This Privacy Statement is meant to inform how Interact collects, stores, processes, uses and protects personal information in the context of the keep.eu web service. This statement is also for informing the user about the user’s rights and how to contact Interact in case the user has any questions regarding the processing of personal information. The processing of personal data will be based on the principles stated in this Statement. However, there may be more detailed guidelines and privacy statements in keep.eu, such as banners and info screens, for highlighting some of the most important aspects of the processing of personal data.
If the user does not approve the processing of personal data according to this Statement and any other guidelines and privacy statements, the user may not be able to benefit from all aspects of keep.eu and, thus, the user may not be able to register to keep.eu.
1 Data Controller
The data controller is ELY Centre for Southwest Finland/Interact Office Turku (hereinafter referred also as “Interact” or “we”).
2 Register matters
For inquiries regarding the processing of personal data, you may contact us by e-mail: firstname.lastname@example.org.
The general data protection officer for ELY centres in Finland may be contacted by e-mail: email@example.com.
3 Name of the register
Interact register for users of keep.eu and project partners.
4 The purpose of personal data processing
This Privacy Statement will be applied to persons who use the keep.eu website (and any applications thereof). As the content of keep.eu is mainly for professional purposes, Interact does not, in general, aim keep.eu at children.
Interact processes personal data from the following sources:
1. Processing of personal data collected from the registered users
2. Processing of personal data collected from the use of keep.eu
3. Processing of personal data received from the programmes/project partners
Interact may collect personal data considered as necessary for identifying the user. The personal data is collected from the user himself/herself but it may also originate from programmes/project partners as described below.
Interact delivers newsletters, event information and communication letters to registered users. All such communication will include instructions on how to unsubscribe such communication in the future. In case a user decides to unsubscribe, Interact may still provide email communication in case it is necessary for any of the legitimate purposes and compliance obligations.
5 Regular information sources and types of information collected by Interact
The processing of personal data is first and foremost based on the consent received from users. In case a user erases his or her consent Interact will not process the data any further and any and all data will be erased unless the processing is in Interact’s legitimate interests (such as administering user account or contacting the user), or processing is necessary for complying with any legal obligation.
I Data received from the data subject
I.1 Keep.eu user’s personal information
Personal data relating to a user are mainly collected from the user and from user’s interactions with Interact. Interact collects the e-mail address and account credentials, such as password, of a person registering to keep.eu. Once registered, the e-mail address will be used for creating and administering the user account and for communication with the registered user, such as posting newsletters and information on upcoming events and developments in keep.eu. Registered users may unsubscribe the newsletter by informing Interact.
I.2 Own and third-party tracking technologies
II Data received from programmes and public sources
Interact receives information and documents from programmes. The information and documents may contain e-mail addresses of persons involved in projects and communicated to Interact. Information may also originate from a publicly available source. Once the e-mail address is received, Interact will send to the e-mail address information on the purpose of the processing of the e-mail address and also how to terminate the processing.
The above-mentioned sending of information will be made in connection with the need to guarantee the accuracy of the data in keep.eu. Interact systematically sends e-mail messages to all the project partners’ e-mails listed in the keep.eu database to guarantee, as much as possible, that those e-mail addresses are working.
If not notified otherwise, Interact will allow users registered in keep.eu who are in search of project partners to contact any of the project partners with e-mails listed in keep.eu. This contact is made possible exclusively through a web form. In no circumstance, other than those lawfully admitted and described in this privacy statement, will Interact disclose the e-mails listed in the keep.eu database.
6 Regular information disclosure
Interact Office Turku may disclose information to other Interact Offices and to data processors which process the data on behalf of Interact. In case keep.eu is transferred to another legal person the personal data may be disclosed in the context of the transfer. The data processors are companies providing hosting and maintenance services for keep.eu web service. The data processors are located in the European Union or in the European Economic Area (EEA). Unless otherwise instructed in the Privacy Statement, Interact shall not disclose the personal data to other third parties without the consent of the data subject unless it is required by law or it is required for the reporting and auditing procedures to which Interact is subjected.
7 Storage and securing of personal information
Personal data are collected to databases protected with firewalls, passwords and with other technical and organisational procedures for protecting the data from illegal and unauthorised use and deletion of the data. All personal data are saved and processed on servers that are located in the European Union or in the EEA. If the data are processed exceptionally outside of the European Union or of the EEA, Interact will confirm the compliance with personal data regulation with respect to all transfers. In addition, Interact will adopt adequate standard contractual clauses with respect to all transfers to third countries.
Interact will retain the personal data only as long as the data subject remains as a registered user or as long as it is necessary for fulfilling Interact’s contractual and legal obligations, including answering and defending any claim or legal dispute, and also as long as the processing is in the legitimate interest of Interact.
8 The rights of the data subject
The user as a data subject has the right:
1) To access their own personal data and to rectify inaccurate or incomplete data. Requests for review must be in writing. Requests for rectification must specify the data to be rectified;
2) To have their personal data erased (“the right to be forgotten”);
3) To object the processing of personal data in certain situations;
4) To restrict the processing of their personal data;
5) To object to the disclosure and processing of their data for direct marketing and other marketing.
More information about the rights of a data subject is provided in www.tietosuoja.fi. The data subject has the right at any time to lodge a complaint with the appropriate supervisory authority in the country where the data subject lives, works or where the claimed breach has taken place. In Finland, this authority is the Data Protection Ombudsman (www.tietosuoja.fi).
9 Changes to the Record of Processing Activities
This Privacy Statement may be updated or changed if it is necessary. The latest version will be accessible in keep.eu. Continuing the use of keep.eu will be considered as approval of the amended sections. All updates will be informed duly.