Privacy policy

#1. Acceptance

This Privacy Policy by Claned Group Oy (“Claned Group”, “we”, “us”) describes our policy on collecting, storing and using your data and personal information within Claned® and the Service. The Privacy Policy also complies with the Finnish Personal Data Act (see below). We are working on bringing the Services into compliance with the General Data Protection Regulation (GDPR) by May 2018. We are updating the features and functionality of the Service to meet the GDPR requirements, and we are updating our documentation and our customer agreements to reflect the GDPR requirements.

In order to understand our privacy practices, it is important for you to understand the Privacy Policy. By opening up a Claned Account and using the Service, you accept the policies outlined in the Privacy Policy. If you feel you cannot agree on the Privacy Policy, you should not use Claned or the Service.

#2. Definitions

In addition to the certain terms defined throughout the Privacy Policy, the following definitions will be used the Privacy Policy. Any definitions used but not defined in the Privacy Policy shall have the meaning ascribed to them in the Claned Group 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).

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.

#3. What Information Do We Collect and Produce?

From Whom Is Information Collected? Personal Identifiers

We only collect and/or receive information from registered Claned Users. As for Claned Users, we ask for certain Personal Identifiers when opening up a Claned Account. Currently, the collected Personal Identifiers consists of your name, gender, date of birth, email address and the country of residence. 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”).

Automatic Collection of Other Information; Techniques

We may further collect or receive Non-Personal Data and use following techniques:

  • For example, in order to develop the service, we collect 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.
  • We may also place a “cookie” on the hard drive of the device that you use to access the Service. Cookies are text files that are saved on the hard drive of your device by means or your browser, enabling us to recognize your browser type and version for purposes such as saving your preferences and directing relevant content to you. Most of the current available browsers give you the option of managing cookies by, for example disabling them entirely, accepting them individually, and deleting saved cookies from you hard drive. We would like to remind you that if you completely disable cookies on your browser, you not be able to use some features of the Service.

Third-Party Service Providers

The Service also uses links to other Websites and we also use third-party services providers in creating the Claned experience. For example, Youtube and Vimeo videos can be linked and added to the Boards and we may partner with third-party service providers to have certain features, such as testing tools, available in connection with Claned user experience. Please note that also such third-party service providers may collect and receive information based on your interaction. We recommend you to get separately acquainted with the privacy policies of such third-party service providers.

#4. The Ways We Use Information and Who Has Access To It

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.

In the event we are under a legal obligation to disclose information to public authority or a similar party, we do best in minimizing the amount to be disclosed information in order to safeguard the privacy of Claned Users.

The Learning Data may further be used to prepare 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. While doing so, however, the Learning Data is always used anonymized and your Personal Data is never sold, transferred, disclosed or otherwise made available to any third parties.

In the event of an assignment of this agreement in whole or in part to Claned Group’s parent or subsidiary companies or in connection with a merger or business acquisition, the Privacy Policy shall remain in force and such assignment shall be deemed to take place in compliance with the Privacy Policy.

#5. What Access and Control Do You Have Over Collected Personal Information?

As Claned User, you have at all time access to your account preferences and settings to check and update your Personal Data and account settings, including the privacy settings. We note that it is not technically feasible to disclose all Learning Data that may be connected to a Claned Account. In general, however, any Personal Data regarding you is displayed to you within the Claned user interface. For example, you may at any time access the Personal Learning Analytics regarding you as available to the Instructors. 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.

#6. How Do We Secure and Protect Collected Information?

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:

  • We restrict access to Personal Data to only those employees and directors of Claned Group 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 policies and practices as advanced as those of Claned Group. 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, industrystandard 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 shall be responsible for protecting the confidentiality of their passwords.

#7. Our Policy Towards Children

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

#8. Changes to the Privacy Policy

Claned Group may change the Privacy Policy by posting an updated version to the Service. We will notify you of the changes on Claned Group website. Please visit this page regularly to learn about possible changes.

Should Claned Group introduce changes that have a material adverse effect on you, Claned Group will inform you when you start using the Service next time. Your continued use of the Service constitutes your acceptance of the modified Terms.