This privacy policy sets out how Viking Leaders Oy (“Viking Leaders”) uses and protects any information that you give us when you use Viking Leaders’ website (the website) or Viking Leaders’ mobile simulation game (”Game”).Viking Leaders is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using the website and/or Game, then you can be assured that it will only be used in accordance with this privacy statement.Viking Leaders may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from April 10, 2020. For any questions or requests that you may have, feel free to contact our customer service via info@vikingleaders.com. 

Name of the Register

Name of the register is Viking Leaders’ Customer and User Register.

Purpose of the Register

• Maintenance of Viking Leaders’ customer service and customer relations management
• Newsletter distribution
• Marketing and direct marketing of Viking Leaders’ products and services in accordance with user consent and as permitted by law
• To be used for personalisation of visits or communications
• Facilitation of delivery of Viking Leaders’ products and services, facilitation of operations and ongoing development of Viking Leaders’ operations, products and services
• Disclosure of information inside Viking Leaders and between Viking Leaders, Viking Leaders Group companies and its subcontractors to facilitate the delivery of Viking Leaders products and services
• To comply with Viking Leaders’ statutory personal data management obligations
• To respond to contact requests
• In this document, Viking Leaders’ products and services may include products and services of group companies and their suppliers. (Third party suppliers)

Content of the Register

Information stored in the register may include, for example, the following:

• User’s first names and surname
• User’s email address
• User’s mobile phone number
• User’s company or other organisation, and the address of the company or other organisation
• User’s position in the organisation
• Information on the user’s geographical location and domicile, acquired with the user’s consent
• Brand and type of the user’s Internet browser
• Brand and model of the user’s computer
• User’s computer operating system
• Brand and model of the user’s mobile phone or other mobile device
• Brand and type of the user’s mobile browser
• User’s current IP address
• IMEI code or other similar unique code of the user’s phone or mobile device
• Information provided by the user about devices belonging to the company or other organisation
• Information about use of and sessions on Viking Leaders products and services
• Usage information about user’s Viking Leaders products and services, such as information about frequency of use, as well as time and duration
• User’s username for Viking Leaders products and services
• User’s password for Viking Leaders products and services stored using a hashing algorithm specifically designed for this purpose
• Information about contracts concluded by the user’s company or other organisation
• Information about mailing list subscriptions
• Customer feedback, queries or competition results relating to the user
• In this document, Viking Leaders products and services may also include products and services of group companies and their suppliers 

Storage time of Personal Data

• Viking Leaders stores personal data in the customer register until the customer or user relationship between the data subject and Viking Leaders is considered to have ended. The ending time is determined from the last service contact or other contact of the data subject, which is then added 2 years. Legislation may require that some data is stored even longer.

Statutory sources of information

• Customer queries on Viking Leaders’ website, by phone or other communication or other form of contact
• Via a contact form or other form
• Information gathered via Twitter/LinkedIn/Facebook etc. as a user signs in or authenticates via third party services, in accordance with the terms of such service providers
• Newsletter subscriptions
• Different user responses to specific questions (areas of interest, etc.)
• From a customer contact request or if a customer wishes to register via Viking Leaders’ website chat feature
• Information provided by the user in connection with delivery of Viking Leaders’ products and services and arising from the use of Viking Leaders’ products and services
• Information from Viking Leaders’ subcontractors and suppliers that provide products or services to the user’s organisation
• In this document, Viking Leaders products and services may also include products and services of group companies and their suppliers

Statutory disclosure of data

• Data will be disclosed to the following entities for the following purposes:
• To a client company or organisation or prospect that the user represents
• To a Viking Leaders subcontractor or principal (such as IT service provider, software provider or supplier, or Viking Leaders group company) to facilitate delivery and development of products and services offered by Viking Leaders
• To Viking Leaders group companies for marketing purposes
• The types of data to be disclosed are the types of data referred to in section “Content of the Register”.
• Information will be disclosed via encrypted data connections, email or other electronic format
• In this document, Viking Leaders products and services may also include products and services of group companies and their supplier

Data transfer outside the EEA

Viking Leaders will not transfer information in the register beyond the European Economic Area (EEA).

Cookies

• Viking Leaders’ websites use cookies. The website sends a cookie to a user’s browser – a small file that is saved on the computer’s hard drive. The site uses both (temporary) session ID cookies that close when the user’s Internet browser is closed, as well as permanent cookies, which are saved on the computer hard drive. The purpose of cookies is to improve user experience on the website. Cookies also give Viking Leaders the opportunity to track and study subjects that are of interest to the user and to enhance its websites, focus marketing and develop products and services. Most Internet browsers accept cookies automatically, but users may modify their browser settings to disable cookies if they wish. Blocking or disabling the cookies may affect the functionality of the websites.
• Advertising cookies help Viking Leaders to select what it believes are the most appropriate ads for users. They may also prevent the same advertisements from being repeatedly displayed. Some third parties, including Google, may also use cookies or web trackers (a one-pixel image file) to display certain ads when a user visits different websites. The information gathered with the help of cookies and web trackers does not provide Viking Leaders or its partner companies with user names, contact information or other personal data. Third-party advertisers may also use technology that measures the effectiveness of advertisements. For this purpose, they may use trackers (a one-pixel GIF file) that are placed on a website to gather anonymous data. With the anonymous data that is gathered from a user’s visit to these and other websites, advertisers can design personalised ads about products and services for the user. The data that is collected is anonymous and none of the actions performed online can be linked to specific individuals.

Data protection principles and procedures

The following procedures and principles will be used to protect personal data:

• Locks at premises used by Viking Leaders and its subcontractors
• Electrical surveillance of equipment and premises used by Viking Leaders and its subcontractors
• Viking Leaders and its subcontractors will use data network firewalls, anti-virus and junk mail filter systems as well as other software and equipment to protect computer network data security
• Viking Leaders staff expertise
• Viking Leaders staff training
• The register’s personal data content will be stored electronically, except for short-term exceptional circumstances
• Viking Leaders’ policies and regulations relating to personal data

Profiling

Viking Leaders shall not make any profiling of the customer data.

The Data Subject’s Right to Prohibit the Processing of Personal Data and Direct Marketing

With regard to a personal special situation, a data subject has the right to prohibit his or her other processing activities which Viking Leaders may direct on the data subject’s personal data to the extent that the grounds for the processing of information is the customer relationship between Viking Leaders and the data subject.The data subject may present his or her request for the prohibition in accordance with this data protection description. In connection with the request, the data subject must identify the special situation on the basis of which he or she objects to the processing of data. Viking Leaders may refuse to implement the request for prohibition on statutory grounds. 

Other Rights of the Data Subjects Regarding the Processing of Personal Data

The Data Subject’s Right to Access to the Data (Inspection Right)

The data subject has the right to inspect Viking Leaders’ customer and user register with respect to the stored data concerning him or her. Such an inspection request must be made in accordance with this data protection description. The right to inspection may be declined on statutory grounds. In principal, there shall be no charge for exercising the right to inspect.

The Data Subject’s Right to Demand Rectification or Erasing of Data or a Restriction on Processing Data

The data subject or customer can request the rectification, erasing, or supplementing the erroneous, unnecessary, incomplete or obsolete personal data. The rectification request shall be made in accordance with this data protection description.The data subject also has the right to demand the controller to restrict the processing of his or her personal data, for example, in a situation where the data subject is waiting for Viking Leaders’ response to his or her request to rectify or erase data.

The Data Subject’s Right to Transfer Data From One System to Another

Insofar as the data subject him/herself has provided information in the customer register for processing on the basis of the data subject’s consent or commission, the data subject has the right to access such data mainly in machine-readable format and the right to transfer such data to another controller.

The Data Subject’s Right to Make a Complaint to the Supervising Authorities

A data subject has the right to make a complaint to the competent supervising authorities, if the controller in its operations has not followed the applicable data-protection regulations.

Other Rights

If the personal data is being processed on the basis of the data subject’s consent, the data subject has the right to cancel the consent by notifying Viking Leaders of this in accordance with this data protection description.

Notice to end-users

Our products are intended for both personal use and use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy. Even if the Services are not currently administered to you by an organization, if you are a member of a team administered by an organization, or if you use an email address provided by an organization (such as your work email address) to access the Services, then the administrator of that team or the owner of the domain associated with your organizational email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. You will be notified if this happens. Board, team, and enterprise administrators are able to restrict your access to and privileges within the respective board, team or enterprise the administrator controls. In some cases, enterprise administrators can also:

• require you to reset your account password;
• restrict, suspend or terminate your access to the Services or your account;
• control your ability to edit, restrict, modify or delete account information;
• change your account information, including profile information or the email address associated with your account;
• access information in and about your account;
• access or retain information stored as part of your account; and
• enable or disable Power-Ups, third-party apps, or other integrations.

If you do not want an administrator to be able to assert control over your account or use of the Services, you should deactivate your membership with the relevant board, team or enterprise or remove any email addresses containing a domain owned or controlled by the administrator entirely from your account. Once an administrator asserts control over your account or use of the Services, you may no longer be able to withdraw membership or change the email address associated with your account without administrator approval.Please contact your organization or refer to your administrator’s organizational policies for more information. 

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

How to unsubscribe from our mailing list

If you wish to get no more marketing messages or updates about our products and services, you can unsubscribe from our mailing list by clicking the unsubscribe link at the end of any of our marketing emails.ContactsIn all matters related to the processing of personal data and all situations regarding the exercising of one’s own rights, the data subject should contact Viking Leaders:

• by e-mail: Info@vikingleaders.com, or
• by post at the address: Viking Leaders Oy, c/o Q-Factory Oy, Malminkatu 34, 00100 Helsinki, Finland

Viking Leaders can request the data subject to further define their request in writing, and, if needed, the identity of the data subject can be authenticated before initiating any other measures.