Hintsa Performance Privacy Policy

25  May 2018  /  In Finnish

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.

2. Hintsa Performance 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 Personal Data Act (HetiL 523/99, §10) and 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. In these cases, the end-user has been informed about the reporting practices in the service description, and the end-user can opt out of reporting containing personal data by opting out of these service elements offered by the customer to the end-user.
  • 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 support@hintsa.com.

3. Product-specific Privacy Statements:

3.1 Better Life

Better Life Privacy Principles:

  • Better Life is a holistic wellbeing coaching programme. We collect and process personal data in order to guide and visualise your habit creation journey.
  • 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 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 Personal Data Act (HetiL 523/99, §10) of the Finnish law

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: support@hintsa.com
  • Register name: Better Life user 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, sex, birthday)
  • Unique customer ID
  • The user’s contact information (email)
  • The user’s personal measurement information (height, weight)
  • 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 prompted to the user in the service
  • The user’s exercise targets
  • The user’s exercise log information and other wellness and other data entered to the service by the user, including journal entries created by the user
  • Wellness 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
  • Email and other notification sending permissions per notification type
  • Email messages sent to the user from Better Life (message title and date)
  • Internet-server technical logs (including user’s IP address and browser information)
  • 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 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.
3.2 HeiaHeia

HeiaHeia Privacy Principles:

  • HeiaHeia (including HeiaHeia for Workplaces, HeiaHeia Pro Tools, Parempi vire, MarsMars) is a social wellbeing service, it is built around peer support.  We collect and process personal data in order to guide and visualise your habit creation journey, as well as social support from your friends and colleagues.
  • 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 control your privacy level from HeiaHeia’s settings. 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 store the information collected during the registration process, such as your email address, in order to provide the service. We also store your exercise data and potentially other information created at the service.
  • Sharing your exercises and other entries to other HeiaHeia users is managed with friendships. Your friends see all your non-private entries in their ‘feeds’. If you mark individual entries as private, your friends will not see them.
  • Your name is always searchable and your profile picture is visible within HeiaHeia’s friend search. The privacy level you’ve selected defines, who can access your full profile page and training log by clicking your name. The default setting is “Only my HeiaHeia friends and colleagues”.
  • When utilising coaching services in HeiaHeia, you give consent for the coach to see all the information you have stored in HeiaHeia, including entries you have marked as private.
  • HeiaHeia’s mobile applications may use and store your current location to record your workouts. You may disable location services from mobile application settings, but then you will not be able to add location data to workouts.
  • Location data (GPS data) created by you with HeiaHeia mobile applications or other compatible methods may be stored to create and annotate training log entries, and is treated with the same privacy principles as all training log data. Maps and “check-ins” created from GPS data have more privacy options than other training log data types, enabling stricter privacy. GPS data created on HeiaHeia mobile apps that is not used to create training log entries is not stored permanently by HeiaHeia.
  • Data created by members of the HeiaHeia for Workplaces service may be used for creating aggregate workplace statistics as well as “top lists” of most active members. Workplace admins do not have access to member data on the level of an individual entry, or detailed profile information, unless allowed by the member in HeiaHeia’s settings. Workplace admins will always know the names and email addresses of workplace community members, who are in most cases invited by the admin. Workplace admins do have access to workplace aggregate statistics and “top lists”.
  • Data created by members of the Parempi vire service may be used for creating aggregate workplace statistics as well as “top lists” of most active members. Workplace admins or representatives of Ilmarinen do not have access to member data on the level of an individual entry, or detailed profile information. Workplace admins will always know the names and email addresses of workplace community members, who are in most cases invited by the admin. Workplace admins and representatives named by Ilmarinen have access to workplace aggregate statistics and “top lists”.

HeiaHeia cookie usage practices:

  • Authentication: If you’re signed in to HeiaHeia, cookies help us to show you the desired information and personalise your experience.
  • Security: We use cookies to enable and support our security features, and to help us detect malicious activity and violations of our Terms of Service.
  • Preferences, features and services: Cookies can tell us which language you prefer and what your communications preferences are.
  • Advertising: We may use cookies to show you relevant advertising both on and off the HeiaHeia site. We may also use a cookie to learn whether members who saw an ad on HeiaHeia later visited the advertiser’s site. Similarly, our partners may use a cookie to determine whether we’ve shown an ad and how it performed, or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off HeiaHeia, such as after you’ve visited a partner’s site or application.
  • Performance, Analytics and Research: Cookies help us learn how well our site performs in different locations. We also use cookies to understand, improve, and research products, features, and services, including when you access HeiaHeia from other websites, applications, or devices such as your work computer or your mobile device.

Most important 3rd party cookies used in HeiaHeia:

  • Google Analytics https://www.google.com/intl/en/policies/privacy/
  • DoubleClick https://www.google.com/intl/en/policies/privacy/
  • New Relic https://docs.newrelic.com/docs/browser/new-relic-browser/page-load-timing-resources/new-relic-cookies
  • Facebook https://www.facebook.com/help/cookies/

Personal data collection in HeiaHeia:

Personal data collection register information according to the Personal Data Act (HetiL 523/99, §10) of the Finnish law

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: support@hintsa.com
  • Register name: HeiaHeia customer register
  • Purpose of use: The register is used for providing the HeiaHeia service, including HeiaHeia for Workplaces, HeiaHeia Pro Tools, and the Parempi vire service, offered by Ilmarinen Mutual Pension Insurance Company to its customers, and the MarsMars service, offered by the the Finnish Defence Forces to any private individual, and for managing customer relations between Hintsa Performance Ltd and its customers and service end-users. Register information is not used for direct marketing without the user’s consent, managed by service settings.

Register content:

  • The user’s personal information (name, sex, birthday)
  • Unique customer ID
  • The user’s contact information (email, phone number optional)
  • The user’s hometown
  • The user’s personal measurement information (height, weight)
  • The user’s exercise targets
  • Types of exercise (sports) of interest to the user
  • The user’s training log information and other wellness and other data entered to the service by the user
  • Wellness data from wearable devices connected to HeiaHeia 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 social connections in the service
  • The user’s messaging history in the service
  • The user’s membership status in communities and groups
  • Answers to surveys inputted by the user
  • Newsletter sending permission (email marketing)
  • The user’s advertisement click-through history in the service
  • Email messages sent to the user from HeiaHeia (message header)
  • Internet-server technical logs (including user’s IP address and browser information)
  • Information sources: Information provided by user her/himself or generated by the HeiaHeia service.
  • 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.
3.3 Hintsa organisational wellbeing surveys

Hintsa organisational wellbeing surveys’ Privacy Principles:

  • Hintsa organisational wellbeing surveys, including Hintsa Insights as well as Työvire, Työyhteisövire, and Organisaatiovire, services 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. Survey results are used for anonymous, aggregate level reports.

Personal data collection in Hintsa organisational wellbeing surveys:

Personal data collection register information according to the Personal Data Act (HetiL 523/99, §10) of the Finnish law

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: support@hintsa.com
  • Register name: Hintsa organisational wellbeing surveys customer register
  • Purpose of use: The register is used for providing the Hintsa organisational wellbeing surveys services, including Hintsa Insights as well as Työvire, Työyhteisövire, and Organisaatiovire, services offered by Ilmarinen Mutual Pension Insurance Company to its customers.

Register content:

  • The user’s personal information (name)
  • Unique customer ID
  • The user’s contact information (email)
  • The user’s organisational identifiers: employer, teams, tags
  • Answers to surveys inputted by the user
  • Reporting showed to 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.
3.4 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 Personal Data Act (HetiL 523/99, §10) of the Finnish law

  • The register is maintained by: Hintsa Performance Oy (Ltd), contact: support@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.
3.5 Hintsa coaching programmes
  • Hintsa coaching programmes include coaching services for individuals and teams.
  • Before starting any of our coaching programmes, we request you to complete our consent form, which specifies how your personal data is collected and processed during the programme. Your personal information is processed in accordance with the consent form and shared only to your nominated coach and supporting team of specialists, whom you have approved to this role.
  • During our coaching programmes, we collect wellbeing data through Hintsa individual wellbeing surveys. The details of the privacy policy related to these surveys is provided in section 3.4 of this document.
  • Digital tools, including Better Life and HeiaHeia, are used as a part of our coaching programmes. The relevant privacy policies for these tools can been found in sections 3.1 and 3.2 of this document.
3.6 Hintsa.com marketing site

Upon certain interactions with Hintsa.com (e.g. subscribing to our newletter), 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.