The Shortcut Privacy Policies
The Startup Shortcut Oy (“The Shortcut”, “we” or “us”) collects personal data of our customers and visitors (“Users”) of our website www.theshortcut.org whilst providing our Users our services.The Shortcut processes your personal data with due care, in accordance with all applicable laws and regulations.
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 websites.
This Privacy Statement only covers personal data processing carried out by The Shortcut. The Privacy Statement does not address, and we are not responsible for, the privacy practices of any third parties.
1.Identity of the controller of the processing of your personal data
The controller of the processing of the personal data is: The Startup Shortcut Oy
Company ID in Finnish Trade Register: 2759222-9
Correspondence address: Lapinlahdenkatu 16 (entrance 15B), 00180 Helsinki, Finalnd
E-mail address: firstname.lastname@example.org
2. Personal data processed and sources of data
The Shortcut collects two types of information from 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.
We may collect and process the following User Data about our customers and visitors: (i) first and last name; (ii) address details, (iii) telephone number, (iv) e-mail address, (v) your location when you use our services, (vi) payment details, (vii) other personal data you provide yourself, including pictures, for example when creating a profile, in correspondence and by phone.
We may collect User Data from our customers and visitors in a variety of ways, including, when you register to our services, subscribe to a newsletter, buy a ticket to one of our events or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through our services. We will collect User Data from customers and visitors only if they voluntarily submit such information to us or carry out transactions or payments through our services or websites.
We and/or our authorized third-party service providers may automatically collect Technical Data when you visit or interact with our services or websites. Technical Data may include the browser name, the type of computer or device, time spent on website, interaction with the Services, URL of the website you visited before and after visiting the Services, the time and date of user visits, surfing habits, IP address, operating system and the Internet service providers utilized and other similar technical information.
Our websites use Google Analytics and other web analytics services to compile reports on visitor usage and to help us improve our websites and services. For an overview of Google Analytics, please visit http://www.google.com/analytics/. You can opt-out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout.
3.Purposes and legitimate grounds for the processing of your personal data
There are several purposes of the processing of your personal data by The Shortcut:
To provide our services and carry out our agreement with you
The Shortcut processes your personal data in the first place 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 handle your payments, provide services or contact you regarding your registration to one of our events. 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)
The Shortcut processes your personal data to contact you regarding our services and to inform you of changes to our services and products. Your data are also used for research and analysis to improve our services and our websites. We may also use your data entered on our websites in certain cases to send information by e-mail about other services of The Shortcut to you, provided that you have given us consent to that.
For quality improvement and trend analysis
We may also process information about your use of the 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.
Legitimate grounds for processing
The Shortcut processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to maintain and develop our businesses.
4.Transfer to countries outside Europe
The Shortcut may transfer your personal data to countries outside the European Union and the European Economic Area. When we transfer any personal data to a country for which no adequacy decision of the European Commission exits, such transfer will be subject to the provisions of the standard contractual clauses adopted by the European Commission. 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, e.g. with our customer service and marketing employees.
We do not share your personal data with third parties outside of The Shortcut unless one of the following circumstances applies:
It is necessary for providing the services
To the extent The Shortcut engages third parties to perform the 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.
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 share your personal data with third parties outside The Shortcut for other reasons than the one mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
The Shortcut does not store your personal data longer than legally permitted and necessary for the purposes for which the personal data were collected. The storage period depends on the nature of the personal data and the purposes of processing. The maximum period may therefore vary.
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 e-mail, including your name, address, phone number and a copy of a valid ID to us on the addresses set out above. If your request regards personal data in a cookie, you have to enclose a copy of the said cookie. 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 to 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 the purposes of processing your personal data and the types of personal data involved.
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 request unless we have a legitimate ground to not delete the 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 necessary for the performance of our services or for compliance with a legal obligation. You may also withdraw your prior consent to process your personal data. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our websites and other services.
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. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our websites and other services.
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.
We will take all reasonable, appropriate security measures to protect The Shortcut and our customers from unauthorized access to or unauthorized alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, 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.
10.Right to make a complaint
You have the right to make a complaint with the data protection authorities concerning our processing of your personal data. You can make 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: http://www.tietosuoja.fi/en/index.html