Privacy

1. General privacy principles for all services by Hintsa Performance Oy

1.1 General

Your privacy is important to us. The Hintsa Performance Privacy Policy (“Privacy Policy”) is designed to protect your privacy and to help you understand, what personal data Hintsa Performance Ltd (“Hintsa Performance”) collects from you, how we collect the data, and how use the data. Hintsa Performance offers a range of services directly to customers, via employers, and via channel partners. Our services include but are not limited to personal coaching, remote coaching via digital tools, and digital wellbeing services. When taking any of our services into use, you have actively given consent to our Terms of Service and this Privacy Policy.  Please read the product-specific details in this Privacy Policy, which provide detailed information about Hintsa Performance’s services, including cookie usage practices and register information for products and services, which collect personal data. This Privacy Policy applies to Hintsa Performance’s interactions with you and the Hintsa Performance products and services listed below, as well as other Hintsa Performance products and services that display this Privacy Policy.

1.2 Our Privacy Principles:

  • We fulfil the requirements of the General Data Protection Regulation 2016/679 (GDPR) and the Privacy and Electronic Communications Directive 2002/58/EC (E-Privacy Directive) of the European Union
  • We fulfil the requirements of the Act on the Protection of Privacy in Working Life 759/2004 of the Finnish law
  • You as an end-user have control over your personal data: You decide, how much of your personal details you want to share with others. You can transfer your personal data from our digital tools in machine readable format (“data portability”). You can remove your personal data from our digital tools (“right to erasure”).
  • We only collect and process personal data that is necessary for providing our products and services.
  • We provide aggregate level reporting to our customers. These reports are only shown, when sample sizes are large enough to not enable identifying individuals. These reports do not contain health data. Some of the reports contain personal data, when used e.g. for rewarding as a part of activity campaigns. In these cases, the end-user has been informed about the reporting practices in the service description, the end-user has given consent to the reporting, and can opt out of the reporting at any point.
  • We use data created in our services for anonymised data analysis for research purposes, targeting to create new knowledge on wellbeing and factors impacting it. Anonymised data used in research is not personal data, and individuals cannot be identified from this data. We might work with research partners such as universities. Results of our research might be made public.
  • We do not sell, rent, loan or give out your name, email address, or other personal data to anyone. However, if the service provider or all of its assets would be acquired, customer information might be transferred to the acquiring party.
  • Your personal data may be transferred across international borders to server locations supporting the service. Details of hosting solutions used are covered in Product-specific Privacy Statements.
  • No security system is impenetrable and security risks exist in any system. However, we make consistent efforts to keep your information secure.
  • We may use cookies in order to provide a better service, related to Authentication, Security, User Preferences, Performance, Analytics, Research, and Advertising. Details of our Cookie usage practices are covered in Product-specific Privacy Statements.
  • Changes to our Privacy Policy will be published on our web site.
  • Should you have any privacy related questions or suggestions, please contact us at info@hintsa.com.

2. Privacy Principles for services we provide customers of Ilmarinen Mutual Pension Insurance Company

Privacy Principles for personal data collected and processed in services Hintsa Performance provides for customers of Ilmarinen Mutual Pension Insurance Company

2.1 General

Your privacy is important to us. The Hintsa Performance Privacy Policy (“Privacy Policy”) is designed to protect your privacy and to help you understand, what personal data Hintsa Performance Ltd (“Hintsa Performance”) collects from you, how we collect the data, and how use the data. Hintsa Performance offers a range of services directly to customers, via employers, and via channel partners and other partners. Our services include but are not limited to personal coaching, remote coaching via digital tools, and digital wellbeing services. When taking any of our services into use, you have actively given consent to our Terms of Service and this Privacy Policy.  Please read the product-specific details in this Privacy Policy, which provide detailed information about Hintsa Performance’s services, including cookie usage practices and register information for products and services, which collect personal data. This Privacy Policy applies to Hintsa Performance’s interactions with you and the Hintsa Performance products and services listed below, as well as other Hintsa Performance products and services that display this Privacy Policy.

2.2 Our Privacy Principles

  • We fulfil the requirements of the General Data Protection Regulation 2016/679 (GDPR) and the Privacy and Electronic Communications Directive 2002/58/EC (E-Privacy Directive) of the European Union
  • We fulfil the requirements of the Act on the Protection of Privacy in Working Life 759/2004 of the Finnish law
  • You as an end-user have control over your personal data: You decide, how much of your personal details you want to share with others. You can transfer your personal data from our digital tools in machine readable format (“data portability”). You can remove your personal data from our digital tools (“right to erasure”).
  • We only collect and process personal data that is necessary for providing our products and services.
  • We provide aggregate level reporting to our customers. These reports are only shown, when sample sizes are large enough to not enable identifying individuals. These reports do not contain health data. Some of the reports contain personal data, when used e.g. for rewarding as a part of activity campaigns. In these cases, the end-user has been informed about the reporting practices in the service description, the end-user has given consent to the reporting, and can opt out of the reporting at any point.
  • We use data created in our services for anonymised data analysis for research purposes, targeting to create new knowledge on wellbeing and factors impacting it. Anonymised data used in research is not personal data, and individuals cannot be identified from this data. We might work with research partners such as universities. Results of our research might be made public.
  • We do not sell, rent, loan or give out your name, email address, or other personal data to anyone. However, if the service provider or all of its assets would be acquired, customer information might be transferred to the acquiring party.
  • Your personal data may be transferred across international borders to server locations supporting the service. Details of hosting solutions used are covered in Product-specific Privacy Statements.
  • No security system is impenetrable and security risks exist in any system. However, we make consistent efforts to keep your information secure.
  • We may use cookies in order to provide a better service, related to Authentication, Security, User Preferences, Performance, Analytics, Research, and Advertising. Details of our Cookie usage practices are covered in Product-specific Privacy Statements.
  • Changes to our Privacy Policy will be published on our web site.
  • Should you have any privacy related questions or suggestions, please contact us at info@hintsa.com.

2.3 Service specific privacy principles:

2.3.1 Vire surveys

Privacy principles of Vire surveys:

  • Vire surveys, i.e. Työvire and Työyhteisövire, offered by Ilmarinen Mutual Pension Insurance Company to its customers, are employee survey tools built for the purpose of improving the quality of working life and employee wellbeing by collecting input and feedback from employees. We collect and process personal data in order to provide the surveys and ensure non-biased sampling in survey data, e.g. by not allowing the same person to answer the same survey many times, when not desirable. Individual users’ survey results are always private, cannot be shared with other users within the service, are never shared to anyone, and are never reported to the employer or other parties. The employer receives anonymous reports from survey answers for the whole organisation and divided to teams, if each reported entity has a minimum of five answers. Ilmarinen receives anonymous reports per employer. Survey results may be used for anonymous, aggregate level reports and anonymous research.

Personal data collection in Vire surveys:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: info@hintsa.com
  • Register name: Vire surveys customer register
  • Purpose of use: The register is used for providing the Vire surveys, and maintaining a customer relationship between the user and Hintsa Performance Oy

Register content:

  • The user’s personal information (name, gender, birthday)
  • Unique customer ID
  • The user’s contact information (email)
  • The user’s organisational identifiers: employer, teams, tags
  • Answers to surveys inputted by the user
  • Reports generated for the user
  • Email messages sent to the user (message header)
  • Internet-server technical logs (including user’s IP address and browser information)
  • Information sources: Information provided by user her/himself or by the employer (name, email, organisational identifiers)
  • Register protection principles: The data is stored on servers located inside the EU, run by Amazon Web Services, Inc (AWS). The application is deployed onto a Virtual Private Cloud (VPC) in AWS. The configuration addresses security by limiting outside access to minimum, applying firewalling for each server instance and deploying services to subnets that have limited access to each other and to outside networks.

3. Privacy principles for Hintsa Performance’s coaching services

  • Hintsa Performance offers coaching programmes for individuals and teams
  • Before starting any of our coaching programmes, participants are required to give a consent for collecting and processing personal data. Personal data is collected and processed in accordance with the consent and shared only to your nominated coach and supporting team of specialists, whom you have approved to this role.
  • During our coaching programmes, we may collect wellbeing data through Hintsa Surveys. The privacy policy for these surveys is provided in section 7 of this document.
  • Our digital tool Better Life may be used as a part of our coaching programmes. The relevant privacy policies for this tool can been found in section 4. this document.
  • The coaching programme may include a medical check or other medical services. All medical and patient data created is collected and processed in patient health records of medical service providers. Nominated representatives of Hintsa Performance may during your coaching program have access to briefings based on your medical data in accordance with your consent.
  • We utilise digital services by external service providers for running our coaching services. These service providers work as data processors on our behalf and have committed to privacy and personal data processing compliant with the GDPR:
    • Acuity Scheduling: booking coaching services
    • MailChimp: communications
    • DropBox and BoxCryptor: storage of notes and other programme data
    • Firstbeat: wellbeing diagnostics
    • SurveyMonkey: surveys and enrollments
    • SurveyLegend: surveys and enrollments
    • Shopify: payment system
    • Stripe: payment system
    • SquareSpace: payment system
    • Typeform: surveys

Personal data collection in Hintsa Performance’s coaching services:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: info@hintsa.com
  • Register name: Hintsa Coaching customer register
  • Purpose of use: The register is used for providing coaching services and for managing customer relations between Hintsa Performance Ltd and its customers and end-users.
  • Register information is not used for direct marketing without the user’s consent.

Register content:

  • The register consists of registers we have collected in different services used for providing our coaching services (Hintsa Surveys, Better Life, Acuity Scheduling, MailChimp, Dropbox, BoxCryptor, SurveyMonkey, SurveyLegend, Shopify, Stripe, SquareSpace).
  • Register content and register protection principles for each of Hintsa Performance’s services (Hintsa Surveys, Better Life) are listed in personal data collection registers of these services, included in the Hintsa Performance Privacy Policy.
  • Register content and register protection principles for external services that we use for providing coaching services:
  • Information sources: Information provided by user her/himself or generated by the services

4. Privacy Principles for the Better Life service

  • Better Life is a mobile application we utilise in our holistic wellbeing coaching programmes. We collect and process personal data in order to guide and visualise your habit creation journey. Please note that we process sensitive personal data about you such as data on your sleep, mood, or physical activity
  • The Better Life remote coaching digital service is by default and design a private service: your personal information is shared only to your nominated coach, whom you have approved to this role.
  • We store the information collected during the registration process, such as your email address, in order to be able to provide the service. We also store your wellbeing related data and potentially other information created at the service.
  • When using a coach as a part of Better Life, you give consent for the coach to see all the information you have stored in Better Life, excluding personal diary entries made under the “Journal” view in Better Life.
  • Data created by users of Better Life may be used for creating aggregate and anonymous workplace statistics visible to workplace admins and other employer representatives. Workplace admins and other employer representatives do not have access to user data on the level of individual wellbeing events, statistics of individual users, or detailed profile information. Workplace admins will in most cases know the names and email addresses of individual users, as the users are in most cases invited by the admin.

Personal data collection in Better Life:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: info@hintsa.com
  • Register name: Better Life customer register
  • Purpose of use: The register is used for providing the Better Life service and for managing customer relations between Hintsa Performance Ltd and its customers and service end-users.
  • Register information is not used for direct marketing.

Register content:

  • The user’s personal information (name)
  • Unique customer ID
  • The user’s contact information (email)
  • Information about the user’s progress in the coaching programme
  • Status of education content consumption provided in the service (completed, not completed, progress)
  • Status of daily tasks given in the service (completed, not completed, inputted data)
  • Answers to wellbeing related and other assessments in the service
  • The user’s wellbeing targets
  • The user’s exercise log information and other wellbeing and other data entered to the service by the user, including journal entries created by the user
  • Wellbeing data from wearable devices connected to Better Life by the user, e.g. exercise data, daily step count, sleep data, resting heart rate
  • Wellness data from health hubs such as Apple HealthKit and Google Fit connected to Better Life by the user, e.g. exercise data, daily step count, sleep data, resting heart rate
  • Photos uploaded to the service by the user
  • The user’s messaging history in the service
  • The user’s employer
  • The user’s coach in the service, notes written by the coach
  • The user’s team mates in the service
  • The user’s mobile device type and OS version
  • Header information from email messages sent to the user from the service
  • Information sources: Information provided by user her/himself or generated by the Better Life service or generated by 3rd party services integrated to Better Life by the user.
  • Register protection principles: The data is stored on servers located inside the EU, run byAmazon Web Services, Inc (AWS). The application is deployed onto a Virtual Private Cloud (VPC) in AWS. The configuration addresses security by limiting outside access to minimum, applying firewalling for each server instance and deploying services to subnets that have limited access to each other and to outside networks.

5. Hintsa Surveys

5.1 Hintsa individual wellbeing surveys

Hintsa individual wellbeing surveys’ Privacy Principles:

  • Hintsa individual wellbeing surveys, including Hintsa Better Life wellbeing survey and Hintsa Better Life wellbeing pulse survey are surveys for the purpose of providing a holistic assessment of an individual person’s status across different elements of wellbeing. We collect and process health and personal data with the active consent of the individual in order to provide an individual report based on survey answers. Consent for personal data processing can be removed at any time by contacting us at support@hintsa.com. Individual users’ survey results are always private and are never shared with anyone, with the following exceptions:
    • If you are taking part in Hintsa coaching programmes, your designated coach and possibly other designated specialists will see your data.
    • If you are taking part in Hintsa coaching programmes via your employer, your results may be included in aggregate level, anonymous reporting for the employer. However, your data cannot be identified from the aggregate level reports and we never share any individual level data from the survey to the employer.
    • Hintsa’s analytics team will have access to your data and process your data in order to create the aggregate reports. However, this access right is not used for the purpose of analysing or monitoring your personal data. All members of the analytics team are bound by confidentiality agreements.
    • If you are taking the free version of our pulse survey (https://www.hintsa.com//better-life-pulse/), our customer relations and admin team will have an access to your results. The results can be used to improve the quality of our services. All members of our team are bound by confidentiality agreements.

Personal data collection in Hintsa individual wellbeing surveys:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: info@hintsa.com
  • Register name: Hintsa individual wellbeing surveys customer register
  • Purpose of use: The register is used for providing the Hintsa individual wellbeing surveys service, including Hintsa Better Life wellbeing survey and Hintsa Better Life wellbeing pulse survey.

Register content:

  • The user’s personal information (name)
  • The user’s contact information (email)
  • The user’s organisational identifiers (employer)
  • Answers to surveys inputted by the user
  • Reporting showed to the user
  • Email messages sent to the user (message header)
  • Information sources: Information provided by the user her/himself

Register protection principles: In order to provide Hintsa individual wellbeing surveys, we use external service providers for data collection and data hosting. Our external service providers include Typeform S.L., SurveyLegend AB and Hubspot, Inc. for the data collection and Amazon Web Services, Inc (AWS) and Google Cloud servers for the hosting. Our service providers fulfil the requirements of the General Data Protection Regulation (GDPR) and/or the Privacy Shield.

5.2 Hintsa Diagnostic Service

The purpose of the Hintsa Diagnostic service is to combine several data sources to offer a holistic analysis of an individual person’s current wellbeing status and provide actionable insights for improving his quality of life as well as performance. Collected data includes survey answers to our individual wellbeing surveys (see part 3.4. Hintsa individual wellbeing surveys) and the data collected from Firstbeat’s comprehensive lifestyle assessment. We collect and process personal and health data with the active consent of the individual in order to provide individual reports based on results. Consent for data processing can be removed at any time by contacting us at support@hintsa.com. Individual users’ results are always private and are never shared with anyone, with the following exceptions:

  • Your designated coach and possibly other designated specialists will see your data
  • If you are taking part in the service via your employer, your results may be included in aggregate level, anonymous reporting for the employer. However, your data cannot be identified from the aggregate level reports and we never share any individual level data to the employer.
  • Hintsa’s analytics team can have access to your data and process your data in order to create the reports. However, this access right is not used for the purpose of analysing or monitoring your personal data. All members of the analytics team are bound by confidentiality agreements.

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: support@hintsa.com
  • Register name: Hintsa Diagnostic customer register
  • Purpose of use: The register is used for providing the Hintsa Diagnostic service

Register content:

  • The user’s personal information (name)
  • The user’s contact information (email)
  • The user’s organisational identifiers (employer)
  • The user’s age, gender, height, weight
  • Answers to the Better Life wellbeing survey inputted by the user
  • Data from the Firstbeat Lifestyle Assessment and Specialist reports: e.g. heart rate, heart rate variability, stress, sleep and physical activity measurements
  • Individual reports created based on collected data
  • Email messages sent to the user (message header)
  • Information sources: Information provided by the user her/himself or generated by the Firstbeat service
  • Register protection principles: In order to provide the Hintsa Diagnostic service, we use external service providers for data collection and data hosting. Our external service providers include Typeform S.L. and Firstbeat Technologies Oy for the data collection and Amazon Web Services, Inc (AWS) for the hosting. Our service providers fulfil the requirements of the General Data Protection Regulation (GDPR) and/or the Privacy Shield.

6. Privacy Principles for the Hintsa.com marketing site

Upon certain interactions with Hintsa.com (e.g. subscribing to our newsletter), you give consent for your personal details to be added to the Hintsa marketing register, which may contain the following personal data, submitted by the user her/himself:

  • Name
  • E-mail address
  • Mobile phone number
  • Age and gender
  • Job level and position
  • Company name and industry
  • User submitted interests for newsletter subscription preferences

In addition to self-submitted data, we use analytics and marketing automation tools, which collect data on users’ browsing information, such as traffic sources, browser and devices used, time spent in Hintsa Performance’s website, pages visited, geographic location etc.

We collect personal data mainly at the point of subscription, but also later during the customer relationship. Hintsa Performance’s website uses cookies, web beacons and other similar methods in order to improve user experience, to develop our websites and services further, and for targeting content and communications. Cookies are small pieces of data sent from a website and stored on the user’s computer by the user’s web browser. Cookies can be blocked from your browser’s settings. Our pages may also include other third-party components, such as lead trackers.

We process personal data for the uses of customer relationship management and  marketing with the consent of the visitor, without disclosing customer personal data to any third party. We maintain a register on newsletter subscribers and other users of our website’s functionality. Newsletters are sent to subscribers by email based on the marketing register’s information.

Hintsa Performance’s website runs a marketing automation system that is used for improving the general user experience of our website and its content, and for creating target segments for marketing.

We places cookies, when a visitor first arrives to our website, in order to learn, how visitors consume content in the site. A visitor’s personal data remains anonymous to Hintsa Performance until:

  1. Visitor subscribes to Hintsa Performance’s newsletter or other material

A user’s personal data may be linked to the cookie, when a visitor subscribes to a newsletter, white paper etc. Submitted information is stored in the Hintsa marketing register.

  1. Visitor arrives at the website from an email marketing message sent by Hintsa Performance

A user’s personal information may be linked to a cookie, when the user arrives at the website via an email marketing message sent by Hintsa Performance. The source for e-mail marketing messages is Hintsa Performance’s marketing register. A user, whose cookie is linked to personal data, may receive email marketing that is personalised based on her/his website visitor history. In case a user wishes to unassociated from their previous browsing history, they can do so by clearing their browser cookies.

You have the legal right to inspect the data we have collected concerning you. You also have the right to request the correction or deletion of incorrect, defective, unnecessary or outdated personal data.

Your data can be removed from the Hintsa marketing register based on a personal request. Requests for register-related matters shall be submitted in writing to the postal address Hintsa Performance Oy, Lapinlahdenkatu 1C, 00180 Helsinki. Newsletter subscribers can unsubscribe directly from the newsletter.

7. Privacy Principles for Hintsa’s support pages

We run a support portal to enable customer service for our Luotaamo service (support.luotaamo.fi). The support portal enables creation of support tickets, we create a personal data register of people, who have sent these tickets, to enable customer service delivery.

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: info@hintsa.com
  • Register name: Hintsa Support customer register
  • Purpose of use: The register is used for providing customer service

Register content:

  • The user’s personal information (name)
  • The user’s contact information (email)
  • The service in case (Luotaamo)
  • Mobile device and OS of the user (Android, iOS, web)
  • Messaging history between the user and customer service
  • Articles visited in the support portal by the user
  • Possible Android log file sent to customer service by the user
  • Information sources: Information provided by user her/himself
  • Register protection principles: We run our support portals with the FreshDesk service provided by Freshworks Inc. Freshworks acts as a personal data processor on our behalf and fulfills the requirements of the GDPR.