gdpr

GDPR Privacy Policy Statement

Privacy NOTICE

10th Muse Ltd. (later “10th Muse” or “we”) collects and processes personal data of our author, customer, potential customer and participants of our contests as well as other users of our services (including our website and social media services) and other our business partners (later: “you” or “data subject”). We are committed to being transparent about how we collect and use that personal data as well as meeting our data protection obligations.

This Privacy Notice helps you understand what personal data we may collect, and how such data is used and processed. “Personal Data” refers to data which allows the identification of an individual person (as defined and in compliance with the European Union’s General Data Protection Regulation 2016/679 (“GDPR”)). This is opposite to “non-personal data” meaning data that cannot be used to identify a person. We commit to adhere to the provisions of the aforementioned legislation and other such applicable laws and regulations pertaining to processing of Personal Data.

1. Contact information and data protection officer

Controller:

Name: 10th Muse Ltd.

Vat-Number: FI30218385

Address: Lapinlahdenkatu 16, Arcade 5

Zip code: 00180

City: HELSINKI

Phone number: +358445241672

Email: company@10thmuse.net

Data Protection Officer:

Name: Karoliina Korppoo

Address: Lapinlahdenkatu 16, Arcade 5

Zip code: 00180

City: HELSINKI

Phone number: +358445241672

Email: company@10thmuse.net

If, at any time, you have questions or concerns about this Privacy Notice or you want to use your rights, please do not hesitate to contact us.

2. Types of personal data we collect and process?

We may collect and processes the following Personal Data of the data subjects:

  • name and contact details, including email address and telephone number and company name
  • username and password
  • other information provided by the data subject

The primary source of Personal Data is the relevant data subject. Mainly, Personal Data is collected when the data subject participates to our contest or communicate with us. In some cases, we may also collect Personal Data from third parties, such as public registers (e.g. ytj.fi) or analytics tool (e.g. Google Analytics).

3. Our legal basis and purposes for processing?

We process Personal Data to organize contests and offer other services and to maintain our relationship with the data subjects. In this context, Personal Data may be processed for the following purposes:

  • organize and maintain contests such as submissions and participations
  • delivery other our services
  • invoicing (including debt collection),
  • management of customer service, feedbacks and related communications
  • registrations for our events
  • direct marketing and customer analysis and surveys
  • business planning and product and application development
  • ensuring security of our products and services and preventing abuses
  • ensuring security of our IT environments and protection of data

We may also need to process Personal Data to ensure that we are compliant with the applicable legal obligations, such as tax law, accounting related obligations. Furthermore, Personal Data may be needed to respond to and defend against legal claims and complaints.

We process Personal Data on the following basis:

  • for the purposes of performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • to comply with legal obligations applicable to us (e.g. tax and accounting)
  • for the purposes of our legitimate interest to inform you about our contests and other services, ask you for feedback, or provide you other relevant marketing information and to maintain customer relationship. Where we rely on our or a third-party’s legitimate interest as a legal basis for the processing of Personal Data, we have considered whether or not those interests are overridden by the rights and freedoms of the data subjects and have concluded that they are not.
  • If the data subject gives their consent for the electronic direct marketing, the processing for this purpose is based on a consent.

4. Who has access to personal data?

We may share Personal Data with third parties that process Personal Data on our behalf, for example with our external service providers such as our IT service provider. We ensure the proper processing of Personal Data through adequate contractual obligations. List of recipients that process Personal Data can be provided upon request.

In case of an emergency or other surprising event, we may need to disclose the Personal Data to protect health, safety and property. In addition, we may be obliged to transfer the Personal Data to the third parties involved in any business operation, merger, sale of our assets, or other similar arrangements.

Personal Data may also be transferred outside the European Economic Area (“EEA”) by 10th Muse or our service providers. In case Personal Data is transferred outside the EEA, such transfers are either made to a country that is deemed to provide a sufficient level of privacy protection by the decision of the European Commission or transfers are carried out by using appropriate safeguards such as standard data protection clauses. More information can be provided upon request.

5. How do we protect personal data?

We commit to follow security provisions of the applicable data protection regulations. We use appropriate technical and organizational safeguards to protect Personal Data, including the use of firewalls, encryption techniques and safe device facilities, proper access control and guidance for personnel as well as subcontractors involved in the processing of Personal Data. The Personal Data is transferred over an SSL secure connection.

Our personnel and processors that process Personal Data are obliged to keep Personal Data confidential. Access to Personal Data is only granted to those employees that need the information to perform their work-related duties.

6. For how long is personal data kept?

Personal Data will be retained only for as long as necessary to achieve the purposes defined in this Privacy Notice. As a rule, Personal Data related to our contests will be retained for a maximum period of 12 months.

More detailed retention times can be provided upon request.

7. Automatic decision making

We do not process Personal Data using automated decision making, as defined in the Article 22 of the GDPR.

8. Your rights

As a data subject, you have several rights under the applicable data protection laws. You can:

  • access your Personal Data.
  • require us to change incorrect or incomplete Personal Data.
  • obtain a copy of your Personal Data in a structured, commonly used and machine-readable format insofar as the processing is based on your consent or a contract, and insofar as you have provided the information to us.
  • require us to delete or stop processing your Personal Data, for example where Personal Data is no longer necessary for the purposes of processing. However, please note that certain Personal Data is strictly necessary to be retained in order to achieve the purposes defined in this Privacy Notice. Thus, such Personal Data may not be deleted.
  • object to the processing of your Personal Data where we are relying on our legitimate interests as the legal basis for the processing. (e.g. you have right to object the processing for direct marketing purposes)
  • ask us to restrict processing of Personal Data for a period if Personal Data is inaccurate or there is a dispute about whether or not your interests override our legitimate grounds for the processing of the Personal Data.
  • withdraw your consent where the processing is based on your consent. However, please note that the withdrawal of consent does not affect the processing performed before the withdrawal of consent.

You may exercise the aforementioned rights by sending a written request to us using the aforementioned contact details.

After receiving all the required information of your request (incl. confirmation of identity), we will start the processing of your request. We will contact you at latest within a period of one month. If your request is denied, you shall be informed about the refusal in writing.

If you believe that we have not complied with applicable data protection laws when processing your Personal Data, you can lodge a complaint with a competent supervisory authority which is in Finland the Office of the Data Protection Ombudsman.

9. Changes to this privacy notice

We may make changes to this Privacy Notice at any time, so please review it frequently. Unless stated otherwise, the then-current Privacy Notice applies to all Personal Data we process at the time.

This Privacy Notice has been published on 19.12.2019, version 1.0

Version history:

  • Version number: 1.0
  • Change description: Document published
  • Date: 19.12.2019


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