - First name 
- S-Etukortti card’s technical identifier 
- Detailed purchase data 
2 years 

4.2 Basis for processing: consent 

Consent is a key basis for processing that offers you the opportunity to tell us that you want your personal data to be processed for a specific purpose. We separately request consent for each of the purposes of use listed below. Providing consent always requires you to take action, such as checking a box regarding providing consent. You can cancel consent regarding the processing of your personal data at any time. 

Purpose of use: Data processed: Processing period: 
Direct marketing using electronic means (e-mail or SMS, for example) - Information regarding customer belonging to a target group 
- Contact information 
- Permissions and prohibitions 
2 years 
Sending notifications regarding mobile services - Information regarding customer belonging to a target group 
- Permissions and prohibitions 
- Subscriptions, services used and data concerning the use of services 
2 years 
Targeting marketing and advertising on the basis of mobile device IDs - Permissions and prohibitions 
- Subscriptions, services used and data concerning the use of services 
- Customer’s digital footprint 
2 years 
Management of a customer relationship - Basic data  
- S User Account  
- Subscriptions, services used and data concerning the use of services  
- Permissions and prohibitions  
- Detailed purchase data 
Throughout the customer relationship + 6 years after the termination of the customer relationship. For S User Account agreements, throughout the validity of the agreement. Detailed purchase data: year of the purchase + 10 years. 
Disclosing data for partners, for example, to get Bonus or other co-op member benefits - Basic data 
- Cooperatives’ membership information 
- Personnel and discount entitlement data 
- Permissions and prohibitions 
Throughout the validity of the co-op membership agreement 
Disclosing data to third parties outside S Group or for external purposes, such as scientific research - Basic data 
- Cooperatives’ membership information 
- Personnel and discount entitlement data 
- Detailed purchase data 
Throughout the customer relationship + 6 years after the termination of the customer relationship. Detailed purchase data: year of the purchase + 10 years 
Processing of digital footprint data based on cookie choices - Customer’s digital footprint Two years. However, no longer than the validity period of the S User Account agreement. 
Combining responses provided to studies and surveys with the customer’s data - Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
- Detailed purchase data 
2 years 
Maintenance of student status - Email address of university Throughout the validity of the student status. The university email address provided by the customer is immediately deleted as soon as the student status has been confirmed. 

4.3 Basis for processing: legitimate interest 

Description of the data controller’s legitimate interest 

We have assessed the legitimate interest on the basis that S Group’s operations are cooperative in nature and S Group is owned by its co-op members. Co-op membership of S Group is optional and the membership scheme is open to anyone. The purpose of S Group's operations is to provide customer-oriented, meaningful and cost-effective services and benefits to co-op members, and thus promote financial wellbeing of co-op members. The analysing of purchasing behaviour and the calculation of customer profiles, as well as related direct marketing and content targeting, opinion polls and market surveys are key ways to achieve this goal. We ensure that the processing based on a legitimate interest is correctly proportioned to your interests and in compliance with your reasonable expectations.  

You have the right to object to the processing of personal data based on a legitimate interest and refuse to allow S Group to process purchase data (apart from the sum total of your receipts), analytics and customer grouping, opinion polls and market surveys, direct marketing and the targeting of advertising in channels outside S Group. You can manage your data and restrict their use in S-mobiili’s “Minä” (“Me”) section or by signing in to your S User Account in any of S Group’s online services. 

Purpose of use: Data processed: Processing period: 
S Group’s customer-oriented planning and development of business operations - Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Detailed purchase data 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
- Customer categorisation and profiling information 
Year of entry + 10 years 
Conducting surveys and market research - Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Detailed purchase data 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
- Customer categorisation and profiling information 
2 years 
Forming customer categories and profiles for developing business operations, and for conducting and targeting advertising and marketing 
- Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Detailed purchase data 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
Year of entry + 10 years
Processing of customer feedback - Basic data 
- Contact information 
- Content of feedback or review 
2 years 
Direct marketing by telephone - Basic data 
- Permissions and prohibitions 
Year of entry + 7 years
Targeting and personalisation of content in digital channels - Basic data 
- Permissions and prohibitions 
- Customer’s purchase data 
- Customer categorisation and profiling data 
- Customer’s digital footprint 
Year of entry + 10 years 
Conducting and targeting marketing in S Group’s digital channels - Basic data 
- Permissions and prohibitions 
- Customer’s purchase data 
- Customer categorisation and profiling data 
- Customer’s digital footprint 
Year of entry + 10 years 
Provision of marketing services to S Group’s partners - Basic data 
- Permissions and prohibitions 
- Customer’s purchase data 
- Customer categorisation and profiling data 
- Customer’s digital footprint 
Year of entry + 10 years 
Profiling and inspections made in the Collect and Scan service - First name 
- S-Etukortti card 
2 years 
Identification and investigation of suspected misconduct, and monitoring of compliance with S Group’s membership scheme - Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Detailed purchase data 
- Customer’s digital footprint 
- Online shopping information 
- Personnel and discount entitlement data 
2 years 
Provision of customer service and quality assurance - Information used for the provision of co-op member benefits 
- User ID, S User Account 
- Customer groups 
- Subscriptions, services used and data concerning the use of services 
- Permissions and prohibitions 
- Detailed purchase data 
- Online store phone call recordings 
2 years 
Provision of personnel discounts   - Basic data 
- Contact information 
- Personnel and discount entitlement data 
- Co-op member household information 
Throughout the S Group employee’s employment relationship, and two years after its termination 
Handling of product requests - Form data provided by customer 
- Telephone number 
30 days 
Defending against legal claims - Data required to defend against claims The data is stored until the matter has been settled 
Monitoring and collection of receivables - Basic data 
- Contact information 
- Online shopping information 
Throughout the collection process 

4.4 Basis for processing: statutory obligation 

Compliance with our statutory obligations requires the processing of your personal data for the purposes indicated below.  

Purpose of use: Data processed: Processing period: 
Member administration of the cooperative  - Basic data 
- Contact information 
- Cooperatives’ membership information 
- Deposit account for benefits payable in cash 
- Customer groups 
End of the calendar year of the last payment transaction after the co-op membership was terminated + 6 years 
Submitting the necessary information to the Tax Administration in accordance with fiscal legislation.  - Basic data 
- Cooperatives’ membership information 

End of the calendar year of the last payment transaction after the co-op membership was terminated + 6 years 
Statutory information requests by authorities, and responses to such requests  - All information related to statutory requests by authorities 2 years  
Provision and storage of accounting - Membership fee and other data recorded in accounting 

Until the end of the calendar year + 6 years 

5. Data sources 

We obtain data from the agreement you sign when you join S Group’s co-op membership scheme, and from you personally during the customer relationship by phone, websites, email or other similar methods or based on your use of services.   

Updates of name, address and mobile phone data, as well as information about death, can also be received from authorities or companies providing updating services. Information on Robinson marketing prohibitions for telemarketing/direct marketing by post comes from Suomen Asiakkuusmarkkinointiliitto ry. Information of employment in the S Group and information of the right to receive the personnel discount come from S Group’s employee registers.  

We obtain data on your use of the S-Etukortti card and any transactions you perform when identified online from those organisations that belong to S Group's co-op member scheme and from partners that grant the S Group Bonus. In addition, we might obtain information from organisations belonging to S Group and partners belonging to the co-op membership scheme that utilise the S-Etukortti card or other credentials to verify your identity in their services.  

We obtain limited personal data also on SOK and S-Bank’s shared customers from our joint register. For more information, see section 12 of this notice.  

6. Recipients of personal data 

We disclose information to the Tax Administration about any interest paid to co-op members on their co-op contribution and return on capital paid to resigned members. We can also disclose information within the limits allowed and required by valid legislation, such as when answering authorities’ requests for information.  

We disclose information about your online groceries purchases to a co-operative in order for them to deliver your order.   

We disclose the delivery information of your order to Posti or other similar operators such as PostNord to deliver products you have purchased. The disclosure of the information is based on the agreement concluded as part of the product purchase.  

With your consent, we disclose information about your co-op membership to a partner that grants S Group Bonus.  

With your consent, we may disclose your data to third parties outside S Group or for external purposes, such as scientific research.  

Your personal data associated with customer feedback is received by S Group’s internal customer service teams, as well as product specialists participating in the processing of your feedback.  

Your demographic data and data about you belonging to a customer group can also be processed with other data in SOK’s customer registers in order to develop business operations in analytics and reporting for each customer group. This data can also be used for improving the quality and targeting of customer service, for example, when you book a room in one of S Group's Sokos Hotels.  

In certain situations, we employ subcontractors who process data on our request and on our behalf. The subcontractors we use carry out services on our behalf, such as IT services, IT system maintenance services, customer communications, marketing and customer research campaigns, and delivery services for our online stores. 

We disclose limited personal data also on SOK and S-Bank’s shared customers to our joint register. For more information, see section 12 of this notice.  

7. Transfer of personal data to third countries or international organisations and data protection safeguards used 

We use subcontractors to process personal data and the data is transferred in a limited way outside the European Union (EU) or the European Economic Area (EEA) for the purposes of service provision, technical administration and support. We can perform these types of transfers if the European Commission has decided that the target country or organisation has a sufficient level of data protection or we can otherwise ensure a sufficient level of protection of the personal data in accordance with applicable legislation, such as by using standard contractual clauses approved by the European Commission. You can read more about the standard contractual clauses approved by the European Commission here. 

We require our subcontractors to agree to follow the data protection and information security requirements of legislation and SOK.  

8. Rights of the data subject 

You have the following rights:  

  • Right to access your data  
  • Right to rectification of your data  
  • Right to erasure of your data (for example, when the processing is based on consent or there is no legal obligation to retain the data)   
  • Right to restrict processing (denying the authenticity of data or illegitimate processing)  
  • The right to object to the use of your personal data in direct marketing or other processing based on a legitimate interest  
  • Right to withdraw your consent  
  • Right to transfer data to another system (in case of automatic processing)  
  • The right to be informed of a personal data breach pursuant to the General Data Protection Regulation.  

To see your personal data that is recorded in S Group’s co-op member and customer register, log in to your S User Account at https://s-kayttajatili.fi/en. You can also update some of your information on the S User Account.  

You can withdraw your consent and object to data processing and direct marketing based on a legitimate interest and thereby control how we use your personal data. To do this, you can grant and withdraw authorizations and prohibitions by logging in to your S User Account at https://s-kayttajatili.fi/en, in the S-mobiili mobile app or by clicking the link in the email message you received.  

To exercise your rights or get more information on how your personal data is processed, you can also contact the controller by sending an email to tietosuoja.asiakkuus@sok.fi.  

You also have the right to file a complaint with a supervisory authority if you are of the opinion that we are in breach of the applicable data protection legislation when we process your personal data.  

9. Effects of not providing personal data on an agreement 

In order to become a co-op member and to join the S Group co-op member scheme, the customer must provide the necessary information so that the agreement can be concluded (name, address, social security code given by the Finnish civil registrant). If the necessary personal data is not provided, the agreement cannot be concluded.  

In order to become a member of a co-op member household and to join the S Group co-op member scheme, the customer must provide the necessary information so that the agreement can be concluded (name, address, social security code given by the Finnish civil registrant or date of birth).   

Providing the information required for concluding the relevant service agreement is a prerequisite for the provision of the services based on the register data. The information required for concluding a service agreement varies depending on the service.   

10. Significant information related to automated decision-making or profiling 

We do not perform such automatic decision-making or profiling on the basis of the data in the register that would result in legal effects concerning the data subject. If you are using the Collect and Scan service, automatic decision-making is performed in the service on the basis of the use of the service and the scanner. The results of such analyses may lead to you being directed to have your products verified at the cash counter.  

11. Impact of the processing of personal data and a general description of technical and organisational security measures 

We diligently protect your personal data by employing the appropriate data protection and information security measures. Our system providers process your personal data at secure server facilities. Access to personal data is restricted, and the personnel are subject to a confidentiality obligation.  

S Group protects your personal data by means of, for example, preventive risk management and security planning, protection measures for data communications, and by using secure hardware facilities, access control and security systems. After initial processing, hard copies containing personal data are stored in locked and fire-safe storage facilities. The granting and monitoring of user rights is a well-managed process. We regularly provide training for our personnel who participate in the processing of personal data, and ensure that our partners’ personnel also understand the confidential nature of personal data and the importance of secure processing. We select our subcontractors with care. We continuously update our internal practices and guidelines.  

If, despite all of our safeguards, your personal data ends up the wrong hands, we will immediately begin investigating the incident and aim to prevent any damage caused. We will inform the relevant authorities and you of the data security breach in accordance with legislative requirements.  

12. Data protection concerning the joint data register and controller role for shared customer data of SOK and S-Bank 

12.1. Purpose and data subjects of the joint register 

Suomen Osuuskauppojen Keskuskunta (SOK) as a data controller and S-Bank Plc as a data controller are the joint controllers of data described in this section 12 of the notice. In this description, we will define the data subjects and what kind of information is processed in the register. We will also explain how the roles of joint data controllers have been determined in relation to the data subjects. This section supplements the privacy policies of the SOK and S-Bank customer registers.   

Natural persons covered by the joint register:   

  • Customers with a co-op membership and S-Bank membership that are active simultaneously.  
  • Customers who have become a co-op member in the “Become a co-op member” online service.  
  • Customers who have an agreement on the deployment of S-mobiili.   

S Group and S-Bank have a shared task of providing their customers with benefits and services. The purpose of the joint register is to enable the production and development of these benefits and services so that you as a data subject can get the most out of both your shopping and banking memberships. With the joint register, we can also develop S Group’s and S-Bank’s shared mobile app (S-mobiili) and provide an even better service.  

We also use the joint register to ensure that you can maintain your customer information as easily as possible and manage consent matters included in the joint register.  

As the data controller, we will use the data included in the joint register for the shared purposes described below. The data will also be used for purposes determined separately in the privacy policies of S Group’s co-op member and customer register and S-Bank’s customer register.  

12.2. Data areas included in the joint register 

These are the shared data that S-Bank and SOK process for joint purposes. 

Data: Purpose of use: Storage period in the joint register *)  Legal basis: 
Basic personal data (name, social security number, date of birth, language, gender, date of death)   Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register, as described in section 1. Contract, legitimate interest in relation to gender data  
Contact information (permanent and temporary postal address, mobile phone number, other phone number, email address) Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register. Agreement   
Employee information (information on belonging to the personnel, information of right to employee discounts) Maintaining and updating data for the provision of employee benefits. For as long as the customer is included in the joint register.  Legitimate interest 
Co-op member’s household (information about a person belonging to a co-op member’s household, validity period, member/customer number) Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register. Agreement 
Deposit account for benefits payable in cash (valid account number for the payment of benefits) Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register. Agreement  
S-Etukortti Visa (card type, card validity, information on which cooperative’s membership was used to order the card) Creation of an S-Etukortti Visa card with the customer’s details. Managing settlements on matters related to the production of co-op member benefits. For as long as the customer is included in the joint register. Agreement  
Consent and prohibitions (direct marketing prohibition, email marketing permission, mobile marketing permission, telemarketing prohibition, survey prohibition and prohibition information of the Robinson prohibition service offered by Suomen Asiakkuusmarkkinointiliitto ry) Maintaining and updating data. For as long as the customer is included in the joint register. Legitimate interest 
Information on the activation of the S-mobiili app Provision of the S-mobiili service. Throughout the validity period of the S-mobiili agreement. Agreement  
Advertising identifier obtained from the mobile device to identify it Maintaining and updating information. For as long as the consent is valid. Consent 
Consents concerning S-mobiili (use of location data, reception of notifications) Maintaining and updating information. Targeting marketing, content and announcements. Improving the customer experience and business. For as long as the consent is valid. However, no longer than the validity period of the S-mobiili agreement. Legitimate interest 
Customer feedback on S-mobiili given in S-mobiili Development of the S-mobiili mobile app and replying to feedback. Two years. Legitimate interest 
S-mobiili’s digital footprint (processing in the joint register and disclosure to the customer registers of S-Bank and SOK)  Improving the customer experience, allocating customers into groups based on their use of S-mobiili, targeting of marketing communications and improving S-mobiili. Two years. However, no longer than the validity period of the S-mobiili agreement. Consent 
Customer’s choice of user interface for S-mobiili Personalisation of the S-mobiili user interface. For the validity of the chosen option. However, no longer than the validity period of the S-mobiili agreement. Agreement  
Information on which benefits the customer has marked as favourite and if they have removed a benefit from favourites Personalisation of the S-mobiili user interface. Improving the customer experience, targeting content and developing S-mobiili. For the validity of the chosen option. However, no longer than the validity period of the S-mobiili agreement. Agreement  
Allocating customers into groups based on their use of S-mobiili Recommending and personalising benefits and services. Personalisation of the S-mobiili user interface. Improving the customer experience, targeting content and developing S-mobiili. Five years. However, no longer than the validity period of the S-mobiili agreement.  Legitimate interest  
Information regarding mobile payment service activation Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register and the service is in use. Agreement. 
Information regarding mobile S-Etukortti activation Maintaining and updating data for the provision of co-op member and employee benefits. For as long as the customer is included in the joint register and the service is in use. Agreement. 

* Personal data will be processed also as part of SOK’s co-op member and customer register and S-Bank’s customer register independently for their own purposes. 

12.3. Recipients and recipient groups of personal data 

We disclose personal data from the joint register to S Group’s co-op member and customer register and S-Bank’s customer register in accordance with the table above. The purpose of use of these data is to maintain basic information, develop S-mobiili and customer analytics. We may disclose register data to third parties in accordance with the privacy policies of the registers.    

We ensure that the transfer of data is lawful if transferring customer data to countries outside the EU/EEA is necessary for technical aspects related to the processing of personal data.  

12.4. Data subject’s rights in the joint register 

As a data subject, you can approach either data controller to exercise your rights related to the joint register data. We recommend contacting the data controller that is relevant to the rights you wish to enforce. In store customer matters, you can turn to SOK, and in banking matters, to S-Bank.   

If you think the processing of personal data is unlawful, you have the right to lodge a complaint or contact the Office of the Data Protection Ombudsman acting as the supervisory authority.  

You can prohibit the processing of personal data for advertising and analytics by using your right to opt out or by revoking your previously given consent. As a result, the contents of S-mobiili may be less personalised and we will not be able to provide you with targeted announcements or advertising in the best way possible.  

12.5. Contact information of the parties to the joint register 

  • SOK’s Data Protection Officer: tietosuojavastaava@sok.fi   
  • S-Bank’s Data Protection Officer: tietosuojavastaava@s-pankki.fi   

13. Contact person for the register 

If you need more information about the processing of personal data, you can contact us by email at the address: tietosuoja.asiakkuus@sok.fi 

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Links to other privacy notice language versions: 

See also: Data protection at S Group