Hopoti Software Oy (hereinafter referred to as “Hopoti”) agrees to protect the privacy of the users of its services and to comply with data protection legislation and other legislation, as well as good data protection practices. This privacy statement specifies Hopoti’s practices concerning the collection and processing of personal data.
“Personal data” refers to data that can be associated with an individual person.
This privacy statement is applied insofar as Hopoti fulfils the role of controller and whenever the applicability of this privacy statement is referred to when using Hopoti’s services. We may also provide additional information regarding data protection within a separate service, website or application.
The primary legal bases for the processing of personal data are the use of Hopoti’s services, another appropriate connection between the user and Hopoti’s service or the user’s consent. Any applications published by Hopoti you may have installed may also process your personal data.
If you are unwilling to accept the practices described in this privacy statement, we recommend that you do not give your personal data to Hopoti.
What type of data is collected?
Hopoti may collect user data necessary for the purposes defined in this privacy statement. The purpose of use defines the type of user data collected in different scenarios.
Your personal data may be collected when you register as a user of Hopoti’s services, when you use the services, within various competitions, campaigns or surveys or whenever you contact us. Personal data from the following categories, among others, are collected by Hopoti.
1. Information submitted to Hopoti
We may ask you to provide information within various services that you may choose to give to Hopoti:
- Name or nickname
- Password or another unique identifier
- Email address and other contact details
- Other details describing the user, such as date of birth, height and weight
- Any content uploaded to the service, such as posts, comments and images
- Permissions, consents and information regarding choice of language or other selections
- Interests and favourites
- Information related to contests prize draws
- Research and survey data
- Information on the devices used by you
- Client feedback and communications, including recordings of phone calls
- Other data given or disclosed with your consent, e.g. data collected from external sources.
We collect data by a variety of means, such as when you enter your data when registering to the service, when you use the service or when you participate in Hopoti’s contests, prize draws or studies.
2. Observed and inferred service usage data
We may collect the following data concerning you and the use of Hopoti’s services:
- Data collected by online analysis service systems (cf. “Cookies”)
- Data related to client communications, e.g. information about clicked links
- The website that redirected the user to Hopoti’s website
- Any possible search terms used to search for Hopoti’s website or used in Hopoti’s services
- Device identifiers such as the model of the user’s device and the unique device and/or cookie identifier
- The channel via which the data was collected: internet browser, mobile browser, application and the browser version
- IP address
- User interface of the user’s device
- Session identifier, time and duration
- Location information, if you have provided an explicit consent for this.
- Data linked to the user based on the Hopoti services’ user history inferred from observed behaviour and/or the data provided by the user, e.g. demographic data, interests or other modes of classifying users
- Other data collected with your consent
Hopoti’s services and functionalities based on location data use satellite-based geographic data, IP addresses or other online-based location data. The use of assisted location services, such as assisted GPS, may include transferring your location data and unique device or network service provider-specific identifiers to our location server. When you use our location-based servers to search for the nearest stable, for example, your location data is sent to Hopoti with your consent in order to provide accurate content.
For what purposes are the personal data processed?
We shall process your personal data for one or more of the purposes described above.
1. Service provision
Your personal data may be used in providing Hopoti’s services, identifying users or making Hopoti’s services more personal, interactive and user-friendly, for example, by allowing you to use Hopoti’s service with various devices you may possess, recommending possibly interesting content and displaying targeted content in our services. Your personal data may also be used for the purposes of replying to your requests and questions, implementing the selections you have made and performing other similar tasks, ensuring data security and preventing the misuse of services.
2. Service development
Your personal data may be used for the purposes of developing Hopoti’s services and improving the user experience. Your personal data may be used to conduct surveys and studies related to Hopoti’s services and content and to perform usage and coverage analyses. We may merge data collected within the use of different services and applications insofar as the data has been collected for the same purpose, and we may create statistics to the extent required by the development of the applications.
3. Marketing and client communications
Your personal data may be used to perform marketing and client communications related to Hopoti’s services, for example, when we send you notifications concerning our services or when we contact you in matters related to customer service or our services. In addition, all the stables with which you are registered may also perform similar methods of marketing and client communications.
What are the bases of the processing of personal data?
We shall process your data for the purpose of providing the Hopoti booking service, i.e. the legal basis for the processing of personal data is the implementation of the agreement between us.
We shall also process your data on the basis of the legitimate interest created by the client relationship or possible client relationship.
We shall process your personal data with your consent, for example, when we process your location data or when we ask you for your authorisation to perform direct marketing or to send you our newsletter. You have the right to withdraw your consent at any time by sending an email to firstname.lastname@example.org.
How is the personal data stored and merged?
As described above, Hopoti’s services may store information related to the use of Hopoti’s services for the purpose of enabling certain functionalities. Hopoti shall retain the observed and inferred service usage data separately from the actual personal data file, so it is impossible to identify individual users.
Are the personal data disclosed or transferred?
Hopoti shall transfer your personal data outside Hopoti under the following circumstances:
1. Your consent
Your personal data may be disclosed with your explicit consent, for example, concerning a service provided by a third party.
In general, your personal data will not be displayed to other users of Hopoti’s services, apart from your name, profile and cover picture, your profile’s URL address and the pictures, comments and similar data added to the service by you. Some Hopoti services allow you to share your data with other users at your discretion. We advise you to consider whether you should share your personal data or other information with other users carefully. The visibility of your data can be defined in your privacy settings.
Companies that sell their services via Hopoti, such as stables, have access to your personal data to the extent necessary for providing the service sold. The data can only be accessed by the stables you are or have been a client of and the stables you have added as favourites.
4. Subcontractors and service providers
We have outsourced the processing of personal data to service providers who process the personal data on our behalf. Hopoti may use subcontractors and service providers for the technical maintenance of its services, customer services, user data management and analysis, research, client communications and conducting various campaigns. Your personal data may be disclosed to Hopoti’s subcontractors and service providers only to the extent necessary for the purpose of providing Hopoti’s services and performing the purposes defined in this privacy statement.
Such third parties are not allowed to use your data for any other purposes than the purposes described in this privacy statement and the purposes defined by Hopoti. Hopoti obliges these parties to maintain the confidentiality of your data and to secure an appropriate level of data security for the protection of your personal data.
5. International data transfer
In general, Hopoti aims to provide its services and process your personal data by using operators and services located within the EU or EEA. However, under certain circumstances, Hopoti’s services may be provided by using operators, services and servers located elsewhere, which means that your personal data may be transferred to another country. Such transfers may include the disclosure of personal data outside the EU or EEA to countries with different legislations concerning the processing of personal data than defined by the Finnish law, for example, to the United States. Even in such cases, Hopoti shall ensure the appropriate level of data protection regarding your personal data by agreeing on matters related to the confidentiality and processing of personal data in accordance with the law, for example, by using the standard contractual clauses adopted by the EU Commission and other measures to ensure that the processing of personal data is performed in accordance with this privacy statement, legislation and good practices.
Under certain circumstances, we may disclose data for the purposes of scientific or other research, provided that the data have first been converted to a format that does not enable identifying individual persons.
7. Disclosure required by mandatory law
Your personal data may be disclosed in accordance with requests presented by a competent authority or requirements based on law.
How are the data kept up to date?
We shall make all reasonable efforts to maintain the accuracy of the personal data we possess by deleting unrequired data and updating obsolete data.
Some Hopoti services allow users to control the personal data collected by us and the users’ selections and consents. We urge you to inspect the timeliness of your data periodically with these tools. Please note that it is your responsibility to update the personal data you have provided if any changes occur.
How are the personal data protected?
We pay special attention to data protection and privacy in the design, provision and maintenance of our services. We apply appropriate physical, technological and organisational measures to protect your personal data from being misused. Specifically designated persons are in charge of data protection and privacy matters. Access to systems and databases containing personal data is restricted to specifically designated persons for whom it is absolutely necessary to have the right to process the personal data in question for the purpose of performing their work.[Rivityskohta][Rivityskohta]Data protection and privacy are ensured by means of pre-emptive risk management, paying attention to data protection and privacy when designing our services, training our personnel and inspecting the compliance of our services regularly. We manage risks related to the misuse of the data and other similar risks by considering the probability of such risks and the nature of the protected data.
Hopoti may also use subcontractors and service providers in the provision of its services and processing of personal data. Under such circumstances, we shall make agreements and other similar arrangements to ensure that your personal data are processed in accordance with the appropriate legislation, good data protection practices and this privacy statement.
For how long are the data retained?
We will retain your data in accordance with the current legislation and only for the duration necessary for the purposes defined in this privacy statement. Your personal data will be deleted in the event that the legal basis for the processing is no longer valid.
A user is deemed to have deleted the account registered by them, such as the Hopoti user ID, if they remove their registration to the service. In such cases, Hopoti will delete the user ID and the data provided by the person from the user database, after which it is not possible for anyone to reactivate the user ID, including the user. Observed and inferred service usage data will be converted to a format that will not allow individual persons to be identified.
Please note that some Hopoti services may include public, interactive and communicational functionalities, such as comment sections and discussion forums, and some content created by you may remain visible even in the event that you delete the user ID registered by you or the user-service provider relationship is terminated.
What kind of rights are involved?
You have a statutory right to inspect the personal data collected by us. You also have the right to request the rectification or erasure of inaccurate, incomplete, redundant or obsolete personal data and the right to transfer the data from one system to another.
You may exercise these rights by contacting our customer service, managing your user account in certain Hopoti services or using the functionalities available on your device or in our applications and services. The contact details of our customer service can be found below.
Inspection requests concerning Hopoti can be submitted via email at email@example.com. For the purpose of identifying the user, the inspection request must be sent from the email address specified in the user account the request is about. Details of registered personal data will be sent back to the same email address connected with the user account. Inspection requests may be submitted once a year free of charge.
You may also prohibit Hopoti from using data concerning you for the purposes of direct marketing and conducting customer satisfaction and other studies. Nevertheless, we may continue sending you notifications regarding our services, such as information about changes, faults and issues in our services.
You have the right to request Hopoti to delete your information from the user register by contacting our customer service. Contact details can be found below. The erasure of your data concerning a Hopoti account may be requested by sending an email to firstname.lastname@example.org. The request to delete the data must be sent from an email address linked to the account the request concerns.
You also have the right to lodge a complaint with the data protection ombudsman if you feel that the processing of personal data violates your rights defined in the General Data Protection Regulation.
Amendments to this privacy statement
Hopoti Software Oy is actively developing its services and may periodically make amendments to this privacy statement without an advance notice. Nevertheless, in the event that essential amendments are made, Hopoti will publish information about this at the beginning of the privacy statement and on its website. The amendments may also be related to legislative changes. We recommend that you review this privacy statement periodically in order to become aware of any amendments made.
Who is the controller and how can they be contacted?
The controller of your personal data is Hopoti Software Oy, Merikatu 6, FI-26200 Rauma, Finland.
Please contact our customer service via email at email@example.com in matters concerning privacy.
Person in charge of Hopoti Software Oy’s registers:
Veli-Pekka Ahonen, Hopoti Software Oy
Please note that, due to data security reasons, we may have to confirm your identity before fulfilling your request.