Privacy Policy

This privacy policy was last changed on: December 2015

 

The following terms and conditions (hereinafter referred to as the “Privacy Policy”) apply to the collection and processing of personal data by TripleWin Oy, a company duly incorporated and existing under the laws of Finland with the Business ID 2271668-3 (hereinafter referred to as “TripleWin”), as regards the access to and use of the NOOA software program and services or applications related thereto (hereinafter referred to as the “Service”).

NOOA is a Software as a Service (SaaS) platform for strategy and change execution. Via the Service, individuals or companies (hereinafter referred to as the “User”) can establish a NOOA account.

When the User accesses or uses the Service, the User will always disclose certain information concerning the User to TripleWin. This Privacy Policy has been compiled in order to inform the User of the relevant principles and of the purpose of collecting and processing personal data by TripleWin. If the User does not agree to this Privacy Policy or to the collection or process of personal data, the User should not access or use the Service.

When the User accesses or uses the Service, the User may also make information about himself/herself available to other users and, to a certain extent, third parties who are not necessarily users of the Service. TripleWin is not responsible for any information the User chooses to make public on the Service.

When the User accesses or uses the Service, the User’s Company Instance (as defined in the NOOA Terms of Service) is defined by the User’s company or organization’s e-mail domain. Only those in the User’s Company Instance can view other member profiles and feeds on the Company Instance.

If the User has any questions regarding the Service or this Privacy Policy, the User should contact TripleWin at the address mentioned below or through the appropriate section of the Service.

1 Controller of the data and personal data file

 

Controller: TripleWin Oy

Business 2271668-3

Address: Linnoitustie 4 02600 Espoo FINLAND

Contact email: support@nooaex.com
Contact person: NOOA Support

 

The name of the personal data file is TripleWin User Register.

2 Purpose of collecting and processing personal data

2.1                  TripleWin collects and processes personal data for the purpose of providing and operating the Service. The provision and operation of the Service also includes maintaining customer relationship, communication with the users, provision of customer service, development and customization of the Service.

2.2                  TripleWin may process collected personal data for the purposes of direct advertising, direct marketing, opinion polling and market research in accordance with the applicable law.

2.3                  The collection and the processing of personal data of the users of the Service is primarily based on the consent of the Users. By accessing or using the Service or by registering as a user of the Service the User consents to the collection, process and disclosure of the User’s personal data as set out in this Privacy Policy.

3 Sources of data

3.1                  TripleWin collects and processes primarily personal data which is provided voluntarily by the Users when accessing or using the Service. This includes, without limitation, names and contact details, e-mail addresses, date of birth, credit card details or other payment details, company names, user names, aliases, avatars, passwords and any content as well as any other information or material provided or submitted by the Users. TripleWin also asks for the URL subdomain prefix for the User’s Company Instance.

3.2                  TripleWin processes certain data collected from third parties that offer services related to the access to or the use of the Service. This includes, without limitation, credit card information, billing address or other payment information when the User makes a purchase.

3.3                  If the User makes User Content (as defined in the NOOA Terms of Service) available via the Service, the User should be aware that any personal data that the User submits through these features can be read, collected or used by other viewers of the User’s Company Instance.

3.4                  TripleWin also processes certain data that is technically generated in the context of accessing or using the Service. This includes, without limitation, IP addresses, operating systems, access times, browser types and languages, referring websites as well as actions taken in the context of the Service. TripleWin processes this type of data also to monitor and analyze the use of the Service as well as to develop and enhance the Service.

4 Disclosing and transferring PERSONAL DATA

4.1                  TripleWin may use affiliates, subcontractors or third party service providers to provide services or technical solutions for the provision and operation of the Service. This includes, without limitation, processing stored data and accessing the stored data by using a technical interface, such as e-mail service providers, credit card and payment processors, data analyzers and business intelligence providers.

4.2                  TripleWin may disclose or transfer personal data, such as e-mail addresses, to affiliates, subcontractors or third party service providers who perform services or work for or on TripleWin’s behalf if it is necessary for them in order to perform their obligations. In such a case third parties are required to protect personal data to the same extent as TripleWin and they shall be prohibited from using it for any other purpose.

4.3                  When necessary and to the extent required for the provision or operation of the Service, TripleWin may transfer personal data outside the European Union or European Economic Area. In such case TripleWin shall comply with the requirements of the applicable law concerning such transfer of personal data.

4.4                  TripleWin reserves further the right to process, disclose and transfer personal data if required or permitted to do so by law.

5 User rights

5.1                  The User has the right to review, update, correct and delete his/her personal data stored in the TripleWin User Register. If the User wishes to use this right, the User should send a signed request thereof to TripleWin by using the contact details mentioned above or through the appropriate section of the Service. TripleWin may retain an archived copy of the User’s records as long as required or permitted to do so by law.

5.2                  The User has the right to prohibit the process of the User’s personal data stored in the TripleWin User Register for the purposes of direct advertising, other direct marketing, market research and opinion polls. If the User wishes to use this right, the User should contact TripleWin by using the contact details mentioned above or through the appropriate section of the Service in order to communicate this to TripleWin.

6 Data SECURITY and storage of the data

6.1                  The TripleWin User Register is maintained in external service providers’ servers with appropriate safeguards, such as password protection, granting the access to the stored information to TripleWin only. The TripleWin User Register is protected by appropriate industry standards, technical and organizational safety measures.

6.2                  The personal data stored in the TripleWin User Register is accessible and may be processed only by persons that are authorized to do so by TripleWin. TripleWin may grant Administrators (as defined in the NOOA Terms of Service) access to the part of the User Register containing personal data of the Users of their Company Instance (as defined in the NOOA Terms of Service).

6.3                  The personal data collected by TripleWin will be stored as long as the personal data is necessary for the purposes it was collected. TripleWin reserves further the right to store personal data as long as required or permitted to do so by law.

7 Cookies, web beacons and log data

7.1                  Cookies are small text files which are received and transmitted by a visitor’s computer, mobile phone, tablet or other technical device capable of receiving and transmitting cookies when a visitor or User is accessing or using the Service. TripleWin may use cookies to provide and operate the Service, to help it identify and track visitors and Users, to their usage of the Service and their website access preferences as well as to improve quality, tailor recommendations and to develop the Service. The cookies will not enable TripleWin to access and review data stored on a visitor’s device.

7.2                  Certain areas, parts or functionalities of the Service may be optimally designed to operate with the aid of cookies and may not function properly without them. It may affect the User’s user experience if the User chooses to decline or opt-out the use of cookies.

7.3                  For further information on the use of cookies, the User should refer to the cookies section of the Service.

7.4                  TripleWin also uses “web beacons,” “web bugs”, “pixel tags,” “clear GIFs” or similar means (hereinafter individually or collectively “Web Beacons“) in the Service. A Web Beacon is an electronic image, embedded on web pages. Web Beacons are ordinarily not visible to Users. Via Web Beacons, TripleWin can count the number of Users who have visited certain pages of the Service or interacted with content shared by Users, to deliver branded services and to generate statistics about how the Service is used.

7.5                  While interacting with the Service, the servers automatically record information sent by the User’s browser whenever the User visits a website or selects a link (hereinafter “Log Data“). Log Data may include information such as the User’s computer’s internet protocol address, browser type, the webpage the User was visiting before and other statistics. TripleWin uses Log Data information to monitor and analyze the use of the Service, for the Service’s technical administration and to increase the Service’s functionality. TripleWin may link information gathered via Log Data with personal data.

8 Third party websites, services and cookies

8.1                  This Privacy Policy is not applicable to the extent the Service contains links or references to third party web sites or services which are not provided or operated by TripleWin. TripleWin does not take any responsibility of third parties' privacy policies, terms and conditions or the processing of personal data in connection with such third parties' operations.

8.2                  The Service may feature content or advertisements of third parties that deliver cookies to visitor’s device so that the content can be accessed and advertisements tracked. Such cookies are not covered by this Privacy Policy (or other TripleWin’s cookie policies or guidelines) and TripleWin shall not be responsible for such use of cookies.

8.3                  TripleWin encourages the User to familiarize himself/herself with the relevant third party privacy and cookie policies and terms and conditions.

9 CHANGES TO THE PRIVACY POLICY

9.1                  TripleWin may make changes to this Privacy Policy at any time in its sole discretion.

9.2                  TripleWin will use reasonable efforts to inform the User of the changes to the Privacy policy by posting them on the relevant section of the Service or contacting the User via the User’s user account. However, TripleWin encourages the User to frequently check this Privacy Policy for any changes.

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Leena Huotari: +358 50 551 3663

leena.huotari(at)nooa.global



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