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.
Name of the register
Personal data register of Metropolia’s Living Game Intelligence Network
Metropolia University of Applied Sciences Ltd
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 (suvi[dot]kiviniemi[at]metropolia[dot]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 (suvi[dot]kiviniemi[at]metropolia[dot]fi)
Contact details in questions concerning the purpose of the register: suvi.kiviniemi [at] metropolia.fi (suvi[dot]kiviniemi[at]metropolia[dot]fi)
Data Protection Officer
Riikka Ikäheimonen, Metropolia’s Data Protection Officer
Tel: +358 50 565 8499
Email: tietosuojavastaava [at] metropolia.fi (tietosuojavastaava[at]metropolia[dot]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
- Analytical data, e.g., number of visitors; location (country); browser type; time spent on site and pages visited; source of visit. 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 .
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.
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
As a general rule, personal data contained in the <em>personal data register of the xx activities / project of Metropolia </em>will not be transferred outside the EU or EEA or to international organisations.
However, personal data contained in the personal data register may be transferred outside the EU or the EEA in order to provide IT services necessary for work or study, on a case-by-case basis. The destination country to which the personal data is transferred then, is mainly the United States. It is also possible that India is the destination country as global ICT service providers use often India as a host country for the international helpdesk service / ICT technical user support. International transfers of personal data from the Metropolia University of Applied Sciences' personal register to the United States and / or elsewhere outside the EU / EEA are primarily secured then by the safeguard provided for in Article 46 of Chapter V of the EU General Data Protection Regulation (GDPR), standard contractual clauses. The SCC (Standard Contractual Clauses) clauses will be included as part of the personal data processing agreement to be drawn up with the ICT service provider. Only the necessary data will be transferred and the transfer will be made in accordance with and within the limits set by data protection law. The security and data protection of the transfer are always agreed separately.
<em> (-> If you use IT systems, softwares etc. provided by IT service provider registered in United States /outside the EU/EAA, it might be possible that the IT service provider uses servers for the data storage located in United States /outside the EU/EEA -> This might mean that personal data will be transferred to United States/ outside the EU/EEA as the storing of personal data is considered as processing of personal data according to the GDPR, and as storing personal data into the data storage servers located outside the EU/EEA, is considered as transferring personal data outside the EU/EEA according to the GDPR).</em>
<em>If that is the case, you need to specify to which third countries outside the EU or EEA you are transferring personal data <strong>(list of countries/mapping of countries).</strong></em>
<em>When mapping transfers, do not forget to also take into account onward transfers, for instance whether your processors outside the EEA transfer the personal data you entrusted to them to a sub-processor in another third country or in the same third country. In other words, you must know where the personal data you exported may be located or processed by the importers <strong>(map of destinations).</strong></em>
<em>Keep in mind that remote access from a third country (for example in support situations) and/or storage in a cloud situated outside the EEA, is also considered to be a transfer. More specifically, if you are using an international cloud infrastructure you must assess if your data will be transferred to third countries and where, unless the cloud provider clearly states in its contract that the data will not be processed at all in third countries.</em>
<em>As a next step, you must <strong>identify the transfer tools (safeguards)</strong> you are relying on amongst those described in the Chapter V of the GDPR (Articles 45 - 49). </em>
<em>Article 46 of the Chapter V of the GDPR lists<strong> standard contractual clauses (SCCs)</strong> as a transfer tool containing “appropriate safeguards” for the data transfer.</em>
<em>Whatever GDPR transfer tool you choose, you must ensure that, overall, the transferred personal data will have the benefit of an essentially equivalent level of protection. <strong>“An essentially equivalent level of protection”</strong> means that the transferred personal data is afforded a level of protection in the third country that is essentially equivalent to that are guaranteed in the EEA where strict data protection legislation prevails. </em>
<em>It might be useful to contact Data Protection Officer of Metropolia UAS (</em><a href="mailto:firstname.lastname@example.org"><em>email@example.com</em></a><em>; </em><a href="mailto:firstname.lastname@example.org"><em>tietosuojavastaava@metropo…;) in a case considering international personal data transfers outside the EU or EEA.</em>
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.
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 (tietosuoja[at]om[dot]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 enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequen
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.