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Vuolearning Ltd (“Vuolearning”) collects personal data of its customers and website visitors whilst providing its services.
Vuolearning processes your data with appropriate care, in accordance with all applicable laws and regulations.
The terms for the delivery and service description of the software have been stated in a separate agreement (‘Service Agreement’ and its attachments), which covers the information, messages and files created in and imported to the system (‘Customer Data’). The ‘Customer’ (e.g., your employer or some other organization or person) that has committed to the Service Agreement is responsible for managing the Customer Data related to their own learning platform.
The purpose of the Vuolearning platform is to act as a platform for the Customer for arraning and managing online trainings and courses. The Customer can use the Vuolearning platform to include in the trainings third-party applications and tools that also process user data. The Customer is responsible for the usage of any such tools, including all the processing of user data performed by the Customer.
The Data Protection Law defines the data controller and the data processor. In most cases, the Customer is the controller of Customer Data and Vuolearning is the processor of Customer Data.
The requests related to the rights of the data subject should be directed primarily to the data controller. When Vuolearning acts as the data processor, any requests related to the rights of the data subject will be forwarded to and be determined and responded by the data controller.
Vuolearning is the data controller for the contacts to the Vuolearning customer support.
If Vuolearning is the data controller, or it is unclear to you, who is the data controller of your Vuolearning platform, you may send your requests regarding your rights as a registered user to Vuolearning:
Company ID in Finnish Trade Register: 2647901-3
Correspondence address: Keilaranta 1, 02150 Espoo
E-mail address: firstname.lastname@example.org
Vuolearning collects two types of information from our Users: (i) User Data; and (ii) Technical Data. Although we do not in usual circumstances use Technical Data to identify you as an individual, you can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.
We may collect and process the following User Data about our customers and visitors: (i) first and last name; (ii) address details, (iii) telephone number, (iv) e-mail address, (v) your location when you use our services, (vi) payment details, (vii) other personal data you provide yourself, including pictures, for example when creating a profile or when interacting with other users, as well as information you have provided by telephone.
We may collect User Data from our customers and visitors in a variety of ways, including, when they register to our services or are invited to the course platform by the course arranger. We will collect User Data from customers and visitors only if they voluntarily submit such information to us through our services or sites.
We may automatically collect Technical Data when you visit or interact with our services or sites. Technical Data may include the browser name, the type of computer or device and other identifying information of your device, time spent on a website, interaction with the Services, URL of the website you visited before and after visiting the Services, the time and date of user visits, IP address, your operating system and Internet service provider, as well as other similar technical information.
We use various technologies to collect and store information when you use the Vuolearning platform, including cookies. The cookies used by the learning platform are technically necessary in order to manage logins and to save some of the choices you have made.
Some courses allow logging in as a guest. The system creates a cookie for the guest account which makes it possible for the user to save their answers, return to continue and to check their performance later.
The Vuolearning learning platform does not use any third party cookies, nor cookies used for tracking platform performance and usability or cookies for targeted marketing.
There are several purposes for the processing of your personal data by Vuolearning:
To provide our services and carry out our agreement with you
Vuolearning processes your personal data in the first place to be able to deliver our services to you and to run, maintain and develop our businesses. We use the data for example to handle your payments, provide services or contact you regarding your registration to one of our events. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. In order to ensure that our services are in line with your needs, these data can be used for things like customer satisfaction surveys. We might also request another party to do this for us.
For customer communication
Vuolearning processes your personal data to contact you regarding our services and to inform you of changes to our services and products.
For quality improvement and trend analysis
We may also process information about your use of the services to improve the quality of our services e.g. by analyzing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally identifiable data.
Legitimate grounds for processing
Vuolearning processes your personal data to perform our contractual obligations towards you and the Customer, and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to maintain and develop our businesses.
Vuolearning may transfer your personal data to countries outside the European Union (EU) or the European Economic Area (EEA) only when a separate agreement is made. When we transfer any data to a country for which no adequacy decision of the European Commission exits, such transfer will be subject to the provisions of the (standard or other) clauses adopted by the European Commission.
If you wish to know more about the international data transferring of your personal data, you may contact us with the contact information stated above.
We share your personal data within the organization of Vuolearning in cases where and to the extent to which it is necessary to do so to perform and develop our services, such as our employees providing our customer support.
We do not share your personal data with third parties outside of Vuolearning unless one of the following circumstances applies:
It is necessary for the purposes of this Privacy Statement
To the extent that third parties need access to personal data to perform such services, Vuolearning has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations. Furthermore, we may provide your personal data to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in accordance with our Privacy Statement and any other appropriate obligations of confidentiality and security measures.
For legal reasons
We may share your personal data with third parties outside Vuolearning 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 Vuolearning, our users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
With your explicit consent
We may share your personal data with third parties outside Vuolearning for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at any given time.
Vuolearning stores your personal data only for as long as it is legally demanded or as long as it is necessary to do so for the purposes stated above. The storage period depends on the nature of the information and the purposes of processing.
The maximum period may therefore vary per use. In general, we store data for backing up our services for a maximum of 30 days after your account has been deleted or after the customer has stopped using the service.
Right to access
Vuolearning offers you access to the personal data we process. This means you can contact us asking us to inform you about your personal data that we have collected and processed and the purposes such data are used for.
Right to correct information
You have the right to have incorrect/unprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed by contacting us.
Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such request unless the data controller has a legitimate ground to not delete the data. After the data has been deleted, we may not be able to immediately delete all residual copies from our active servers and backup systems. We store your data in the backup copies of the learning system for no more than 30 days after your user account has been deleted.
Right to object
You may object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of our services or for compliance with a legal obligation. You may also object to any further processing of your personal data even after prior given consent. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our services.
Right to restriction of processing
You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to using our services.
Right to data portability
You have the right to receive your personal data from us in a structured, commonly used format in order to transmit the data to another controller.
How to use your rights
You may use these rights by sending a request according to the instructions the data controller has provided in their Privacy Statement. If you need help identifying the data controller or finding the instructions, or if Vuolearning is the data controller, you may send us a request by letter or e-mail, including your name, address and phone number to us on the addresses indicated above.
If your request regards personal data in a cookie, you must enclose a copy of the said cookie. We may request you to provide additional information if it is needed to confirm your identity. We may reject requests that are unreasonably repetitive, unreasonably demanding or manifestly unjustified. In case you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection.
We will take all reasonable, appropriate security measures to protect Vuolearning and our customers from unauthorized access to or unauthorized alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should, despite the security measures, such a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible.