1. General

Sympa Oy (“we”, “us”, “our”) is committed to protecting the confidentiality and privacy of the personal data entrusted to it. This Privacy Policy applies to personal data collected by us in connection with the Sympa Pulse mobile application (the “Application”). This Privacy Policy describes what kind of personal data we receive and collect through your use of the Application and how we process your personal data. Personal data means information about you, which can be used alone, or in combination with other data, to identify you personally.

By using the Application, you agree with the information practices described in this Privacy Policy. Please note that we may periodically update this Privacy Policy, which is why we recommend that you occasionally review this Privacy Policy for any changes. We will use reasonable efforts to notify you of any changes in advance.

2. Data controller and data protection officer

Sympa Oy (business ID 1938597-5) is the data controller of personal data collected in the Application. Sympa Oy’s contact details are: Teknobulevardi 3–5, 01530 Vantaa, Finland, tel. +358 290 001 200.

Sympa Oy’s data protection officer is Tommi Surakka, ICT Manager. The data protection officer’s contact details are: [email protected]

3. What personal data do we collect and how?

3.1 Personal data submitted by you

Please note that the use of the Application is not possible without signing up by using your Microsoft Office 365 corporate account. When you log in to the Application, it connects you with your place of work (the “Organisation”) so that you are able to provide anonymous content and participate in anonymous surveys with other members of your Organisation’s personnel.

When you sign up to the Application we ask you to provide your name, email address and the name of your Organisation. Accessing or using the Application is not possible without you providing us the aforesaid information. We do not ask you to provide us any other personal data. If you use the group functionality of the Application, we will also collect information about the group, such as the name of the group and the members of the group.

3.2 Personal data collected through your use of the Application

We may collect certain personal data about you that we receive automatically when you use the Application. We may use cookies and similar technologies to collect such data (for more information on this see Section 9 below).

Such data relates to your mobile phone or other device and your use of the Application, and includes the following technical information: your IP address, device identifier and access times of your use of the Application. Furthermore, such data includes details pertaining to your use of particular features of the Application and the content you provide in the Application.

4. Purpose of processing your personal data

The processing of your personal data is based on (1) the performance of a contract between you and us regarding your use of the Application and (2) our legitimate interests, in particular providing services and information to you and providing direct marketing to you. Upon your consent, we may send marketing communications via email to you.

We process your personal data to:

  • provide, personalize and improve the Application;
  • ensure technical functioning of the Application, develop new features, functionalities and provide support;
  • perform research, analyze and compile statistical information about the use of the Application; and
  • communicate with you for purposes related to user relationship management (e.g. support, newsletters, etc.); and
  • use the data to send you promotional material and other marketing communications relating to our products and services (See further information in Section 11).

5. Sharing your personal data with third parties

We respect the confidentiality of your personal data. We will not sell your personal data or make it commercially available to any third party. We will not disclose your personal data to any third parties.

We may transfer your personal data with our subcontractors involved in the provision of the Application for the purposes set out in Section 4. In case we transfer your personal data to third parties, we will ensure that the data are transferred only to the extent necessary and only for the purposes set out in this Privacy Policy.

We will not share your personal data with your Organisation and will only share the content you provide in the Application anonymously with other users of the Application, including your Organisation.

6. Transfers of personal data outside the EU or EEA

We may transfer your personal data outside the European Union or the European Economic Area in accordance with the data protection legislation. We will only transfer your personal data outside the European Union or the European Economic Area in accordance with one of the legal grounds described below:

  • the recipient country is regarded by the European Commission to provide adequate protection for your personal data;
  • we have put in place appropriate safeguards for the transfer by using the model contracts for the transfer of personal data to third countries issued by the European Commission. You may receive a copy of these contracts by contacting us at the address set out in Section 14; or
  • you have given your consent to the transfer, or there is another legal basis for the transfer under the data protection legislation.

7. Security of your personal data

Our personnel have no general access to your personal data. Access to your personal data is limited to our or our subcontractors’ authorized personnel, for instance, in connection with the supply of support services relating to the Application. We have ensured that such personnel do not process personal data on a wider basis than required for the production of the Application.

We have implemented security technologies and measures to protect and prevent your personal data from unauthorized access, use and disclosure.

8. How long do we store your personal data?

We will retain your personal data for the period of time required for the processing purposes set out in this Privacy Policy. We will in any case remove your personal data, at the latest, one year after you last used the Application.

We may store some data for a longer time, if this is required by applicable laws. In such case, we will ensure that your personal data will continue to be processed in accordance with this Privacy Policy.

9. Information about cookies and similar technologies

Cookies are small text files that a website saves on your computer or mobile device when you visit the site. They enable websites to remember your actions and preferences, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. Cookies also help to record and analyze usage statistics, which in turn can be used to improve the website’s offering.

We use cookies to record and analyze usage statistics to improve the user experience of the Application.

We use Google Analytics to analyse how users use the Application. Google Analytics is a web analysis service that works using cookies. Google Analytics is provided by Google Inc. (“Google”). Please note that the cookies placed by Google are subject to the terms and information practices of Google and you may find more information about them at https://www.google.com/policies/privacy/partners/.

You have the option to manage your cookie preferences through, for example, your web browser or your mobile device’s settings. You may accept, block or delete all or certain cookies. Please note that if you choose to block cookies, this may prevent the proper functioning of the Application.

10. Third party services and external websites

The Application may contain cookies or links to third party websites through which your information may be processed by such third party. Please note that we do not control, and are not responsible for, the content or practices of such websites, which are also subject to their own terms and privacy policies.

11. Right to prohibit processing of personal data for direct marketing purposes

We will send you advertising and other marketing communications by email, if you have given your consent to such communications. You have the option to unsubscribe from such marketing communications and prohibit us from processing your personal data for direct marketing purposes at any time. You can exercise this right by following the instructions in the marketing email or by contacting us in person, by post or by email at the address set out in Section 14 of this Privacy Policy.

12. Your other rights

You have the right at any time and in accordance with applicable data protection legislation to:

  • request access to your personal data;
  • request the rectification or erasure of your personal data;
  • request us to update, remove and correct your personal data;
  • object to our use of your personal data to the extent the processing is based on our legitimate interest;
  • request the restriction of processing of your personal data; and
  • receive your personal data in machine-readable format and transfer such data to another controller, where you have provided the personal data to us and where the processing of such data is based on the performance of a contract.

You can exercise any of your rights above by contacting us in person, by post or by email at the address set out in Section 14 of this Privacy Policy. We may request you to specify your request in writing and to authenticate your identity before handling your request. Should we be required to do so by an applicable law.

13. Right to make a complaint

If you are unhappy with the way we process your personal data, you have a right to make a complaint to the competent supervisory authority responsible for monitoring compliance with the applicable data protection legislation.

14. Contact details

Should you have any questions or concerns about how we use your personal data or this Privacy Policy in general, or should you wish to exercise your rights, please contact us at:

Sympa Oy
Teknobulevardi 3–5
01530 Vantaa, Finland
+358 290 001 200

Contact person:
Tommi Surakka
ICT Manager
+358 50 4308360
[email protected]