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PRIVACY POLICY AND COOKIE POLICY
Privacy Policy
Voimassa alkaen: 7.8.2016
Rekisterinpitäjä: Polku Learning
Y-tunnus:
Yhteystiedot: info@polkulearning.com
Verkkosivusto: polkulearning.com
This Privacy Policy explains how Polku Learning processes personal data in connection with the use of its website and digital services.
1. What personal data do we collect?
We collect the following personal data when necessary for using or purchasing the services, managing the customer relationship, or communicating with users:
name
email address
user account information
login information
purchase history and subscription information
information related to payment transactions
customer service communications
content submitted by the user to the services
technical information, such as IP address, browser, device, time of use and log data
marketing consents and communication preferences.
Polku Learning does not store users’ full payment card details in its own systems. Payments are processed by Stripe.
2. For what purposes do we use personal data?
Personal data is processed for the following purposes:
creating and managing user accounts
providing and maintaining the services
processing subscriptions and payments
providing customer support
sending service-related notifications
ensuring the security of the services
preventing misuse
complying with legal obligations
developing the services
sending marketing communications where the user has given consent or where another lawful basis applies.
3. Legal bases for processing
The legal basis for processing personal data may include:
performance of a contract, when the user purchases or uses a service
legal obligation, for example obligations related to accounting
consent, for example for newsletters or non-essential cookies
legitimate interests, for example service security, customer relationship management and service development.
4. Payments and Stripe
Payments are processed through Stripe.
Stripe processes personal data related to payment transactions, such as payment card information, billing information, email address, IP address and technical information related to the payment transaction.
Polku Learning receives from Stripe the information necessary to process payments, manage subscriptions, provide receipts and handle customer service.
Polku Learning does not store users’ full payment card details.
5. Content submitted by users to the services
Users may submit topics, instructions, their own texts, files or other content to the services for the purpose of creating or adapting learning materials.
Content submitted to S2-Selkokieli and ESL Simplifier is sent to Polku Learning’s AI service provider for processing so that the learning material requested by the user can be generated.
Users must not submit sensitive personal data, confidential student or learner information, health information, personal identity numbers or other confidential information to the services.
Users are responsible for ensuring that they have the necessary rights to use and process any material they submit to the services through an AI service.
6. Data retention
We retain personal data only for as long as necessary for the purposes described in this Privacy Policy.
Information related to a user account is retained for as long as the account remains active or for as long as the information is needed for contractual purposes, customer support, accounting, legal claims or security.
Accounting-related information is retained for the period required by applicable law.
Users may unsubscribe from marketing communications at any time.
7. Data disclosures and service providers
Polku Learning uses external service providers to operate and provide its services.
These may include, for example:
Stripe for payment and subscription processing
technical service providers for the website, applications and user accounts
email service providers
AI service providers for operating S2-Selkokieli and ESL Simplifier
customer support and communication services
analytics services, if introduced in the future.
Service providers may process personal data on behalf of Polku Learning to the extent necessary to provide the relevant service.
Polku Learning does not sell users’ personal data to third parties.
Personal data may also be disclosed where required by law or where necessary to protect the rights of Polku Learning.
8. Transfers of data outside the EU or EEA
Some service providers may be located outside the European Union or European Economic Area or may process personal data outside the EU or EEA.
Where personal data is transferred outside the EU or EEA, Polku Learning ensures that an appropriate legal mechanism for the transfer is in place in accordance with applicable data protection legislation.
Such mechanisms may include, for example, an adequacy decision by the European Commission, Standard Contractual Clauses approved by the European Commission, or another lawful transfer mechanism recognised under applicable data protection legislation.
9. Data security
Polku Learning seeks to protect personal data through appropriate technical and organisational measures.
These may include, for example:
restricting access rights
encrypted connections
using security-conscious service providers
maintaining log data
regular maintenance of systems.
However, complete security cannot be guaranteed for services operating over the internet.
10. Rights of the data subject
Under applicable data protection legislation, users may have the right to:
receive information about the processing of their personal data
request access to their personal data
request correction of inaccurate personal data
request deletion of personal data
request restriction of processing
object to processing in certain situations
receive and transfer their data to another service in certain situations
withdraw consent where processing is based on consent
lodge a complaint with a supervisory authority.
In Finland, the supervisory authority is the Office of the Data Protection Ombudsman.
Requests concerning personal data rights may be sent to:
11. Marketing communications
Polku Learning may send users service-related communications, such as order confirmations, payment-related notifications and important service notices.
Marketing communications are sent only where the user has given consent or where another lawful legal basis applies.
Users may unsubscribe from marketing communications at any time by using the unsubscribe link included in the message or by contacting Polku Learning.
12. Changes to this Privacy Policy
Polku Learning may update this Privacy Policy from time to time.
The current version will be published on the Polku Learning website.
Where appropriate, users will be informed of material changes in a reasonable manner.
Cookie Policy
Polku Learning uses cookies and similar technologies to enable the operation of its website and digital services.
1. What are cookies?
Cookies are small files stored on a user’s device when they use a website or online service.
Cookies may be used, for example, to maintain a login session, enable user account functionality, process payments and support the security and technical operation of the services.
2. Essential cookies
Polku Learning uses essential cookies for purposes such as:
enabling login
supporting user account functionality
processing payments and purchases
enabling the technical operation of the services
ensuring security
remembering user choices where necessary for the operation of the service.
Essential cookies are necessary for the website and services to function and do not require separate consent.
3. Analytics and marketing cookies
Polku Learning does not currently use analytics or marketing cookies such as Google Analytics, Meta Pixel or Hotjar.
If Polku Learning introduces non-essential analytics or marketing cookies in the future, users will be asked for consent before such cookies are placed.
Users will then have the option to accept or reject non-essential cookies and to change their choices later.
4. Third-party services
The website and services may use third-party technical services for purposes such as payment processing, login functionality or other service features.
These third-party services may use their own essential cookies or similar technologies where necessary to provide their functionality.
5. Managing cookie settings
Users can manage cookies through their browser settings.
If Polku Learning later introduces a separate cookie banner or cookie preference management tool, users will also be able to change their choices regarding non-essential cookies through that tool.
Blocking essential cookies through browser settings may affect the functionality of the website or services.
6. Changes to this Cookie Policy
Polku Learning may update this Cookie Policy if the services, technologies used or applicable legislation change.
The current version will be published on the Polku Learning website.