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INTRODUCTION

 

REAL is an application provided Humap Software Oy (“Supplier”, “we”, “us”, “our”).  We are committed to protecting your privacy and to complying with applicable data protection and privacy laws.

REAL is a Software as a Service (SaaS) platform for consulting assignments. In its most typical use, a consultant invites a group of users from the customer organisation into a virtual workspace. Those users then interact with the consultant and each other over a period of time, through text, images, videos, and other content.

This Privacy Policy applies to personal data collected in connection with the REAL application, however accessed and/or used, whether via personal computers, mobile devices such as mobile device applications or otherwise (the “Service”). This Privacy Policy is a part of the Suppliers Terms of Service and should be construed together with the Terms of Service.

By using this Service and/or by submitting personal data to the Service, you express your consent to the processing of personal data about you in the manner provided in this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not use the Service or provide us with personal data about you.

 

1 - DATA PROVIDED BY YOU

 

The minimum user data required to invite a user into a workspace is either:

  1. Email address for an email invitation, or
  1. Mobile phone number for an SMS invitation

Typical additional user data that a consultant might deem relevant for engagement could include: 

  1. First name, and
  1. Last name of user, and
  1. Profile picture

If consultant utilises the dialogue widget by creating the organizational structure of the client organisation into the workspace, then the following user information will also be stored: 

  1. Name of direct superior
  1. Title or role
  1. Function or department 

Other information provided by you:

  1. Details of the queries, requests and other communication you have made,
  1. Financial details (including payments made, credit card details, billing address, credit checks and other such financial information), and
  1. Details of agreements between you and

 

2 - DATA WE COLLECT

 

A log of user demographics and actions is generated when a user visits the workspace and interacts with the content there.

User data from visits includes:

  1. IP address
  1. Operating system in use on device
  1. Web browser used to access workspace 

User data generated by user actions:

  1. Which chat & dialogue entries user has seen
  1. Which chat & dialogue entries user has liked or voted on (given stars to)
  1. How many pages of a PDF document user has seen
  1. Whether user has seen a particular video to the end
  1. All content created or uploaded by the user, be that text in a chat widget, uploaded file in file share widget, responses to a poll or survey question, or a booked slot in the booking widget

 

3 - USE OF YOUR DATA

 

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

  1. to set up and maintain your registration with the Service and to fulfil your requests;
  1. to provide features available in the Service;
  1. to ensure the security of the Service; 
  1. to operate, manage, develop and improve the Service;
  1. to personalize the Service;
  1. to communicate with you; and
  1. to audit and analyze the Service, including analyzing trends related to the use of the Service;
  1. to process any transactions you may enter into in the Service;
  1. for market research and direct electronic marketing in accordance with applicable law;
  1. to ensure the technical functionality and security of the Service;
  1. to protect our rights and/or our property and to prevent and investigate fraud and other misuses; and
  1. to comply with any mandatory legal requirements and/or in connection with law enforcement or other civil or criminal legal proceedings.

 

4 - SHARING OF YOUR DATA

 

We do not sell, lease, rent or otherwise disclose personal data about you to unauthorized third parties without your explicit consent unless expressly otherwise stated below.

We may provide personal data about you to third parties who work on our behalfd. Such parties are not permitted to use personal data about you for other purposes, and we require them to act consistently with this Privacy Policy and to use appropriate security measures to protect personal data about you.

We may transfer, assign and disclose personal data about you to our 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 Policy.

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.

 

5 - SECURITY OF YOUR DATA

 

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.

 

6 - LOCATION OF AND ACCESS TO USER DATA

 

All data is stored on Humap Software’s servers, located in France, and managed by OVH Hosting. Each workspace’s data is stored in an individual MongoDB database.

The only parties with access to user data included in a workspace are the administrators of said workspace.

Administrators of a workspace include:

  1. Original creator of workspace
  1. Other administrators invited by creator, be they consultants or client representatives
  1. Support entity representing HumapSoftware, automatically created in all workspaces
  1. Other administrators automatically created as requested by customer, e.g., keyuser(s)

Within Humap Software, all employees currently have access to the Support entity. This is to ensure level of service and redundancy. By customer’s request, the Support entity can, in individual workspaces, be replaced with a named support person from Humap Software.

In the next version of REAL the architecture will be different, and there will no longer be a Support entity created in every workspace.

 

7 - REMOVAL OF USER DATA

 

User data is stored in a MongoDB database for the workspace. When deleting an individual user from a workspace, user data is “soft deleted”, i.e., user data still remains in the MongoDB database.

User data (and all workspace data) is deleted only after workspace has been permanently removed. At this point the workspace database is deleted. 

After deletion of database, user data will remain in backup copies of the workspace database for approximately 6 months. Backup copies older than this are automatically removed from the backup system, and user data is completely and permanently deleted from the servers.

 

8 - COOKIES AND ANALYTICS

 

We may place a “cookie” on the hard drive of the device that you use to access the Service. Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling us to recognize your browser type and version for purposes such as saving your preferences and directing relevant content to you. Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, accepting them individually, and deleting saved cookies from your hard drive. We would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Service . Please also note that if you use the Service on a mobile device, we 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.

 

9 - CONTACT DETAILS

 

Your personal data is controlled by Humap Software Oy (2153753-6), Yliopistonkatu 36, 40100 Jyväskylä, Finland. Contact person for privacy matters is Kim-Mikael Arima, kimi.arima@humapsoftware.com.