Skhole processes personal data confidentially and only to the extent necessary. The starting point in all activities relating to the processing of personal data is the General Data Protection Regulation (2016/679/EU). Personal data refers any information concerning an identifiable natural person (data subject). Examples of personal data include name, e-mail address and telephone number. On the other hand, information about which browser you are using is not necessarily personal data.
In Skhole’s learning environment, everyone with a Skhole user ID is a data subject. Processing of personal data refers to almost any activity pertaining to personal data, such as collection, recording, editing and even viewing personal data. The processing of personal data in Skhole is based on the consent of the data subject. The data subject can withdraw their consent at any time and that will result in the service not being available any more.
Skhole Oy is the controller of the data file comprising the personal data of the end user data subjects. This imposes certain obligations on Skhole. The data subject also has rights, and they are described in more detail below. The data subject may contact Skhole in all matters pertaining to the processing of personal data by printing out and submitting the form available through this link to Skhole’s office:
Skhole Oy, Paasivuorenkatu 4-6, FI-00530 Helsinki, Finland
Access to personal data in Skhole is strictly limited. Only employees who need to process personal data as part of their duties have access to it. These persons have also been trained to process personal data in a lawful way that respects data protection and data security.
Skhole takes data security seriously. The data security of the service is ensured through common and proven methods. The personal data processed by Skhole is located on the secure servers of those providers proven to be trustworthy. The level of data security is reviewed on a monthly basis, and the required updates are run regularly; if critical vulnerabilities occur, updates are run immediately. In addition to meticulous software development, vulnerabilities are prevented with hosting-level and DNS-level protection (Cloudflare). The employees with access to personal data use very strong and continuously changed passwords. Those who process personal data also use an encrypted VPN connection when outside the office. All employees are also subject to a non-disclosure obligation with regard to all personal data.
As a rule, Skhole stores the personal data it has collected for as long as is necessary for providing the service. Once the data subject ceases to be a user of Skhole’s service, the personal data concerning the data subject will be erased within six months. In this case, Skhole may anonymise the data so that study data can be utilised for statistical and research purposes. However, the data cannot be attributed to any individual person.
The starting point in the processing of personal data at Skhole is the “purpose limitation”. Therefore, the personal data we have collected will only be processed for the purpose for which it was collected. Personal data is primarily processed so that we can guarantee the end users the best learning experience and most effective service possible. At Skhole, personal data can only be used for providing the service, advertising the services, managing and developing the customer relationship (data subject–Skhole), ensuring events in the learning environment (including log-in, communication and providing feedback, passing courses and examinations), carrying out the company’s internal statistical follow-up and developing our service.
Skhole can collect the following data, some of which is personal data: name, IP address and location, identifying name of the user ID, e-mail address, browser details, operating system (e.g. Windows, iOS etc.), occupation, lecture feedback (including the lecture on which the feedback was provided, content of feedback, score given, time, name, e-mail address and group to which the data subject belongs), data subject’s organisation (e.g. educational institution or company), group name, number of log-ins to the learning environment, date of most recent use, registration data, data subject’s achievements (exams, tests, courses and their results) and clicks of e-mail links sent by Skhole. Test users are additionally requested to provide their telephone number, which may be called after the test period.
The data collected by Skhole is based on information collected by it and information provided by the data subject.
“Admin” users of educational institutions and other organisations have the right to add members of their organisation as Skhole users and delete their user IDs. In these cases, the data subject’s personal data (name, e-mail address, organisation) will be received from the admin user. Admin users have the right to view the following personal data concerning the data subjects they administer: name, user ID, e-mail address, name of the data subject’s group, date of the data subject’s most recent use, and the data subject’s achievements.
Skhole uses the following services for providing its service: Heroku, Upcloud, Google Analytics, LogDNA, MailChimp, Intercom, mLab & Amazon's cloud services. In providing the service, Skhole may transfer the data subject’s personal data (name, e-mail address, IP address, data transmitted by the browser, information about the time of using the service, information about studying and courses) to these services. If the data subject uses CSC-Haka or Facebook log-in, Skhole can transmit personal data to these services in order to ensure the log-in. The EU General Data Protection Regulation is also applicable when the above-mentioned service providers process personal data collected by Skhole. Skhole can use external service providers that process personal data collected by Skhole under a “processor agreement”.
The servers used by Skhole are located within the European Union.
The data subject has the right to be informed by Skhole that personal data concerning the subject is processed, and they can choose to request the personal data concerning them from Skhole. If there are inaccuracies or errors in the personal data processed by Skhole, the data subject may demand that the data be rectified. The data subject similarly has the right to be forgotten. Thus, in some cases, the data subject can have the personal data concerning them erased. The data subject can also object to, or in certain cases restrict, the processing of their personal data. Having personal data erased and objecting to or restricting their processing will, however, lead to not being able to use the service provided by Skhole. The data subject can make an information request concerning their own personal data, for example, to Skhole using the form mentioned in section 1 above. In addition, the data subject has the right to prohibit direct marketing, and it will not prevent future use of the service.
Each data subject also has the right to lodge a complaint concerning the controller’s activities to the supervisory authority at any time. In Finland, the supervisory authority is the Data Protection Ombudsman.
(valid as of 5 November 2018)
Skhole Ltd owns this Website and the Services on it. Skhole Ltd’s domicile is Helsinki. These terms and conditions of use are applied to the use of Skhole Ltd’s Website and all Services provided by Skhole, unless otherwise caused by individual Service-specific terms and conditions of use or delivery.
By using the www.skhole.fi Website and Skhole Ltd’s Services, you accept these terms and condition of use and the terms and conditions of the record of personal data processing activities, and undertake to comply with them. If you do not accept these terms and conditions of use and the record of personal data processing activities, you may not use this Website or its Services. If the Customer is a minor, they must ensure that their guardian gives consent to using the Service and is aware of the content of the terms and conditions of use.
Skhole Ltd reserves the right to amend these terms and conditions of use at any time. Amendments to the terms and conditions of use are communicated on Skhole Ltd’s Website, and the terms and conditions enter into force immediately after their publication as binding on the users of the Website and Services. By continuing the use of the Website and Services, you accept the amendments to the terms and conditions of use.
The Services provided by Skhole Ltd may have special technical requirements. The user of the Website and Services is personally liable for ensuring the technical compatibility relating to the use of the Website and Services.
Skhole Ltd is not responsible for temporary obstacles or problems relating to the availability of the Website or Services caused by technical reasons or updates.
The availability of certain Services may require registration as a user and paying a fee for the Service in question. Upon registration as user, the user declares that the information they have provided is correct. If incorrect information is provided, this gives Skhole Ltd the right to terminate the agreement granting the right to use the Service. The information collected from the person registering as a user is specified in more detail in the record of personal data processing activities and any possible Service-specific terms and conditions. Upon registration as a user, a personal user account is created for the user and the log-in to it uses a password. Confidentiality is required from the user with regard to storing the log-in credentials and disclosing them to third parties. The user account is personal, and the associated Right of Use may not be sold, leased or otherwise transferred to a third party without the separate advance written consent of Skhole Ltd. If the user account is transferred to a third party, this gives Skhole Ltd the right to terminate the agreement granting the right to use the Service. In this case, the user of the Website or Service is not entitled to damages or a refund of paid fees. The user of the Website or Service is liable for losses incurred by Skhole Ltd due to misuse.
The user of the Website or Service may publish links to the Website or the home page of the Service in social media and other media as can be deemed acceptable, lawful and does not damage or exploit Skhole Ltd’s reputation. However, the user of the Website or Service must not represent themselves as a representative, employee or partner of Skhole Ltd or as being otherwise associated with Skhole Ltd’s business.
Skhole Ltd owns the content of the Website and Services and all the related economic rights referred to in the Copyright Act unless specified otherwise. Skhole Ltd grants the holder of the User Account a Right of Use to the Service in question in accordance with the Service-specific terms and conditions of use. The user of the Website or Service does not have a right to copy, transfer, publish, make available to the public, commercially use or otherwise use the databases or software included in the Website, Services or their content in a way other than in compliance with these terms and conditions of use or the Service-specific terms and conditions of use. The user of the Website or Service does not have a right to collect components from the Website or Services and compile them into its own service or material packages. Use or utilisation of content under the provisions of the Finnish Copyright Act on agreement licence is not applicable. However, reasonable copies may be made of any text materials of the Services for one’s private use. The copies made must not be used for other purposes.
If Skhole Ltd has a justified reason to suspect that the user of the Website or Service has acted in violation of these terms and conditions, record of personal data processing activities or Service-specific terms and conditions of use, Skhole Ltd shall have the right to remove the Right of Use and take other measures to the extent required for discontinuing the activities breaching the terms and conditions of use (including submitting a police report). In this case, the user of the Website or Service is not entitled to damages or a refund of paid fees. The user of the Website or Service is liable for losses incurred by Skhole Ltd due to misuse.
If a party other than Skhole Ltd (e.g. an educational institution’s teacher with admin rights) processes personal data in Skhole’s Service, they undertake to comply with the record of personal data processing activities. The record of personal data processing activities specifies the purpose, nature and duration of the processing of personal data and which personal data will be collected. The admin user shall only process personal data in accordance with the Company’s record of personal data processing activities, unless otherwise required by legislation. The admin user is under a non-disclosure obligation with regard to personal data. The admin user must erase any personal data in their possession once their right of use to the Service expires.
The admin user has the right to add members of their organisation as Service users and delete their user IDs. In these cases, the data subject’s personal data (name, e-mail address, organisation) will be received from the admin user. Admin users have the right to view the following personal data concerning the data subjects they administer: name, user ID, e-mail address, name of the data subject’s group, date of the data subject’s most recent use, and the data subject’s achievements.
Skhole Ltd may update the Website and Services as necessary at its discretion. Some of the Services may be static and not updated at all. However, Skhole Ltd does not guarantee that the information presented on the Website and in the Services is up to date or correct. Unless otherwise provided by legislation, Skhole Ltd is not liable for and direct or indirect losses incurred by the user of the Website or Service due to the use and application of the Website or Service or their content.
The information and advice included in the Website and Services is intended to be used as is, and Skhole Ltd gives no explicit, indirect or compelling or other guarantees of their commercial suitability or suitability for the User’s purpose. Skhole Ltd is not liable for any direct or indirect losses incurred due to an advice given on the Website or Service by an expert or another User, or the User’s question not having been answered in time or at all.
Skhole Ltd does not guarantee the constancy of the coverage or range of the Website and Services and their content.
Skhole Ltd is not liable for the functioning of links from the Website or websites maintained by it to external sites, or the content of such sites.
If any part of these terms and conditions of use is found to be unlawful or unenforceable, said part shall be severed from these terms and conditions. All other parts shall remain in force without the severance of said part affecting them.
The use of the Website and Services and these terms and conditions of use are governed by the laws of Finland except for the provisions on conflict of laws. Any disputes arising from the use of the Website or Services shall be resolved by the District Court of Helsinki.