Privacy notice for applicants and visitors
Drafted on 01 March 2023
The Masterclass of Happiness is a 4 day event in Finland organised by Visit Finland, the Finnish travel promotion organisation, headquartered in Helsinki. Visit Finland is part of Business Finland and fully owned by the Finnish Government. This Privacy Policy describes:
- the ways we collect personal data about the applicants and visitors and why we do so,
- how we use your personal data, and
- the choices you have about your personal data.
1. CONTACT INFORMATION OF THE CONTROLLER IN DATA PROTECTION MATTERS
Name: Business Finland Oy/Visit Finland (Business ID: 2725690-3)
(hereinafter “Visit Finland”, “Controller” or “we”)
Address: Porkkalankatu 1, 00180 Helsinki, Finland
Phone: Switchboard: +358 (0)29 50 55000
Email: dataprotection@businessfinland.fi
2. DATA WE COLLECT
We collect following data of the applicants and visitors (together participants) of the Masterclass of Happiness campaign:
Basic information such as name, date of birth, age, gender, nationality, communication language, time-zone, contact information (email address, home address, cellphone number), person to contact in emergency situations (name email address, home address, cellphone number)
Profile information such as profession, education, hobbies, language skills, other special skills, descrip-tion of personal features, video material attached to the application, information from the portfolios, profiles and other services on the Internet referred to by the candidate or otherwise made public or available to us (via your privacy settings in the service), and any other information applicants have provided to Visit Finland in application, interviews and video presentations, tracking data about your performance and behavior in the campaign challenge.
Data related to the admission process, such as:
- Agreement data such as data about your signing up to the Masterclass of Happiness campaign including application process and participation in the session, agreement to the terms and conditions of the campaign and session and giving consents to the processing of personal data,
- Device Data, such as your device IP address, device name and ID; operating system, browser type and language, data we collect with cookies and similar technologies, general location da-ta based on your IP address,
- Admission process data, such as data about your progress in the admissions process, data about the evaluation and selection of visitors, data of your communication with the admissions sup-port,
- Identity documentation from the chosen visitors, e.g., a copy of passport.
Data related to the participation, such as:
- data of the travel and accommodation arrangements
- copies of insurance certificates
- information required to be entered into the application for the tax-at-source card in accord-ance with the laws of Finland.
- data necessary for the management of the Masterclass of Happiness session, and participant re-lationship, e.g., arrangement of events during the visit, special diets and other requirements and wishes of the visitors
- communication related to the session between visitors, hosts, coaches, and Visit Finland
Documentation data of the Masterclass of Happiness session
- documentation of the visit on videos, voice recordings, photographs and written descriptions
- wellbeing data collected in the form of a survey before and after the visit.
3. WHY DO WE COLLECT YOUR DATA
We process the collected personal data for the following purposes and on the following legal basis:
3.1. Purpose of processing
Marketing of Finland’s travel image:
- the launch and execution of the Masterclass of Happiness campaign
- publishing and distributing information on the Masterclass of Happiness campaign,
- fulfilling Visit Finland’s contractual and other promises and obligations
Data processed for the purpose
- Basic information
- Agreement data
- Profile information, Device data
- Identity documentation
- Data of the travel and accommodation arrangements
- Content posted by applicants with their Instagram or TikTok handle in relation to the campaign
- Wellbeing reports and other Documentation data of the Masterclass of Happiness session
Legal basis for processing
- Performance of Masterclass of Happiness campaign Contract
- Participant´s consent for processing Device data, and data collected by cookies for marketing purposes
3.2. Purpose of processing
Management of the application and admission process and applicant relationship: to contact you; to process applications, to inform you about the status of your application or to obtain additional information; to set up and conduct interviews and assessments and to select suitable applicants
Data processed for the purpose
- Basic information
- Profile information
- Data related to the admis-sion process
Legal basis for processing
- Controller’s legitimate interest based on the applicant relationship
- Applicant´s consent for processing Device data, and cookie based tracking data about applicant´s performance, and behavior in the campaign challenge
3.3. Purpose of processing
Manage the Masterclass of Happiness session, travel and accommodation arrangements and visitor relations of the Masterclass of Happiness campaign
Data processed for the purpose
- Basic information
- Profile information
- Data related to the admis-sion process
- Data related to the participation
Legal basis for processing
- Controller’s legitimate interest based on the visitor relation
- Visitor´s consent for processing Device data, and cookie based tracking data about visitor´s performance in the session.
3.4. Purpose of processing
Development of Visit Finland’s services, particularly marketing campaigns.
Data processed for the purpose
- All personal data is aggregated so that individual persons are not identifiable
Legal basis for processing
- Controller’s legitimate interest based on the participant relations
3.5. Purpose of processing
Keep the application and admission process and participation safe and fair and to fight fraud by analyzing and monitoring the process and taking action against fraudulent or misbehaving candidates and participants.
Data processed for the purpose
- All collected data
Legal basis for processing
- Controller’s legitimate interest based on the participant relations
The personal data shall not be processed for automated decision-making.
4. WHERE DO WE COLLECT THE DATA FROM
The data is collected directly from the participants or from third parties, and other services on the Internet referred to by the candidate or otherwise made public or available to us. Documentation data and data related to participation are collected from the session and events, coaches, and hosts.
5. HOW YOUR PERSONAL DATA IS SHARED
Information may be disclosed within the framework of the Act on Innovaatiorahoituskeskus Business Finland and Business Finland Oy (1146/2017) to Innovaatiorahoituskeskus Business Finland.
Data may be disclosed to Visit Finland’s co-operation partners, other companies and organizations to make the travel and accommodation arrangements and to arrange visits and events. It may be provid-ed to public authorities to fulfill our legal obligations and in response to lawful requests.
Documentation data will be published on the Campaign websites, on VisitFinland.com, on Visit Fin-land’s social media channels such as YouTube, Facebook, Instagram and Twitter (“Visit Finland’s Mar-keting Channels”), on any national or international media organization channels, and on the marketing channels of Visit Finland’s partners outside Finland (together “Other Marketing Channels”).
Content posted by applicants who have filled out the application form with their Instagram or TikTok handle and who tag @ourfinland (IG) or @visitfinland.com (TikTok) and use the hashtag #findyourin-nerfinn can be shared on the Masterclass of Happiness site and Visit Finland’s social media channels.
Processing tasks may be outsourced to third party service providers. For example, on-line tools and video interviews, ICT services, marketing and communication, may be outsourced to external suppli-ers. Each supplier processes personal data only on behalf of Visit Finland to the extent necessary for the performance of its services subject to confidentiality obligations. The suppliers are bound by writ-ten agreements on the processing of personal data, including confidentiality and data security obliga-tions.
Otherwise, personal data will not be disclosed to third parties without the participant’s consent un-less required by law.
Personal data may be transferred for processing to a country outside of the EU/EEA. Unless the European Commission has approved the adequacy of the data protection in the processing country, we will ensure the appropriate data protection by entering into written agreements with subcontractors under the standard contractual terms approved by the European Commission. The standard terms and conditions can be found at: https://ec.europa.eu/info/system/files/1_en_annexe_acte_autonome_cp_part1_v5_0.pdf
We also use third party services to collect and analyze data about the users of Visit Finland´s website. These service providers may use cookies to collect information for their own use in accordance with their own terms and conditions and privacy policies. See our cookie policy here: Cookies policy | Visit Finland.
6. PROTECTING AND RETAINING PERSONAL DATA
Any material to be retained on paper will be stored in locked facilities equipped with access control. The data controller’s personnel have undertaken confidentiality obligations.
Only persons who need personal data for the performance of their work are entitled to use the personal data and are bound by confidentiality obligations. Personal data is saved in databases that are protected by firewalls and anti-virus malware software, and other technical means. The databases are located in locked and guarded premises, and the data can only be accessed by pre-defined and designated persons.
We retain participant data until the Masterclass of Happiness and all related contractual and legal rights and obligations have been fulfilled.
Document data can be stored as long as it is used for Visit Finland´s marketing purposes in accordance with terms and conditions of the Masterclass of Happiness campaign.
The data collected by using cookies will be deleted in accordance with the retention periods specified in connection with the cookie consents.
We assess the need for the retention of personal data on a regular basis and take reasonable measures to ensure that no incompatible, outdated or incorrect personal data is retained.
7. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
You may:
- Request access to the Personal Data that we process about you;
- Request that we correct or delete inaccurate or incomplete Personal Data about you;
- Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
- Request transfer of Personal Data to you or a third party in situations provided by law.
- Object to our use of Personal Data about you where our use is based on or our legitimate in-terests.
- You can always withdraw your consent.
You do not have to pay a fee for exercising your rights and we will aim to respond you within 30 days. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes
If you consider that our processing of your personal data infringes applicable law, You may lodge a complaint with the relevant supervisory authority Data Protection Ombudsman in Finland.
In all questions concerning the processing of personal data and situations related to the exercise of the data subject’s rights, you should contact dataprotection@businessfinland.fi.