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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 11.12.2020 - 11:33

Name of the register

Personal data register of Metropolia’s UniBuddy.com chat activities

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: Liisa Salo
Position: Head of Communications and Marketing
Address: Metropolia Ammattikorkeakoulu Oy, PO Box 4000, FI-00079 METROPOLIA
E-mail: liisa.salo [at] metropolia.fi
 

Contact details of the contact person for the register:

Name: Sirpa Rutanen
Position: Communications Specialist
Address: Metropolia University of Applied Sciences, PO Box 4000, FI-00079 METROPOLIA
E-mail: sirpa.rutanen [at] metropolia.fi
 

Contact details in questions concerning the purpose of the register:

Contact details in questions concerning the purpose of the register: viestinta [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 personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences and the personal data it contains is to provide interactive chat opportunities and general guidance for Metropolia’s potential international applicants. The chat will not deal with any sensitive and personal data, questions related to the admissions process and criteria, scholarships or application enclosures, in these matters, the person in concern is advised to contact the Admission Services: admissions [at] metropolia.fi

The chat services will be provided and implemented in Metropolia Communications and Marketing.

Legal basis for the processing of personal data:

The processing of the personal data contained in the personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences is based on consent obtained from the data subjects.

The following privacy notice supplements the privacy notice of personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences:

The privacy notice of personal data register of Metropolia’s public website (Metropolia.fi).

Legitimate interests of the data controller or a third party

The legal basis for the processing of personal data contained in the personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences is not “legitimate interests”. Therefore, this section does not apply.

Data recipients or recipient groups and regular disclosures

The data subjects in the personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences are potential interested applicants of Metropolia UAS, student ambassadors and employees of Metropolia UAS. 

The following personal data are stored in the personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences:

BASIC INFORMATION AND CONTACT DETAILS

  • Prospective students
    Basic information:
    forename(s), surname, gender, locality, email address, password, degree subject/level of interest, phone number, chat conversations and interactions with student ambassadors and staff.
  • Student ambassadors
    Basic information: forename(s), surname, gender, locality, email address, photo, language spoken, academic history, general information on degree studies and personal interests/hobbies, password, chat conversations and interactions with prospective students.
  • Staff members
    Basic information: forename(s), surname, gender, locality, email address, photo, password, chat conversations and interactions with prospective students.
  • Device specific information will be collected on all chat parties.
  • Potential interested applicants: The information you will be asked to provide to us for these purposes will include first name, last name, email address, password, country, the degree level you are interested in, (undergraduate/postgraduate), whether you have already applied to the university, and chat conversations and interactions with student ambassadors.

CONSENT FOR AND INFORMATION ON CERTAIN ACTIONS

  • Information on consent given for actions targeted at the data subjects in the personal data register of the Unibuddy.com chat activities of Metropolia for receiving advertising mail related to the marketing activities.
  • With the regard to Unibuddy users visits to Metropolia University of Applied Sciences’ public website, we may collect the personal data concerning the details of visits to our website (for example cookies).  The personal data collected by Metropolia University of Applied Sciences’ public website is descriped in the privacy notice of personal data register of Metropolia’s public website (metropolia.fi).
     
  • The personal data collected by the Unibuddy.com chat service:

-device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;

- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes;

-details of your visits to our Website, including the full Uniform  Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the Unibuddy widget.

Regular sources of personal data

The personal data are obtained from the data subjects themselves. 

Information systems used in the processing of personal data

The data contained in the personal data register of the Unibuddy.com chat activities of Metropolia University of Applied Sciences are processed using the various IT systems, applications and software procured by the Metropolia Communications and Marketing.

The various IT systems, applications and software used by Metropolia Communications and Marketing include:

Liana Cloud Email Marketing: Postiviidakko newsletter tool (communications about services and e.g. sending of invitations to events)

Information about the activities of the Metropolia Communications and Marketing and, for example, invitations to events (if the data subject has given their express consent for it in writing) are sent by email through the Postiviidakko newsletter sending system.

Metropolia’s email system

Information about the activities of the Metropolia’s Communications and Marketing and, for example, invitations to events (if the data subject has given their express consent for this in writing) are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.

Unibuddy.com chat 

-device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;

- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and

 details of your visits to our Website, including the full Uniform  Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the Unibuddy widget.

Description of the groups of data subjects and personal data groups

Access to the personal data contained in the Personal data register of Metropolia’s UniBuddy.com chat activities 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 the Metropolia’s Communications and Marketing, personal data processing agreements in accordance with Article 28 of the GDPR will be concluded by the Metropolia’s Communications and Marketing with the following cooperation partners:

Liana Technologies Oy; Postiviidakko newsletter tool (communications concerning the services of Metropolia’s application admissions and international student recruitment)

Information about activities related to the personal data register of  Metropolia’s Communications and Marketing and, for example, invitations to events (if the data subject has given their express consent for it in writing) are sent by email through the Postiviidakko newsletter sending system.

Microsoft Corporation; Metropolia’s email system

Information about activities related to the personal data register of  Metropolia’s Communications and Marketing and, for example, invitations to events (if the data subject has given their express consent for this in writing) are sent by email through Metropolia’s Microsoft Outlook Exchange email system. Although Metropolia has procured the email system as part of the Microsoft O365 service package, the system is operated on Metropolia’s own server.

Unibuddy Platform Ltd; Unibuddy.com chat service

Device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information. In addition, technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and details of your visits to our Website, including the full Uniform  Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the Unibuddy widget.

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

Personal data contained in the personal data register of the Unibuddy.com chat activities of Metropolia’s Communications and Marketing will not be transferred outside the EU or EEA or to international organisations.

Personal data retention times

The personal data collected for and processed within the personal data register of the Unibuddy.com chat activities of Metropolia’s Communications and Marketing are, as a general rule, stored in the register for a period of two years.

The retention period is based on the last interaction in the chat services.

The following regulations have been observed when determining the retention times:

- EU General Data Protection Regulation (“GDPR”, 2016/679)

- Data Protection Act (1050/2018)

- Universities of Applied Sciences Act (932/2014)

- Decision of the National Archives of Finland on retention times – order given to universities of applied sciences concerning the permanent storage of data in electronic format (AL/20757/07.01.01.03.02/2016)

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)

Not applicable.

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, 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
Fax: + 358 9 56 66735
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 in the personal data register of Metropolia University of Applied Sciences 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 account has been given for each register regarding how the personal data was obtained.

The personal data register of Metropolia’s UniBuddy.com chat activities of Metropolia University of Applied Sciences is based on voluntary registration and it is used to manage the activities and services of the Unibuddy.com chat at Metropolia University of Applied Scienses.

It is not compulsory to be registered in the personal data register of Metropolia’s UniBuddy.com chat activities of Metropolia University of Applied Sciences.

 The personal data stored in the register have mostly been collected from the data subjects themselves.

Automated individual decision-making, including profiling

The personal data register of Metropolia’s UniBuddy.com chat activities of Metropolia University of Applied Sciences and the data contained in it will not be used in automated decision-making or profiling.