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SILTA Education Oy Updated 5.9.2024

PRIVACY POLICY
Focus Tiger online training program
 

1 GENERAL
This privacy policy describes how your personal data is processed in the Focus Tiger Online Training Program, what personal data is collected and for what purposes the personal data is processed. This privacy policy also describes to whom the personal data is disclosed or transferred, and how you, as a data subject, can exercise your rights in relation to processing of your personal data. In addition, the privacy policy defines the obligations that are complied with regarding processing of personal data. 
This privacy policy is applicable to SILTA Educations Oy’s (the “Controller”) Focus Tiger Online Training Program and the use thereof.
The Controller processes personal data according to the applicable data protection legislation. Data protection legislation shall mean the general data protection regulation (EU 2016/679) (“GDPR”) and national data protection act (5.12.2018/1050) as amended. Terms which are not defined in this policy shall have the same meaning as in the relevant applicable data protection legislation.
 

2 NAME OF THE REGISTER
Focus Tiger Online Training register.

3 CONTROLLER’S CONTACT INFORMATION 
Silta Education Oy (Business ID: 3241267-5).
Oikokatu 4 B 12, 00170 Helsinki
Email address: [email protected]

4 REGISTER’S PERSONAL DATA CONTENT
The register contains the personal data of Focus Tiger Online Training Program’s participants.
The following personal data is processed:

• name
• email
• username, password, screen name or another identifier and user language;
• Information on the use of the Focus Tiger Online Training service;
• Other information concerning the user and the user account which are formed on the basis of the information that the user (i.e., data subject) has provided;
  Updated 5.9.2024
• Consent given for marketing and contacting and the subject matter of the consent;
• Other information received from the data subject or on the basis of his/her consent or authorization that is necessary for the execution of the service he/she has requested;
• Customer feedback and communication between the Controller and the data subject;
• Data generated in the context of using the Focus Tiger Online Training service:
  • browsing data;
  • the web page, from which the application and/or services was accessed, the individual device and/or cookie identification and other relevant browsing and IP address data; and
• “Dig Deeper” -answers
  • You as the data subject, have the option to participate to the exercises, where you can ask for feedback on your answers. Your answers will be anonymized after completing the exercise and receiving feedback, after which the answers you have given cannot be identifiable to you in any way.

5 PURPOSE OF PROCESSING
The Controller or its authorized partner, who processes personal data on behalf of or for the Controller, uses personal data according to data protection legislation for the following purposes:

• providing and developing the Focus Tiger Training Program (including data analysis)
• feedback, support and assistance during the Focus Tiger Training Program
• IT support during the Focus Tiger Training Program
• marketing and contacting purposes (for those who have given their consent for marketing or contacting purposes)

The Controller has the right to process personal data on the following basis:

• Data subject’s consent: the data subject has given consent to processing of personal data.
• Contractual relationship: effective contract between the Controller and data subject.
• Legitimate interests: the Controller has a legitimate interest to utilize customer data to provide services and to develop its services and products in accordance with applicable legislation.

6 COLLECTING PERSONAL DATA
The data collected in the Focus Tiger Online Training register is mainly received from the data subject him/herself. Such data comprises information given by the data subject in connection with the use of and/or registration for the Focus Tiger Online Training and/or in connection with other forms of contact with the Controller. The Controller also collects data by technical means when the data subject uses the Focus Tiger Online Training.
The Controller may also receive data collected via a third-party customer procuring the Focus Tiger Online Training (e.g., employer of the data subject).
In addition, personal data is collected through cookies in compliance with relevant applicable legislation.

7 COOKIES
The Controller uses cookies to enable the technical execution of the Online Focus Tiger Training Program and to monitor use of the service. Cookies are small text files, which the internet browser saves on the user’s or visitor’s device. A detailed description of the Controller’s cookie policy can be found on the Controller’s website.
Certain cookies may be necessary for the proper operation of the Online Focus Tiger Training Program. The user or the visitor may opt-out of the use of cookies by referring to the browser settings in accordance with the instruction of the browser provider. Some functionalities of the Online Focus Tiger Training Program may not function properly if the user chooses to decline or opt-out of the use of cookies. The decline or opt-out of the use of cookies may also otherwise adversely affect the Online Focus Tiger Training Program user experience. Use of cookies is further defined in a separate cookie policy, which can be found on the Controller’s website.

8 DATA PROCESSORS AND OTHER RECIPIENTS
As a rule, the personal data collected in the Focus Tiger Online Training register is not transferred to third parties. However, data may be transferred in the following situations:
Information collected in the Focus Tiger Online Training register may be disclosed to third parties on the basis of legal requests by competent authorities, or in accordance with other legal requirements or the data subject´s consent.
The Controller may use subcontractors for the processing of the data in the Focus Tiger Online Training register for the purposes set out in section 5. In such cases the Controller shall use contractual clauses to ensure compliance with personal data legislation.
The Controller may disclose statistical or anonymous data to third parties.

9 TRANSFERS OUTSIDE OF THE EU OR EEA
The Controller does not transfer personal data outside of EU or EEA, unless it is necessary for the purpose or the technical execution of processing of personal data. However, the Focus Tiger Training platform is provided to you in cooperation with third parties Thinkific and Intercom, which may transfer your personal data outside the EU or EEA to be able to provide the platform and other related services. The third
Updated 5.9.2024
4 (5)
parties in question are committed to use adequate transfer mechanisms when transferring your data, such as adequacy decisions or EU Commission’s standard contractual clauses regarding data transfers.
For more information on how the said third parties process and transfer your personal data, please see the following privacy policies:
Thinkific: Privacy Policy (thinkific.com)
Intercom: Privacy Policy | Intercom

10 RETENTION
Personal data is retained for as long as necessary for the Controller to utilize the personal data for the purposes defined in section 5.
Data subject’s personal data shall, however, be deleted thirty (30) days after the Focus Online Training Program has ended or immediately upon data subject’s request. The Controller shall, however, keep the personal data beyond the above-mentioned term, if applicable legislation or binding contractual obligations with third parties require the Controller to store the personal data for a longer period or if the data subject has consented to e.g., storing and using of their contact information for marketing or contacting purposes.

11 DATA SECURITY
The register’s data security and confidentiality, integrity and availability are ensured with appropriate technical and organisational measures.
Only SILTA Education Oy’s personnel or its authorized third parties, whose tasks require processing personal data, shall have the right to access said personal data. The register is protected with personal user IDs and passwords. Personnel and partners shall be required to commit to necessary protection and confidentiality obligations regarding any personal data.

12 DATA SUBJECT RIGHTS
Data subjects have the rights defined in the applicable data protection legislation. Notice that use of said rights is always evaluated in regard to each case separately.
Data subjects must send their requests concerning their rights to the following email:
[email protected]
The Controller does not charge any fees for data subject requests. However, if the data subject’s requests are apparently unfounded or unreasonable, such as for example if they are presented repeatedly, the Controller may charge the data subject a reasonable fee based on the administrative costs of processing such request.
12.1 Right to access and rectification
Data subjects have the right to access the personal data relating to him/her. The data subjects also have the right to correct or complete incorrect, imprecise, incomplete, outdated, or unnecessary personal data.
12.2 Right to deletion
Data subjects may ask to delete their personal data from the systems e.g. if the personal data is no longer necessary for the purposes for which it was collected.
12.3 Right to withdraw consent
In case the processing of personal data is based on the data subject’s consent, the data subjects have the right to withdraw their consent to such processing at any time.
12.4 Right to restriction of processing
The data subjects may in certain situations have the right to request that the Controller restrict the processing of their personal data.
12.5 Right to object
The data subjects may object to certain processing of personal data including for example processing of personal data for other purposes than purposes necessary for the performance of the services or for compliance with a legal obligation. The data subject may also object to further processing of personal data after the data subject has given consent to processing. With regards to direct marketing, the data subject can unsubscribe from any direct marketing messages to prohibit the Controller from using the data subject’s personal data for such purposes.
12.6 Right to data portability
The data subject has the right to request that the Controller provides the personal data regarding the data subject in question in a structured and commonly used electronic form. The data subject may also request that the personal data is transferred to another controller if this is technically feasible.
12.7 Lodging a complaint
If you, as the data subject, consider the processing of personal data does not comply with applicable data protection legislation, you may lodge a complaint with the local national supervisory authority (Data Protection Ombudsman).

13 CHANGES TO THIS PRIVACY POLICY
SILTA Education Oy develops its services continuously and needs to update this privacy policy accordingly from time to time. Changes to this policy may also be needed due to changes in the legislation. The latest version of this privacy policy can be found on SILTA Education Oy’s website.