Data Protection and Privacy Policy

Updated: 2.2.2022
Name of the registry: Reactored language tool user registry
Registry keeper: Rouhia Oy
Business ID: 2722150-8
Address of the registry keeper: Viipurintie 4, 13200 Hämeenlinna, Finland
Contact number: +358 40 5370375

Contact person for registry matters: Kari Savolainen
Postal address: Emalitehtaankatu 2, 04410 Järvenpää, Finland

Telephone number: +358 40 5370375
E-mail: info@reactored.com

1. What types of data do we collect and why?

The purpose of keeping the register is the processing of personal data related to the Reactored service and its respective functions (hereinafter “Service”) with the consent of the Reactored service user (hereinafter “User”). Reactored serves as a browser-based tool for teachers and students to develop and teach language skills. The personal information provided by the User on the Service may be used for the following purposes:

User registration in the Service and maintenance of the User’s profile on the Service
Producing, delivering, developing, improving and protecting the Service
User-specific Personalization of the Service
Service analysis and statistics
Electronic direct marketing in accordance with the Personal Data Act and the Electronic Communications Data Protection Act (with the consent of the data subject)
Prevention and detection of abuse
Protection of rights and / or property related to the Service

* Mandatory information when registering are username, email address and password.

To enable a personalized learning experience, Reactored can automatically collect certain information about a learner’s activities in the form of statistics such as: time spent on learning, learning occurrences, learning outcomes, emphasis on learning style.

2. How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an active account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

3. Registry information

The register may contain the following information:

Contact information, such as name, email address
Registration information, such as username, password, or any other unique identifier
User nickname or pseudonym
Feedback from the user on the learning material

4. Sources where personal information is collected

We collect personal information primarily only from the data subject herself / himself, when she / he registers with the Reactored Language learning platform.

Information is obtained in connection with the use of the Service by means of cookies or other similar technologies. If the User ses a third-party service maintained by a third party to register and / or log in to the Service, personal information (such as username and email address) may be collected from the external service in accordance with the terms of use and privacy regulations of that service.

5. Disclosure or sharing of personal information

The information provided by the User on the Service may be disclosed to the following parties:

For other users of the Service, with appropriate access restrictions, e.g. school teacher, IT management of the educational institution.
Service providers involved in the implementation of the service.
To the authorities in the event that the law or the interests of the registry keeper or a third party so require.
Subsidiaries and associates of the Registrar, or the new owner or co-owner or carrier of the Service and their advisers in connection with the acquisition or arrangement.

In addition, the data may be disclosed to third parties in a form that does not allow the identification of individual Users, in which case it is not personal data.

6. Transfer of data outside the EU or EEA

As a general rule, personal data are processed and stored within the EU or the EEA. However, some of the information contained in the Service may also be processed or stored outside the EU or the EEA if it is necessary for the technical implementation of the Service. In such cases, before transferring the data, we ensure that the data protection is properly protected and that the data processor meets the requirements set by the GDPR. Possible data to be transferred are the name, company name and e-mail address.

Rouhia Oy may disclose the information contained in the register within the limits permitted and mandatory by applicable legislation. Otherwise, the information in the register will not be disclosed to a third party without the customer’s consent. The information may be disclosed, for example, to clarify a suspicious online payment transaction with a payment intermediary. For our Services, we use the Google cloud server service, the data processing and data protection terms of which comply with the applicable GDPR data protection legislation.

7. Registry security

We respect the confidentiality of your personal information, and your personal information will be processed in accordance with the requirements of the GDPR. The register is stored in an information system protected by technical means. Only those employees of the registry keeper and the registry keeper’s subcontractor who have an unconditional right to process personal data for their work are entitled to process personal data.

If, despite security measures, security breaches occur that are likely to have an adverse effect on the privacy of Reactored users, we will promptly notify the appropriate persons and other interested parties, as well as the appropriate authorities, when required by applicable data protection law.

8. Data subject rights

The user has the right to check the information about himself, the right to request the correction of incorrect information or the completion of incomplete information. The request for inspection must be submitted in writing and signed to the person responsible for registry matters mentioned in this register description. The controller will respond to the customer within the timeframe set out in the EU Data Protection Regulation (generally within one month). We may require you to provide proof of identity in order to fulfill a request for information. The provision of information is subject to a fee in accordance with the price list if less than one year has elapsed since the User last received the information in the register for review.

Right to request the correction of data: you can update your own basic data through the settings by logging in to the service. If necessary, you can also forward the repair request to customer service using the contact methods found on our website. If the repair is made other than directly through our service, the customer must provide the necessary basic information in order for the customer to be identified as reliable. Required information may include, for example, name, address, telephone, e-mail, username.

Right to give or withdraw consent: If we process your personal data on the basis of your consent, you have the right to give or withdraw your consent at any time.

Right to be forgotten: you have the right to ask us to delete your stored personal data if 1) the data is no longer needed for the original purpose of collection 2) you withdraw your consent to have personal data processed 3) your data has been processed unlawfully 4) personal data must be deleted in order to comply with the legal obligation of the registry keeper 5) personal data of a child has been processed in order to provide information society services.

Right to object to the processing of data: you may have the possibility to object to the processing of your personal data when the processing is carried out on the basis of the performance of a task in the public interest or our legitimate interests.

Right to restrict the processing: you may have the possibility to restrict the processing of your data in situations under Article 18 of the GDPR.

Right to transfer data from one system to another: you have the right to receive the data you provide in a structured, commonly used and machine-generated format and to transfer it to another data controller if the data is processed under consent or agreement.

Right to complain to the supervisory authority: you have the right to complain to the supervisory authority if you consider that the processing of your personal data is contrary to the GDPR. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

9. Changes to privacy policy

Rouhia Oy may change its privacy policy by updating this document. We will notify Users of any changes to the privacy policy section of the Reactored.com website. Please visit the site regularly for information on any changes.

If changing the terms and conditions entails changes that have a significant adverse effect on the user, Rouhia Oy will notify you when you start using the service next time. Continuing to use the Service means that you have accepted the amended Terms.