Skip to content

Data record description

Data protection and processing of personal data in this service

The EarlyBird service allows you to request delivery tasks for specific days and earn compensation on your own terms by delivering the morning’s papers. You make a commitment only to the tasks that you reserve and you can take up as many tasks as you want – you are your own boss. Join, the mornings are awaiting their earner. You can work as a delivery person both through your business and as a self-employed person with a tax card.

This record description includes a description of the use of personal data in the service as a whole. What data the service processes depends on what parts of the service are being used. Data is gathered primarily from the users themselves, and is processed for the purpose of implementing the distribution contract between the user and Sanoma Media Finland. User accounts and the data related to them are retained for two years following the last sign-in. Data may be retained for a longer time in order to fulfil statutory obligations.

A more detailed description of the data processing is presented below.

1. Controller

Apilut Oy

Postal address: Martinkyläntie 9, 01770 Vantaa

Visiting address: Martinkyläntie 9, 01770 Vantaa

Business ID: 33586575-7


2. Contact information for matters related to data records

EarlyBird registry

Riku Punkkinen

3. Name of record

User record for Apilut Oy’s EarlyBird service

4. Purpose of data processing

  • provision of the EarlyBird service
  • making a distribution (delivery) contract between Apilut Oy and the user, and the creation, management and maintenance of company-/freelancer payment data
  • sending marketing communications and reports
  • opinion surveys, market research, and other research
  • development of products and services
  • other, similar purposes

5. Content of the data file

  • Data provided in the process of registration, such as: user ID, username, password, strong authentication
  • The user’s distribution duties, and entries made in the electronic delivery book
  • Contact persons:
    • Contact information, such as name, address, telephone number, e-mail address,
    • Personal ID number, age, gender and first language
    • Period of validity of the person’s work permit (this is verified via a third party)
  • Companies
    • Company information, such as: name, address, telephone number, e-mail address
    • Contact person’s details, such as: name, telephone number, e-mail address
    • Business ID
  • Data concerning distribution contract and distribution duties, such as: billing- and payment information, product- and order information, customer feedback and instances of contact,
  • Data concerning payment of commission: bank details, copy of tax cards, work permits
  • Data on instances of communication, such as: data regarding the use of services (browsing- and search data),
  • Location data is processed only with the express permission of the data subject
  • Any other profiling- and interest-related data, and
  • Any relevant permissions and consents, as well as any sales-blocking data.

6. Regular sources of data

  • Data collected from users in the context of use of the application, or data they have otherwise reported (by phone, internet or e-mail)
  • Data collected in the context of strong authentication (e.g. TUPAS authentication)
  • Observed application-use data

7. Regular disclosure of data

  • Generally, data from a record is not disclosed to third parties without the prior consent of the data subject.
  • Apilut Oy, and companies that (at a given time) are part of the same corporate group, generally have the right to use and disclose data from a record for justified purposes (such as direct mailing, distance selling, and other direct marketing activities, as well as for conducting opinion polls and market research), in accordance with the Personal Data Act.

8. Transfer of data outside the EU or EEA

  • Data from records is not regularly transferred outside the area of the EU or EEA.

9. Data subject’s rights

  • Right of access and review

The data subject has the right of access to the data on him or her in a personal data file. Communication related to the right of access must be submitted in writing, with a signature, to the address presented in Section 1.

If the information in the data file contains errors, the data subject may submit a revision request to the person specified in Section 2.


  • Right of refusal

The data subject has the right to forbid the controller to process information pertaining to the data subject for direct advertising, distance selling and other direct marketing purposes as well as market survey, opinion survey, public register and genealogy purposes.


In matters concerning bans/refusal or corrections, the data subject may contact the customer service department by phone at 09 1221, or by post at the address mentioned in Section 1.

10. Principles of data file protection

  • Manual materials

There are no manual materials.


  • Electronically stored data

The system containing customer data can be accessed only by employees who have the right to process customer information as part of their duties. Each user has a specific user ID and password to the system. Access to the premises is controlled by means of passes. Data is collected in databases protected by firewalls, passwords and other technical means. Databases and their backups are located on locked premises, and the data can only be accessed by certain designated personnel.




This page contains the information to be presented in the record description according to Section 10 of the Personal Data Act (523/1999).