Privacy Policy

INTRODUCTION

Priocta is a service operated by Easteam Oy (1986940-0), a company headquartered in Finland. This Privacy Policy explains how we at Priocta collect and otherwise process personal information.

Priocta enable our Members to, among other things, collect and analyze data, create questionnaires and notify answerers.

We understand that you are aware of and care about your own personal privacy interests, and we take data privacy seriously. In this privacy policy we describe what personal information we may collect from you, what are the purposes for which we collect it, how we use it and how we keep it secure. This Policy also explains the choices you can make about your personal information, including how you can manage, delete or have access to your personal information.

This Privacy Policy observes the General Data Protection Regulation (EU 2016/679).

Please read this policy carefully to understand our views and practices regarding your personal information and our ways to treat it. By visiting our website(s) or using our services you are accepting and consenting to the activities and data usage as described in this policy.

KEY TERMS

In this privacy policy, these terms have the following meanings:

“Services” and “Priocta” refers to Priocta software, platform and application.

“We”, “us”, “our” and “Priocta” refer to Easteam Oy.

"Member" or “administrative user” signifies a person or entity that is registered with us to use the Services and has administrative rights. In other words, member is usually an employer or team leader.

“Contact”, “client user”, “survey recipient” or “answerer” is a person a member can contact through our services. In other words, a contact is for instance an employee or team member.

“You” and “your” means, depending on the context, either a member, a contact or a visitor.

"Personal Information" or “personal data” refers any information relating to you. This means any information that identifies or can be used to identify a member, a contact or a visitor directly or indirectly. Examples of personal information include, but are not limited to, first and last name, email address, occupation, or other demographic information. In addition, personal data may include your contact details, online identifiers and any comments or opinions made by you or about you.

"Website(s)" means any website(s) we own and operate (such as www.priocta.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.

"Visitor" means any person who visits any of our Websites.

“Your employer” or “your team leader” refers to the entity who has entered into the agreement with us.

OUR STATUS AND RESPONSIBILITIES

The data controller in the case of survey recipients and client users is their administrative user, which is usually the employer or team leader. Priocta and your employer or team leader has agreed in Terms of Service to grant client users to access to the application and selected surveys.

Priocta will process client user’s personal data on behalf of the administrative user and in accordance with lawful instructions.

In the case of marketing contacts, we are the data controller in respect of your personal information. We are also the data controller in respect of contact information for each member which we hold for account and contract management purposes, for example for contract queries and billing purposes.

INFORMATION WE COLLECT AND RECEIVE

We collect and process data from the following roles

• Administrative users of Priocta. These users can manage the surveys and analyze the data from those via dashboards. Administration can also supervise personnel and groups. Administration is usually employer or team leader or employee who has got administrative rights.
• Survey recipients (usually employees or team members). This type of users has been granted access to Priocta usually by their employer of team leader.
• Page visitors and trial users.
• Agency users. These users work as retailers and can therefore work with multiple organizations. Working as an agency user requires a specific contract with Priocta.

The collected data varies by the role you have (survey recipient, administration user or visitor) and your interaction with Priocta, Priocta websites, Priocta application and other Priocta services. We collect a variety of data including contact information, payment details, business information and communications you may have with our team. Here are some examples concerning data collection.

Information you give us:

• You may give us information about you and your organization when you sign up for a free trial or subscribe to a plan (for example company name, information about your personnel, industry and payment details)
• You may give us information about you, when using Priocta’s functions, including by filling in forms or completing surveys. The extent of the information collected is set by the maker of a survey, which is usually your employer or team leader (data may include your name and details related to your working)
• In case of contacting or corresponding with us (for instance, using any support function made available by us), we may keep a record of correspondences directly or through our service providers

Information we receive from other sources:

• Your employer may give us information about you when creating a user profile for you in order to enable you to access the platform or surveys. This information may include for example your first and last name, company email address, employer, job title and department.
• We may receive information about you or your organization by others who use Priocta’s functions, for instance completing surveys. Like earlier was mentioned, the extent of the information collected depends on the set of a survey, which is usually made by your employer or team leader.
• We may receive information about you from an agency user in case of you are a customer organization of agency user or a member of a customer organization of agency user. In these cases, there is always an agreement between an agency user, customer organization and Priocta.
• We work closely with third parties (including for example business partners, other companies within our group, subcontractors and analytics providers). We may receive information about you or your organization from these third parties, for example in a case of technical support. You can read more about information and third parties in the section below entitled “THIRD PARTIES”.

Information we collect about you. Each time you complete a survey or otherwise use Priocta’s functions we may automatically collect different kind of information. The information can be for instance

• details of a usage (for example date, time, frequency and duration of the usage)
• any comments, opinions and feedback you provide to us regarding Priocta
• technical information about your computer or mobile device for system administration and analysis (for example IP address, URL clickstreams, unique device identifiers, operating system and network and browser type)
• other information about your use of Priocta, for instance the pages you have viewed, the duration spent on the services and possible data files you have uploaded to Priocta (personnel information CSV)

OUR PROCESSING OF PERSONAL DATA

Please take into account that we are permitted to collect, use, disclose and/or otherwise process any information, including data that you give via surveys or otherwise provide to us, to the fullest extent permitted by the agreement made with your employer (Terms of Service).

We may use collected, received or generated personal data from or about you on the legal bases as set out below.

For survey recipients and client users:

We may use the information you give to us to

• Enter you a registered user and verify your eligibility to use the application in case of you are a client user
• Provide your employer reports and analysis summarizing information provided during your and your colleagues use of the service. This is our obligation arising from the agreement made with your employer.
• Provide you with information, products and services you request from us
• Contact you for your feedback on our services and to help us evaluate and improve our services
• Notify and inform you about changes in our services, for instance new versions or features
• Deal with any inquiries or concerns have been raised

We may use information we collect about you to

• Improve and administer our services
• To report to your employer relating the use of the services
• For internal operations such as troubleshooting, testing and analyzing
• To permit you to participate in interactive features
• As part of our efforts to keep our services safe and secure
• To compose reports of usage of our services. These do not personally identify you.

Information we receive from other sources

• We may combine the information you give to us or we collect about you to information from other sources. This information may be used as specified above.

We process your personal data on the legal basis that is necessary for the purposes of our or your employer’s legitimate interests.

Please note that:

• Your employer is in responsible of the content of the surveys you are involved. Priocta is not related to creating the content.
• Your employer can decide whether answering to the survey is anonymous or not
• Data collected from you and your colleagues may be used by us in an anonymized form for statistical and benchmarking purposes including enabling comparisons to other organizations

In marketing purposes, we will collect and use data to contact you of about our services and news relating to them. This data is processed by us or our third parties on the legal basis that is necessary for the purposes of our legitimate interests.

Our service providers are based in Finland, Europe. Access to digital registers and databases are secured by encryption protocols, firewalls, passwords and other necessary technical security measures.

All personal data is processed with confidentiality and only those users who need the data to perform their tasks will have access to it.

Data is regularly backed up safely so it can be restored in case of system failures.

We utilize built-in security technologies enabled by Google Cloud Platform.

Google Cloud's security model, world-scale infrastructure, and unique capability to innovate will help keep your data secure and compliant.

YOUR RIGHTS

You have the following rights concerning your personal information:

• You have the right to receive a confirmation that your personal information is being processed by us and access your personal data and the personal information we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable, excessive or repetitive requests, or requests for further copies of the same information. Alternatively, we may refuse to comply with the request in such circumstances.
• You have the right to object to processing of your personal information where that processing is being carried out based on our (or a third party’s) legitimate interest. In such a case we must be able to cease processing your data unless we can demonstrate compulsory reasons which override your objection. You also have a right to object at any time to object to processing of personal data for direct marketing purposes.
• You have the right to request that we rectify incomplete or incorrect data that we hold about you.
• You have the right to request that we erase any personal information that we hold about you under certain circumstances, such as when you have withdrawn a previously given consent and we do not have another legal basis for the processing of your personal information. This right does not extend to information which is not personal data. Please also note that it is possible to be necessary for us to store your personal data for the purposes of assessing and verifying data that is submitted or held on the platform, and your rights under applicable law to request erasure may be limited accordingly. We also reserve the right to store your personal data in an anonymized form for statistical and benchmarking purposes.
• You have the right to restrict the processing of your personal data under certain circumstances, for example if you want us to establish its accuracy or the reason for processing it.
• You have a right to change your data processing preferences at any time.

In case of using your rights, be prepared to confirm your identity or to give specific information about you. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. Any requests must be made by company’s administrative user.

Please take into account that if you require us to restrict or end processing or to delete personal data, and this type of processing is required in order to enable your use of Priocta, you will no longer be able to use our services from the date on which we fulfill your request. Please allow at least 30 days for your request to be fulfilled.

SECURITY OF INFORMATION

You need to have a username and password to access to our services. As a different kind of user, you have different kind of accesses (administrative user and client user). You are responsible for keeping your access credentials confidential. You must not share these details with anyone or store them in a way that may allow a third party to access them.

We maintain appropriate technical and organizational operations to ensure that an appropriate level of security exists related to our services and personal data we process. Unfortunately, the transmission of information via internet is not always secure. We will do absolutely our best to protect your personal data, we cannot guarantee the security of your data transmitted to the platform. Therefore, you need to acknowledge that any transmission is at your own risk. Once we have received your information, we will apply strict operations and security features to keep your data safe.

In case of an agency user, the organization operating as an agency user has full access to the data of its customer organizations and personnel. Data in these cases is similar with the data described above (administrative user and survey recipient). In these cases, a written contract is made by agency user, customer organization and Priocta.

YOUR CONSENT

By using our services, you approve this privacy policy and our ways to process your personal data.

RETAINING YOUR INFORMATION

We will store your personal data as long as is reasonably necessary for supplying the services.

COOKIES

When you interact with our services, we want to make your experience easy and meaningful. We and our third party service providers may use cookies and similar tracking technologies to distinguish you from other visitors and to collect and use personal information about you. This helps us to provide you a good experience when you browse our website and allows us to improve our site and to serve you interest-based advertising.

A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. Cookies assign a random, unique number to each visitor’s computer.

Cookies do not contain information that would personally identify the visitor, although we can combine a cookie with any identifying information that is or has been provided by a customer while visiting our site.

We or our third party service providers use cookies that remain on your computer for a defined period of time or until they are deleted. These are called persistent cookies, and they record clickstream information, such as data reporting the URLs, or names of the pages on our site that you have been visited. Another type of cookies we may also use exist only transitorily during an online session. These session cookies allow you to log in to your account and let us to identify you temporarily as you move through the site.

We may also use web beacons, which are tiny graphics with a unique identifier. In contrast to cookies, web beacons are embedded invisibly on webpages and may not be disabled or controlled through your browser.

THIRD PARTIES

We may collaborate with third parties to track and analyze our site activity and to take care of payment transactions. To enable this, these third parties may place cookies or web beacons to trach user activity on our site. We use the data collected to help us improve the quality of our site and platform and to analyze usage of the services.

We may share your personal data to third parties in case of necessary or desirable purposes such as delivering the services to you, technical support, marketing activities or in legal reasons. These kinds of third parties may be our service providers, payment service providers, business partners, suppliers or government or other law agencies.

We require all our third parties to take appropriate and strict security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

We may also disclose your personal data to other third parties

• If we sell or buy any business assets or receive investment into our business. In this circumstance, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business of assets.
• If we need to disclose your personal data to our legal advisers if they need to have access to this information in order to advise us on our legal rights and obligations
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or other contracts between us and you or your employer or to protect the rights, property or safety of us, our customers or others.

If you are a Survey Recipient, please note that comments and feedback provided by you via surveys are received by your employer, who decides if the survey is anonymous or not.
Excpet as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

CHANGES IN OUR PRIVACY POLICY

Any changes we may make to our privacy policy will be posted on this page. Continued use of the platform will signify that you agree to any such changes.

CONNECT

If you have any questions or concerns about our Privacy Policy or processing of your Personal Data, please contact us at [email protected].
If for any reason you are unhappy with the way that we process your personal data, you are welcome to contact us if you have any questions or complaints. You also have the right to make a complaint to the relevant supervisory authority, which is in Finland the Office of the Data Protection Ombudsman.