GDPR PRIVACY NOTICE TEMPLATE
Last updated [December 1, 2020]
Thank you for choosing to be part of our community at Iotas Oy (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
<![if !supportLists]>1. <![endif]>WHAT INFORMATION DO WE COLLECT?
<![if !supportLists]>2. <![endif]>HOW DO WE USE YOUR INFORMATION?
<![if !supportLists]>3. <![endif]>WILL YOUR INFORMATION BE SHARED WITH ANYONE?
<![if !supportLists]>5. <![endif]>DO WE USE GOOGLE MAPS?
<![if !supportLists]>6. <![endif]>HOW DO WE HANDLE YOUR SOCIAL LOGINS?
<![if !supportLists]>7. <![endif]>IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
<![if !supportLists]>8. <![endif]>WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
<![if !supportLists]>9. <![endif]>HOW LONG DO WE KEEP YOUR INFORMATION?
<![if !supportLists]>10. <![endif]>HOW DO WE KEEP YOUR INFORMATION SAFE?
<![if !supportLists]>11. <![endif]>DO WE COLLECT INFORMATION FROM MINORS?
<![if !supportLists]>12. <![endif]>WHAT ARE YOUR PRIVACY RIGHTS?
<![if !supportLists]>13. <![endif]>DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
<![if !supportLists]>14. <![endif]>DO WE MAKE UPDATES TO THIS POLICY?
<![if !supportLists]>15. <![endif]>HOW CAN YOU CONTACT US ABOUT THIS POLICY?
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.
When your are using our wearable app i247Care we collect indoors and outdoors location, but also all the wellfare information available; pulse, activity, step counts.
We collect personal information that you voluntarily provide to us when registering at the i247c.com or in i247Care apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites [(such as posting messages in our online forums or entering competitions, contests or giveaways)] or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.
Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "Social Logins" [LINK] below.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. Find out more: www.iotas.fi/privacy
In Short: We may collect information regarding your geo-location, mobile device, push notifications, and Facebook permissions when you use our apps.
If you use our Apps, we may also collect the following information:
<![if !supportLists]>· <![endif]>Geo-Location Information. We may request access or permission to and track location-based information from your mobile and wearable device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
<![if !supportLists]>· <![endif]>Wellfare Information. Our i247Care wearable app collects and shares you welfare information based on your selection to your own group account. The app collects indoor and outdoor location, pulse, general activity and steps count data.
<![if !supportLists]>· <![endif]>Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
<![if !supportLists]>· <![endif]>Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
<![if !supportLists]>· <![endif]>Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.]
<![if !supportLists]>· <![endif]>Facebook Permissions. We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
<![if !supportLists]>· <![endif]>To facilitate account creation and logon process [with your Consent]. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "Social Logins" for further information.
<![if !supportLists]>· <![endif]>To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).
<![if !supportLists]>· <![endif]>To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
<![if !supportLists]>· <![endif]>Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
<![if !supportLists]>· <![endif]>To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [INSERT CONTACT] and be sure to include your name, testimonial location, and contact information.
<![if !supportLists]>· <![endif]>Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
<![if !supportLists]>· <![endif]>Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.
<![if !supportLists]>· <![endif]>To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
<![if !supportLists]>· <![endif]>To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user's consent.
<![if !supportLists]>· <![endif]>To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
<![if !supportLists]>· <![endif]>To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
<![if !supportLists]>· <![endif]>For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
<![if !supportLists]>· <![endif]>For Care, Safety and Wellfare Sharing Purposes. We use wearable App to collect location and sensor (pulse, activity and step count etc.) data for care, safety and welfare sharing purposes inside your group with your consent. Your group is allowed to see your welfare data, events amd alarms to care purposes.
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
<![if !supportLists]>· <![endif]>Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
<![if !supportLists]>· <![endif]>Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
<![if !supportLists]>· <![endif]>Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short: Yes, we use Google Maps for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). We will be collecting the following information: user name and location etc. See
For a full list of what we use information for, please see the previous sections titled “Use of Your Information” and “Disclosure of Your Information.” [You agree to allow us to obtain or cache your location. You may revoke your consent at anytime.] [We use information about location in conjunction with data from other data providers.]
[The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our EU User Consent Policy, which can be found at this link: [link from question].]
In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites offers you the ability to register and login using your third party social media account details (like your Instagram, Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. [If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.]
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Azure North Europe (Ireland) and West Europe (Netherlands).
If you are accessing our Sites from outside EU, please be aware that your information may be transferred to, stored, and processed by us in our services in Finland and in EU and by those third parties with whom we may share your personal information (see "Disclosure of Your Information" above), in Finland and other EU countries .
European Commission's Standard Contractual
Such measures implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site [and App]. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
In Short You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm]
You may at any time review or change the information in your account or terminate your account by:
<![if !supportLists]>· <![endif]>Logging into your account settings and updating your account
<![if !supportLists]>· <![endif]>Contacting us using the contact information provided below
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:
<![if !supportLists]>· <![endif]>Noting your preferences at the time you register your account with the Sites.
<![if !supportLists]>· <![endif]>Logging into your account settings and updating your preferences.
<![if !supportLists]>· <![endif]>Contacting us using the contact information provided below
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the [Sites/ Mobile Application/ Facebook Application], you have the right to request removal of unwanted data that you publicly post on the [Sites/ Mobile Application/ Facebook Application]. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the [Sites/ Mobile Application/ Facebook Application], but please be aware that the data may not be completely or comprehensively removed from our systems.
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
If you have questions or comments about this policy, email us [Our Privacy Officer] at [INSERT CONTACT EMAIL] or by post to:
[City, State Zip]
[If you are a resident in the European Economic Area, the "data controller" of your personal information is [INSERT NAME OF THE COMPANY]. [COMPANY, has appointed [INSERT NAME] to be its representative in the EEA. You can contact them directly regarding the processing of your information by COMPANY, by email at [INSERT CONTACT EMAIL] or by post to: [INSERT ADDRESS].]
If you have any further questions or comments about us or our policies, email us at [CONTACT EMAIL] or contact us by post at:
CrazyTown Kauppakatu 39,
40100 Jyväskylä, Finland