General information on data processing activities relating to the operations of Combient Oy
Combient Oy (“the Company”, “we”) develops and manages open innovation projects (“Projects”), and provides the combientfoundry.com website (“Website”) relating to such Projects. For these purposes the Company may collect and process personal data of the users of the Website, and the applicants and participants of the Projects.
1. CONTROLLER’S CONTACT DETAILS
Name: Combient Oy
Business ID: 2842718-8
Correspondence address: Tekniikantie 14 02150 Espoo, Finland
Name: Luukas Castrén
2. PERSONAL DATA PROCESSED AND SOURCES OF DATA
User data and analytics data
We collect two types of information from the Users: User Data and Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered to be personal data under applicable laws and we will treat the combined data as personal data.
The Company may collect and process the following User Data received from the Users application forms completed on the Website or by email, User Data received from the Users on the phone or in person before, during and after the delivery of the Projects and User Data generated by us:
- First name
- Last name
- Phone number
- Roles and responsibilities in the company the User represents
- Information regarding professional background
- CVs and other certificates
- Customer feedback received via email or in person
- Information relating to approvals and rejections of the User’s Project applications
- Data transfer consents and prohibitions
- Marketing opt-ins and opt-outs
- Any other information provided by the User on the Website, such as information relating to User’s personal ownership of the company the User represents.
In addition to the above mentioned, we obtain User Data from registers maintained by the authorities and customer default registers as well as other reliable private and public registers.
Analytics Data we gather in connection with the use of our Website includes for example the following data: (i) your IP address; (ii) device and device identification number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi) language setting.
We use various technologies to collect and store Analytics Data and other information when the Users visit the Websites, including cookies and web beacons.
A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.
Web analytics services
The Website uses Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services. 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.
3. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA
There are several purposes for the processing of personal data by the Company:
To provide and develop the Services and to develop and manage the Projects
We process personal data in the first place to be able to offer the Services to the Users, and to develop and manage the Projects. We process personal data for the evaluation and selection of potential individuals and companies to partner with the Projects.
We also process the personal data provided by the Users in order to develop the quality of our Services and Projects, for instance by analyzing the previous employment track record of the Users.
For customer communication and marketing
We process personal data for the purpose of maintaining our customer relationships with the Users, for instance by contacting the Users regarding the Services and Projects. We also process personal data of the Users in order to inform the Users of changes relating to the Services and the Projects. We use personal data for marketing and advertising the services and products provided by us, e.g. to customize the User’s experience by providing the User with targeted offers and advertising information based on the information gathered from the User during his/her previous visits to the Services and participation in the Projects.
If the User contacts us to give feedback with respect to our Services or Projects, we will use the provided information for answering questions and solving possible issues.
Legitimate grounds for processing
We process personal data to perform our contractual obligations towards the Users with respect to the Users having applied or accepted as partners in the Projects. Furthermore, we process personal data based on our legitimate interest. Our legitimate interest is based on running, maintaining and developing our business, improving the customer experience of the Users as well as on performing direct marketing. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible.
In some parts of the Services, the Users may be requested to grant their consent for the processing of personal data. In this event, Users may withdraw their consent at any time.
4. TRANSFERS TO COUNTRIES OUTSIDE EUROPEAN ECONOMIC AREA
The Company stores the 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 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 through other appropriate safeguards, such as the Privacy Shield Framework.
We only share personal data within the Combient organisation if and as far as reasonably necessary to perform and develop our Services and the arrangements relating to the delivering the Projects. We do not share personal data with third parties outside of Combient organization unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside Combient 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 the Company, the Users or the public in accordance with the law. When possible, we will inform the Users about such transfer and processing.
To authorized service providers
With explicit consent
We may share personal data with third parties outside the Combient organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so.
6. STORAGE PERIOD
Combient does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Services and Projects or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.
We will store the User Data collected in connection with the application process for as long as the User in question is a relevant partner or applicant in our Projects or subscriber of our newsletters.
We will delete or anonymise all the User Data within a reasonable time and at the latest after 5 years after the end of the latest Project the User has interacted with, save for when we are required by law, claims handling or accounting standards to store some of such information in the form of personal data.
Please note that if you have applied for our Projects and are a User of our Services, we will store your User Data relating to your application for as long as we see you as a potential participant in our Projects. You may, at any time, request us to delete your User Data. Thereafter, we will delete or anonymise all your User Data within a reasonable time, save for when we are required by law, claims handling or accounting standards to continue storing some of such information in the form of personal data.
7. USERS’ RIGHTS
Right to access
The Users have the right to access the personal data relating to them and processed by the Company. This means that the Users may contact us, and we will inform what personal data we have collected and processed regarding the said User and communicate the purposes such data are used for.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
The Users have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about the User corrected or completed. By contacting us on the addresses indicated above, the User may update e.g. his/her contact details or other personal data.
Right to deletion
The Users may also ask us to delete the Users’ personal data from our systems. We will comply with such request unless we have a legitimate ground not to delete the data. Such legitimate ground may be based on e.g. applicable legislation.
Right to object
You may 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 delivery of the Projects 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 Services or to partner in the Projects.
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 the Services or to partner in the Projects.
Right to data portability
The Users have the right to receive their 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 email to us on the addresses set out above. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
8. DIRECT MARKETING
The User has the right to prohibit us from using the User’s 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.
9. LODGING A COMPLAINT
The User can lodge a complaint with the local supervisory authority for data protection, in case the User considers the Company’s processing of personal data to be inconsistent with the applicable data protection laws. In Finland, the local supervisory authority is the Data Protection Ombudsman (www.tietosuoja.fi).
10. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Website, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.