DATA PROTECTION NOTICE TO HUMANSCALE PRESENTER (”Software”) USERS
According to the EU General Data Protection Regulation and the UK Data Protection Act
2018, the personal data controller of a register is obligated to inform the register’s data
subjects in a clear manner. This statement fulfils these informing obligations.
- Personal data controller
Oy CDQ Solutions Ltd (”Supplier”) acts as a controller for the personal data register of
the Humanscale Presenter (“Software”) user data as referred to in the EU General
Data Protection Regulation (2016/679).
Oy CDQ Solutions Ltd
00510 Helsinki, Finland
The Client company Humanscale Corporation (“Client”) acts as a controller for the
personal data register as referred to in the EU General Data Protection Regulation
- Data subjects
Users of the Software. These may include the Client’s employees, partners or agents
to whom access rights have been granted.
- Purpose of use of personal data
The data is used by the Supplier for monitoring the use of the presentation tool. The
data is used by the Client for monitoring and developing the Client’s presentation
material and its use. The information will not be used for direct marketing.
- Categories of personal data processed
The information in the user register includes the user’s email address, as well as
information about the devices on which the application is installed, their operating
systems, the version numbers of the application, the use of presentation material,
and when the application has been used. Unique identifiable personal data is the
user’s email address which serves as a username. This information is collected with
the explicit consent of the user.
- The data subject’s rights
The data subject has the following rights, and requests for their use should be sent
to the personal data controller.
Right to access data
The data subject may check the data we have recorded.
Right to rectification
The data subject may request the rectification of inaccurate or incomplete
Right to object
The data subject may object to the processing of personal data if the data
subject feels that personal data has been processed unlawfully.
Right to forbid direct marketing
The data subject has the right to forbid the use of personal data for direct
Right to deletion
The data subject has the right to request the deletion of data if personal data
processing is not necessary. We will handle the request for deletion and
proceed to either delete the data or state a justified reason for not being able
to delete the data.
It should be noted that the controller may have legal or other rights to not
delete the requested data. The controller is obligated to preserve accounting
materials for the duration (10 years) set out in the Accounting Act (Chapter 2,
Section 10). For this reason, materials related to accounting cannot be deleted
before that term has expired.
If the processing of personal data is only based on the data subject’s consent
and not for instance on a customer relationship or membership, the data
subject may withdraw consent.
The data subject may complain of the decision to the Data Protection
The data subject has the right to demand us to restrict the processing of
controversial data until the matter is solved.
Right to complain
The data subject has the right to complain to the Data Protection Supervisor if
the data subject feels that we are violating the effective data protection
regulation when processing personal data.
Contact information of the data protection supervisor:
- Regular information sources
User data is regularly obtained from the use of the Software.
- Regular disclosure of data
We are disclosing information to the Client, who has committed to complying with
the requirements of the data protection regulation by using data protection
safeguards in the form of standard contractual clauses. On request, the data subject
has the right to obtain a copy of these clauses.
- Duration of processing
Personal data will be kept for as long as necessary for the service. When a data
subject terminates their user account or their account is deleted, the personal data is
removed from the register.
- Personal data processors
In case the Client has been granted admin rights to monitor the user data in the
Software, the Client acts as a processor of user data as referred to in the GDPR
Access to the personal data register is only available to designated admin users on
the Client side. The Client will disclose the processed personal data to its personnel
only to the extent where it is strictly necessary. The processor will ensure that
persons who are entitled to process personal data are bound by an obligation of
professional secrecy or are subject to an appropriate legal obligation of secrecy.
- Transferring data outside the EU
Personal data is regularly transferred outside the EU or the EEA to the client
company which resides in the US. Personal data is not transferred to any other
recipients than the Client company.
If personal data is transferred outside the EU and the EEA, we will safeguard the
sufficient level of personal data protection by e.g. agreeing on matters related to the
confidentiality and processing of personal data in compliance with legislation.
- Automatic decision making and profiling
User data is not used for automatic decision making or profiling