Privacy Policy

1. About this Privacy Policy

This Privacy Policy by Claned Group Oy (“Claned”, “we”, “us”) desc­ribes our processing of the Per­sonal Data of the users of our service (“Claned Users” or “you”) in accor­dance with the EU General Data Pro­tection Regu­lation (GDPR) and the Finnish Data Pro­tection Act.
Please note that this Privacy Policy only applies to processing of Per­sonal Data carried out by Claned as a data controller.
Your privacy is important to us. It is the­refore important that you care­fully read and understand this Privacy Policy.
This Privacy Policy may be updated if required in order to reflect the changes in data processing prac­tices or otherwise. The current version can be found on our website.

2. Controller

Claned Group Oy Ab:

Business ID: 2422442-0
Address: Man­ner­hei­mintie 15, Fl 00260 Hel­sinki, Finland
Tel: +358405860863
E-mail: info@​claned.​com

Contact Person: Vesa Perälä

3. Definitions

In addition to the certain terms defined throughout the Privacy Policy, the fol­lowing defi­ni­tions will be used in the Privacy Policy. Any defi­ni­tions used but not defined in the Privacy Policy shall have the meaning asc­ribed to them in the Claned Terms of Use (the “Terms”) acces­sible from here.
“Learning Data” shall mean auto­ma­tically col­lected infor­mation on user activity of any Claned User within Claned as desc­ribed hereunder.
“Non-Per­sonal Data” shall mean Learning Data and other non-per­sonal infor­mation we may collect or receive from a Claned User that is not con­nected with a Per­sonal Identifier.
“Per­sonal Identifier(s)” shall mean any of the fol­lowing: (1) first and last name; (2) home or other phy­sical including street and name of city; (3) online contact infor­mation; (4) screen name; (5) telephone number; (6) date of birth; and (7) a pho­to­graph, video, or audio file where such con­tains an image iden­ti­fiable with a Claned User.
“Per­sonal Data” shall mean (1) the Per­sonal Identifier(s) col­lected or received by us from a Claned User and (2) Learning Data and other infor­mation regarding you col­lected by us and iden­ti­fiable with Per­sonal Identifier(s) or otherwise.
“Col­la­bo­ration Notes” shall mean your or other Claned Users’ com­mu­nica­tional inte­rac­tions on the Boards con­sisting of high­lighting of content, likes, com­ments and other pos­sible col­la­bo­ration tools as avai­lable from time to time within Claned.

4. What Personal Data Do We Process?

We process the fol­lowing Per­sonal Data of Claned Users

Claned Users can optio­nally also provide orga­niza­tional infor­mation, lan­guage skills and pre­fe­rences and study goals. At all times, we restrict the col­lection of Per­sonal Iden­ti­fiers and Per­sonal Infor­mation to the extent that is necessary to produce the Claned User experience.

Auto­matic Col­lection of Learning Data and its Processing into Analytics
In order to produce advanced learning benefits, Claned may auto­ma­tically collect selected infor­mation about the user activity of a Learner when the Learner uses the Service, the Learning Data. By such activity we refer to your inte­raction within Claned, including your Col­la­bo­ration Notes as well as your learning beha­viour such as study time, study frequency, studied content and other similar beha­vioural aspects as needed for Ana­lytic Fea­tures (as defined below) and other fea­tures, such as content recommendations.
The Learning Data is, among others, used (a) to provide a Learner with infor­mation and ana­lytics about his/​her learning beha­viour (“Per­sonal Learning Ana­lytics”) and also (b) to generate refe­rence group infor­mation and ana­lytics of other Learners within the same Board or other refe­rence group (“Refe­rence Group Ana­lytics”). The Refe­rence Group Ana­lytics can by com­pared with a Learner’s own Per­sonal Learning Ana­lytics (Per­sonal Learning Ana­lytics and Refe­rence Group Ana­lytics together “Ana­lytics”).
We may further process certain data relating to your use of the Ser­vices such as the Internet pro­tocol (IP) address of the device you use to access the Service, infor­mation about the ope­rating system or your device, type and version of your browser as well as the name of you Internet service provider.
Alt­hough we do not nor­mally use such data to identify indi­vi­duals, some­times indi­vi­duals can be recog­nized from it, either alone or when com­bined or linked with Claned User data. In such situa­tions, ana­lytics data shall also be con­si­dered to be Per­sonal Data under applicable laws and we will treat the com­bined data as Per­sonal Data.

5. Cookies and Third Party Links and Content

“Cookies” are placed on the hard drive of the device that you use to access the Service. Cookies are text files that enable us to keep you logged in to the service and to identify you for the pur­poses of pro­viding and improving the Service.Third-party ser­vices are used to analyze usage of the Service, help detect and solve tech­nical issues and to provide essential parts of the Service. Third-party ser­vices don’t receive Per­sonal Iden­ti­fiers which can be used to identify the user, except when strictly necessary in order to offer the Service. For example, an email sending service receives the email address of the user.
The fol­lowing third-party ser­vices are used:
Mailchimp is used to send noti­fication and announcement emails to the user as part of the Service. Read Mailchimp’s privacy policy here. Bugsnag is used to auto­ma­tically detect and help solve tech­nical issues as part of the Service. Read Bugsnag’s privacy policy here. SCORM Cloud is used to host special learning content that adheres to the SCORM standard. Read SCORM Cloud’s privacy policy here.
Google Ana­lytics is used 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.
The Service may include links to other Web­sites which may have their own terms and privacy policies.

6. Access Rights within the Service

Access to Claned and the Boards
Only Claned Users have access to see any inte­raction within Claned, and in general, the use of your Per­sonal Data and the Ana­lytics is restricted to pro­viding a better learning expe­rience through Claned.
The Boards created by Claned Users are public, shared or per­sonal, as deter­mined in the res­pective set­tings by the creator of the res­pective Board. Public Boards can be accessed and seen by all Claned Users. Per­sonal Boards can only be accessed and seen by its creator. A shared Board can be accessed and seen by its creator as well as other Claned Users invited to the Board by its creator. We note that alt­hough under the Policy and the Terms the Col­la­bo­ration Notes and other User Content are meant to remain within Claned i.e. they are gene­rally non-public, we cannot exhaus­tively prevent Claned Users from disclosing any such content publically and thus user disc­retion on what to post to the Boards is recommended.
Access to and Use of Ana­lytics and Learning Data
The Ana­lytics are made avai­lable to Claned Users through ana­lytics fea­tures within the Claned as avai­lable from time to time (the “Ana­lytics Fea­tures”). Per­sonal Learning Ana­lytics, processed from Learning Data iden­ti­fiable with Per­sonal Identifier(s) regarding you can only be seen by yourself and by the aut­ho­rized Instructor (or Co-Instructor) of the Educator you have been con­nected to and who has created the shared Board you have been invited to. Claned Users within the same Board or other refe­rence group (“Group Members”) as well as the Instructor of the Educator you have been con­nected to can see group Refe­rence Ana­lytics. When Group Refe­rence Ana­lytics is gene­rated and shown to Group Members, infor­mation regarding your refe­rence group is ano­ny­mized, meaning that such infor­mation is not con­nected to Per­sonal Iden­ti­fiers. The Ana­lytics and Ana­lytics Fea­tures made avai­lable to Instructors and Educators shall exclusively be used only to serve the Instructor’s and/​or the Educator’s educa­tional goals and pur­poses. If you act within Claned in the capacity of an Instructor or other Claned User with extended user rights, you are obli­gated to use the Ana­lytics and any other Per­sonal Infor­mation strictly for the said educa­tional purpose.
The Learning Data may further be used to prepare ano­nymous learning modeling, pre­dic­tions and ana­lyses, to conduct internal R&D and research for aca­demic pur­poses, to make recom­men­da­tions of Third Party Content or User Content to you as well as to make use of it for other similar pur­poses in order to enhance your learning process. With such use of the Learning Date, we give our best efforts in pro­viding you with a per­so­na­lized learning expe­rience taking into account your per­sonal characteristics.

7. Purposes and Legitimate grounds of Processing

Per­sonal Data is processed by Claned for the fol­lowing purposes:
To provide our Services
We process Per­sonal Data in the first place to be able to offer the Ser­vices to Claned Users. We may use the data for example to offer essential func­tio­na­lities of the Ser­vices and to provide access to the Ser­vices. If you contact us, we will use the pro­vided infor­mation for answering ques­tions and solving pos­sible issues.
For mar­keting purposes
Subject to your opt-in, we may process Per­sonal Data for the pur­poses of direct mar­keting, trend detection or mar­keting-related analysis.
For quality impro­vement and trend analysis
We may process infor­mation regarding the use of the Ser­vices to improve the quality of our Ser­vices e.g. by ana­lysing 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
We process Per­sonal Data to perform our cont­ractual obli­ga­tions towards Claned Users. In certain cases we may process Per­sonal Data to to comply with legal obli­ga­tions. Furt­hermore, we process Per­sonal Data to pursue our legi­timate interest to run, maintain and develop our business and to create and maintain Claned User rela­tionships as specified above. When choosing to use your data on the basis of our legi­timate inte­rests, we weigh our own inte­rests against your right to privacy.
In some parts of the Ser­vices, Claned Users may be requested to grant their consent for the processing of Per­sonal Data. In this event, Claned Users may withdraw their consent at any time.

8. How Do We Secure and Protect Your Data?

We give our utmost best effort in pro­tecting the privacy of your Per­sonal Data and for the said purpose, and we use various tech­nical, admi­ni­strative and other methods in safe­guarding your Per­sonal Data from being lost, misused, disclosed, accessed without aut­ho­rization etc. Please find below some of the mea­sures we apply:
Within the Claned orga­nization we restrict access to Per­sonal Data to only those employees and directors of Claned who abso­lutely need the access in order to appropriately operate, develop or improve the Service.
When col­la­bo­rating with third party service pro­viders in hosting the Ser­vices and storing your data, we do so only with parties of impeccable repu­tation having privacy prac­tices as advanced as those of Claned. Further, in each such case the use of your data is cont­rac­tually pro­tected to be treated as con­fi­dential and merely to be used for pur­poses of storing and hosting such data.
At all time, our and our partners’ servers are secured and pro­tected by a firewall. Further, industry standard enc­ryption tech­niques are being used when storing your Per­sonal Data, especially your Per­sonal Identifiers.
Please notice that despite of our mea­sures taken in order to safe­guard data security, our system cannot be invul­ne­rable against all pos­sible security breaches. On their turn, all Claned Users are res­pon­sible for pro­tecting the con­fi­den­tiality of their passwords.
Should despite of the security mea­sures, a security breach occur that is likely to have negative effects to the privacy of Claned Users, we will inform the relevant indi­vi­duals and other affected parties, as well as relevant aut­ho­rities when required by applicable data pro­tection laws, about the breach as soon as possible.

9. Children’s Data

The Service is not intended for users younger than thirteen (13) years of age. We do not knowingly to collect any Per­sonal Infor­mation from children under thirteen (13) years of age.

10. International Data Transfers

We store Per­sonal Data pri­marily within the European Eco­nomic Area.
However, in certain cases we may access or use service pro­viders in juris­dic­tions outside the European Eco­nomic Area or outside of the Claned Users’ domicile.
In such cases we will take steps to ensure that 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 secured under other appropriate safe­guards as foreseen by Data Pro­tection Regulation.
More infor­mation regarding the transfers of Per­sonal Data may be obtained by con­tacting us on any of the addresses indicated above.

11. Personal Data Recipients

We do not share Per­sonal Data with third parties outside of Claned’s orga­nization unless one of the fol­lowing circums­tances applies:
It is necessary for the pur­poses set out in this Privacy Policy
To the extent that third parties need access to Per­sonal Data to perform the Ser­vices, Claned has taken appropriate cont­ractual and orga­ni­sa­tional mea­sures to ensure that Per­sonal Data are processed exclusively for the pur­poses specified in this Privacy Policy and in accor­dance with all applicable laws and regulations.
For legal reasons
We may share Per­sonal Data with third parties outside Claned’s 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, identity theft, security or tech­nical issues; and/​or (iii) protect the inte­rests, pro­perties or safety of Claned, our Claned Users or the public in accor­dance with the law. When pos­sible, we will inform Claned Users about such processing.
To aut­ho­rized service providers
We may share Per­sonal Data to aut­ho­rized service pro­viders who perform ser­vices for us (including data storage, sales, mar­keting and Claned User support ser­vices). Our agree­ments with our service pro­viders include com­mit­ments that the service pro­viders agree to limit their use of Per­sonal Data and to comply with privacy and security stan­dards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide Per­sonal Data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.
For other legi­timate reasons
If Claned is involved in a merger, acqui­sition or asset sale, we may transfer Per­sonal Data to the third party involved. However, we will con­tinue to ensure the con­fi­den­tiality of all Per­sonal Data. We will give notice to all Claned Users concerned when the Per­sonal Data are trans­ferred or become subject to a dif­ferent privacy policy as soon as rea­so­nably possible.
With explicit consent
We may share Per­sonal Data with third parties outside Claned’s orga­nization for other reasons than the ones men­tioned before, when we have the Claned User’s explicit consent to do so. The Claned User has the right to withdraw this consent at all times.

12. Storage Period

Claned does not store Per­sonal Data longer than is legally per­mitted and necessary for the pur­poses of pro­viding the Ser­vices or the relevant parts thereof. The storage period depends on the nature of the infor­mation and the pur­poses of processing. The maximum period may the­refore vary per use.
Claned User Data relating to your use of the Ser­vices are typically deleted within rea­so­nable time after you no longer use the Ser­vices. We will store Claned User’s Per­sonal Data for as long as the Claned User is a regis­tered user of our Ser­vices and, the­reafter, for no longer than is required by law or rea­so­nably necessary for our legi­timate inte­rests for example for claims handling, internal reporting and reconci­liation purposes.
We will store iden­ti­fiable Ana­lytics Data relating to the Ser­vices for as long as the Claned User is a regis­tered user of our Services.

13. Direct Marketing

Notwiths­tanding any consent granted befo­rehand for the pur­poses of direct mar­keting, you have the right to pro­hibit us from using your 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 func­tio­na­lities of the Ser­vices or the unsubscribe pos­si­bility offered in con­nection with any direct mar­keting messages.

14. Your Rights

Right to access
You have the right to access your Per­sonal Data processed by us.
Pri­marily such access should be exercised by using the func­tions of the service.
You may also at any time access the Per­sonal Learning Ana­lytics regarding you as made avai­lable to the Instructors.
Right to withdraw consent
In case the processing is based on a consent granted by Claned User, Claned User may withdraw the consent at any time. With­drawing a consent may lead to fewer pos­si­bi­lities to use our Ser­vices. The with­drawal of consent does not affect the law­fulness of processing based on consent before its withdrawal.
Right to rectify
Claned Users have the right to have incorrect or incomplete Per­sonal Data we have stored about the Claned User cor­rected or completed. Certain data can be cor­rected or updated through the your indi­vidual user account.
Right to erasure
Claned Users may also ask us to erase their Per­sonal Data from our systems. We will comply with such request unless we have a legi­timate ground to not delete the data. Please note that You may also at any time cease to use the Service by deleting your Claned Account. In such case, any Per­sonal Learning Ana­lytics and Per­sonal Data regarding you will no longer be avai­lable to any Educator you have been con­nected to or its Instructors and the Learning Data gene­rated by your use of the Service will con­tinue to exist only ano­ny­mized. Accor­dingly, if you delete your Claned Account, you should notice that your his­to­rical Learning Data is no longer reco­ve­rable should you wish to open a Claned Account again. This means that your prior learning history cannot be used to enhance your sub­sequent learning process.
Right to object
Claned Users may object to the processing of Per­sonal Data if such data are processed for other pur­poses than pur­poses necessary for the per­for­mance of our Ser­vices to the Claned User or for compliance with a legal obli­gation. In case we do not have legi­timate grounds to con­tinue processing such Per­sonal Data, we shall no longer process the Per­sonal Data after your objection.
Right to restriction of processing
Claned Users 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 our Services.
Right to data portability
Claned 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
To the extent that the above men­tioned rights cannot be exercised by using the fea­tures of the Ser­vices, you may send us a letter or an e-mail to the addresses set out above, including the fol­lowing infor­mation: the full name, company name, address, e-mail address and a phone number. We may request the pro­vision of addi­tional infor­mation necessary to confirm the identity of the Claned User.
We may reject requests that are unrea­so­nably repe­titive, excessive or mani­festly unfounded.

15. Lodging a Complaint

In case you con­sider our processing of Per­sonal Data to be incon­sistent with the applicable data pro­tection laws, a complaint may be lodged with the local super­visory aut­hority for data protection.