Valo Motion Oy (“Valo Motion”) respects the privacy of its customer’s representatives and employees (“Customers”) and other users (“Users”) of Valo Motion products and services, including ValoClimb, an automatic and interactive game platform and the Valo Motion cloud platform at https://cloud.valomotion.com/, Valo Motion website at http://valomotion.com, and any Valo Motion social media channels (“Services”).
“Personal data” refers to data which allows the identification of an individual person (as defined and in compliance with the European Union’s General Data Protection Regulation 2016/679 and Data Protection Directive 95/46/EC). This is opposite to “non-personal data” meaning data that cannot be used to specifically identify any person.
We commit to adhere to the provisions of the aforementioned legislation and other such applicable laws and regulations pertaining to processing of personal data, as well as to process personal data in compliance with good data processing practice. All personnel processing personal data are obliged to keep such data strictly confidential.
TYPES OF DATA AND SOURCES OF PERSONAL DATA
Personal data may include:
- Information provided by Customer and required for the provision of our products and services, such as name and contact detail, including email address.
- Information provided by User and required for the provision of requested services, such as name and contact detail, including email address.
- Technically gathered online data, such as IP addresses.
You are likely to provide personal data also when you complete the subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, use the social media functionalities, or send any other electronic communications to us.
In addition to personal data, Valo Motion may collect non-personal data relating to the Services. This information includes either anonymous or anonymized data that is generated during the use of the Services. Such non-personal information may be collected by the Augmented Climbing equipment or systems that are integrated with the Services.
RETAINING OF PERSONAL DATA
The storage period depends on the nature of the information and the purposes of processing, and the maximum period may therefore vary per use. Further, Valo Motion will store the following categories of your personal data for the retention periods outlines below:
|Information required for the provision of our products and services||During your customer relationship and for a period of 6 years thereafter, unless a longer retention period is required by applicable laws.|
|Technically gathered data||During your subscription term in our Services and for a period of 6 years thereafter, unless a longer retention period is required by applicable laws.|
PURPOSE AND GROUNDS OF PROCESSING PERSONAL DATA
Users’ personal data may be used to:
- Provide our Services;
- Improve and personalize the Services, as well as to develop new products and services;
- Correspond with our Customers and Users regarding customer service issues;
- To enforce the contracts with our Customers and Users;
- Ensure the functioning and maintenance of the Services;
- Update Customers and Users with operational news and information about the products and services, and
Valo Motion processes personal data to perform our contractual obligations and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to maintain and develop our businesses.
DISCLOSING AND SHARING INFORMATION
Valo Motion will not disclose your stored personal data to third parties for direct marketing, market research, polls or public registers without your consent or except as part of a specific program or feature for which you will can opt-in or opt-out. Personal data might be used to email marketing by Valo Motion. You may opt-out of receiving promotional emails by following the instructions in those emails. If You opt-out, Valo Motion may still send you non-promotional customer information, such as emails about providing our products and services to you or our ongoing business relations.
We may share non-personal data (such as anonymous usage data, platform types, asset views, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality of the Services.
We may share personal data with third parties for other reasons than the one mentioned before, when we have the data subject’s explicit consent to do so. The data subject has the right to withdraw this consent at all times.
Third Party Services and Tools
In order to analyze and improve the Services Valo Motion may use tools provided by third party service providers to collect and use non-personal data. Users may decline the collection and storage of such data from their devices’ settings.
Valo Motion may disclose your personal data to its third-party service providers to enable them to provide their services to Valo Motion, including email, CRM and mobile payments providers.
COOKIES AND OTHER TRACKING TECHNOLOGIES
In addition to cookies, Valo Motion may use other now and later developed tracking technologies. Users will be notified of use of such tracking technologies.
Valo Motion does not enable third parties to collect any personal data on the Services’ users. However, in Valo Motion uses the following third-party data analytics platforms:
- Google Analytics, a web analytics service provided by Google, Inc. This information is anonymized by removing the last part of your IP address.
- Users may opt-in to allow Hubspot tools to track their use of our website. This service also gathers demographic information about them.
Valo Motion processes personal data on its systems in accordance to the applicable data protection legislation. We may also outsource the processing of personal data to a third party supplier or vendor, in which case we ensure through contractual measures that the personal data is processed appropriately and in compliance with the applicable data protection legislation. Valo Motion takes reasonable measures to protect personal data and to protect the data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, our Customers and Users should always keep in mind that no Internet transmission is 100% secure or free from errors.
The register will be maintained on external service providers’ servers with appropriate safeguards. The register is protected by appropriate industry standard, technical and organizational safety measures. Although Valo Motion makes good faith efforts to store the data collected from the Services in a secure operating environment that is not available to the public, Valo Motion cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Valo Motion will post a notice in the Services in case material security breach that endangers your privacy or personal data, and if necessary, will contact affected users directly. Valo Motion may also temporarily shut down the Services to protect the personal data.
RIGHTS OF DATA SUBJECTS
Right to access, correct and object
Data subject may contact us and we will inform what personal data we have collected and processed regarding the said data subject and the purposes such data are used for. Data subjects have the right to have corrected any incorrect, incomplete, outdated, or unnecessary personal data stored about the data subject by contacting us.
Data subjects may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services or for compliance with a legal obligation, such as direct marketing. Data subjects may also object any further processing of personal data after prior given consent. If data subject objects to the further processing of personal data, this may lead to fewer possibilities to use our Services
Right to deletion and restriction of processing
Data subjects may also ask us to delete the data subject’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.
Data subject may request us to restrict processing of certain personal data, this may however lead to fewer possibilities to use our website and other Services.
Right to data portability
Data subjects have the right to receive personal data provided by Users from us in a structured, commonly used format.
How to use the rights
These rights may be used by sending a letter or e-mail to us on the addresses set out below, including the following information: name, company, phone number and a copy of a valid ID. We may request the provision of additional information necessary to confirm the identity of the data subject. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case data subject considers our processing activities 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