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.