Privacy policy - Trainda

1. General notes

Trainda Oy takes the processing of their customers’ personal data seriously and complies with the current data protection legislation. This privacy policy informs our customers of what personal and other data we collect and how we process it. This privacy policy is applied to the online services provided by Trainda Oy.

Personal data refers to data that allows a person to be potentially identified.

Customer must accept the terms of this privacy policy to use Trainda Oy’s services. Customers who refuse to accept this privacy policy or the terms of use for the service have no right to use the service.

2. Who is the controller and who can I contact regarding this privacy policy?

The controller is Trainda Oy. You can contact us by email at support@trainda.fi.

3. For which purpose is my personal data processed?

Trainda processes your personal data for the following purposes:

to provide, produce, maintain, protect, and develop service(s)
to handle and develop customer service
to send newsletters
for customer communications
for marketing

4. On what basis is my personal data collected and processed?

We process your personal data based on the following grounds as stated in the EU General Data Protection Regulation:

Contract

When you register as a user to our service(s), we will process your data based on a contractual relation. We only process data that is required for the delivery of the agreed service, that is, contact information and data required to carry out the features of the service.

Legal obligation

We may be obligated to keep some of your data even after the customer relationship ends to comply with the Bookkeeping Act legislation or some other peremptory provision of the law. In this case, processing your data is based on fulfilling a legal obligation.

Consent

With your consent, we may process your data to, among other things, perform marketing.

Legitimate interest

We process your data for the purposes described in section 3 above entitled ‘For which purpose is my personal data processed?’. We see these purposes as essential to our business operations and thus they constitute a legitimate interest. When we process personal data based on a legitimate interest, we always consider the benefits and potential harm that may be the result of processing to customers. You have the right to object to the processing of your personal data based on a legitimate interest.

5. What data about me is collected and processed? What sources is my data collected from?

Personal data is mainly collected from the users themselves at the time of registration. In addition, we may receive data from our partners, for example, the party who sold you a coaching package.

User-supplied data:

contact information such as name and email address
gender
choices related to direct marketing
email conversations related to customer service and online discussions in, for instance, social media
provided areas of interest and other information
other data collected with user’s consent

Data from partners:

contact information used in coaching activation received from the seller

Data derived from using the service:

data related to the use of the service
other data collected with user’s consent

6. Who will process my personal data?

To produce our service(s), we use contracting parties, and this may involve transferring data to a third party. Due to data processing, the data physically resides on external subcontractor servers, and personal data is processed over technical user access. All our partner contracts comply with the requirements of the EU General Data Protection Regulation and other legislation. To learn more about transferring data to third parties, please refer to section ‘Will you transfer my personal data to third parties?’.

7. How is my data stored and protected?

Your data is maintained and protected by using various technical and organisational means.

Our processing of personal data and our technical solutions follow good data protection practices, such as data consolidation, minimisation, pseudonymisation, anonymisation, and encryption.

We report all potential data security threats and possible breaches directly to the police and the National Cyber Security Centre Finland (NCSC-FI). We may also temporarily close our service to protect personal data.

Trainda stores personal data in the EU and/or EEA areas.

8. For how long is my data stored?

We keep our customers’ personal data in compliance with the currently applicable legislation and only for as long as is required to carry out the purposes described in this privacy policy.

When processing your personal data is no longer legitimate, we will remove your personal data.

Consumers

We can process your personal data for as long as you have active online coaching, and for two calendar years after your last login to the service.

After this period, we will transfer your personal data to the marketing register and treat you as a potential customer. In the marketing register, we will process your personal data for as long as you become our customer or until you request the removal of your data.

Corporate customer representatives

We can process your personal data for as long as you represent our corporate customer, and for two calendar years after the year during which your representation ends.

9. What rights do I have?

You have the legal right to:

verify what data pertaining to you we have collected
- After receiving the appropriate and identifiable request from you, we will submit a report stating what personal data we have collected
request that we correct erroneous, incomplete, unnecessary, or outdated personal data
- If you notice errors in your personal information, you can submit a request for rectification, and we will make the required corrections.
request removing data
- At your request, we will remove your data in compliance with the EU General Data Protection Regulation, article 17, unless one or several of the following make processing necessary: exercising the right of freedom of expression and information; complying with a legal obligation; archiving purposes in the public interest; or the establishment, exercise, or defence of legal claims
restrict processing of personal data
- If you request that we restrict processing your personal data, we can only process your personal data with your consent for the purposes of making, presenting, or defending a legal claim, for public interest, or to protect the rights of another person.
object to processing of personal data
- In some cases, you can also object to processing your personal data, in other words, request that your data not be processed in any way. Objecting is possible if we process your data based on a legitimate interest. A legitimate interest is created when, for instance, your personal data is used for direct marketing.
transfer your data to another controller
- If the automated processing of your personal data is based on your consent or a contract, you have the right to receive the personal data you have provided us in a generally used format and to transfer the said data to another controller.
withdraw your consent
- However, please note that you cannot withdraw your consent afterwards for actions that have already been taken.

We principally carry out your request within one month. You can exercise your rights by contacting our customer service at support@trainda.fi. Please note that we must always be able to identify the person requesting information/processing.

If you feel that we, as the controller, refuse your request and you cannot see any grounds for this refusal, you may contact the Data Protection Ombudsman.

Part of the data, such as an email address, must be stored for the purposes of using the service. When you withdraw your consent to collect the data listed in our privacy policy, using the service may become partly or completely limited.

10. Will you transfer my personal data to third parties?

Your data may be transferred in the following situations:

Consent

Personal data can be transferred, by express consent, for the purposes of, for example, a service provided by a third party.

Communities

Personal data is not principally revealed to other users of the Trainda online service, but users can themselves share data with other users by, for instance, taking part in a conversation via using a nickname on a discussion forum.

Subcontractors and service providers

Trainda Oy can use subcontractors and service providers for the technical support, customer service, customer communications, and other development of Trainda’s services. Personal data is transferred to subcontractors and service providers only in so far as they participate in carrying out Trainda Oy’s services.

Personal data can be processed and transferred to outside the EU and/or EEA areas when our service provider also has operations outside these areas. In these cases, we take appropriate protective measures to ensure the data subjects’ rights and liberties in compliance with the applicable data protection legislation.

In connection with an acquisition or some other form of corporate restructuring, or if our business is transferred to another company, we may share your personal data.

If required, we will also transfer data at the request of authorities, if the authority has the right to receive the data based on a, for example, court order or relevant legislation. We will inform our customers of such requests if legislation so allows.

11. Does your service use cookies and what are they?

Trainda Oy’s Web site and the Trainda online service use cookies and other similar technologies. Cookies are small text files that are stored on the user’s end device to extend site functionality.

We use cookies and other similar technologies to:

identify customers
maintain logins

For these functionalities, Trainda Oy requires that you accept the use of cookies to use the Trainda online service.

Cookies and other identifiers are set to expire after a certain period, and browsers will remove cookies after this period. You can also remove cookies in your browser's history settings whenever you like. Visiting our Web site/service will reset the cookies every time if your browser allows this.

We also employ other technologies (such as Piwik Pro Analytics) and tracers for the users of our service(s), trends, popular products, and - with your consent - also targeted marketing. All data sent to the partners we use for targeting analytics and marketing is anonymised.

You can stop the use of cookies by adjusting your browser’s settings so that storing cookies is not allowed. Please note that limiting the use of cookies may, however, have negative effects on Web page functionality.

12. Profiling and automated decision-making

We do not use your data for automated decision-making and profiling.

13. Can this privacy policy change?

For the purposes of service development and due to legislative changes, we reserve the right to revise our privacy policy. We recommend that you revisit this privacy policy periodically to stay current regarding potential changes made to our policy.