Lifedu Oy (hereinafter ”LifeLearn” or “us“, “our“ and similar expressions) offers a platform service for learning-related services and products (“Platform”). When a user of our service (hereinafter “you”, “your”, “yourself” and similar expressions) uses and/or registers for our service, we collect, use, share and store information on the user (“your information”) in the manner described in this policy. Below, we wish to inform you on how your information, and in particular any personally-identifiable information we may hold about you, is collected, used, stored, disclosed and removed (each and all referred to as “processing”). This policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
The Information We Process
We collect and process two types of information about users through the Platform:
1) Non-Personal Data
We may use tools or third party analytical software to automatically collect and use certain Non-Personal Data. The types of Non-Personal Data we may collect and use include, but are not limited to: (i) end user software and hardware profile information, including, for example, information on browser and operating system settings and version; (iii) general data on Platform usage trends and patterns; (iv) other Non-Personal Data as reasonably required by us to enhance the Platform and related products and services.
2) Personal Data
Situations where you make, or may make, Personal Data available to us include without limitation:
- (i) using and registering for the Platform, a Learning Path and/or an Add-on;
- (ii) making a transaction on the Platform for a service or product;
- (iii) sending us email messages or through other means of communications directed at us; or
- (iv) otherwise through the use of the Platform where personal data is required for use and/or participation.
The personal data we collect and process may include without limitation:
- Your name, email address and other contact details, date of birth as well as other personal details we may ask and you may provide us in the context of the Platform for purposes of identification, directing communications and use of the Platform;
- Details on your communications with us, including without limitation any messages, notifications, requests and similar sent to us by email, by using the Platform features or otherwise;
- Your account details and Platform activity information, including without limitation your account settings as well as enrolments, subscriptions and/or purchases related to Learning Paths, Add-ons or other services and products , or any other information related to your account;
- Credit or debit card information and/or other banking information;
- Your preferences in relation to different Learning Paths, Add-ons or other products and services, or for particular learning or lifestyle activities when you share such preferences with us, or when we make predictions on what they could be based on how you use the Platform.
Legal Bases of Processing
For the activities described in this notice, we rely on the following legal bases for processing personal data:
- Fulfilment of your requests prior to entering into a contract, for example, requests for information or quotation;
- Performance of a contract between you and us;
- Compliance with our legal obligations, such as data retention obligations related to accounting and taxation;
- Our legitimate interests to conduct and develop our business, where your interests and fundamental rights do not override those interests: This is the legal basis we mainly rely on for activities not covered by the above-mentioned legal bases, such as for managing our customer relationships as well as developing and marketing our products and services.
In individual cases, and where legally required, we may also rely on your separate consent. You may later revoke your consent at any time.
If you need details about the grounds we are relying on with respect to specific data or circumstances, please contact us as set out above.
How We Use Your Information
We may use and process your information to:
- Provide our services to you and to enable other users of the Platform to provide you with the services and products that you order or sign up for
- Manage your account, orders and your participation and subscription to Platform activities
- Invoice you for Platform-related products or services, and for debt recovery purposes
- Respond to any issues or inquiries you may have regarding the Platform or our services and provide you with information relevant to your use of the Platform, such as updates on scheduled downtime, new features or issues related to your subscriptions or orders on the Platform
- Contact you with offers or promotions based on how you use the Platform or inform you about other companies’ products and services we think may interest you – provided that we have obtained your consent for this where necessary
- Protect and maintain our network and the Platform, and to prevent, identify and repair any technical problems or security issues
- Prevent, detect and investigate fraud, money laundering, criminal activity or other misuse of the Platform
- Perform research and statistical analysis on the Platform, including observing how our customers use the Platform and the related products and services
- Better allocate our resources and enhance and improve the services provided to you and to other users of the Platform
After your account has been closed, we will stop processing and storing your Personal Data unless otherwise required by law, regulation or an order issued by a competent authority, or unless the retention of particular data is necessary for us in order to protect important interests or ours or those of third parties such as other users of the Platform, including without limitation to be able to present or defend against existing or potential claims or complaints; defend our rights or property or those of users of the Platform; comply with legal, regulatory or contractual responsibilities or obligations; or assist in or fulfil our obligations with respect to any ongoing or expected trial, legal proceeding or criminal investigation. We will retain your Personal Data only in the extent necessary for such purposes.
Please note that some of your Personal Data may be transformed by us to Non-Personal Data which we may continue to use, process and store after you cease to use the Platform. This information can be, for example, general-level data on the demographics or usage patterns of Platform users. Unless expressly agreed separately, we are not responsible for retaining your account information in the form enabling you to resume the use of the same account. As part of our services, we may offer the possibility for you to have some account information retained by us in encrypted form in case you want to resume the use of the Platform by providing us with a key known only to you. This service, however, will be subject to separate terms and conditions.
In order to optimize the products and services we offer, we reserve the right to make automated decisions, including using machine learning algorithms, about our customers and the content and services they offer or make use of.
How We Share Your Information
We may disclose your information to:
- Platform users, partners or agents engaging in the delivery of products or services you have ordered or subscribed to, or who assist in or carry out the processing of the transactions you make, such as payment service providers
- Companies who are involved in performing services for or on behalf of us in connection with our Platform service
- Debt recovery organisations engaging in debt recovery on our or your behalf or in connection to your use of the Platform
- Law enforcement agencies, courts, regulatory organisations or other public authorities if required or authorised to by law
We may also transfer your information to other third parties, if we need to counter or prevent any malicious or fraudulent actions, or to invoke any available legal remedies or to limit potential damage incurred to us, or if we sell, merge, de-merge or otherwise restructure our business operations and a new party becomes the owner of the information.
We may also share your information with carefully selected partner organizations, so they can let you know about their products and services – provided, however, that we have obtained your consent where necessary.
How We Secure and Store Your Information
- Our premises are physically protected with mechanical and electrical locks and other break-in prevention methods
- Our data connections utilise firewalls and protection from malicious programs, as well as other protection mechanisms and software which improve the security of our telecommunications and data connections
- Only designated persons and a limited amount of our personnel have access to the information. Our personnel have been trained to observe data security in their work.
We keep your personal data only as long as we have a legitimate business need to retain it for the purposes described above, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period, we consider the scope, nature, and sensitivity of the personal data we process, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data and the relevant legal requirements. We will also regularly assess the data we keep, and where we deem retention unnecessary, we will either erase or anonymize the data or, if this is not possible – for example, for information stored in backup archives – we will store the data securely and block any further processing until deletion is possible.
We will usually retain personal data related to a customer relationship only for the duration of the relationship and for a reasonable period thereafter in order for us to be able to respond to inquiries or pending issues related to the relationship. However, some data may be retained for longer where we believe retention is necessary for compliance with laws or regulations (such as in the fields of accounting and taxation), or to exercise, establish or defend our legal rights or those of our customers, affiliates or partners.
Your Rights as a Data Subject
You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed by us, and where that is the case, access to that personal data as well as to have any inaccurate or incomplete personal data rectified or completed. In certain circumstances, you may also have the right to request the erasure, or the restriction of processing, of your personal data or parts of it, to object to the processing and/or to receive the data in a structured, commonly used and machine-readable format.
Please contact us for any inquiries related to exercising the above rights.
If you consider our processing activities of your personal data to be inconsistent with applicable data protection laws, you may lodge a complaint with the responsible supervisory authority. Contact information for the supervisory authority in Finland can be found here: www.tietosuoja.fi
Changes to This Policy
We may update this notice from time to time in response to changing legal, technical or business developments. When we update this notice, we will strive to inform you in a manner consistent with the significance of the changes we make.
This policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Lifedu Oy (Business-ID: 2766985-5)
Otaniementie 9, 02150 Espoo, Finland
Otaniementie 9, 02150 Espoo, Finland