Privacy Policy

Sopiva.io Oy (“Sopiva”, “we”, “us”, “our”) is committed to protecting your privacy and to complying with applicable data protection laws. Personal data means information relating to an identified or identifiable individual (i.e. a natural person). This Privacy Notice applies to personal data collected in connection with the beta testing of the Sopiva service, however accessed and/or used (the “Service”). If you do not agree with how your personal data is processed when using the Service, please do not use the Service or provide us with personal data about you. Please acknowledge that this Privacy Notice applies to personal data that is processed by Sopiva as a data controller. It does not apply to such personal data that is collected and processed by a third party through the use of the Service (e.g. an employer who is using the Service and with whom you interact through the Service). With respect to such personal data, that third party acts as data controller under applicable data protection laws. The processing of personal data in such case is not controlled by us, and such third party is solely liable for appropriate and legal processing of your personal data performed by them. Moreover, this Privacy Notice does not apply to any access to third parties’ content and/or services which you may encounter when you use the Service. The collection, use and disclosure of any personal data by any third parties will be subject to such third parties’ applicable privacy policies/notices. We encourage you to carefully familiarize yourself with any applicable third party privacy policies. Please be aware that we are not responsible for the privacy practices of any third parties.

2.1 Data you provide

When you use the Service, we collect data that you provide to us directly. For example, when you use or register for the Service, we may ask you to provide us with registration information, such as your name, email address, as well as user names, passwords and other such credentials that are used to authenticate users and to validate their actions or that may be needed to provide you access to the Service. Part of this data may also be provided, at your choice, from a third party (such as Google/Alphabet) when you log in to the Service. When logging into the Service using a third party authentication provider you can make choices on some of the information you choose to share with us. Some personal data may be required for the proper functioning of the Service, or for us to be able to provide the Service to you at all, and if you choose not to give this data to us, you may not be able to use the Service. In addition, we may collect or ask for information relating to your use of the Service and other interactions with us. Such information may include, for example, details of your use of the Service, its functionalities and content and third party services accessed through the Service. We may also process records of contacts and communications between you and us, as well as information and details relating to the content you have provided us with.

2.2 Data Collected Automatically

Certain information may be collected automatically as a standard part of your use of the Service. Such information includes, for example, your IP-address, location, access times, functionalities you used and content you accessed, information about your devices such as (but without limitation) device type and model, unique ID and operating system version of the device, and other such technical information your device provides us with or as may be otherwise collected in connection with your use of the Service. Please also note we may store data from the Service in your device’s local storage for caching purposes. We may use third party data analytics service providers, such as Google Analytics, which help us understand usage patterns of the Service. We may permit these service providers to use cookies and other technologies to perform their services for us. Usage information and personal data are stored by such service providers and are subject to their privacy policies. The current list of data analytics service providers we use in connection with the Service can be requested from us at any time by contacting us at privacy@sopiva.io.

Your personal data may be processed for the following purposes and to the extent necessary for that purpose:

• to set up and maintain your registration with the Service and to fulfil your requests;

• to provide functionalities available in the Service;

• to ensure the security of the Service;

• to operate, manage, develop and improve the Service;

• to personalize the Service;

• to communicate with you; and§

• to analyze the Service, including analyzing trends related to the use of the Service;

• for market research and direct electronic marketing in accordance with applicable law;

• to protect our rights and/or our property and to prevent and investigate fraud and other misuses; and

• to comply with any mandatory legal requirements and/or in connection with law enforcement or other civil or criminal legal proceedings.

The legitimate grounds for processing your personal data are either compliance with the agreement entered into between us and you, our legitimate interest, compliance with legal obligations to which we are subject or your consent as further described in the examples below.

• Contractual obligations: Processing of your personal data to certain extent is necessary to enable us to fulfil the agreement we have concluded with you. For example, when you subscribe to our Service, it is necessary for us to process your personal data so that we can carry our contractual obligations so that you can use the Service.

• Our legitimate interest: We process your personal data based on our legitimate interest in particular to analyze and improve the Service as well as for administrative purposes and to preventing and resolving possible misconduct.

• Consent: Based on your consent, we can process your location and personal data to send you direct electronic marketing.

The provision of your personal data as described in this Privacy Notice is partially a contractual requirement. For example, when you subscribe to the Service, you are required to provide us with certain personal data for processing purposes specified in this Privacy Notice. Failure to provide us personal data may prevent us from performing our contractual obligations, which may lead to you being unable to use our Service.

Through the Service you may interact with and disclose personal information to our customers, for example when you apply to a job and as part of the recruitment process. To the extent our customer processes such information, or directs us to process such information, our customer is the controller for that information. We may provide personal data about you to third parties who work on our behalf. Such parties are not permitted to use personal data about you for other purposes. Certain functionalities of the Service require that the personal data about you are transferred to third parties (such as when you apply to a job through the Service and personal information is transferred to a prospective employer). Such third parties may be located anywhere in the world, and thus personal data about you may be transferred across international borders outside the country of your residence and/or the country where you use our Service, including to countries outside the European Economic Area that do not have similar laws providing specific protection for personal data or that have different legal rules on data protection. We may be obligated by mandatory legislation to disclose personal data about you to certain authorities, such as law enforcement agencies. We may also process personal data about you in case needed to defend our legitimate interests in civil or criminal legal proceedings or to prevent and investigate fraud and other misuses. We may transfer, assign and disclose personal data about you to our future subsidiaries and affiliates or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock and/or assets or in connection with bankruptcy proceedings or other corporate reorganization, in accordance with this Privacy Notice. Moreover, we may disclose information to third parties in an aggregate and/or anonymized format that does not constitute personal data and does not allow the identification of individual users.

We recognize our responsibility to protect the personal data and other information you have provided us. We take reasonable technical and organizational information security measures to safeguard personal data about you against loss and misuse, as well as unauthorized access. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

In case you wish to know what personal data we hold about you, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us through the contact points referred to below. Also, in case you wish to rectify any incomplete, incorrect or outdated personal data, you may, as appropriate and in accordance with applicable law, exercise such rights by contacting us through the contact points referred to below. You also have the right at any time to request us to erase personal data concerning you and processed by us and we are obliged to erase the data if there is no longer a legal ground for processing the data. Also, in some cases, you have the right to object to the processing of your personal data if the data has been processed on the basis of our legitimate interest, and we are obliged to stop processing such personal data unless we can demonstrate compelling legitimate grounds for further processing of such personal data. You have also the right to opt out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us through the contact points referred to below. In addition, you as a data subject have the right to file a complaint with the competent supervisory authority regarding our processing of personal data.

The Service is not directed to children younger than 16-years of age. We do not intend to collect personal data from children under 16. If you are under 16, please do not use the Service and do not send any information about yourself to us.

Your personal data is controlled by Sopiva.io Oy, privacy@sopiva.io.

We may from time to time change this Privacy Notice. We recommend that you revisit this Privacy Notice from time to time to learn of any changes. If you at any time disapprove of how we process your personal data, we ask you to cease from using the Service.