ICARE ACADEMY PRIVACY POLICY
This privacy policy has been updated on 22nd September 2022.
1 CONTROLLER
ICARE FINLAND Oy (Business ID 1084502-3) (“iCare”)
Address: Äyritie 22, 01510 VANTAA, Finland
telephone: +358 9 8775 1150
email: [email protected]
The contact details may be amended from time to time and you can find current details at
https://www.icare-world.com.
2 PERSON IN CHARGE OF REGISTER MATTERS
Name: Artturi Kantanen
Contact information: [email protected]
3 NAME OF REGISTER
The name of the register is iCare Academy register. The iCare Academy register contains Personal Data
originating from the use of the academy.icare-world.com (“Website”).
The provision of Personal Data (as defined below in Section 5) to iCare is voluntary. However, if you do not
provide the Personal Data that is marked as obligatory, iCare is not able to register you as a Website user
and iCare is not able to provide you with the access to Website
4 PURPOSE OF USE OF PERSONAL DATA AND LEGAL BASIS FOR PROCESSING
4.1 The purposes of the processing and the legal grounds for the processing of Personal Data are:
(a) To enable access to eLearning materials available in the Website. “The legitimate interests pursued
by iCare” is the legal basis for processing of the Personal Data for these purposes.
(b) Identification of users and the users’ organization. “The legitimate interests pursued by iCare” is the
legal basis for processing of the Personal Data for this purpose
(c) To perform a contract and to use of iCare’s contractual rights. “The legitimate interests pursued by
iCare” is the legal basis for processing of the Personal Data for these purposes.
(d) To track performance in eLearning to ensure fulfillment with contractual obligations. “The legitimate
interests pursued by iCare” is the legal basis for processing of the Personal Data for these purposes.
(e) To ensure health and safety and the correct use of iCare’s products. “Compliance with iCare’s legal
obligation” and “the legitimate interests pursued by iCare” are the legal bases for processing of
Personal Data for this purpose.
(f) To ensure compliance with quality requirements and mandatory laws applicable to iCare.
“Compliance with iCare’s legal obligation” is the legal basis for processing of Personal Data for this
purpose.
(g) Taking care of data security. “Compliance with iCare’s legal obligation” is the legal basis for
processing of Personal Data for this purpose.
(h) Preventing fraud. “The legitimate interests pursued by iCare” is the legal basis for processing of
Personal Data for this purpose.
(i) The Website is provided on TalentLMS platform. The terms of service of the Website provider
Epignosis LLC available at https://www.talentlms.com/terms need to be accepted. “Your consent” is
the legal basis for processing of Personal Data for this purpose.
(j) when the processing is necessary for compliance with a legal obligation to which iCare or its subprocessor is subject.
4.2 The legal basis for the processing of Personal Data:
(a) “Consent”. Consent to the processing is the legal basis for processing of the Personal Data to the
extent mentioned above in Section 4.1. If you withdraw a consent given to the processing, the
withdrawal of consent does not affect the lawfulness of the processing based on consent before its
withdrawal.
(b) “Compliance with iCare’s legal obligation” is the basis for the processing of the Personal Data to the
extent mentioned above in Section 4.1.
(c) “The legitimate interests pursued by iCare” is the basis for the processing of the Personal Data to the
extent mentioned above in Section 4.1. iCare has then considered that iCare’s legitimate interests
are not overridden by your fundamental rights and freedoms.
Such legitimate interests exist as there is a relevant and appropriate relationship with you and/or
your organization, such as a customer, trial customer or cooperation relationship with iCare. Your
interests and fundamental rights and freedoms are respected, as no special categories of Personal
Data are processed and you can expect iCare’s processing activities. Provision of iCare’s products and
services and performance of a contract would not be possible without using the Personal Data.
iCare’s security methods are maintained by iCare in order to protect the Personal Data from
unauthorized access.
5 CONTENT OF REGISTER
The following Personal Data is contained in the register:
(a) email address;
(b) first name(s) and last name(s);
(c) name of your employer;
(d) country of location;
(e) information given by you regarding interests in iCare’s products;
(f) your responses to eLearning questionnaires or participation in eLearning.
6 REGULAR SOURCES OF PERSONAL DATA
The primary source of Personal Data is you or your organization. The Personal Data can be collected also
automatically when the Website is used.
7 REGULAR TRANSFEREES OF DATA
iCare may transfer Personal Data to ICT or other processors that process Personal Data for the purpose of
providing services to iCare. The current processors are listed below:
(a) EPIGNOSIS LLC provider of the platform TalentLMS, where the Website is located, processes
Personal Data, which you provide while using the Website. TalentLMS uses cookies and Personal
Data may be transferred outside the European Union. Further information:
https://www.talentlms.com/privacy
8 TRANSFER TO COUNTRIES OUTSIDE EEA
iCare and its processors can transfer Personal Data outside of the European Union (EU) or the European
Economic Area (EEA) (“Third Countries”) for the purposes set out in this policy.
The legal basis for the transfer of the Personal Data to Third Countries is iCare’s or its processor’s Binding
Corporate Rules, European Commission’s Standard Contractual Clauses for the transfer of Personal Data to
processors established in third countries (“Standard Contractual Clauses”), alternative data export
mechanisms for the lawful transfer of Personal Data (as recognized under EU data protection laws) or
other legal basis.
Further information on Standard Contractual Clauses:
New Standard Contractual Clauses are available here:
Standard contractual clauses for international transfers
Old Standard Contractual Clauses are available here:
Transfer of personal data between two controllers (2001/497/EC)Link to an external website
Transfer of personal data between two controllers (2004/915/EC)Link to an external website
Transfer of personal data between a controller and processor (2010/87/EU)
9 LINKS TO THIRD PARTY WEBSITES
The Website may have links to third party web sites. Please note that iCare is not liable for Personal Data
processing on such web sites. Such third parties are not iCare’s processors.
10 COOKIES
10.1 The TalentLMS platform requires the use of cookies, further information in Section 7 (a).
11 RIGHT OF ACCESS
You have the right to get information on which Personal Data on you is being processed by iCare or
information that no such Personal Data is being processed. Where such Personal Data is being processed
by iCare, iCare shall provide you with a copy of the Personal Data and the following information:
(a) the purposes of the processing;
(b) the categories of the Personal Data concerned;
(c) the recipients or categories of recipients to whom the Personal Data are to be or have been
disclosed, in particular to recipient in Third Countries;
(d) the period for which the Personal Data will be stored;
(e) the existence of the right to request from iCare rectification or erasure of your Personal Data or to
object to the processing of such Personal Data;
(f) the right to lodge a complaint to the supervisory authority and the contact details of the supervisory
authority;
(g) communication of the Personal Data undergoing processing and of any available information as to its
source; and
(h) the significance and envisaged consequences of automated decision-making and related profiling, if
any.
Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive
character, iCare may either: (a) charge a reasonable fee taking into account the administrative costs of
providing the information or communication or taking the action requested; or (b) refuse to act on the
request.
12 RECTIFICATION AND RIGHT TO LODGE COMPLAINT WITH SUPERVISORY AUTHORITY
12.1 iCare shall, at your request, without undue delay correct, erase or supplement the Personal Data if the
Personal Data is erroneous, unnecessary, incomplete or obsolete as regards the purpose of the processing,
including by way of supplementing a corrective statement.
12.2 If iCare refuses your request of the correction of the Personal Data, iCare will inform you, and you can lodge
a complaint with a supervisory authority and seek a judicial remedy.
12.3 You have the right to lodge a complaint to the supervisory authority. The contact details of the Finnish
supervisory authority are:
Office of the Data Protection Ombudsman
P.O. Box 800
FIN-00521 HELSINKI
FINLAND
Address:
Ratapihantie 9, 6rd floor
00520 HELSINKI
Tel: +358 29 56 66700 (exchange)
Fax: +358 29 56 66735
Email: [email protected]
13 RIGHT TO RESTRICTION OF PROCESSING
13.1 ‘Restriction of processing’ means the marking of stored Personal Data with the aim of limiting its use in the
future.
13.2 If you request, iCare must restrict processing in the following situations:
(a) the accuracy of the Personal Data is contested by you, for a period enabling iCare to verify the
accuracy of the Personal Data;
(b) the processing is unlawful and you oppose the erasure of the Personal Data and request the
restriction of its use instead;
(c) iCare no longer needs the Personal Data for the purposes of the processing, but it is required by you
for the establishment, exercise or defense of legal claims; or
(d) you have objected to processing, but verification whether the legitimate grounds of iCare override
your interests is still ongoing.
13.3 In the situations listed above, iCare can only process the Personal Data:
(a) with your consent or for the establishment, exercise or defense of legal claims;
(b) for the protection of the rights of another natural or legal person;
(c) for reasons of important public interest of the EU or of an EU Member State; and
(d) to store the Personal Data.
14 PERIOD FOR WHICH PERSONAL DATA WILL BE STORED
14.1 The Personal Data is processed as long as this is required and allowed under applicable law. Information
regarding the contractual relationship can be processed at least for the time until claims related to the
contractual relationship expire. Main rule according to Finnish law for claims related to the contractual
relationship to expire is three years. When the applicable law describes a longer or a shorter time period for
the processing, such limitation is applied.
14.2 Subject to the requirements of the applicable law, the Personal Data can be processed for longer than the
above-mentioned time periods if it is needed for the establishment, exercise or defense of possible legal
claims.
15 RIGHT TO BE FORGOTTEN
You have the right to have your Personal Data erased at your request if one of the following grounds
applies:
(a) the Personal Data is no longer necessary for the purposes for which it was collected or otherwise
processed;
(b) you withdraw your consent on which the processing is based and where there is no other legal
ground for the processing;
(c) you object to the processing in accordance with Section 16;
(d) the Personal Data has been processed unlawfully; or
(e) the Personal Data has to be erased for compliance with a legal obligation in EU or EU Member State
law to which iCare is subject.
However, iCare does not have to erase the Personal Data based on above grounds to the extent iCare still
needs to process the Personal Data:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by law to which iCare is subject or
for the performance of a task carried out in the public interest or in the exercise of official authority
vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with legal requirements;
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical
purposes in accordance with legal requirements; or
(e) for the establishment, exercise or defense of legal claims.
16 RIGHT TO DATA PORTABILITY
At your request, if iCare processes the Personal Data based on your consent or based on a contract with you
and if the processing is carried out by automated means:
(a) iCare shall provide the you with the Personal Data which you have provided to iCare, in a structured,
commonly used and machine-readable format;
(b) On your request and if technically feasible, iCare shall transmit the Personal Data in the same format
directly to another controller
17 RIGHT TO OBJECT PROCESSING
17.1 You have the right to object, on grounds relating to your particular situation, to the processing of the
Personal Data which is based on either of the following legal basis for processing: (i) when processing has
been found necessary for the purposes of the legitimate interests of iCare or (ii) when processing has been
found necessary in order to protect your vital interests. You however do not have the right to object, if iCare
demonstrates compelling legitimate grounds for the processing which override your interests or
fundamental rights and freedoms.
17.2 Where Personal Data is processed for direct marketing purposes, you have the right to object at any time
to the processing of your Personal Data such marketing, including the right to object to profiling to the
extent that it is related to such direct marketing.
18 AUTOMATED DECISION-MAKING AND PROFILING
18.1 You have the right not to be subject to a measure which produces legal effects concerning you or
significantly affecting you, and which is based solely on automated processing intended to evaluate certain
personal aspects relating to you or to analyze or predict in particular your performance at work, economic
situation, location, health, personal preferences, reliability or behavior.
Such automated decision-making is not used to process your Personal Data by iCare when its processes your
Personal Data according to this policy.