PRIVACY NOTICE
Last updated June 11, 2021
Thank you for choosing to be part of our community at Fluent Progress RT Oy (“Company”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@fluentprogress.fi.
When you use our mobile application, as the case may be (the “App”) and more generally, use any of our services (the “Services”, which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
Terminology
All data related to an identified or identifiable person is personal data. Information such as names, telephone numbers and location data is personal data.
A controller (Customer organization) is an individual or organization that determines the purposes and means of the processing of personal data. A controller can be an association that collects information on its members for example a road maintenance operator.
A processor (Fluent Progress RT Oy) is an individual or organization that processes personal data on behalf of a controller. A processor can be a marketing agency taking care of another company’s marketing or an IT service provider with access to the personal data collected by the controller.
TABLE OF CONTENTS
- 1. WHAT INFORMATION DO WE COLLECT
- 2. HOW DO WE USE YOUR INFORMATION
- 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE
- 4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY
- 5. HOW LONG DO WE KEEP YOUR INFORMATION
- 6. HOW DO WE KEEP YOUR INFORMATION SAFE
- 7. WHAT ARE YOUR PRIVACY RIGHTS
- 8. CONTROLS FOR DO-NOT-TRACK FEATURES
- 9. DO WE MAKE UPDATES TO THIS NOTICE
- 10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE
- 11. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and Services, when you participate in activities on the App (such as by posting messages in our online forums or performed maintenance operations) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following:
Personal Information Provided by You
We collect usernames; passwords; and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our App.
We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.
The information we collect includes:
Device Data
We collect device data such as information about your computer, phone, tablet or other device you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
Information collected through our App
In Short: We collect information regarding your geo-location, mobile device, when you use our App.
If you use our App, we also collect the following information:
Geo-Location Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings. Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Purpose of location data collection
Fluent Kunto collects location data from device to report the performed operations with their location to respective server application within the organization of the user. Location data needs to be collected also when the application is in the background since the routes of the performed operations tracked by the application are required to be uninterrupted when any of the operations available in the client are active. Fluent Kunto tracks and reports location data to fulfill user organizations’ needs related to reliable and uninterrupted reporting and tracking of maintenance operations. We need your precise location data to draw your exact driven route on map, including for example the lanes you have used, so that your organization can make sure their maintenance regulations and requirements are being met.
Collected data might be shared to 3rd parties in anonymized form to fulfill your organization’s contract obligations. Within the organization, the data may be used to collect reports and statistics about operations that are needed to fulfill maintenance regulations and requirements for the organization.
Mobile Device DataWe automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed. This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To respond to user inquiries/offer support to users
We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our services
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below. We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.. This might include any subcontractor of ours in order to fix problems or perform other maintenance tasks as agreed upon.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers, on which the data we collect is saved are located in Finland. If you are accessing our App from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above) in Finland and other countries.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time. If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at info@fluentprogress.fi.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact your local Kunto administrator
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
9. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@fluentprogress.fi or by post to:
Fluent Progress RT Oy, Länsikatu 15, 80110 Joensuu, Finland
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact your local Kunto administrator.