Privacy Statement
PRIVACY STATEMENT
Last updated April 05, 2022

Howya Solutions Oy (“Howya”, “we”, “our”, “us”) process personal data of their users of Howya’s wellbeing services (“Howya App”) and the visitors of the website howya.fi (“Website”).

In this Privacy Statement, the word “Howya” refers jointly to the Website and the Howya App. In this Privacy Statement, the word “User” or “you” refers jointly to our customers, representatives and other authorized users of our customer organizations, potential customers and the users of the Howya Services. Our Privacy Statement explains, for example, the types of personal data we process, how we process the personal data and how you may exercise your rights as a data subject (e.g. right to object, right of access).

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

This Privacy Statement may be updated from time to time in order to reflect the changes in data processing practices or otherwise. You can find the current version on the Website. We will not make substantial changes to this Privacy Statement or reduce the rights of the Users under this Privacy Statement without providing a notice thereof.

1. DATA CONTROLLER(S)
This Privacy Statement applies to processing of personal data carried out by Howya.

Howya Solutions Oy is an independent data controller and it is nominated to handle all the requests and questions which include Howya Solutions Oy’s privacy data.

2. HOWYA’S CONTACT DETAILS
Name: Howya Solutions Oy
Business ID: 3269215-2 
Correspondence address: Maneesikatu 1-3 D 30, 00170 Helsinki, Finland
E-mail address: support@howya.fi
howya.fi

Howya has appointed a data protection officer who you can reach through the above contact details.

3. PERSONAL DATA PROCESSED AND SOURCES OF DATA
The personal data collected and processed by us can be divided into two general data categories: User Data and Analytics Data.

User Data
User Data is personal data collected directly from you or from our customer organization on behalf of which you are using the Howya services (“Customer Organization”), as the case may be. We may collect User Data from our Users and Customer Organizations in a variety of ways, including, after conclusion of a service agreement with the Customer Organization or when Users first time signs to the Howya Services, subscribe to a newsletter or fill out a form.

User Data that is necessary in order to use the Howya Services
The following personal data collected and processed by us is necessary in order for a proper performance of the contract between you and us as well as for our legitimate interest whilst fulfilling our contractual obligations towards our Customer Organizations and for the compliance with our legal obligations.

After the conclusion of the service agreement between us and the Customer Organization, the Customer Organization provides us with your full name and email address.  

When you register to the Howya Services and sign to your user account, you need to provide us with the following information:
- Full name
- Email address 
- User Data you give us voluntarilyYour user or customer experience may be enhanced by providing us with the following information: 
Additional Account Information:
- Gender
- Profession
- Year of Birth
- Role

This information is used for analytical and development purposes. In addition, the role helps your organization to use the service.
Other Information. We may also process other information provided by you voluntarily such as:
- Information you provide when rating our services
- Marketing opt-ins and opt-outs
- Information you provide by phone or in email or chat correspondence with us

In addition to User Data collected from you and the Customer Organization, we process certain personal data third party service providers provide about you. 
Analytics Data
Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data.

We may automatically collect the following Analytics Data when you visit or interact with the Howya Services.
Device Information. We may collect the following information relating to the technical device you use when using the Howya Services:
- Device and device identification number, device IMEI
- Country
- IP address
- Browser type and version
- Operating system
- Internet service providers
- Visitor identifier
Usage Information. We may collect information on your use of the Howya Services, such as:
- Time spent on the Howya Services interaction with the Howya Services
- Information on your orders made through the Howya Services
- The URL of the website you visited before and after visiting the Howya Services
- The time and date of your visits to the Howya Services
- The sections of the Howya Services you visited
Cookies
We may use various technologies to collect and store Analytics Data and other information when the Users visit the Howya Services, including cookies and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify visitors of the Howya Services and facilitate the use of the Howya Services and to create aggregate information of our visitors. This helps us to improve the Howya Services and better serve our Users. The cookies will not harm your device or files. We use cookies to tailor the Howya Services and the information we provide in accordance with the individual interests of our Users.

The Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers: 
Safari Google Chrome Internet Explorer Microsoft Edge Mozilla Firefox

Please note that some parts of the Howya Services may not function properly if use of cookies is refused.

A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read. 
Web analytics services
The Howya Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Howya 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.
Visitor identifiers
The Howya Services may use pseudonymized identifiers to track and predict your app and service usage and preferences.

4. PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATAPurposes
There are several purposes of the processing of your personal data by Howya:

To provide the Howya Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)

Howya processes your personal data to be able to offer the Howya Services to you under the contract between you and Howya or between Customer Organization and Howya.

We use the data for example to provide your organization with the information necessary for getting the picture about organizational wellbeing status. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. 
For our legal obligations (legal ground: compliance with a legal obligation)
Howya processes data to enable us to administer and fulfill our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
Howya may process personal data in relation to claims handling and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.
For customer communication (legal ground: legitimate interest)
Howya processes your personal data to contact you regarding the Howya Services and to inform you of changes relating to them, for example in clear changes in our privacy statement.
For quality improvement, trend analysis, and further development of Howya services (legal ground: legitimate interest)
We may also process information about your use of the Howya Services to improve the quality of the Howya Services e.g. by analyzing any trends or changes in the answers provided by users. In order to ensure that our services are in line with your needs. When possible, we will do this using only aggregated, non-personally identifiable data. It is not in our interest to recognize any individuals and track them.
Legal grounds for processing
Howya processes your personal data to perform our contractual obligations towards you or the Customer Organization and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with easy to use opt-out from our marketing communications and use pseudonymized or non-personally identifiable data when possible. It is not in our interest to recognize any individuals and track them.

5. TRANSFER TO COUNTRIES OUTSIDE EUROPE
Howya stores your personal data primarily within the European Economic Area. However, we have service providers and operations in several geographical locations. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.

We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which they are 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 theStandard Contractual Clausesor through other appropriate safeguards.

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.


6. RECIPIENTS
We only share your personal data within the Howya Solutions Oy if and as far as reasonably necessary for the purposes of this Privacy Statement.
We do not share your personal data with third parties outside of Howya’s organization unless one of the following circumstances applies:
For the purposes set out in this Privacy Statement and to authorized service providers

Furthermore, we may provide your personal data to our affiliates or to authorized service providers who perform services for us (including data storage, accounting, sales) to process it for us.

When data is processed by third parties on behalf of Howya, Howya has taken the appropriate contractual and organizational measures to ensure that your data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations and subject to our instructions and appropriate obligations of confidentiality and security measures.

Please bear in mind that if you provide personal data directly to a third party, such as through a link in the Howya Services, the processing is typically based on their policies and standards.

Third party is an independent controller of the Personal Data and responsible for the lawfulness of its processing operations.
For legal reasons and legal processes
We may share your personal data with third parties outside Howya 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, crime, security or technical issues; and/or (iii) protect the interests, properties or safety of Howya, the Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
If Howya is involved in a merger, acquisition or asset sale, we may transfer your 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 the Users concerned when the personal data are transferred or become subject to a different privacy statement. 
With your explicit consent
We may share your personal data with third parties outside Howya when we have your explicit consent to do so. You have the right to withdraw this consent at all times free of charge by contacting us.

7. STORAGE PERIOD
Howya does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Howya Services or the relevant parts thereof. The storage period depends on the nature of the information and on the purposes of processing. The maximum period may therefore vary per use.

Most personal data relating to a User’s user account with the Howya Services will be deleted after a period of 90 days have lapsed after the User has deleted its user account with the Howya Services. Thereafter, a part of the personal data relating to a User’s user account with the Howya Services may be stored only as long as such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes. All personal data relating to a User’s user account with the Howya Services will be deleted within a period of 10 years after the User has deleted its user account with the Howya Services, with the exception of personal data required in certain rare situations such as legal proceedings.

To delete a user account, you can contact us in the following email address: support@howya.fi.

8. YOUR RIGHTSRight of access
You have the right to access and be informed about your personal data processed by us. We give you the possibility to view certain data through your user account with the Howya Services or request a copy of your personal data.
Right to withdraw consent
In case the processing is based on a consent granted by the User, the User may withdraw the consent at any time free of charge. Withdrawing a consent may lead to fewer possibilities to use the Howya Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You can correct or update some of your personal data through your user account in the Howya Services. 
Right to erasure
You may also ask us to delete your personal data from our systems. We will comply with such requests unless we have a legitimate ground to not delete the data. 
Right to object
You may have the right to object to certain use of your personal data if such data is processed for other purposes than necessary for the performance of the Howya Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the Howya Services.
Right to restriction of processing
You 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 the Howya Services.
Right to data portability
You have the right to receive the personal data you have provided to us yourself in a structured and commonly used format and to independently transmit those data to a third party.
How to use your rights
The abovementioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject or charge requests that are unreasonably repetitive, excessive or manifestly unfounded. 

9. LODGING A COMPLAINT
In case the User considers our processing of personal data to be inconsistent with the applicable data protection laws, the User may lodge a complaint with the local supervisory authority for data protection in Finland, the Data Protection Ombudsman (tietosuoja.fi).Alternatively, the User may lodge a complaint with the local supervisory authority for data protection of the User’s country of domicile. 

10. UPDATING THIS PRIVACY STATEMENT
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy statement, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy statement frequently to be informed of how we are protecting your information

11. INFORMATION SECURITY
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, pseudonymization, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability to restore the data. We regularly test the Howya Services, systems, and other assets for security vulnerabilities. Furthermore, access to personal data by employees of Howya is restricted and access is subject to what is necessary for purposes of the employee’s work assignments.

Should despite the security measures, a security breach occurs that is likely to have negative effects to the privacy of the Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

Howya Solutions Oy has been appointed responsible for handling all data subject requests and questions relating to the personal data processing.
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