PRIVACY STATEMENT

Protecting the data of our customers and other persons who use our services is important to us. We have updated our data protection practices. This does not necessarily require any action from our customers and other persons who use our services.

Kouvola Innovation Oy’s personal data protection practices

Kouvola Innovation Oy (hereafter “Kinno”) is committed to protecting the privacy of its service users and follows data protection and other legislation and good data protection practices in its operations. This privacy statement describes Kinno’s practices related to the collecting and processing of personal data. “Personal data” means data that can be linked to an individual person.

This privacy statement is applied when Kinno acts as a controller and when a reference is made to the applicability of this privacy statement in connection to the use of Kinno’s services. We can also provide additional information related to data protection in connection to individual services, websites, or applications.

The primary basis for personal data processing is the use of Kinno’s services, some other appropriate connection to our services, or the consent of the user. Also applications published by Kinno that you have installed can process your personal data.

Kinno’s services can be provided on various technical platforms, and the services can contain links or provide access to websites or services of other operators. The services offered by Kinno can be used e.g. on mobile devices or a third-party application, which have their own and independent data protection practices and terms of use. We recommend that you read the data protection practices and terms of use of such third parties carefully. Kinno is not responsible for the data protection practices and terms of use of third parties.

Which data is collected?

Kinno can collect data concerning its service users that is necessary for the purposes specified in this privacy statement. The purpose determines the kind of data that is collected of the users in each situation.

Your personal data can be collected when you register as a user of Kinno’s services, in connection to the use of the services, and in connection to competitions, campaigns, studies, and other contacts with us. Kinno collects personal data falling into e.g. the following categories:

1. Information you have provided to Kinno

We can request optional information from you in connection to various services, such as:

- Name

- Password or other unique ID

- Email address or other contact details

- Other personal user details, such as the date of birth and gender

- Permissions, consents, and selections, such as the language

- Information related to competitions and lotteries

- Comments submitted in Kinno’s online services

- Other information related to content production

- Research and questionnaire data

- Information of the devices you use

- Customer feedback

- Other information you have given or has been disclosed subject to your consent, e.g. information collected from external sources.

We collect data by various means, e.g. in connection to registration, use of the services, or when you participate in Kinno’s competitions, lotteries, or studies.

2. Observations made of and data derived from the use of the services

We can collect the following information of you and the use of Kinno’s services:

- Data collected by the analytics systems of online services (cookies)

- Customer communication data, such as information on clicking on links

- The website from which you came to the Kinno website

- Equipment identifiers, such as the model and the unique device and/or cookie ID of the terminal device

- Data collection channel: Internet browser, mobile browser, application, and browser version

- IP address

- Operating system of the terminal device

- Session ID, time and duration of the session

- Location data subject to your explicit consent

 - Data that can be linked to the user based on the past use history of Kinno’s services and has been derived from observed use and/or information provided by the user him- or herself, such as demography, interests, and other classification of users

 - Other data collected subject to your consent

Kinno’s location data -based services and features utilise satellite, IP address, and other web-based location data. The use of assisted location methods, such as assisted GPS, can include exchanging your location data and identifying device and operator -specific IDs with the location server. When you use our location-based services, your location data will be sent, subject to your consent, in order to provide the correct Kinno content.

Why do we process personal data?

We process your personal data related to one or several of the purposes specified below.

1. Provision of services

Your personal data can be used to provide Kinno’s services, to identify the user, and to make the services more personal, interactive, and user-friendly e.g. by enabling the use of Kinno’s services on various devices, by offering recommendations of content that you might find interesting, and by displaying targeted content in our services. Your personal data can also be used to answer to your requests and questions, to fulfil various tasks such as implementing the choices you have made, to ensure information security,  and to prevent the misuse of services.

2. Service development

Your personal data can be used in developing Kinno’s services and in enhancing the user experience. Your personal data can be used in implementing questionnaires and studies related to Kinno’s services and contents, and availability and user analyses related to audience studies. We can link data collected in connection to different services and applications to the extent that the said data has been collected for the same purpose, and can also use the data for statistical purposes to the extent required by service and application development.

3. Marketing and customer communications

Your personal data can be used for the marketing of Kinno’s services and for customer communications, e.g. when we send you notifications related to our services or contact you in matters related to customer service or our services.

How do we store and combine personal data?

As described in the above, Kinno’s services can save data related to the use of Kinno’s services in order to enable various functions, such as creating statistics. Kinno stores data related to or derived from the use of Kinno’s services separately from the actual personal data file.

Do we convey personal data?

Kinno does not principally sell or otherwise disclose your personal data to third parties. Kinno can only convey your personal data to a third party in the following situations:

1. Your consent

Personal data can be conveyed subject to your explicit consent e.g. related to a third-party service.

2. Communities

Your personal data is not displayed to other users of Kinno’s services. However, in some of Kinno’s community services you can decide to share e.g. your pseudonym or other data with other users.

3. Subcontractors and service providers

Kinno can use subcontractors and service providers for the technical maintenance of its services, customer service, management and analysing of user data, research, customer communications, or implementation of various campaigns. Your personal data can be conveyed to Kinno’s subcontractors and service providers only to the extent that they participate in providing Kinno’s services and in fulfilling the purposes specified in this privacy statement.

Such third parties must only use your personal data for the purposes specified in this privacy statement and by Kinno. Kinno obliges them to keep your personal data confidential and to ensure a sufficient level of information security in order to protect your personal data.

4. International data transfers, e.g. in international project operations

Kinno aims to implement all services and process your personal data primarily by using operators and services located within the EU or EEA. However, in some cases Kinno’s services can be implemented by using operators, services, or servers located elsewhere, and in such a case your personal data can be transferred between various countries. These kinds of transfers can include the conveyance of personal data outside the EU or EEA to countries where legislation on personal data processing differs from the requirements of Finnish legislation, e.g. the United States. Kinno will ensure a sufficient level of personal data protection also in these cases e.g. by agreeing on matters related to confidentiality and processing of personal data in a manner required by law, including the use of standard contractual clauses approved by the European Commission, and otherwise so that personal data is always processed in accordance with this privacy statement.

5. Research use

We can in some cases convey data for scientific or other research requiring that the said data has first been rendered so that individual persons can no longer be identified.

6. Conveyances based on legislation

Your personal data can be conveyed if required by a competent authority or legal requirements.

 

How do we ensure that data is up to date?

We aim to keep all personal data in our possession correct in every reasonable manner by deleting unnecessary data and updating outdated data.

In some of Kinno’s services, the users can manage the personal data, selections, and consents that we collect. Please note that you must update your personal data in case of changes.

 

How do we protect your personal data?

We pay special attention to data protection and information security in the design, implementation, and maintenance of our services. We use the appropriate physical, technical, and administrative protection measures to protect your personal data against misuse. Persons that have been specifically appointed for the task will be responsible for data protection and information security. We restrict access to systems and databases that contain personal data to named persons only who need the said data for and have the right to process the said personal data due to their work tasks.

We implement data protection and information security e.g. through predictive risk management, by observing data protection and information security in the design of our services, by training our staff, and by regularly inspecting the compliance of our services with the requirements. We prepare for risks related to the misuse of data and similar based on the probability of the risk and the nature of the data to be protected.

Kinno can use subcontractors and service providers for implementing its services and for personal data processing. In such cases, we ensure through contracts and other arrangements that your personal data is protected in accordance with legislation, good data protection practices, and this privacy statement.

 

How do we use cookies?

Kinno uses cookies, beacons, and other similar methods to provide and develop Kinno’s websites and services and to target content and communications. Our websites can also include other third-party components e.g. related to community services.
 

How long do we store your data?

Your data will be stored in accordance with current legislation and only for as long as it is needed in order to fulfil the purposes specified in this privacy statement. 

Please note that some of Kinno’s services may contain public, interactive, and communicative functions, such as comment sections and discussion forums, and your pseudonym and content that you have produced can remain visible in these services also after you have removed the username you have registered or your user relation ends.

 

Which rights do you have?

Based on the law, you have the right to inspect the data concerning yourself that we have collected. You also have the right to require that erroneous, defective, unnecessary, or outdated personal data be corrected or deleted.

You can use your rights by contacting the information security contact person specified below, by managing your user account (in some Kinno services), and by utilising the functions available on your device, in our applications, or in our services.

You can also forbid Kinno from using data concerning yourself for direct marketing and research on e.g. customer satisfaction. However, we can still send you notifications on our services, such as information on changes and on defects and errors in the availability of services.

 

Changes to this privacy statement

Kinno develops its services constantly and can make changes to this privacy statement from time to time without a prior notification. However, Kinno will notify the users of any significant changes to this privacy statement at the beginning of this privacy notice and on its website at least 30 days before the changes take effect. Changes can also be caused by changes in legislation.  We recommend that you read this privacy statement from time to time to be notified of any changes made thereto.

 

Who is the controller and who to contact?

The controller of your personal data is Kouvola Innovation Oy, address: Paraatikenttä 4, 45100 Kouvola.

In privacy protection matters, you can contact financial manager Hanna Korjala, who is responsible for Kinno’s information security.

Please note that we might need to verify your identity before fulfilling your request for security reasons.