Privacy policy - Simulationstore database

This description is based on EU General Data Protection Regulation (679/2016) and Personal data act (523/1999)

Date of drafting: 24 May 2019

 

1. Subject of the privacy policy
 

Database of registered users of VTT's SimulationStore.

2. Controller, Data Protection officer and Contact person Controller
Name: VTT Technical Research Centre of Finland Ltd ("VTT"), Business ID 2647375-4
Address: Vuorimiehentie 3, FI-02150 Espoo, Finland

Data protection officer
Name: Seppo Viinikainen
Address: VTT Technical Research Centre of Finland Ltd, Koivurannantie 1, FI-40400 Jyväskylä, Finland
Email address: tietosuoja@vtt.fi or seppo.viinikainen@vtt.fi

Contact person
Name: Pasi Laakso
Address: VTT Technical Research Centre of Finland Ltd, Kivimiehentie 3, FI-02044 VTT, Finland
Email address: apros.support@vtt.fi or pasi.laakso@vtt.fi
 
3. Handled user information and user groups From all data subjects following information is stored:
  1. Email address
  2. Company (if applicable)
  3. Title
  4. First and second name
  5. Date of registration and last activity
  6. User name for the SimulationStore
  7. Address
  8. Time zone
  9. Computer Machine IDs
  10. Information about owned software licenses managed in SimulationStore

Handled user groups are either SimulationStore users or users registered to SimulationStore.
 

4. The purpose for processing the personal data Main purpose of SimulationStore is to provide customers tools to manage their software licenses, download installation packages and License key files. Personal data is stored verify that the user is eligible to use the services of SimulationStore, for customer relations management and marketing the products of VTT. Marketing is implemented in the form of emails (e.g. news letters) and phone calls.

The legal justification for storing the data is either direct contract relation between VTT and the customer or because of customer requesting SimulationStore services.

Storing personal data is necessary to give SimulationStore services and to form a contract relationship between the data subject and the controller.
 
5. User data source User information is given by the user during the registration or when purchasing a license or asking access to download installation or license key packages. The date of registration and last activity information are collected automatically.
 
6. Regular destinations of disclosed data VTT can disclose Personal data to 3rd parties, if this is necessary because of technical reasons related to service or legislation demands disclosure.

More specifically data will be transferred to these 3rd parties:
  • Fortum Oyj - All personal data of Apros simulation software users. Apros is co-owned with Fortum Oyj.
  • Semantum Oy - All personal data of Sulca users. Sulca is developed and maintained by Semantum Personal data is disclosed with proper arrangements following the data protection regulation and applicable other legislation.

Personal data could be disclosed outside of EU- and ETA-region, if that is necessary because of the technical implementation of the service. In these cases the data protection regulation is followed. Owner of the register could use e.g. model contract clauses accepted by competent authority to be used for international data transfer.
 

7. Transfer of personal data to countries outside the the European Union or the European Economic Area Personal data could be disclosed outside of EU- and ETA-region, if that is necessary because of the technical implementation of the service. In these cases the data protection regulation is followed. Owner of the register could use e.g. model contract clauses accepted by competent authority to be used for international data transfer.
 
8. Automatic desicion making, profiling Information stored in the SimulationStore shall not be used for profiling or automated desicion making.
 
9. Time limits of storing personal data Information shall be removed or anonymized from the system after 5 years of inactivity in the usage of Simulation store services, if there are no legal basis to continue storing the data.
 
10. The principles how the data file/register is secured Data is stored to Linux server located in to the internet. It has a limited number of Administrators that have access to all the data stored and are committed to keep the data secure. Personal data is stored to mysql database and User management is done using Drupal user management system. User roles are Administrator, Application manager, Customer administrator and regular user. Administrators have access to all information, Application managers have access to personal data related to the users of particular application (e.g. Apros, Balas and Sulca are applications). Customer administrators can see the personal data of the regular users and other customer administrators that belong to the Customer group they are administrating. Regular users can see partial information of the other Regular users in the same customer group.

No manual register is related to the Simulation store.
 
11. Rights of data subjects Data subjects have following rights. These could limited or there could be exceptions based on the Data Protection Regulation.
  • Access to personal data - Data subjects have the right to receive confirmation from the controller whether or not the controller is processing personal data that concerns them. Upon request the controller shall provide copy of personal data being processed and data defined in the Data Protection Regulation concerning the handling of personal data.
  • Ask rectification of personal data - Data subject has right to get faulty, inaccurate or lacking information rectified without unnecessary delay.
  • Ask for personal data removal - Data subject has right to get his information removed without unnecessary delays in case the Data Protection Regulation conditions are met.
  • Limit handling of personal data - Data subject has right to limit handling of personal data in case the Data Protection Regulation conditions are met.
  • Request transfer of personal data between systems - Data subject has right to ask personal data that he has given to the controller and right to transfer this information to other controller from those parts that are based on contract relationship and handling is done automatically.
  • File a complaint to supervising authority - Data subject has right to complain to supervising authority, if he feels that his rights based on Data Protection Regulation has been violated.

Data subject can fulfill these right via contacting to the contact person of the controller mentioned in the item 2, preferably via email using the email address used to register the data to the database. The controller has rights to ask further information to verify the identity of the data subject.