PRIVACY POLICY

 

Name of the document

3stepIT Privacy Policy

Scope

This privacy policy applies to personal data that you give us when visiting our website, using our Asset Management services, using our other services and/or portals, reporting suspected misconduct, interacting with us in meetings, social media, emails and other means of communication.

For recruitment related data, please refer to Privacy policy for Recruitment.

For Speak Up (whistleblowing) related data, please refer to Privacy policy for Recruitment.

Purpose

The purpose of this privacy policy is to inform you about:

  • What personal data we collect about you;
  • How we use your personal data and on which basis;
  • Who we share your personal data with;
  • International transfers of your personal data;
  • For how long we retain your personal data;
  • What actions we have taken to keep your data secure;
  • What are your rights as a data subject and how you may exercise them;
  • How you can contact us in case of questions related to this privacy policy.

Classification

Public

Version

4.0

Last updated

11.9.2025

Review schedule

When required by the Data Protection Legislation. Furthermore, due to changes in our operations or the technology used, we may need to update our privacy policy from time to time. When this happens, we will revise this privacy policy and refresh it on our website.

The protection of your personal data is important to 3Step IT Group Oy and its affiliated companies, hereinafter referred to as "3stepIT" or "we". 3Step IT Group Oy (business ID 2087590-4), Limited Liability Company registered in Finland acts as a contact point for all 3Step IT Group companies in privacy related requests:

 

  • Office address: Mechelininkatu 1A Helsinki 00180, Finland
  • The general phone number: +358 10 525 3200
  • Data Protection Officer: dpo(at)3stepit.com

If you have any questions relating to our use of your personal data under this privacy policy, please contact our Data Protection Officer at the contact details provided above, or use the contact form provided on our website: tell us a bit about your enquiry and we will pass it to the right expert and controller, if need be.

 

Contact Details of Affiliated Companies

 

3Step IT Oy

Business ID 2161942-7
Mechelininkatu 1A, 00180 Helsinki
Registered in Finland
3 Step IT A/S

Business ID 26106427
Vandtårnsvej 62, 2860 Søborg
Registered in Denmark
3 Step IT AS

Business ID 878703812
Wergelandsveien 7, 0167 Oslo
Registered in Norway
3 Step IT Sweden AB

Business ID 556488-0218
Drottninggatan 19, 582 25 Linköping
Registered in Sweden
3Step IT OÜ

Business ID 10731756
Telliskivi 60/2, Tallinn 10412
Registered in Estonia
3 Step IT Services Limited

Business ID 13762523
100 Liverpool Street, EC2M 2AT London
Registered in UK
LeaseCloud AB

Business ID 559089-4308
Erik Dahlbergsgatan 12, 115 32 Stockholm
Registered in Sweden
3 Step IT Inc.

Business ID 10047902
2521 Golden Bear Drive Suite 120, Carrollton
Registered in Texas, USA
3 Step IT Corp.

Business ID 727869224
181 University Ave, Suite 2100, Toronto
Registered in Ontario, Canada

 

The data controller for your personal data may be either 3Step IT Group Oy or any of its affiliated companies, depending which company has a contractual or other relationship with you. We may also act as a data processor and in that role process personal data on behalf of our contractual parties. Please note that this privacy policy does not cover personal data subject to processing activities we conduct as a processor, such as customer data processed when using our Asset Management systems.

 

1 WHAT PERSONAL DATA DO WE COLLECT?

 

We collect and use your personal data to the extent necessary to carry out our operations and provide our services as well as to comply with any regulatory obligations in our activities.

 

CUSTOMERS, SUPPLIERS AND MARKETING

Purpose of processing Legal basis Personal data
Fulfill AML, KYC, sanctions, export control, and accounting requirements. Legal obligation; Legitimate interest for financial sanctions. Name, date of birth, nationality, ID copy, address, PEP-status.
Market products, send newsletters, and develop customer relationships. Legitimate interest. Name, title, and contact information of customer representatives.
Provide and deliver products and services. Performance of a contract. Contact details and identification (passport/ID, photo, nationality).

Sources: Data is collected directly from you or indirectly from customers, business partners, public sources (LinkedIn), and data brokers. Retention: Personal data related to customers/suppliers is generally retained for five years after the end of the contractual relationship. KYC data and marketing data are also retained for five years.

 

WEBSITE VISITORS

 

3stepIT processes data from website visitors and social media users obtained through cookies, newsletter sign-ups, and contact forms.

Purpose Legal basis Personal data
Improve website performance and analyze traffic. Consent (non-essential); Legitimate interest for retrieval. IP address, device info, pages visited, duration of visit.
Targeted advertising. Consent; Legitimate interest. Cookie tracking data, IP address, and interaction history.

2 WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We share personal data within 3stepIT and with external service providers (IT, logistics, advisory), commercial partners, and authorities when required by law. If we assign lease agreements, data may be transferred to refinancing partners who act as independent controllers.

3 INTERNATIONAL TRANSFERS

Transfers outside the EEA follow legal safeguards, such as adequacy decisions or standard contractual clauses approved by the European Commission.

5 HOW DO WE SECURE YOUR DATA?

We use physical, administrative, and technical security measures. Access is restricted to personnel who require it for their work. External processors must comply with this policy and applicable laws.

6 YOUR RIGHTS AS A DATA SUBJECT

Right of access Request information and a copy of your personal data.
Right to rectify Request modification of inaccurate or incomplete data.
Right to erase Request deletion of data, unless a legal obligation requires storage.
Right to object Object to processing for direct marketing or based on your situation.
Right to withdraw consent Withdraw consent at any time (e.g., via unsubscribe links).
Right to lodge a complaint Lodge a complaint with a supervisory authority.

To exercise these rights, contact our Data Protection Officer at the details provided above.