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: Konepajankuja 1, 00510 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
- Personal identifiers including (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 user.
- Organisation to which the user may be connected to
- Selected user interactions by users as described in Claned’s privacy policy.
- Information regarding services or products ordered
- Any analytics data that can be directly or indirectly linked to Claned User
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.
