Privacy Policy

Welcome, and thank you for your interest in Huubia and Visionbay Solutions services.

This Privacy Policy describes the information that we gather on or through the Huubia Service, Huubia web site and Visionbay Solutions web site or other sources, how we use and disclose such information, and the steps we take to protect such information. By visiting our web sites, or by purchasing or using the Service, you consent to the privacy practices described in this Privacy Policy.

 

Definitions

Account: An account enabling a Client and/or User to access and use the Service. Account stands for one Client instance of the Service.

Client: means a registered Customer of Huubia® Service

Client Data: All data, content, and information owned, held, used or created by or on behalf of the Client that is stored using, or input into, the Service.

Customer: natural or legal person who has accepted the Terms of service and/or and who represents registered organization, company or entity or “consumer“– a natural person not representing any registered entity/company/organization who has accepted these terms. “Consumers” are only allowed to use the Trial version of Huubia self-service.

GDPR: European Union’s General Data Protection Regulation

Personal Data: means information that specifically identifies an individual or that is linked to information that identifies a specific individual.

Platform: The platform managed by the Provider and used by the Provider to provide the Service, including the application and database software for the Service, the system and server software used to provide the Service, and the computer hardware on which that application, database, system and server software is installed.

Policy: means this Privacy Policy document

Provider: Visionbay Solutions Oy business identity code FI26322227 (2632222-7), located at Finland also later as “We”, “Us” or “Visionbay Solutions”.

Public Area: means the area of the Site that can be accessed both by Users and Visitors, without needing to login into Service.

Restricted Area: means the area of the Service that can be accessed only by Users, and where access requires the use of personal login ID and a password.

Service: Software (Huubia ®) made available via www.gohuubia.com or from its sub domains or mobile application or, Platform and service and/or products available through the Platform and/or Site. Commercial version available only for registered entities/companies/organizations.

Site: the compilation of all web documents (including images, php and html files) made available via www.huubia.com, www.visionbaysolutions.com and www.visionbay.fi or from the sub domains under top domains or domains with identical names under other top domains and owned by Provider.

Terms of Service: means the Huubia self-service terms of service or other service agreement or agreements between the Customer and Provider.

User: means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Service

Visitor: means an individual who uses the Public Area.

 

The Information We Collect on the Site:

i) User-provided Information. When you contact Provider using contact of forms on the Site as Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual.

ii) “Automatically Collected” Information. When a Visitor visits the Site, we may automatically record certain information from the Visitor’s device by using various types of technology, including cookies. This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after visiting the Site, the pages or other content the Visitor views or interacts with on the Site, and the dates and times of the visit or access.

 

The Information We Collect on the Service:

i) User-provided Information. When you register or use the Service, as a User, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with other users of the Service through communication or messaging capabilities, or send us customer service -related requests.

ii) Information Collected by Clients. A Client or User may store or upload into the Service Client Data. Provider has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third party persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data. If Customer is using Provider’s other services which includes processing of Personal Data on behalf of Customer, a separate agreement and documentation has been made between Customer and Provider in terms of the GDPR.

iii) “Automatically Collected” Information. When a User uses the Service, we may automatically record certain information from the User’s device by using various types of technology, including cookies. This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the pages or other content the User views or interacts with on the Service, and the dates and times of the access or use of the Service. We also monitor the activities on Account in order to improve and maintain the Service and as a base for the Service billing principle. We also collect information which reports and data visualizations and outcomes of reports and visualizations User viewed in the Service.

 

The Information We Collect from Other Sources:

i) Other Sources: We may obtain information, including Personal Data, from third parties and sources other than the Service or Site, such as our partners, advertisers, and integrated services. If we combine or associate information from other sources with Personal Data that we collect through the Service or Site, we will treat the combined information as Personal Data in accordance with this Policy and GDPR.

ii) Certain third parties, including analytics companies, advertisers and ad networks, may also automatically collect information about you through our Site, using cookies, Web beacons, and device identifiers, including personally identifiable information about your online activities over time and across different websites, devices, online channels and applications when you use our Site.
You agree that any information we collect and process is relevant and not excessive in relation to the purposes for which the information is collected and/or further processed.

 

How We Use the Information We Collect on the Site

i) Communicational purposes: We may use a Visitor’s email address or phone/mobile phone number – other than Client Data – to contact that Visitor (i) for administrative purposes such as customer service, to address intellectual property infringement any unlawful, illegal, fraudulent or harmful purpose or activity on the Account or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with.

ii) We use Google Analytics to measure and evaluate access to and traffic on the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing. We do not use any of this information to identify Visitors.

iii) We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors.

 

How We Use the Information We Collect on the Service

We use the information that we collect in a variety of ways in providing the Service, including the following:

i) Operational purposes: We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to questions and comments and to provide support to Users of the Service. We process Client Data solely in accordance with the Service and the related Terms of Service.

ii) Billing purposes: We use the information relating to User’s activity within the Service as a base for our billing principle. The charges relating to the usage of the Software are based on the count of Users, sessions, actual usage of the Software, reserved and used capacity and activated functionalities.

iii) Improvements: We use the information – other than Client Data – to monitor and analyze the usage trends and preferences, to improve the Service and to develop new products, features and functionalities.

iv) Communicational purposes: We may use User’s email address or phone/mobile phone number – other than Client Data – to contact that User (i) for administrative purposes such as customer service, to address intellectual property infringement any unlawful, illegal, fraudulent or harmful purpose or activity on the Account or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with.

v) We use automatically collected on the Service through cookies to: i) enable our Service work. The Service uses cookies to store Users session identifier (token), ii) personalize the Service, such as remembering a User’s log-in information to the Restricted Area so that User doesn’t have to re-enter all of the login details when logging into Service again iii) identifying User’s web browsers to improve the security of the Service.

vi) Auditing the usage of the Service by User when Customer User activity audit: We use the information to create reports for Customer of the User activities in the Service when Customer has legitimate reason to audit User activities. For example when a security breach has occurred by using User’s user account and Customer needs to know the information of viewed data in the Service by using the user account, the Provider will provide Users usage reports and content of User’s viewed reports or data visualizations to the Customer from the time period the security breach occurred.

 

How We Use the Information We Collect on Other Sources

i) Communicational & commercial purposes: We may use email address or phone/mobile phone number – other than Client Data – to i) contact person to communicate with updates on promotions and events, relating to products and services offered by us and by third parties we work with ii) Set-up meetings with potential customers or partners.

 

Disclosing Information

We will keep Client Data strictly confidential and will not disclose Client data to any third parties. All Client Data you upload into the Service will be stored in databases located in Finland (within the EU) .

We will not disclose Personal Data collected from the Service to any third party besides the members of our corporate group, except when, to the extent, and to persons (i) expressly allowed by the Customer or Visitor or User concerned, (ii) required by law, or (iii) necessary in order to perform our obligations under the Agreement, or its statutory obligations, or to exercise its legal rights, or defend against claims or other process.

We will not disclose Personal Data collected from Site or Other Sources to any third party besides the members of our corporate group, except when, to the extent, and to persons (i) expressly allowed by the Customer or Visitor or User concerned, (ii) required by law, or (iii) necessary in order to perform our obligations under the Agreement, or its statutory obligations, or to exercise its legal rights, or defend against claims or other process, or iv) necessary partner employees when Provider is using a partner for commercial purposes, example setting up new meetings with potential customers.
All Personal data we gather and store will be stored in databases located in Finland (within the EU).

 

Security in Huubia Service

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further secure your data.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

 

Jurisdiction

Any dispute that may arise between Customer and Provider or between and User or Visitor and Provider in connection with this Policy or Provider’s data processing activities shall be subject to the jurisdiction specified in the respective Provider’s Terms of Service.

 

Access, Correction, Deletion in Huubia Service Personal Data

We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Service. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you, you may contact us as set forth in the “How to Contact Us” section.

You may update and/or correct your account information in the Service and preferences at any time by accessing your my settings page on the Service. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Your Account administrator can mark User’s Account as a deleted user. In this scenario user account is not fully deleted from the Service, but it is marked as deleted and you can’t use the Service with this user account anymore. If you wish to fully delete your Personal Data from the Service please contact us as set forth in the “How to Contact Us” section. In this scenario we will ask your Account’s administrator for further instructions. This situation may prevent Us providing you the Service.

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you our Service.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us as set forth in the “How to Contact Us” section. You also have a right to lodge a complaint with data protection authorities.

This provision does not apply to Personal Data that is part of Client Data. In this case, the management of the Client Data is subject to the Customer’s own Privacy Policy, and any request for access, correction or deletion should be made to the Customer responsible for the uploading and storage of such data into the Service.

 

Access, Correction, Deletion in Site and Other Sources Personal Data

If you wish to access or amend any other Personal Data we hold about you, or to request that we correct, delete or transfer information about you, you may contact us as set forth in the “How to Contact Us” section.

 

Opting out from Commercial Communications

If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.

 

Data Retention

Personal Data is kept in the user register of the Huubia Service when Customer has active Account. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

the contents of closed Accounts are deleted within 14 days of the date of closure;

backups are kept for 30 days;

billing information is retained for a period of 7 years as of their provision to Provider in accordance with the Finnish accounting and taxation laws.

 

Data Controller and Data Processor

Provider does not own, control or directly use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and directly use of such Client Data unless Client or User has specifically asked the Provider to process Client Data or there is an agreement of services between the Customer and Provider which requires processing of the Client Data by the Provider. Under these circumstances Provider will only process the Client Data by the instructions given or agreed by the Client.

Because Provider does not collect or determine the use of any Personal Data contained in the Client Data and because it does not determine the purposes for which such Personal Data is collected, the means of collecting such Personal Data, or the use of such Personal Data, Provider is not acting in the capacity of data controller in terms of the GDPR and does not have the associated responsibilities under the GDPR. Provider should be considered only as a processor on behalf of its Clients and Users as to any Client Data containing Personal Data that is subject to the requirements of the GDPR.

The Client or the User is the data controller under the regulation for any Client Data containing Personal Data, meaning that such party controls the manner such Personal Data is collected and used as well as the determination of the purposes and means of the processing of such Personal Data.

Provider is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) nor is Provider responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.

 

Changes To This Privacy Policy

This Privacy Policy is effective as of (25th May 2018) and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our Site or Service.

 

How to Contact Us

Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email at info@visionbay.fi.

If you have any concerns or complaints about this Policy or your Personal Data, you may contact Visionbay Solutions at info@visionbay.fi