PRIVACY POLICY – Personal data act (523/1999) 10 ja 24§

Updated: May 2018

  1. Data controller

Name: Odum Oy, 0224529-8

Address: Hitsaajankatu 22, 00810 Helsinki

Contact information: (09) 2511 7170, info@odum.fi

  1. Contact person with matters concerning the privacy policy

Name: Henri Rautamo, data protection officer

Address: Hitsaajankatu 22, 00810 Helsinki

  1. Name of the data file system

AlvinOne

  1. Purpose of processing personal data

Personal information is collected from users to evaluate and improve their well-being. In addition, the system may produce anonymised group level reports for the employer of the users. In these reports all identifiable personal information is removed and reports are only created for groups comprising 20 persons or more so that individuals cannot be identified. No personal information is ever shared with supervisors, company management, colleagues or authorities.

If agreed upon separately by written consent bewtween AlvinOne and the User, designated healthcare professionals can be granted access to the information as a part of the user’s occupational healthcare, i.e. as a part of a health exam.

Email addresses are used to individualise users and to communicate with users when needed. Such occasions include sending a confirmation email when registering to use AlvinOne, sending reminders and other content agreed upon in co-operation with the employer of the user. Date of birth and the user’s sex are used to calculate the user’s results.

The information is stored in the data file until for the time being and as long as the employer of the user has a valid contract with AlvinOne. If the contract ends all personal information is erased within six months of the contract expiry. If the employer notifies the data controller of the termination of employment of a user the user’s personal information is erased within one month of the notice.

The collected data may also be used anonymously in research as the company develops the methods used in the data analysis processes of their product. In this case all identifiable personal information is removed so that individuals cannot be identified.

  1. File’s data content

Name, sex, email address, employer, date of response and responses to questions regarding the user’s well-being and health.

  1. Regular data sources

The data the user voluntarily provides while using AlvinOne, such as personal data and information about the user’s health and well-being.

  1. Disclosure and regular data transfers

Data is not regularly transferred.

  1. Disclosure and data transfers outside the EU or the EEA

Information is not transferred outside the European Union or European Economic Area.

  1. File protection policy

The data is saved and stored in a protected and secure data system. If necessary designated healthcare professionals can be granted access to process personal information and AlvinOne results.

Healthcare professionals are bound by confidentiality. Logging into the system takes place by using a personal user ID and password and an SMS confirmation. Healthcare professionals have restricted read-only access to information that’s relevant to treat the user. No individual personal information is ever shared with supervisors, company management, colleagues or authorities.

All data communication is strongly encrypted and stored in a secured data center. The advanced security solutions of the data center meet the existing requirements. The system collects user-specific logs of all actions and changes to the data and the times of their occurrence. The data file is backed up regularly.

  1. Privacy requests

Users have the right to review all personal information stored in the system. Privacy requests shall be submitted by email to the following address: support@alvinone.com.

  1. Correction requests

Users have the right to make changes to incorrect personal information stored in the system. Correction requests shall be submitted by email to the following address: support@alvinone.com.

  1. Other rights

Users have the right to request removal of all personal information stored in the system. Removal requests are always fulfilled as soon as possible but at the latest within one month of the request. Removal requests shall be submitted by email to the following address: support@alvinone.com.

The data file is not used for direct advertising, sales, other direct marketing, market research or polling.