Privacy Policy
Skillwell collects, stores and processes personal data of Data Subjects in accordance with EU General Data Protection Regulation, GDPR and national privacy legislation. We are executing clearly defined data protection processes, documentation, policies and data processing actions.
1. Data Controller
The owner of the service is Skillwell Oy (later Skillwell), Business ID 2920924-6. Address: Kauppakatu 39, 40100 Jyväskylä, Finland
2. Data contact point
Skillwell. Kauppakatu 39, 40100 Jyväskylä, Finland. Contacts and requests regarding data control and personal data are answered at code@skillwell.fi.
3. Basis for processing personal data
The legitimate basis for processing personal data is a contractual relation between Skillwell and customer, the intention to form a customer relationship, customer consent, a request for cooperation from customer or other legitimate connection.
Data subject data can be used for the following purposes:
conducting and follow up of marketing, communications and sales,
targeting and personalizing services, conducting campaigns, managing service process,
analyzing customers, grouping, reporting and creating statistics,
customer service, customer relationships management,
developing business processes and,
conducting market research.
Processing of personal data can be outsourced within the corporation or to third parties in compliance with EU data protection regulation and national legislation.
4. Data register content
The register may contain following data:
Person´s first name, last name, title, name of the organization and contact information
Other content delivered or linked by data subject
Information provided by data subject
Restrictions provided by data subject
Use of website based on IP-address and cookies
Actions performed by sales, marketing, communications and
Data connected to processing data, such as save date and source of information.
Email address
Address information
Work phone number
Contact person at Skillwell
Customer level and / or customer life cycle
The person must be accompanied by the so-called "Buyer"
Language
Basis for processing personal data (agreement, consent, legitimate interest)
Skillwell assignments (call / email / references / appointment)
Notes (call / appointment / other tasks)
Call details (because called and spoken)
Appointment information (as met and spoken)
Sales history
Email correspondence
Recruitment announcements made publicly by the company
Information about the use of the ActiveCampaign website, such as: IP credentials, leadscore, completed forms, email openings and clicks, call-to-action clicks, website usage information, and various usage activities (dates, numbers, traffic sources)
Marketing consents / prohibitions
5. Storage period of data
Data will be stored for as long as the data controller has legitimate need for in regard to the purposes of the processing. If the data subject has restricted marketing rights of Skillwell, the restriction request related data shall be stored to fulfill data subject’s rights.
6. Regular sources of data
Data may be collected from the following sources
Data subject themselves
cookies and cookie related technologies. We may collect the following “cookie” information: your IP address, when you visited, pages you visited and the duration, browser. You may change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies.
Our network and partners
Service providers such as directory companies, public registers and other legitimate sources.
7. Regular transfers of data within EU of outside of EEA
Personal data is processed by Skillwell or third parties working on behalf of Skillwell. No other transfers of personal data will be carried out. Personal information may be transferred or admitted with consent from the customer into temporary records. The data in these registers will only be handled for a specific purpose with clearly defined instructions.
Data will be admitted to authorities as required by law or in legal proceedings, such as investigating and preventing malpractice.
Data can, when necessary, be transferred outside of EU or EEA in compliance of the EU Data Protection Regulation and national legislation. Skillwell reserves the right to transfer all data, including personal data to a third party in corporate acquisition, merger or other business arrangement.
8. Joint controllers with Facebook
We have conducted separate documentation on our joint controller role with Facebook and you can read it here.
9. Principles of protecting the register
All personal information is stored as confidential. Personal data is only processed in technical transfers through secure interfaces. Only persons for whom it is imperative due to their job description to have access to systems will have the right to process personal data. Data is stored in systems that are protected with high technical protection measures, and access is limited with user control and identification.
10. Profiling
Processing data subjects registered data may contain profiling. The purpose of profiling is to target marketing, communications, sales and customer service actions to the right recipients.
11. Rights of the registered Data Subject
Right of access and rectification
Data Subject has the right to ask for rectification of inaccurate information. This should be performed in writing according to section 2 in this document. Data Subject has the right to obtain what information is recorded and processed about them. Requests regarding personal data should be performed according to section 2 in this document. The reply to the request will be delivered when the authenticity of the person is confirmed.
Right to prohibit processing
The Data Subject has the right to prohibit Data Controllers processing their information for the purposes of direct marketing and sales by informing the Data Controller according to section 2 in this document.
Right to erasure
The Data Subject has the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay. Requests regarding personal data should be performed according to section 2 in this document.
Right to be forgotten
Data Subject has the right to be forgotten. Then all personal information of the Data Subject will be erased from Skillwell systems immediately and indefinitely, unless there is legitimate ground for maintaining them. If a Data Subject wishes to apply their right to be forgotten, requests should be performed according to section 2 in this document.
Right to data portability
The Data Subject has the right to receive their personal data in a structured, commonly used and machine-readable format. The following applies only to data the Data Subject has provided. Requests regarding personal data should be performed according to section 2 in this document. The reply to the request will be delivered when the authenticity of the person is confirmed.
Right to restriction of processing and profiling
The data subject has the right to obtain from the controller restriction of processing and/or profiling. This would apply to a situation where the Data Subject is waiting for Skillwell´s reply to requests of rectification or erasure. Requests should be performed according to section 2 in this document.
Right to lodge a complaint
The Data Subject has the right to lodge a complaint with the competent supervisory authority about the way the Data Controller processes their personal data. Complaint is lodged with the supervisory authority, who in Finland is The Office of the Data Protection Ombudsman (https://tietosuoja.fi/en/home)
12. Changes to our Privacy Policy
Skillwell is developing continuously and reserves the right to make changes or updates to this Privacy Policy at any time. Changes may also be made on grounds of changing legislation. All changes are effective immediately upon posting. Skillwell encourages Data Subject to periodically review this page for the latest information on our privacy policies.
