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This Privacy Notice is based on the EU's General Data Protection Regulation (2016/679, “GDPR”), namely the obligation to inform the data subjects (GDPR Articles 12–14), the data controller's obligation to maintain a record of processing activities under its responsibility (GDPR Article 30), as well as the obligations set out in the Finnish Data Protection Act (1050/2018) supplementing the GDPR.

Additionally, this Privacy Notice has been prepared with the aim of making it accessible in accordance with the requirements of the EU's Web Accessibility Directive (Directive (EU) 2016/2102 of the European Parliament and of the Council on the accessibility of the websites and mobile applications of public sector bodies) and the Finnish Act on the Provision of Digital Services (306/2019) supplementing it.

 

Submitted on 31.8.2021 - 11:51

Name of the register

Personal data register of Metropolia’s Living Game Intelligence Network

Data controller

Name:

Metropolia University of Applied Sciences Ltd

Contact information:

Metropolia University of Applied Sciences Ltd (Business ID: 2094551-1)

Postal address: P.O. Box 4000, FI-00079 Metropolia

Visiting address: Myllypurontie 1, 00920 Helsinki, Finland

Telephone (switchboard): + 358 9 7424 5000

Person responsible for the register at the data controller:

Name:         Riitta Konkola

Position:      President, CEO of Metropolia University of Applied Sciences

Person responsible for the content of the register:

Name: Suvi Kiviniemi

Position: Project Specialist

Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA

E-mail: suvi.kiviniemi [at] metropolia.fi

Contact details of the contact person for the register:

Name: Suvi Kiviniemi

Position: Project Specialist

Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA

E-mail: suvi.kiviniemi [at] metropolia.fi

Contact details in questions concerning the purpose of the register: suvi.kiviniemi [at] metropolia.fi

 

Data Protection Officer

Tuulia Aarnio, Metropolia’s Data Protection Officer
Tel: +358 40 844 0690
Email: tietosuojavastaava [at] metropolia.fi

Purpose and legal basis of the processing of personal data

Purpose of the processing of personal data:

The purpose of the Living Game Intelligence Network register is to manage the information needed to organise the field of business and manage partner, student, employee, customer, and visitor information.

Living Game Intelligence Network (LGIN) organises mentoring, education, peer support and incubation for game entrepreneurs and people willing to become game entrepreneurs. It is operated by Metropolia University of Applied Sciences.

The purpose of processing personal data of the data subjects registered in the project register of LGIN, are:

  • processing activities in relation to communication and information activities of LGIN
  • processing activities in relation to financial reporting of LGIN
  • manage the contact information of the financiers of LGIN
  • manage the contact information of the external co-operation partners (enterprises and organizations and their contact persons) of Metropolia
  • organize startup-business and startup-business support in relation to LGIN
  • manage and organize game industry related events, workshops, education and different kinds of meetings and activities for the individuals, companies and organizations interested in game entrepreneurship
  • collect feedback and collect survey information in relation to the activities performed by LGIN
  • understanding the background and behaviour of LGIN website visitors

The controller processes the information in house, as well as subcontracting parties to process the data on the controller’s behalf.

Legal basis for the processing of personal data:

The processing of the personal data contained in the LGIN register is partly based on the consent obtained directly from the data subject as they have given consent to the processing of their personal data for one or more specific purposes. This basis is relevant to all members of the LGIN network, including mentors and team members.

The processing of the personal data contained in the LGIN register is partly based on the processing necessary for the performance of an employment or other contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract. This basis is relevant in the case of employment contracts, partner contracts, co-operation contracts etc.

Consent is used as the legal basis for the processing of special categories of personal data contained in the register as well as the processing of sensitive personal data, such as biometric data (e.g. facial photos, video material collected from the events, workshops, education activities etc. in which persons are identifiable). This basis is relevant for anyone participating LGIN events.

Legitimate interests of the data controller or a third party

Doesn’t apply to this register.

Data recipients or recipient groups and regular disclosures

The data subjects in LGIN register are consented members of the network, students of Metropolia, employees of Metropolia, partners of LGIN, corporate partners of LGIN, financiers of LGIN activities, game related event participants, workshop visitors and education activity enrollees (participants) and customers of LGIN.

 

In general, the personal data contained in the LGIN register may include, among others, the first name and surname and possible contact details of a data subject who has agreed to be a part of the network or registered for one of the controller’s events, as well as other data recorded for the events.

 

Registration details entered personally by the data subject may include the following, among others: email, telephone number, address, date of birth, billing details and dietary requirements.

 

The following personal data is stored in the personal data register of LGIN:

 

BASIC INFORMATION AND CONTACT DETAILS

  • forename; family name;
  • birthday;  birth month; birth year;
  • address; postal code; city;
  • telephone number; email address

 

CONSENT FOR AND INFORMATION ON CERTAIN ACTIONS

consent for receiving newsletter mail related to the LGIN activities

Information in relation to game related event enrollees/participants, workshop visitors, education activity enrollees/participants, data subjects of a LGIN meeting:

  • enrollee’s/participant’s forename; last name;
  • information in relation to related event/workshop/education activity and/or meeting, time and place

 

INFORMATION IN RELATION TO A SURVEY/QUERY/RESEARCH /FEEDBACK OPTION/COACHING SESSION ORGANIZED BY LGIN

  • forename and family name of a data subject giving feedback to LGIN
  • forename and family name of a participant of a survey/query/research organized by LGIN
  • information in relation to the subject/name of the survey/query/research/feedback option/coaching session organized by LGIN, time and place
  • information in relation to the content/answers given and submitted for a survey/query/research /feedback option/coaching session organized by LGIN, time and place

 

PHOTOGRAPHS AND VIDEO MATERIAL

  • Volunteers may be photographed or (video)filmed during events, workshops and educational activities organized by LGIN
  • The data subjects will be informed and asked to consent photographing or video filming prior to photographing or video filming activity

 

Information in relation to performing activities with collaborators, partners, financiers of LGIN:

 

BASIC INFORMATION AND CONTACT DETAILS

  • collaborator’s/ partners’ name/organization; name of the contact person of the collaborator/partner; email address of the contact person; title of the contact person within organization

 

ANALYTIC DATA OF WEBSITE VISITORS

Regular sources of personal data

The personal data are obtained from the data subjects themselves.

Additionally, the controller collects personal data related to the purpose of use of the personal data register, generated as part of the controller’s operations. Within the bounds of applicable legislation, personal data are collected from sources in the public domain, as well as from other third parties, such as companies in the same group and other contractual partners.

Information systems used in the processing of personal data

The data contained in the LGIN register is processed using the various IT systems, applications and software procured by Metropolia University of Applied Sciences and/or by LGIN.

 

The various IT systems, applications and software used by the controller include:

Eventbrite event management system

The enrolment process for the game related events, meetings, workshops and educational activities are being organized by using Eventbrite event management system.

 

G Suite for Education

The personal data processed within Metropolia's LGIN register is being managed by Google's so-called G Suite for Education toolkit included in the educational application package. Personal and contact information, tables and feedback information from the data subjects is being processed by Google Drive cloud storage tool. Also, other Google-based tools are being used to process images, videos and research survey answers received from LGIN’s data subjects.

Metropolia’s email system and CRM (Microsoft Office 365 Education and Dynamics 365)

The employees of Metropolia’s LGIN are using Metropolia’s email system and CRM to manage and organize work tasks. Although Metropolia has procured the email system as part of the Microsoft Office 365 Education service package, the system is operated on Metropolia’s own server.

LianaMailer

LGIN’s newsletters are sent using LianaMailer or abovementioned Microsoft Dynamics 365. Newsletters are sent only if the data subject has given their express consent for this processing activity.

Microsoft TEAMS (Microsoft Office 365 Education)

The employees of Metropolia’s LGIN are using Microsoft Teams for internal communication within LGIN and other Metropolia actors. Microsoft Teams has been procured to Metropolia as part of Microsoft Office 365 educational application package. Also, other Microsoft -based tools are being used to process information within the tasks and work assignments of the LGIN.

Zoom

LGIN’s online events, meetings, workshops, and educational activities are organised using the Zoom video conference tool.

Dynasty case and contract management system

Contracts relating to Metropolia’s LGIN are managed through the Dynasty case and contract management system.

Reportronic and Halli project management systems

Reportronic and Halli project management systems are used for processing data about the activities of LGIN.

Wordpress –web pages

Public webpages of LGIN are constructed and published by using Wordpress tool kit. LGIN’s web pages are operated on Metropolia’s own server.The LGIN’s employees contact information is being published in the LGIN’s web pages. Personal information of LGIN members is published on the webpages with their express consent.

Google Analytic tools

Public webpages of LGIN use Google Analytics to analyse our visitor data. For more information, visit http://www.google.com/analytics/learn/privacy.html. To opt out, install Google’s browser add-on: https://tools.google.com/dlpage/gaoptout .'

Description of the groups of data subjects and personal data groups

Access to the personal data contained in LGIN register will be given, where necessary, in the systems listed below. (For the purpose of repairing a technical fault, for example, access will be given with administrator rights to the system provider or to the maintenance personnel of a measurement device.) All system/equipment/software providers used (the companies behind them) can be deemed to be recipients of personal data and recipients of regular disclosures from the register.

With respect to the systems used by LGIN register Data Processing Agreements in accordance with Article 28 of the GDPR will be concluded by Metropolia with the following cooperation partners:

Eventbrite, Inc. and Eventbrite event management system

The enrolment process for the events, meetings, workshops and educational activities are being organized using Eventbrite event management system.

 

Google LLC and G Suite for Education

The personal data processed within Metropolia's LGIN register is being managed by Google's so-called G Suite for Education toolkit included in the educational application package. Personal and contact information, tables and feedback information from the data subjects is being processed by Google Drive cloud storage tool. Also, other Google-based tools are being used to process images, videos and research survey answers received from LGIN’s data subjects.

 

Microsoft Corporation and Metropolia’s email system and CRM (Microsoft Office 365 Education and Dynamics 365)

The employees of Metropolia’s LGIN are using Metropolia’s email system to manage and organize work tasks. Although Metropolia has procured the email system as part of the Microsoft Office 365 Education service package, the system is operated on Metropolia’s own server.

 

Microsoft Corporation and Microsoft TEAMS (Microsoft Office 365 Education)

The employees of Metropolia’s LGIN are using Microsoft Teams for internal communication within LGIN and with other Metropolia actors. Microsoft Teams has been procured to Metropolia as part of Microsoft Office 365 educational application package. Also, other Microsoft -based tools are being used to process information within the tasks and work assignments of the LGIN.

 

Innofactor Oyj and Dynasty case and contract management system

 

Contracts relating to Metropolia’s LGIN are managed through the Dynasty case and contract management system.

 

Sebitti Oy and Reportronic project management system

 

Reportronic project management system is used for processing data about the activities of LGIN.

 

Thinking Portfolio Oy and Halli project management system

 

Halli project management system is used for processing data about the activities of LGIN.

 

Automattic Inc. and Wordpress web pages

 

Public webpages of LGIN are constructed and published by using Wordpress tool kit. LGIN’s web pages are operated on Metropolia’s own server. The LGIN’s employees contact information is being published in the LGIN’s web pages. Personal information of LGIN members is published on the webpages with their express consent.

 

Zoom Video Communications Inc. and Zoom video conference tool

 

LGIN’s online events, meetings, workshops, and educational activities are organised using the Zoom video conference tool.

 

Liana Technologies Oy and LianaMailer

 

LGIN’s newsletters are sent using LianaMailer or abovementioned Microsoft Dynamics 365. Newsletters are sent only if the data subject has given their express consent for this processing activity.

 

Google Analytic tools

 

Public webpages of LGIN use Google Analytics to analyse our visitor data. For more information, visit http://www.google.com/analytics/learn/privacy.html. To opt out, install Google’s browser add-on: https://tools.google.com/dlpage/gaoptout .

 

Transfer of information outside the EU or EEA or to international organisations

Personal data from LGIN’s register is not habitually transferred outside the EU or EEA, nor processed outside the EU or EEA, unless this is necessary for the technical implementation of the processing (for example if the technical maintenance of systems is located outside the EU or EEA), or in order to manage international functions related to the purpose of use of the project register.

In transferring personal data, the controller complies with the standard contractual clauses approved by the European Commission in relation to the transfer of personal data to third-party countries, or alternatively implements other appropriate safeguards, or alternatively ensures that the third-party country can guarantee a sufficient level of data protection.

Personal data retention times

When the data collection is based on consent, the personal data collected for and processed within LGIN register will be immediately removed upon request. When data collection is based on a contract, such as an employment contract or a collaboration contract, the data will be stored for as long as the contract stands.

The controller of the data file regularly evaluates the need for storing data in accordance with its internal practices. The personal information in the project register is only stored for as long as and to the extent that each category of data is needed, proportionate to the purpose of processing of the personal data.

Rights of the Data Subject

The data subjects have the right to receive confirmation from the data controller of whether their personal data are being processed. Furthermore, the data subjects have the right of access to their personal data and the right to inspect their personal data stored in the register and to receive copies of them. Under the GDPR, the data controller must respond to requests by the data subjects to exercise their rights within one month of receiving such a request.

A. Right of access to personal data

The data subjects have the right to check whether their personal data are stored in the personal data register. A data subject may submit a request for information by delivering the data subjects’ information request form, which can be found on Metropolia’s public website and/or Metropolia’s intranet, to one of the three offices of Metropolia’s Student and Admission Services. The form must be filled in carefully, printed and signed personally by the data subject. If the data subject is a member of staff, they can deliver the request form to Metropolia’s Human Resources Management unit. When submitting the request, the data subject must prove their identity in a reliable manner (for example by presenting an official personal identity document or driving licence to the Metropolia employee receiving the request).

 

The visiting addresses of the offices of Metropolia’s Student and Admission Services are:

 

Metropolia’s Myllypuro campus

Myllypurontie 1, 00920 Helsinki, Finland

 

Metropolia’s Arabia campus

Hämeentie 135 D, 00560 Helsinki, Finland

 

Metropolia’s Myyrmäki campus

Leiritie 1, 01600 Vantaa, Finland

 

The visiting address of Metropolia’s Human Resources Management unit is:

 

Metropolia’s Myllypuro campus (Buildings C and D, 5th floor)

Myllypurontie 1, 00920 Helsinki, Finland

 

 

All information requests will be forwarded from the offices of Metropolia’s Student and Admission Services and/or the Human Resources Management unit to Metropolia’s Data Protection Officer (email: tuulia.aarnio [at] metropolia.fi, tietosuojavastaava [at] metropolia.fi).

Metropolia’s Data Protection Officer will respond to information request submitted by the data subjects. If necessary, the Data Protection Officer can be requested to provide additional information on progress in the processing of the request or on the content of the response.

 

B. Right to rectify personal data and to restrict processing

The data subjects have the right to request the data controller to restrict the processing of their personal data in the following cases:

the data subject disputes the correctness of their personal data (right to rectify personal data), in which case processing will be restricted until the data controller can ascertain that the data is correct;

processing violates the law and the data subject objects to the erasure of their personal data, instead requesting that the processing of the data be restricted;

the data controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to establish, exercise or defend a legal claim.

Such a request for rectifying personal data in a Metropolia personal data register or restricting processing can be submitted in person to one of the above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

C. Right to erase personal data

The data subject has the right to obtain from the controller the erasure of their personal data from a Metropolia register without undue delay if any of the following conditions are met:

 

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

the data subject withdraws consent on which processing is based and there is no other lawful basis for processing;

the personal data have been unlawfully processed; or

the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

 

Such a request for the erasure of personal data in a Metropolia personal data register can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

 

D. Right to data portability (transfer of data from one system to another)

Partly applicable. Article 20 of the General Data Protection Regulation (GDPR) introduces a new right of data portability of a data subject. This right allows for data subjects to receive the personal data that they have provided to a data controller, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller without hindrance. The new right to data portability aims to empower data subjects regarding their own personal data, as it facilitates their ability to move, copy or transmit personal data easily from one IT environment to another (whether to their own systems, the systems of trusted third parties or those of new data controllers).

In accordance with Article 20(1)(a) of the GDPR, in order to fall under the scope of data portability, processing operations must be based:

 

- either on the data subject’s consent (pursuant to Article 6(1)(a), or pursuant to Article 9(2)(a) when it comes to special categories of personal data);

 

- or, on a contract to which the data subject is a party pursuant to Article 6(1)(b).

 

 The GDPR does not establish a general right to data portability for cases where the processing of personal data is not based on consent or contract.

 

Such a request pursuant to Article 20 of the GDPR can be submitted in person to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity in a reliable manner when submitting the request.

 

E. Right to not be subjected to a personal data breach

The data subject has the right to not be subjected to a personal data breach, as referred to in Article 33 of the EU’s General Data Protection Regulation, due to the data controller’s negligence in data protection and/or data security matters or due to negligence on the part of a data processor used by the controller in data protection and/or data security matters. The data subject has the right to be informed without undue delay if a personal data breach is likely to pose a high risk to the rights and freedoms of natural persons.

Right to Object

According to Article 21 of the EU’s General Data Protection Regulation, the data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on point (e) of Article 6(1) (processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), such as profiling based on these provisions. The data controller may no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

The request to stop processing of collected personal data can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services or Metropolia’s Human Resources Management unit (staff only), where the data subject must prove their identity when submitting the request.

Right to withdraw consent

If the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw their consent for processing at any time without the withdrawal of consent affecting the lawfulness of processing based on consent before its withdrawal.

The withdrawal of consent for the processing of personal data collected by Metropolia (withdrawal request) can be submitted to one of the three above-mentioned offices of Metropolia’s Student and Admission Services (or in the case of a member of staff, to the Human Resources Management unit), where the data subject must prove their identity when submitting the request.

Right to lodge a complaint with a supervisory authority

Every data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of their personal data infringes the applicable data protection regulations.

 

The national supervisory authority in Finland is the Office of the Data Protection Ombudsman. Contact details:

Office of the Data Protection Ombudsman

Street address: Lintulahdenkuja 4, 00530 Helsinki, Finland

Postal address: PO Box 800, FI-00531 Helsinki

Telephone (switchboard): + 358 29 56 66700

Registry: +358 29 566 6768

Email: tietosuoja [at] om.fi

Registry Security Principles

General description of the technical and organisational security measures aiming at protecting the personal data of the data subjects and the personal data registers at Metropolia:

  • The data controller (Metropolia) and the system providers have agreed on the protection of the register. If necessary, the responsibilities have been described in adequate detail in the appropriate agreements.
  • The employees and other personnel of the data controller (Metropolia) have undertaken to comply with the obligation of secrecy and to keep confidential the information they receive in connection with the personal data processing.
  • The system providers (personal data processors that act on behalf of the data controller, Metropolia) undertake to maintain the register and the personal data relating to it in accordance with good data processing practices and comply with the obligation to absolute secrecy and confidentiality.
  • The data security of the personal data register of the data controller (Metropolia) and the confidentiality of the data contained therein are ensured with appropriate technical and administrative means in accordance with good data processing practices.
  • The data controller (Metropolia) has restricted user rights and authorisations to data systems, tools and other storage platforms in such a way that they can only be accessed and processed by the persons who are necessary for such processing due to their job duties or position.
  • The system containing personal data may only be used by employees who are entitled to process personal data due to their job duties and/or position. Such employees will be given the appropriate training for their duties.
  • Every user of a tool/system must identify themselves with their personal codes, which are issued when the right to access the tool/system is granted. The right of access will expire once the employee resigns or is transferred from the duties for which they were granted the right at Metropolia.
  • The data are collected in databases that are protected logically and physically.
     
  • The databases and their back-up copies are located in locked premises, and the data can only be accessed by certain pre-appointed persons.

Information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to e

Information on whether the provision of personal data for processing activities of the project register of the LGIN, is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data:

An explanation has been given for each register regarding how the personal information was obtained.

Personal data of the data subjects registered in the project register of the LGIN is based on voluntary registration and it is used to manage the activities and services of the LGIN.

It is not compulsory to be registered in the personal data register of LGIN.

The personal data stored in the project register have mainly been collected from the data subjects themselves. However, the controller collects personal data related to the purpose of use of the personal data register, generated as part of the controller’s operations. Within the bounds of applicable legislation, personal data is collected from sources in the public domain, as well as from other third parties, such as companies in the same group and other contractual partners.

Volunteers may be photographed or (video)filmed during events, workshops and educational activities organized by LGIN. The data subjects will be informed and asked to consent to photographing or video filming prior to photographing or video filming activity.

Automated individual decision-making, including profiling

The data register of Living Game Intelligence Network of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.