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This privacy policy (“Privacy Statement”) provides information on how The Startup Shortcut Oy (“The Shortcut” or “we”) collects, processes, transfers, and stores personal data of our customers, partners, and visitors (“Users” or “you”) of our website www.theshortcut.org whilst providing our services to you. This Privacy Statement is dated 02.05.2022.
The Shortcut processes your personal data with due care, in accordance with all applicable laws and regulations, including the European Union General Data Protection Regulation (2016/679).
This Privacy Statement explains what personal data we process, how we process the personal data and how you may use your legitimate rights as a data subject (e.g. right to object, right of access). This Privacy Statement may be updated from time to time. You can find the current version on our website www.theshortcut.org. This Privacy Statement applies to all personal data that The Shortcut processes during the execution of our services, including the personal data of visitors of The Shortcut website.
This Privacy Statement only covers personal data processing carried out by The Shortcut or its possible processors. The Privacy Statement does not address, and we are not responsible for, the privacy practices of any third parties.
The Shortcut collects two types of information of our Users: (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify you as an individual, you can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.
The personal data is mainly collected from the Users themselves when they, for example, contact us regarding our services or fill in a form required for the provision of our services. In addition, we may also receive and collect personal data on our Users (e.g. name and contact details) from other sources, e.g. from Uusimaa TE office or from our other partners.
We may collect and process the following User Data about our Users (“User Data”):
The Shortcut Spark Academy
B.Y.O.B / DMP (Be Your Own Boss, Digital Marketing Program or another program supervised by the ELY Centre)
We receive the below information mainly from the Uusimaa TE Office when you apply for the project through their website.
Työ-SIB
We receive the below information from the Työ-SIB program (S-Pankki, TE Office, through Kuntakokeilu or when you contact us directly. For more information on the program: https://tyosib.fi/en/.
Partners
From our partners, we collect the name and contact details of our partners’ representatives. Further, we also collect details of any transactions and payments our partners may carry out in connection with our services.
Events, Talent Community and other
We may collect your personal data in a variety of ways, including, when you subscribe to a newsletter, join our Talent Community, join one of our events or fill out a form. We will collect such personal data from you only if you voluntarily submit such information to us.
We and/or our authorized third-party service providers may collect technical data when you visit or interact with our services or website (“Technical Data”). Technical Data may include the browser name, the type of computer or device, time spent on website, URL of the website you visited before and after visiting the website, the time and date of user visits, surfing habits, IP address, operating system and the Internet service providers utilized and other similar technical information.
Cookies
We use various technologies to collect and store information when you visit The Shortcut website, including cookies. Cookies allow us to calculate the aggregate number of people visiting our website and to monitor the use of the website. This helps us to improve our website and enables us to serve our Users better. We also use cookies that make the use of the website easier for you, for example by remembering usernames, passwords and (language) preferences. We also use tracking and analytics cookies to see how well our services are being received by our Users. Additionally, we use anonymous cookies to track information on your browsing history on our website, and third-party advertising networks, such as Meta Ads and LinkedIn Ads, use the information to serve ads to you on The Shortcut’s behalf on other sites throughout the Internet.
You may choose to accept or refuse cookies through the banner when entering our website. If you choose to refuse cookies, note that this could affect your experience of our website as some parts of our website and services may not function properly.
Our website uses Google Analytics and other web analytics services to compile reports on visitor usage and to help us improve our website and services. For an overview of Google Analytics, please visit http://www.google.com/analytics/.
There are several purposes of the processing of your personal data by The Shortcut:
Carry out our agreement with you or our other partners (legal basis: performance of a contract)
The Shortcut processes your personal data to fulfill our obligations under the agreement concluded with you when you e.g., apply for the Työ-SIB, B.Y.O.B, or DMP program and to handle matters related to your participation in the relevant program. Further, we only process your personal identification number when it is necessary to uniquely identify the User in order for us to implement the rights and duties as the data controller e.g., in order to be able to comply with our obligations under agreements concluded with third parties such as the S-Pankki Pääomarahastot Oy.
To comply with our legal obligations (legal basis: fulfilling a legal obligation)
We process your personal data to administer and fulfill our legal obligations. For example, we may process the data to fulfill our bookkeeping obligations and to provide information to competent authorities such as tax authorities.
To provide our services (legal basis: legitimate interest)
The Shortcut also processes your personal data to be able to deliver our services to you and to run, maintain and develop our businesses. We use the personal data for example to provide our services and trainings to you, contact you regarding your registration to one of our events, maintain our partnership with you or handle your potential payments. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. In order to ensure that our services are in line with your needs, your personal data can be used for things like customer satisfaction surveys.
For customer communication, including marketing (legal basis: legitimate interest)
The Shortcut processes your personal data to contact you regarding our services and to inform you of changes to our services and products. Your personal data are also used for research and analysis to improve our services and our website. We may also use your data entered on our website in certain cases to send information by email about other services of The Shortcut to you, provided that you have given us consent to that.
For quality improvement and trend analysis (legal basis: legitimate interest)
We may also process information about your use of our services to improve the quality of our services e.g., by analyzing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally identifiable data.
Consent
In addition, we may process your personal information with your consent if such consent has been requested and obtained. In these cases, you have the right to withdraw your prior consent at any time.
The Shortcut processes your personal data to perform our contractual obligations towards you when you apply for our programs, e.g., when you apply for Työ-SIB, B.Y.O.B or DMP program and when we provide you our services under such programs. We may also process some of the personal data related to these programs based on your consent if you have consented to such processing.
In addition, The Shortcut processes your personal data to comply with our legal obligations.
Furthermore, The Shortcut has a legitimate interest to process your personal data to provide you with our services e.g., trainings in The Shortcut Spark Academy and to improve the quality of the services, including compile trend analysis. This interest arises from the relationship we have with you as our User.
In some cases, we may also request your consent for processing of your personal data. In these cases, you have a right to cancel your consent at any time.
We process your personal data mainly in the European Union (“EU”) or the European Economic Area (“EEA”).
However, the service providers we use may process personal information on our behalf on servers located outside the EU or the EEA. If we transfer any personal data to a country for which no adequacy decision of the European Commission exists, such transfer will be subject to provisions of the standard contractual clauses adopted by the European Commission or other applicable legal ground for transfer of personal data. If you wish to know more about international transfers of your personal data, you may contact us via the contact details above.
We only share your personal data within the organization of The Shortcut if and as far as reasonably necessary to perform and develop our services as described in this Privacy Statement.
However, in certain circumstances, our activities may require us to share personal data with parties outside The Shortcut. In these situations, personal data will be transferred or disclosed in accordance with and only to the extent permitted by the GDPR and other applicable legislation and this Privacy Statement.
It is necessary for providing our services
To the extent The Shortcut engages third parties to perform its services, The Shortcut has taken the appropriate contractual and organizational measures to ensure that your personal data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations. Furthermore, we may provide your personal data to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in accordance with this Privacy Statement and any other appropriate obligations of confidentiality and security measures.
Authorities or other entities
We may be required to transfer or disclose your personal data to public authorities (e.g., Uusimaa TE Office and Uusimaa ELY Centre) or other entities (such as S-Pankki Pääomarahastot Oy, TalentAdore, and Claned) based on our obligation to report certain information to them as the service providers of the programs we are involved in, such as Työ-SIB, B.Y.O.B, or DMP. We will only share the personal data necessary for the parties to fulfill their requirements as the supervising parties.
For legal reasons
We may share your personal data with third parties outside The Shortcut if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of The Shortcut, our Users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
With your explicit consent
We may also share your personal data with third parties outside The Shortcut for other reasons than the ones mentioned before if we have your explicit consent to do so. This is the case for example when we request your consent for sharing your information with potential employers who may have potential job offers. You have the right to withdraw this consent at all times.
For another justified reason
If we are a party to a merger, business transaction or other acquisition, we may transfer your personal data to third parties involved in the process, such as a potential purchaser and its advisors. However, we continue to ensure the confidentiality of all personal data we transmit.
As a general rule, we will only store your personal data for as long as it is necessary for the purpose(s) for which it was collected. When personal data is no longer needed for such purposes, we will delete the data unless we have a legal obligation under applicable law or regulation to store such data for a specified period of time. In some cases, we may store personal data after the personal data is no longer necessary for the purpose for which it was collected, if such retention is necessary to ensure, for example, that we have complied with our legal obligations (such as bookkeeping obligations).
Please see below some examples of our storage periods:
We regularly evaluate the retention periods of your personal information. When personal information is no longer needed, we will delete it or make it anonymous as soon as possible.
How to exercise your rights
You have various rights with regard to your personal data that we process as described in this Privacy Statement. These rights include, in particular, the rights described below. However, these various rights may be subject to certain qualifications, such as arising from applicable laws or regulations by public authorities, which qualifications are not fully described below.
You may use these rights by sending a letter or an email, including your name, address, phone number and a copy of a valid ID to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Right of access
The Shortcut offers you access to your personal data that we process. This means that you can contact us and request us to inform you about, e.g., the purposes of processing your personal data and the types of personal data processed or obtain a copy of the data we process about you. We may refuse to provide you with a copy of your data if doing so would compromise the rights and freedoms of others.
Right to correct
You have the right to have incorrect/unprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed.
Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate ground to not delete your personal data.
Right to object
You may object to certain use of your personal data if such personal data are processed for other purposes than what is necessary for the performance of our services or for compliance with a legal obligation.
You have the right to opt out of receiving electronic direct marketing communications from us by clicking on the opt-out link provided in all marketing communications we send you and choosing not to receive marketing communications from us in the future. You also have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling by contacting us on the addresses indicated above.
Right to restriction of processing
You may request us to restrict certain processing of your personal data, for example, for the period required for verifying the correctness of your personal data if you have denied the accuracy of your personal data.
Right to data portability
You have the right to receive your personal data from us in a structured, commonly used format in order to transmit the personal data to another controller.
Right to withdraw consent
Where we process personal data on the basis of your consent, you have the right to withdraw your consent at any time by sending an e-mail or postal letter to the e-mail or postal address provided in this Privacy Statement. Withdrawal of consent does not affect the lawfulness of the processing of personal data carried out prior to the withdrawal.
We will take all reasonable, appropriate security measures to protect The Shortcut and our Users from unauthorized access to or unauthorized alteration, disclosure or destruction of the personal data we hold. Measures include, where appropriate, anonymization, encryption, firewalls, secure facilities and access rights systems. Should a security breach occur that is likely to result in a high risk to your rights and freedoms despite the security measures, we will inform you about the breach as soon as reasonably possible.
This Privacy Statement is applicable worldwide, to all of the services offered by The Shortcut. This Privacy Statement is published in English.
You have the right to lodge a complaint with the data protection authorities concerning our processing of your personal data. You can lodge the complaint with the data protection authority of the EU member state where you have your permanent residence or where you work, or where you find that a potential breach with regard to your personal data has occurred. In Finland, the relevant data protection authority is the Data Protection Ombudsman.
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