upiopi - Privacy and Cookies Policy
Version: June 7, 2021
General
We respect the privacy of our customers and users. However, in order to provide our platform and services relating to online out-of-school programs, we need to collect and process personal data of customers and users of the service. We process personal data in compliance with this privacy policy and applicable laws, so we ask you to read this policy carefully. We may do updates to this privacy policy from time to time associated with development of our business operations or changes in applicable laws. Updated privacy policy can be found from our website, so we ask you to visit this page from time to time.
Data controller
Education House Finland Oy
Business ID: 3005310-3
VAT ID: FI30053103
Haahkatie 3 A 13
00200 HELSINKI
Finland
upiopi.com
Email: learn@upiopi.com
You can use the above contact information for privacy related matters as well.
Data about children
Children may use our service when participating in out-of-school activities and programs, even if an adult (i.e. parent, guardian) is required for registering an account and purchasing a class enrollment. When purchasing a program, the parent/guardian at the same time provides the name (or alias) and the birth date of the child who will be taking part in the program.
For what purposes is personal data collected and used?
We collect, store and process your personal data only for predefined purposes. The main purposes for processing personal data are:
Provision of the online out-of-school programs and platform
We collect and process personal data for offering and providing the Upiopi.com online service and fulfilling contractual rights and obligations (incl. handling of payments). The service requires purchasing of class enrollment and creation of personal user accounts.
We may also use personal data for handling support and contact requests.
The legal basis for this processing is a contract between us and the customer (or preparations for a contract) as well as our legitimate interest.
Marketing and customer communication
We may process personal data for customer communication and notifications.
We may process personal data also for direct marketing purposes, for personalizing advertising and content as well as for developing customer and user segments.
Based on our legitimate interest we may also send email marketing messages. If it is required by law, we ask for your consent for it, which you may then withdraw at any time. Even if marketing would not require your consent, you can always prohibit direct marketing targeted to you.
We may use third party services for customer communications and marketing activities.
The legal basis for this processing is especially our legitimate interest, sometimes also a person’s consent.
Analysing the use of the service and developing our business
We aim to constantly develop the service. This requires analyzing and monitoring the use of the service.
We also use personal data for improving the quality of the services, for resolving technical issues and for data security purposes.
We may also use third party services providers for analysis and monitoring purposes.
The legal basis for this processing is especially our legitimate interest.
Fulfilling legal obligations and other legal reasons
We may also use personal data for fulfilling legal obligations, responding to legal claims or preparing them, fraud prevention and detection and also if required by a court or an authority.
The legal basis for this processing is fulfilling legal obligations, partly also our legitimate interest.
What is the legal basis for processing personal data?
We may process your data on several different legal grounds. Firstly, we may process your data to fulfill and execute a contract, such as deliver and collect payments regarding ordered services. Secondly, we may process your data also to further our legitimate interests, which are especially handling customer feedback, developing our online offering and website marketing analytics. With consent (if required by law) we may send you email newsletters and marketing messages. Finally, we may also process your personal data to fulfill legal obligations, such as bookkeeping and requests made by authorities.
From which sources is personal data collected?
We collect personal data about customers and users mainly from the customer or user itself when contacting us or purchasing our services. We may also collect personal data about our website visitors with Google Analytics or other similar analytics services to analyze our website use, develop it further and for targeting relevant marketing content for our customers and website visitors.
What personal data do we collect?
We collect and process especially the following information relating to our online store customers and users:
Website users and visitors:
website user
ip address
type of device
location / country
email address (website visitor who enters the address to our online chat)
website browsing history / data
Registered users:
name
email address
child's name and birth date (user of the service)
direct marketing opt-in / opt-out
possible communication history
User who has purchased paid services:
billing address
shipping address (when ordering materials)
order history
The third party services providers we use for handling payments may also store personal data for their own purposes during the payment process.
Who processes your personal data and is it transferred to anyone else?
Primarily your personal data is processed by people within our own organization. However, some subcontractors may process or have access to our personal data based on agreements we have with them. In these situations, we make sure especially contractually that the confidentiality of your personal data is secured and data is otherwise processed lawfully. We may also disclose information to fulfill our other contractual or legal obligations or when a legal authority requires a disclosure. We may also disclose your personal data if we are a party of a business sale, such as a merger or an acquisition.
Educational organizations and teachers offering their programs on our platform may process your personal data also as a data controller for their own program and teaching purposes subject to their own privacy policies. Such processing may not however be in conflict with the principles described herein.
Is personal data transferred outside the EU?
Personal data may be transferred outside the EU/EEA, as for instance some of our service providers (e.g. cloud storage) may be located outside the EU. In these situations we ensure that data is transferred outside the EU with adequate safeguards, e.g. by using the Standard Contractual Clauses published by the EU Commission.
How long is personal data stored?
We will not store your personal data for a longer period than is necessary for its purpose or required by contract or law. The storage times for personal data may vary based on its purpose and the situation.
How is personal data stored and kept secure?
Your data is stored on servers, which are secured according to general industry standards and practices. We consider and keep your personal data confidential and do not disclose it to other than those who need it for their work or confidentially to our subcontractors based on contracts we have made with them.
Is it mandatory to provide personal data?
If you don’t provide us with some of your personal data or allow processing of it, it is very likely that we cannot serve you and fulfill the purpose of our business, as we sell services online. The use of our service requires registration and purchase of paid programs, so it is mandatory to provide some amount of personal data in order to be able to use our services. If you don’t want us to process your data, we ask you to not provide us any personal data.
What rights do you have relating to your personal data?
Withdraw your consent
If we process personal data based on your consent, you can at any time withdraw your consent by notifying us, for instance by sending email to us to the address provided above.
Access to data
You have the right to have confirmed if we are processing your personal data and also to know what data we have about you. In addition, you have the right to some supplemental information described in the law about the processing activities.
Right to have errors corrected
You have the right to request that we correct any inaccurate or outdated personal data we have about you.
Right to prohibit direct marketing
You have the right to request that your personal data is not processed for direct marketing purposes by sending us an email to the address provided above.
Right to object processing
If we process your personal data based on public interest or our legitimate interest, you have the right to object processing of your data, to the extent that there is no such significant other reason that would override your rights or the processing is not necessary for handling legal claims. Please notice that in this situation we may not be able to serve you anymore.
Right to restrict processing
In certain situations you have the right to require that we restrict processing of your personal data.
Right to data portability
If we process your personal data based on your consent or fulfillment of a contract, you have the right to require transfer of the data you have provided to us to another services provider in a commonly used electronic format.
How can you use your rights?
You can execute and use your rights by contacting us, for instance by sending email to us. Please note that we may need to verify your identity before we can perform the actions you are requesting. If you consider that the processing of your personal data is not lawful, you can always also make a notification to a supervisory authority (tietosuojavaltuutetun toimisto).
Can this privacy policy be updated?
We may make updates to this privacy policy when our operations change or develop. Also changes in law may make it necessary to update this privacy policy. The changes become valid once we have published them in the form of an updated privacy policy. Therefore, please visit this page and read this privacy policy from time to time.
Cookies and third party applications
We use essential cookies to run our online store and out-of-school platform. We also use non-essential cookies to analyze the use of our website and for targeting content and advertising on our website or on third party channels, such as search engines and social media.
What are cookies?
Cookies are small text files that are placed on a web user’s computer and are designed to hold a modest amount of data particular to a user and a website. Cookies give information about how users use our website. Usually it is not possible to recognize a person or the user of the website from the data contained in cookies, but if you have previously registered as a user on our website or we otherwise have already personal data about you, the data from the cookies may be incorporated with such data. Therefore, sometimes data in the cookies may be considered as personal data.
You can change your cookie preferences in the cookie settings bar that is presented to you when visiting our website.
Third party cookies and applications on our website
When using our website, we may run third party applications and certain third party services providers may store cookies on your device for the purposes of website and marketing analytics and development as well as targeting of content and advertising. These may include services providers such as Google Analytics, Google Tag Manager, Google Ads, Facebook and other similar services providers and marketing networks. Some of these may be located outside the EU. More information about the cookie and privacy policies of these services providers can be found from their website. We are not responsible for their data processing practices. Third party advertising targeting can also be managed on Your Online Choices website.
Important websites
Google Analytics tracking management and opt-out >>
Google Ads tracking management >>
We may update our practices relating to cookies due to changes in our business practices or in applicable laws.