Cookies and privacy notice
Valid as of 1 May 2020
PRIVACY NOTICE
1 INTRODUCTION
2 PERSONAL DATA COLLECTED ACCORDING TO CUSTOMER CATEGORY
2.1 Unregistered users
2.2 Registered users
2.3 Users of services purchased from the online store
2.4 Contracting customers and contact persons for contracting customers
Prospects (personal data collected for marketing purposes)
3 USAGE DATA COLLECTED BY US AND USE OF COOKIES
3.1 Services
3.2 Free Services
4 USE OF DATA COLLECTED BY US AND BASIS FOR DATA PROCESSING
4.1 Regular sources of information
5 DATA STORAGE
5.1 Retention time of personal data
6 DISCLOSURE OF PERSONAL DATA OR TRANSFER OF DATA TO OUTSIDE THE EU OR EUROPEAN ECONOMIC AREA
7 USAGE BY MINORS
8 RIGHTS OF THE DATA SUBJECT
9 FURTHER INFORMATION
1 INTRODUCTION
We respect your privacy and are committed to collecting, storing and processing your personal data in accordance with current legislation. This privacy notice describes the basis upon which Redfox Languages Oy (“Redfox”) processes personal data in the services it provides. The sections of this privacy notice are applied to private individuals or employees of organisations.
We develop our services continuously so we may have to edit or update this privacy notice. Changes in data protection legislation may also be the cause for changes in this privacy notice. We recommend that you familiarize yourself with the contents of the privacy notice regularly.
This same notice can be viewed in our following services: Redfox Basic, Redfox Basic+, Redfox Pro, Redfox Master, Redfox-verkkokauppa ja redfoxsanakirja.fi (hereinafter all or any of these are referred to as “Service”).
2 PERSONAL DATA COLLECTED ACCORDING TO CUSTOMER CATEGORY
We collect, store and process different kinds of personal data according to whether you use the Service as an unregistered or registered individual, whether you use paid Services as a private individual or an employee of a business customer, whether you are acting as a contact person for a contracting customer, and whether you belong to our marketing register. The use of some features of the Service requires registration and/or payment, in which case providing the requested data is a prerequisite for being able to use the Service feature in question.
2.1 Unregistered users
For individuals who use the Service as unregistered users (without identifying themselves) or registered (identify yourself), we collect data on the use of the Service (see below section “3 Usage data and cookies”).
2.2 Registered users
When you register (identify yourself) as a user of our Service, we may request the following information from you:
first name, surname, password, email address and marketing consent.
If you sign into the Service using a third-party application (e.g. Facebook), we also store your identification data (your name and your email address).
2.3 Users of Services purchased from the online store
If you purchase paid Services, we collect various kinds of payment-related data in addition to the data mentioned in the section “Registered users”.
Our partnering payment processor may also store your credit card details (e.g. card type and date of expiry) and other data that is needed for processing your payment. We may also collect some limited data, such as data about your payment history, where this is essential for providing the Service. In addition, payment processors normally provide us with some limited data which relates to you, such as a personal identifier through which you can make further purchases using their saved data about you. In order for us to show you the details of the cards you have used, the payment processors provide us with data on your card type, the date of expiry, and some of the digits of your card number.
2.4 Contracting customers and contact persons for contracting customers
If you are a contact person for legal persons (companies and other communities and organisations) that have a customer relationship with Redfox Languages, we collect from you the following personal data:
name, telephone number, name and address of office, email address, and position and role within the organisation.
In addition to the personal data of contact persons, we process certain data relating to the company or organisation where this is needed for managing the invoicing and customer relationship. Such data includes:
name of the company or organisation, business ID, address, contract and invoicing details, and data on Service usage.
2.5 Prospects (personal data collected for marketing purposes)
If you participate in the procurement of Services provided by Redfox Languages Oy, or if you can be reasonably assumed to be participating in such procurement based on your position and/or work duties, we will process your personal data in our marketing register. Such data includes:
Name, phone number, name and address of office, email address, position and role within the organisation, and details of any marketing ban.
We collect these data for current and former customers from agreement information, as part of the registration for and use of the Service, or directly from the data subject themselves. Personal data is collected also from other relevant public and private registers.
For consumers, we process in the marketing register only the personal data of those that have given marketing consent.
3 USAGE DATA COLLECTED BY US AND USE OF COOKIES
3.1 Services: Redfox Pro, Redfox Master, Redfox Basic, Redfox Basic+, Redfox webstore and redfoxsanakirja.fi
We make use of different technologies (e.g. cookies) to collect from Service users data on how they use our Services and how they enter the Service. These data include, for example, the following:
-The type of order.
-Searches carried out and content which you produce and publish in our Service.
-Technical data, such as URL data, network address, cookie data, type of hardware used, browser type, language, type of network connection and service provider.
3.2 Free Redfox Services: Redfox Basic, Redfox Basic+, Redfox webstore and redfoxsanakirja.fi
In addition to those mentioned in Section 3.1, the free Redfox Services operate as follows with respect to usage data, cookies and advertisements.
We may collect information about your use of the Services through the use of cookies and other similar technologies, such as your browser's local data warehouse, application identifier or device identifiers.
A cookie is a small text file that a browser stores on a user's terminal. Cookies contain an anonymous, unique identifier that allows us to identify and count the various browsers that visit our site. Cookies do not move online by themselves, but are set on the user's terminal only with the site the user invites. Only the server that sent the cookie can later read and use the cookie. Cookies or other technologies do not damage the user's terminal or files, and cookies cannot be used to access programs or spread malware.
Javascript and server logs allow us to collect information about how and when our services are used: for example, from which page the user has accessed the service, when and what web pages the user has browsed, whose advertiser’s advertisements the user has seen on our page and clicked, what browser the user uses, what is user screen resolution, device operating system and version, and IP address.
The purpose of using cookies and other similar technologies is to further analyze and develop our services to better serve our users. Among other things, the technologies make it possible for the user not to have to re-enter usernames, passwords and personalization choices every time.
We use cookies and other similar technologies to statistically monitor the number of visitors to our services and to measure the effectiveness of advertising. For example, we may collect information from marketing emails and newsletters to determine whether messages have been opened and acted upon, such as moving to an online store. To improve the usability of our sites, we may conduct short-term surveys in which we may also record information about a user's mouse movement and clicks on a particular page.
We may also use the information we collect about the use of our sites to generate advertising or content targeted to a particular browser. We may create audience segments based on which websites certain browsers have visited over a period of time. These audience segments are presented with advertising or content that is likely to be of interest to them. For example, a browser belonging to a target group may frequently visit a hockey site and thus become classified as a “sports” group.
In addition to us, cookies may also be used by third parties to collect information. Third parties include, for example, advertisers or ad networks who work with us, as well as various measurement service providers. In our online services we use e.g. Google Analytics to measure the use of our online services. Third parties, such as Google Analytics, may set cookies to collect information about, for example, the number of visitors to websites. You can read more about Google Analytics terms here.
Our services may also use social plugins such as the Like or Share buttons on Facebook, Twitter or Instagram. Such community-linked buttons may appear on our services, but their content comes directly from the button’s source. A social plug-in on our service recognizes that you are logged in to that service, at which point the page will display customized content on the plug-in. Community plug-ins do not display custom content unless you are signed in to that service. Community-based services may collect information about your visit in accordance with their applicable privacy policies. Such services will not disclose the information they collect to us unless you have given your express consent to do so. You can read the terms of social networking services here for Facebook, here for Twitter and here for Instagram.
Our web service uses JavaScript to detect the use of ad-blocking add-ons in web browsers. JavaScript mimics the ad and confirms that it will be displayed on the device. We do this, but we do not store any data on your device and for this purpose we do not process data that could personally identify you. If we find that your browser is using an ad blocker, we may restrict the content we offer. If you don't want us to use ad blocker detection mechanisms, you can disable JavaScript functionality in your browser settings. We reserve the right to restrict the content of our online service if you do not agree to our use of ad blocking program identification mechanisms.
You can clear cookies from the browser settings of the device you are using, which will change the identifier used to collect information about the device. You also have the option to completely block the use of cookies by changing the browser settings of the device you are using. Blocking cookies may affect the operation of our services and the targeting of advertising. If you choose to block cookies, you may not be able to take full advantage of the online services we provide.
4 USE OF DATA COLLECTED BY US AND BASIS FOR DATA PROCESSING
We use the data we collect for the following purposes:
To provide our Services and to improve your user experience through, for example, offering personalised content.
To ensure the technical functionality of the Services, develop new functionality and analyse the use of the Services.
To communicate with you by email on Service-related matters.
We send you direct marketing by email if you have given your consent for this when registering or if you are participating as part of your organisation in the procurement of Services provided by us. If you wish, you may refuse to receive marketing communications.
To process your payments and to manage in other ways the customer relationship with you.
The processing of personal data is based on:
Consent.
The customer relationship, use of the Service, and fulfilment of the license agreement.
Legislation, in areas where data processing relates to complying with accounting obligations.
Legitimate interests, in areas where data processing relates to customer management and marketing, which are not, however, incongruous with the interests and rights of the data subject.
4.1 Regular sources of data
Data is collected from the data subject themselves when they log into the Service. From contracting customers we collect into the customer register and marketing register the personal data which is needed for maintaining the contract relationship. We collect into the marketing register data obtained from the data subject if they have given marketing consent. We also collect into the marketing register personal data from public sources or from authorities or companies who provide personal data about individuals that participate in the procurement of Services provided by us based on their position in a company.
5 DATA STORAGE
Through the use of various continually-updated technical measures we seek to prevent the unauthorised access to and unauthorised use of the data you provide.
The data provided is transferred online using a secure connection (https protocol). We protect the register created from the provided data using appropriate technical methods, such as firewalls, access right management and regular backups. The backups are located in separate premises. They are easily accessible and the backup process works in such a way that the new versions replace the old ones and the old data is automatically removed. The only individuals with access to the data are those that require it for their work.
5.1 Retention time of personal data
After the termination of the customer relationship, the personal data is retained for a maximum of six calendar years, starting from the year following the termination of the customer relationship. Customer data on payment transactions and invoicing history is retained for the period required by law, and after this it is destroyed as soon as possible. Data relating to a legitimate interest of Redfox Languages, however, is retained for as long as this legitimate interest exists. After the termination of the customer relationship, Redfox Languages may retain in Redfox Languages’s marketing register personal data for direct marketing purposes as permitted by law.
6 DISCLOSURE OF PERSONAL DATA OR TRANSFER OF DATA TO OUTSIDE THE EU OR EUROPEAN ECONOMIC AREA
Personal data is disclosed only to employees of Redfox Languages Oy or parties participating in the sale, distribution and production of the Services of Redfox and only for the purpose of managing and maintaining our Services and the customer relationship.
However, we may, upon request, disclose the information you entered when you registered as a user to the contact person representing the contracting customer who offers you the Service you registered to.
Personal data is not transferred outside of the EU or the European Economic Area.
7 USAGE BY MINORS
Persons registering to use the Service must be at least 13 years old. Paid Services can be acquired only by adults.
8 RIGHTS OF THE DATA SUBJECT
The data subject has the right to:
Obtain confirmation as to whether or not their personal data is being processed.
Access their data.
Demand correction of inaccurate data.
Erase data and be forgotten.
Restrict processing of their data.
Receive the personal data they have provided in digital form.
Object to the processing of their data.
Not be the subject of automatic decision-making.
Lodge a complaint with a supervisory authority.
Communications and requests relating to the matters detailed above can be sent by email to support@redfoxlanguages.com or in written form to:
Redfox Languages Oy
Yliopistonkatu 30
40100 JYVÄSKYLÄ
The right to examine data is person-specific. We recommend that you attach documents that confirm your identity and also a clear description of the data which you want to access, change, or deal with in some other way.
9 FURTHER INFORMATION
If you have questions relating to this privacy notice, you may contact us by email at support@redfoxlanguages.com. You may also contact our customer service by ringing +358 40 5519240.
Controller:
Redfox Languages Oy
Yliopistonkatu 30
40100 JYVÄSKYLÄ
FINLAND
FI-2604482-1