Privacy policy

21 April 2022

Change log:
- Updated company name: H2 Platform Oy -> HeiaHeia Oy
- Updated list of most important cookies: DoubleClick removed

 

This document covers all products, services, and other operations of HeiaHeia Oy.

1. General privacy principles for all services by HeiaHeia Oy
2. Privacy Principles for services we provide for the Finnish Defence Forces
3. Privacy Principles for the HeiaHeia service
4. Privacy Principles for the HeiaHeia marketing site
5. Privacy Principles for HeiaHeia’s support pages
6. Google user data

 

 

 

1. General privacy principles for all services by HeiaHeia Oy

1.1 General

Your privacy is important to us. The HeiaHeia Privacy Policy (“Privacy Policy”) is designed to protect your privacy and to help you understand, what personal data HeiaHeia Oy (“HeiaHeia”) collects from you, how we collect the data, and how use the data. HeiaHeia offers a range of services directly to customers, via employers, and via channel partners. Our services include but are not limited to personal coaching, remote coaching via digital tools, and digital wellbeing services. When taking any of our services into use, you have actively given consent to our Terms of Service and this Privacy Policy.  Please read the product-specific details in this Privacy Policy, which provide detailed information about HeiaHeia’s services, including cookie usage practices and register information for products and services, which collect personal data. This Privacy Policy applies to HeiaHeia’s interactions with you and the HeiaHeia products and services listed below, as well as other HeiaHeia products and services that display this Privacy Policy.

1.2 Our Privacy Principles:

  • We fulfil the requirements of the General Data Protection Regulation 2016/679 (GDPR) and the Privacy and Electronic Communications Directive 2002/58/EC (E-Privacy Directive) of the European Union
  • We fulfil the requirements of the Act on the Protection of Privacy in Working Life 759/2004 of the Finnish law
  • HeiaHeia Oy either a Data Controller or a Data Processor working on behalf of the Data Controller for all personal data collected and processed in all the services it provides.
  • You as an end-user have control over your personal data: You decide, how much of your personal details you want to share with others. You can transfer your personal data from our digital tools in machine readable format (“data portability”). You can remove your personal data from our digital tools (“right to erasure”).
  • We only collect and process personal data that is necessary for providing our products and services.
  • We provide aggregate level reporting to our customers. These reports are only shown, when sample sizes are large enough to not enable identifying individuals. These reports do not contain health data. Some of the reports contain personal data, when used e.g. for rewarding as a part of activity campaigns. In these cases, the end-user has been informed about the reporting practices in the service description, the end-user has given consent to the reporting, and can opt out of the reporting at any point.
  • We use data created in our services for anonymised data analysis for research purposes, targeting to create new knowledge on wellbeing and factors impacting it. Anonymised data used in research is not personal data, and individuals cannot be identified from this data. We might work with research partners such as universities. Results of our research might be made public.
  • We do not sell, rent, loan or give out your name, email address, or other personal data to anyone. However, if the service provider or all of its assets would be acquired, customer information might be transferred to the acquiring party.
  • Your personal data may be transferred across international borders to server locations supporting the service. Details of hosting solutions used are covered in Product-specific Privacy Statements.
  • No security system is impenetrable and security risks exist in any system. However, we make consistent efforts to keep your information secure.
  • We may use cookies in order to provide a better service, related to Authentication, Security, User Preferences, Performance, Analytics, Research, and Advertising. Details of our Cookie usage practices are covered in Product-specific Privacy Statements.
  • Changes to our Privacy Policy will be published on our web site.
  • Should you have any privacy related questions or suggestions, please contact us at helpdesk@heiaheia.com.

 

2. Privacy Principles for services we provide for the Finnish Defence Forces

Privacy Principles for personal data collected and processed in services HeiaHeia provides the Finnish Defence Forces

2.1 MarsMars Privacy Principles

  • MarsMars, a service offered by the Finnish Defence Forces to private individuals, is a social wellbeing service, based on peer support. We collect and process personal data in order to enable personal wellbeing tracking and improvement, as well as peer support among friends.
  • You as an end-user have control over your personal data: You decide, how much of your personal details you want to share with others. You can control your privacy level from MarsMars’s settings. You can transfer your personal data from our digital tools in machine readable format (“data portability”). You can remove your personal data from our digital tools (“right to erasure”).
  • We store the information collected during the registration process, such as your email address, in order to provide the service. We also store your wellbeing data and potentially other information created at the service.
  • Sharing your exercises and other entries to other users is managed with friendships. Your friends see all your non-private entries in their ‘feeds’. If you mark individual entries as private, your friends will not see them.
  • Your name is always searchable and your profile picture is visible within MarsMars’s friend search. The privacy level you’ve selected defines, who can access your full profile page and training log by clicking your name. The default setting is “Only my friends and colleagues”.
  • When utilising coaching services in MarsMars, you give consent for the coach to see all the information you have stored in MarsMars, including entries you have marked as private.
  • MarsMars mobile applications may use and store your current location to record your workouts. You may disable location services from mobile application settings, but then you will not be able to add location data to workouts.
  • Location data (GPS data) created by you with MarsMars mobile applications or other compatible methods may be stored to create and annotate training log entries, and is treated with the same privacy principles as all training log data. Maps and “check-ins” created from GPS data have more privacy options than other training log data types, enabling stricter privacy. GPS data created on MarsMars mobile apps that is not used to create training log entries is not stored permanently by MarsMars.
  • Data created by users of MarsMars may be used for creating anonymous aggregated statistics. In these statics, exact figures are shown only, if N ≥ 5.
  • Most important anonymous aggregated statics created from MarsMars user data include the following:
    • Amount of active users
    • Distribution of activity levels
    • Distribution of performance survey results
    • Most popular sport types and wellness entries
    • Amount of training programs and habit challenges started
    • Amount of cheers given
    • Average amount of exercise and steps
    • Amount of users who have exercised on average over 2,5 hours per week

Personal data collection in MarsMars:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: HeiaHeia Oy (Ltd), contact: helpdesk@heiaheia.com
  • Register name: MarsMars user register
  • Purpose of use: The register is used for providing the MarsMars service and for managing user relations between HeiaHeia Oy and its customers and service end-users.
  • Register information is not used for direct marketing without the user’s consent.

Register content:

  • The user’s personal information (name, sex, birthday)
  • Unique customer ID
  • The user’s contact information (email)
  • The user’s hometown
  • The user’s personal measurement information (height, weight)
  • The user’s exercise targets
  • Types of exercise (sports) of interest to the user
  • The user’s training log information and other wellness and other data entered to the service by the user
  • Wellness data from wearable devices connected to the service by the user, e.g. exercise data, daily step count, sleep data, resting heart rate
  • Photos uploaded to the service by the user
  • The user’s social connections in the service
  • The user’s messaging history in the service
  • The user’s membership status in communities and groups
  • Answers to surveys inputted by the user
  • Newsletter sending permission (email marketing)
  • The user’s advertisement click-through history in the service
  • Email messages sent to the user (message header)
  • Internet-server technical logs (including user’s IP address and browser information)
  • Information sources: Information provided by user her/himself or generated by the service.
  • Register protection principles: The data is stored on servers located inside the EU, run by makandra GmbH. The server configuration addresses security by limiting outside access to minimum, applying firewalling for each server instance and deploying services to subnets that have limited access to each other and to outside networks. We operate a server cluster optimized for data and failure safety with multiple machines in order to be able to guarantee high availability even in case of hardware failures.

 

3. HeiaHeia Privacy Principles

  • HeiaHeia (including HeiaHeia for Workplaces, HeiaHeia for Schools, HeiaHeia Pro Tools) is a social wellbeing service, it is built around peer support.We collect and process personal data in order to guide and visualise your habit creation journey, as well as social support from your friends and colleagues.
  • Identifying the data controller and data processor: The GDPR differentiates between the “controller” and “processor” of personal data. HeiaHeia Oy is the data controller for the free version of HeiaHeia. HeiaHeia’s premium versions are distributed via “communities”, a community may have its own personal data register and data controller. The personal data register of a premium community includes personal data created in the community in accordance with the purpose of the community. An individual user’s wellbeing data is exported from the premium register also to the free service’s register (excluding data types only available in the premium service) so that the user may continue using the free service also in the case that the premium service is discontinued. The data controller of a premium service may be HeiaHeia Oy (in case the customer of the premium service is an employer), the customer (in case the customer is not an employer), or a reseller (in case the customer is an employer and the reseller defines the contents of the premium service). The Act on the Protection of Privacy in Working Life of the Finnish law limits, what kind of personal data of employees an employer may process and thus also the employer’s possible data processing related roles in HeiaHeia. In cases, where HeiaHeia Oy is not a data controller, it is typically a data processor on behalf of the controller. Data processing related roles and responsibilities are defined in data processing agreements (DPA) between controllers and processors.
  • You as an end-user have control over your personal data: You decide, how much of your personal details you want to share with others. You can control your privacy level from HeiaHeia’s settings. You can transfer your personal data from our digital tools in machine readable format (“data portability”). You can remove your personal data from our digital tools (“right to erasure”).
  • We store the information collected during the registration process, such as your email address, in order to provide the service. We also store your exercise data and potentially other information created at the service.
  • Sharing your exercises and other entries to other HeiaHeia users is managed with friendships. Your friends see all your non-private entries in their ‘feeds’. If you mark individual entries as private, your friends will not see them.
  • Your name is always searchable and your profile picture is visible within HeiaHeia’s friend search. The privacy level you’ve selected defines, who can access your full profile page and training log by clicking your name. The default setting is “Only my HeiaHeia friends and colleagues”.
  • When utilising coaching services in HeiaHeia, you give consent for the coach to see all the information you have stored in HeiaHeia, including entries you have marked as private.
  • HeiaHeia’s mobile applications may use and store your current location to record your workouts. You may disable location services from mobile application settings, but then you will not be able to add location data to workouts.
  • Location data (GPS data) created by you with HeiaHeia mobile applications or other compatible methods may be stored to create and annotate training log entries, and is treated with the same privacy principles as all training log data. Maps and “check-ins” created from GPS data have more privacy options than other training log data types, enabling stricter privacy. GPS data created on HeiaHeia mobile apps that is not used to create training log entries is not stored permanently by HeiaHeia.
  • Data created by users of HeiaHeia may be used for creating anonymous aggregated statistics. In these statics, exact figures are shown only, if N ≥ 5.
  • Most important anonymous aggregated statics created from HeiaHeia user data include the following:
    • Amount of active users
    • Distribution of activity levels and accumulation of wellbeing score points from different areas of activity
    • Most popular sport types and wellness entries
    • Amount of training programs and habit challenges started
    • Amount of cheers given
    • Average amount of exercise and steps
    • Amount of users who have reached personal goal during campaign
    • Amount of users who have exercised on average over 2,5 hours per week
    • Amount of users who have taken on average over 10 000 steps per day
  • If you join HeiaHeia via a company or community invitation, you also give consent to participate in possible activity challenges, which may include rewarding for activity, being included on participant lists, and reporting. Participating in activity challenges includes sharing high level personal data, like meeting your daily step target or the amount of “wellbeing points” you have collected, with the campaign organiser and other participants. You can choose to opt-out or opt-in to the parts including personal data sharing at any point via the settings, under “Participant lists and reporting”.
  • Detailed participant lists:
    • List of people or teams, who have reached a personal or team goal during campaign
    • List of people or teams, who have logged on average over 2,5 hours of exercise per week
    • List of people or teams, who have taken on average over 10 000 steps per day
    • List of people or teams, who have reached a wellbeing score level that reflects active use and good foundation for wellbeing (level 2).
  • Workplace admins have access to the aggregated anonymous statistics as well as possible participant lists of people that have exceeded threshold limits and given consent.

HeiaHeia cookie usage practices:

  • Authentication: If you’re signed in to HeiaHeia, cookies help us to show you the desired information and personalise your experience.
  • Security: We use cookies to enable and support our security features, and to help us detect malicious activity and violations of our Terms of Service.
  • Preferences, features and services: Cookies can tell us which language you prefer and what your communications preferences are.
  • Advertising: We may use cookies to show you relevant advertising both on and off the HeiaHeia site. We may also use a cookie to learn whether members who saw an ad on HeiaHeia later visited the advertiser’s site. Similarly, our partners may use a cookie to determine whether we’ve shown an ad and how it performed, or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off HeiaHeia, such as after you’ve visited a partner’s site or application.
  • Performance, Analytics and Research: Cookies help us learn how well our site performs in different locations. We also use cookies to understand, improve, and research products, features, and services, including when you access HeiaHeia from other websites, applications, or devices such as your work computer or your mobile device.

Most important 3rd party cookies used in HeiaHeia:

  • Google Analytics and Google Tag Manager https://www.google.com/intl/en/policies/privacy/
  • Facebook https://www.facebook.com/help/cookies/
  • LinkedIn: https://www.linkedin.com/legal/privacy-policy
  • HubSpot: https://legal.hubspot.com/privacy-policy

Personal data collection in HeiaHeia:

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: HeiaHeia Oy (Ltd), contact: helpdesk@heiaheia.com
  • Register name: HeiaHeia user register
  • Purpose of use: The register is used for providing the HeiaHeia service and for managing user relations between HeiaHeia Oy and its service end-users. Register information is not used for direct marketing without the user’s consent, managed by service settings.

Register content:

  • The user’s personal information (name, sex, birthday)
  • Unique customer ID
  • The user’s contact information (email, phone number optional)
  • The user’s hometown
  • The user’s personal measurement information (height, weight)
  • The user’s wellbeing targets
  • Types of exercise (sports) of interest to the user
  • The user’s training log information and other wellbeing and other data entered to the service by the user
  • Wellbeing data from wearable devices connected to HeiaHeia by the user, e.g. exercise data, daily step count, sleep data, resting heart rate
  • Photos uploaded to the service by the user
  • The user’s social connections in the service
  • The user’s messaging history in the service
  • The user’s membership status in communities and groups
  • Answers to surveys inputted by the user
  • Newsletter sending permission (email marketing)
  • The user’s advertisement click-through history in the service
  • Email messages sent to the user from HeiaHeia (message header)
  • Internet-server technical logs (including user’s IP address and browser information)
  • Information sources: Information provided by user her/himself or generated by the HeiaHeia service.
  • Register protection principles: The data is stored on servers located inside the EU, run by makandra Gmbh. The configuration addresses security by limiting outside access to minimum, applying firewalling for each server instance and deploying services to subnets that have limited access to each other and to outside networks.

 

4. Privacy Principles for the HeiaHeia marketing site

Upon certain interactions with heiaheia.com (e.g. subscribing to our newsletter), you give consent for your personal details to be added to the HeiaHeia marketing register, which may contain the following personal data, submitted by the user her/himself:

  • Name
  • E-mail address
  • Mobile phone number
  • Age and gender
  • Job level and position
  • Company name and industry
  • User submitted interests for newsletter subscription preferences

In addition to self-submitted data, we use analytics and marketing automation tools, which collect data on users’ browsing information, such as traffic sources, browser and devices used, time spent in HeiaHeia’s website, pages visited, geographic location etc.

We collect personal data mainly at the point of subscription, but also later during the customer relationship. HeiaHeia’s website uses cookies, web beacons and other similar methods in order to improve user experience, to develop our websites and services further, and for targeting content and communications. Cookies are small pieces of data sent from a website and stored on the user’s computer by the user’s web browser. Cookies can be blocked from your browser’s settings. Our pages may also include other third-party components, such as lead trackers.

We process personal data for the uses of customer relationship management and  marketing with the consent of the visitor, without disclosing customer personal data to any third party. We maintain a register on newsletter subscribers and other users of our website’s functionality. Newsletters are sent to subscribers by email based on the marketing register’s information.

HeiaHeia’s website runs a marketing automation system that is used for improving the general user experience of our website and its content, and for creating target segments for marketing.

We places cookies, when a visitor first arrives to our website, in order to learn, how visitors consume content in the site. A visitor’s personal data remains anonymous to HeiaHeia until:

  1. Visitor subscribes to HeiaHeia’s newsletter or other material

A user’s personal data may be linked to the cookie, when a visitor subscribes to a newsletter, white paper etc. Submitted information is stored in the HeiaHeia marketing register.

  1. Visitor arrives at the website from an email marketing message sent by HeiaHeia

A user’s personal information may be linked to a cookie, when the user arrives at the website via an email marketing message sent by HeiaHeia. The source for e-mail marketing messages is HeiaHeia’s marketing register. A user, whose cookie is linked to personal data, may receive email marketing that is personalised based on her/his website visitor history. In case a user wishes to unassociated from their previous browsing history, they can do so by clearing their browser cookies.

You have the legal right to inspect the data we have collected concerning you. You also have the right to request the correction or deletion of incorrect, defective, unnecessary or outdated personal data.

Your data can be removed from the HeiaHeia marketing register based on a personal request. Requests for register-related matters shall be submitted in writing to the postal address HeiaHeia Oy, Valhallankatu 14 B 19, 00250 Helsinki. Newsletter subscribers can unsubscribe directly from the newsletter.

 

5. Privacy Principles for HeiaHeia’s support pages

We run support portals to enable customer service for our different services (support.heiaheia.com ja support.marsmars.fi). The support portals enable creation of support tickets, we create a personal data register of people, who have sent these tickets, to enable customer service delivery.

Personal data collection register information according to the GDPR (679/2016), articles 12-14:

  • The register is maintained by: HeiaHeia Oy (Ltd), contact: helpdesk@heiaheia.com
  • Register name: HeiaHeia Support customer register
  • Purpose of use: The register is used for providing customer service

Register content:

  • The user’s personal information (name)
  • The user’s contact information (email)
  • The service in case (HeiaHeia and MarsMars)
  • Mobile device and OS of the user (Android, iOS, web)
  • Messaging history between the user and customer service
  • Articles visited in the support portal by the user
  • Possible Android log file sent to customer service by the user
  • Information sources: Information provided by user her/himself
  • Register protection principles: We run our support portals with the HubSpot service provided by HubSpot, Inc. HubSpot acts as a personal data processor on our behalf and fulfills the requirements of the GDPR.


6. Google user data

Accessing Google user data:

  • HeiaHeia users are able to connect to external providers, like Google Fit, to get wellbeing data automatically, e.g. exercise data, daily step count, sleep data, and weight data. The connection is enabled by the user in the app, and users can revoke the connection at any time.

Using Google user data:

  • Wellbeing data from Google Fit is used similarly as wellbeing data from all other sources (e.g. data created manually in the app, data from wearable connections): the data is used to create statistics and achievements for the user, e.g. exercise data is used for entries that can be cheered by your friends, exercise and step data may be used as input for activity challenges in communities.

Storing Google user data:

  • Data is stored as all other data, and follows the same principles for sharing and privacy levels, set by the user. If the user chooses to delete their account, also all automatically fetched data will be deleted.

Sharing Google user data:

  • HeiaHeia is a social wellbeing service based on peer support. Some of the wellbeing data from Google Fit (e.g. exercises, weekly level step streaks) is used to create events that can be shared to your friends in a feed in HeiaHeia. Sharing can be managed in settings of the service and in individual entries. It is also possible to share individual entries outside HeiaHeia e.g. to social media services. This is always done manually by the user.

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