HOW WE USE YOUR INFORMATION

PRIVACY STATEMENT

Register and Privacy Statement – Simulation Platform User Register

This is the Register and Privacy Statement of SmoothTeam Ltd for EU General Data Privacy Regulation (GDPR). Created on May 25, 2018. Last change on May 25, 2018.

1. Registrar

SmoothTeam Ltd, Finnish Business ID 2679043-4, Nekalantie 28, 33100 Tampere, Finland

2. The contact person responsible for the register

Jaakko Heikkilä, Rekisterit [at-symbol] smoothteam.fi

3. The name of the registry

SmoothTeam Ltd’s user register

4. Legal basis and the purpose of processing personal data

The processing of personal data is based on the consent of the data subject.

The purpose of processing personal data is to manage and develop a customer relationship or to implement a service.

Information is not used for automated decision making or profiling.

5. Information content of the register

The information to be stored in the register is:

  • Personal information: first name and last name, e-mail address
  • The person’s answers to the game questions and the person’s choices in the game situation

This information will be retained for as long as SmoothTeam has a need for data retention based on a contract with the customer, but at least three years after gaming, such that we can produce the customer when requesting reports for the customer. By way of derogation, when requested by the customer, the data will be deleted from the register without delay.

The information in the register is reviewed every six months and data whose retention is no longer justified will be removed.

6. Regular sources of information

The data stored in the register is obtained from the registered persons (the data fields filled in the gaming system) and by means of cookies or other similar techniques.

7. Regular transfers of data and transfer of data outside the EU or EEA

The information is given to third parties as follows:

  • Service providers participating in the service who have a contract (data processor) with SmoothTeam Ltd.
  • Person’s first name and the choices made in the gaming system given to Google Inc. to provide graphical representation of the data. In this context, data is transferred outside the EU or the EEA. Google Inc. is a Privacy Shield Certified Service Provider who is committed to comply with the EU Privacy Policy by signing the Privacy Shield Agreement.

8. Principles of registry protection

Careful handling of the registry is ensured and data processed by the information systems is adequately protected. Electronic databases are protected by firewalls, passwords and other generally accepted technical means. Access to personal data is available only to persons specifically identified whose job requires handling of personal data stored in the register. These people will be able to access the system with their personal user IDs.

9. The right of inspection and the right to demand correction

Every registered person has the right to check his / her data stored in the register and to demand that any incorrect information be corrected or incomplete information supplemented. If a person wishes to check the data stored or to request correction, the request should be sent to the registrar. The registrar may, if necessary, request the applicant to verify his / her identity. The registrar responds within the time limit set by the EU Data Protection Regulation (usually within one month).

10. Other rights related to the processing of personal data

A registered person has the right to request the removal of his / her personal data from the register (“the right to be forgotten”). Also, those who are registered have other rights under the EU’s general data protection regulation such as restricting the processing of personal data in certain situations. Requests should be sent to the registrar. The registrar may, if necessary, request the applicant to verify his / her identity. The registrar responds within the time limit set by the EU Data Protection Regulation (usually within one month).

Note! This is an English translation of the original Finnish document.