Privacy policy

Cuckoo Workout®

1.   GENERAL

Cuckoo Networks Ltd, 2612255-9, (”Cuckoo”, ’’we” or ”us”) acts as a controller in relation to the processing of personal data in connection with customer relationship management, provision of Cuckoo’s services and marketing communication. This privacy policy applies to your use of the Cuckoo Workout service, our website as well as when we communicate with you about our services or for customer relationship management reasons.

In this privacy policy, we describe how we collect, process and share your personal data when we act as a controller. Personal data means any information which may be used to identify you.

It is important to us that you feel safe with how we handle your personal data. We take all necessary measures to ensure that your personal data is protected and that the processing of your personal data is carried out in accordance with applicable data protection legislation and our internal policies.

2.   TO WHOM IS THIS PRIVACY POLICY ADDRESSED?

This privacy policy covers and applies to the following categories of data subjects:

  • Users who use our Cuckoo Workout service with their personal username.
  • Users who access our website or follow us through other electronic communication channels, such as Cuckoo’s newsletters.
  • Our customers’ contact persons or representatives who act as contact persons, for example in connection with customer relationship management and invoicing.

3.   HOW DO WE COLLECT PERSONAL DATA?

We may collect your personal data in the following ways:

  • Personal data that you give to us, for example, when you contact us by email or telephone, and when you provide information through forms on our website or via the chat service.
  • Personal data that you give to us when using the Cuckoo Workout service, including creating a user account and profile, and sharing the workouts and activities you perform within the service.
  • Personal data that we collect about your activity on the Cuckoo Workout service, such as information about break exercises, invitations and challenges you have sent, and groups you are have joined within the service.
  • Through automated means, for example when you enter our website or log into Cuckoo Workout service, in which case we automatically collect logging data and online identifier data, such as your IP address. Such automated means also include cookies placed on your terminal by our website and service.

4.   WHEN AND WHY DO WE PROCESS PERSONAL DATA?

Managing and protecting website, services and related IT systems

We may process personal data in order to manage and protect our website, Cuckoo Workout service and related IT systems, for example, when collecting logging data about logins to our website and service as well as solving any problems or deviations. When you visit our website or use Cuckoo Workout service, we place so-called essential cookies on your terminal so that we can fulfill your requests and ensure the basic security of our services.

Categories of personal data Legal basis for processing
·     Identity details

·     Contact details

·     Online identifier data

·     Logging data

·     Additional information provided in relation to possible support requests

Legitimate interest. The processing is necessary in order to fulfil our legitimate interests of managing and protecting our services and related IT systems.

 

Storage period: Personal data is stored for as long as it is necessary to carry out the purpose of the processing. We store online identifier data stored in logging databases and logging data for troubleshooting and resolving deviations for up to 24 months from the time of the logging of the log event.

Measuring and developing our website

We may process personal data in order to measure and develop our website, including compiling statistics on the use of our website. In connection with the use of our website, to achieve this purpose, we can set so-called analytical and statistical cookies on your terminal. Statistics composed for this purpose do not include personal data.

Categories of personal data Legal basis for processing
·     Online identifier data Consent. The setting of analytical and statistical cookies when using our website is based on the consent given by the user.
Storage period: Analytical and statistical cookies on our website will remain on the user terminal for the time specified for each cookie, unless you delete cookies from the browser settings. If you do not delete cookies separately, the session-specific cookies will automatically exit at the end of the session, while the other cookies we use for this purpose remain for up to 2 years. Statistics that do not include information linked to a natural person are stored until further notice.

Providing electronic marketing communications and online advertising

We may process personal data in order to provide electronic marketing communications if you subscribe to our newsletter or other similar electronic marketing content or communications. When you visit our website, we can also place so-called marketing cookies on your terminal so that we can provide relevant advertising on our website and elsewhere on the web.

Categories of personal data Legal basis for processing
·     Identity details

·     Contact details

·     Online identifier data

Consent. The delivery of electronic marketing communications, such as newsletters, is based on the consent given by the user. Equally, setting marketing cookies when using our website is based on the consent given by the user.
Storage period: Personal data is stored until the electronic marketing communications subscription is active. When you withdraw your subscription, we will delete the personal data processed for this purpose. The marketing cookies set by our website will remain on the user terminal for the time specified for each cookie, unless you delete cookies from the browser settings. If you do not delete cookies separately, the session-specific cookies will automatically exit at the end of the session, while the other cookies we use for this purpose will remain longer.

 

Managing the customer relationship

We process the personal data of our customers’ contact persons and representatives in order to manage the customer relationship, for example, when storing contact person’s and customer-specified users’ contact details, archiving customer agreements, keeping in touch in relation to the business relationship, and in connection with billing and receivables management.

Categories of personal data Legal basis for processing
·     Identity details

·     Contact details

·     Organisational information

·     Additional information provided in relation to communications

Legitimate interest. The processing is necessary in order to fulfil our legitimate interests of managing the customer relationship.

Contract. If our customer is considered as a consumer under the applicable legislation, the processing is necessary for concluding or performing the contract between Cuckoo and the customer.

Storage period: Personal data is stored for the duration of the customer relationship, after which unnecessary personal data will be deleted. However, we may store some of the personal data for longer period if it is necessary in order to fulfil our legitimate interest in managing and defending legal claims or to comply with our legal obligations (such as, for example, compliance with the Accounting Act).

Providing the Cuckoo Workout service to the users

We must process the personal data of the user of Cuckoo Workout service in order to provide the Cuckoo Workout service at the request of the user and in accordance with the applicable terms of use of the service. To accomplish this purpose, we can also process the user’s personal data to answer questions and send notifications about the use of the Cuckoo Workout service and to customize the content of the Cuckoo Workout service.

Categories of personal data Legal basis for processing
·     Identity details

·     Contact details

·     Organisational information

·     User profile and choices

·     Service usage and activity information

·     Online identifier data

Contract. The processing is necessary for concluding or performing the contract between Cuckoo and the user.

 

Storage period: Personal data is stored during the use of the Cuckoo Workout service and thereafter for a maximum period of 2 years following the last login in order manage and defend potential legal claims.

Providing improved service features at the request of the user

The user may load Cuckoo Workout add-on for Microsoft Teams app. We process the user’s personal data in connection with the use of the add-on in order to provide improved service features to the user, such as enabling the user to log in to Cuckoo Workout service through Microsoft account, communicate with our chatbot and receive suggestions or notifications about exercises. In addition, the user may indicate to the chatbot his/her mood before starting exercise. The purpose of this is to provide the user with information on how exercising effects the user’s mood in the long run.

Categories of personal data Legal basis for processing
·     Contact details

·     Microsoft account and profile information

·     Cuckoo Workout user profile and choices

·     Communication data (e.g. communication with the chatbot)

·     Online identifier data

Contract. The processing is necessary for concluding or performing the contract between Cuckoo and the user.

Legitimate interest. The processing is necessary in order to fulfil our legitimate interests in providing improved service features at the request of the user.

Storage period: Personal data is stored during the use of the Cuckoo Workout service or the add-on, after which unnecessary personal data will be deleted. In any case, user’s personal data will be deleted at the latest after 2 years following the last login to the Cuckoo Workout service.

Measuring and developing the use of the Cuckoo Workout service

We may process the personal data of the user of the Cuckoo Workout service in order to measure the use of the service, compile combination statistics on the use of the service, as well as to improve and develop our service on the basis of these.

Categories of personal data Legal basis for processing
·     Identity details

·     Organisational details

·     Service usage and activity information

·     Logging data

Legitimate interest. The processing is necessary in order to fulfil our legitimate interests of measuring and developing the use of Cuckoo Workout Service.
Storage period: Personal data is processed for the duration of the compilation of statistical analyses. Statistics that do not include information linked to a natural person are stored until further notice.

Promoting the safety and integrity of the Cuckoo Workout service

We may process the personal data of the user of the Cuckoo Workout service in order to prevent abuses, combat malicious activity within the service, and detect and prevent other poor or harmful user experiences. To accomplish this purpose, we may also use the necessary personal data to investigate violations of our terms of service or practices.

Categories of personal data Legal basis for processing
·     Identity details

·     Contact details

·     Organisational information

·     User profile and choices

·     Service usage and activity information

·     Online identifier data

·     Logging data

Legitimate interest. The processing is necessary in order to fulfil our legitimate interests of promoting the safety and integrity of the Cuckoo Workout service.

 

 

Storage period: Personal data is processed for the duration of the investigation of abuses or other harmful user experiences. In addition to this, however, we may store the necessary personal data for a longer period where it is necessary in relation to managing and defending a legal claim or in order to comply with legal obligations.

Complying with legal obligations

We process personal data in order to fulfil our legal obligations, such as for example accounting or tax legislation related obligations.

Categories of personal data Legal basis for processing
·       All categories of personal data that have been col­lected and which are necessary in order to comply with legal obligations. Legal obligation. The processing is necessary in order to comply with legal obligations.
Storage period: Personal data is stored for as long as a certain legal obligation requires. For example, the Accounting Act imposes an obligation to maintain information on the accounting’s supporting material for 6 years following the end of the financial year.

5.   TO WHOM DO WE SHARE PERSONAL DATA?

Where necessary, we also share personal data with others. We differentiate the recipients of personal data between service providers and other recipients. Service providers are processors of personal data who process personal data on behalf of Cuckoo, for the purposes specified in this privacy policy. Other recipients, who may receive personal data, are controllers and process personal data for their own purposes.

Service providers

We use a variety of service providers (e.g. Pipedrive, Amazon, Microsoft and Intercom) in order to fulfil the purposes of the processing defined in this privacy policy. The service providers process personal data on our behalf, and we are responsible for the activities of the service providers we use when processing personal data. These service providers provide us with data warehousing, information technology, analytics, marketing communications and IT system services, among others. The service providers may only process your personal data for these purposes and in accordance with our instructions and not for their own purposes. We are the data controller for the processing of personal data that the service providers carry out on our behalf. We never sell personal information to third parties.

Other recipients

Recipient Purpose
Customer (the employer of the user of the Cuckoo Workout service) Personal data of the Cuckoo Workout service’s users may be disclosed from time to time to the user’s employer who has ordered the service from Cuckoo for their own personnel or their other users, and are in contractual relationship with Cuckoo.
Public authorities If necessary, we share your personal data with the authorities if we have a legal obligation to share information.
External advisors If necessary, we may share information with external advisors, e.g. audit firms and law firms, if required by law or if the sharing of personal data is necessary in order to prepare and defend ourselves against any legal claims that may be brought against us.
Courts, counterparties etc. We may share your personal data with courts, counterparties etc. if it is necessary in order to defend ourselves against any legal claims that may be brought against us.
Potential buyers and sellers We may share necessary personal data with potential buyers and sellers in case of an acquisition of the business or a merger.

6.   HOW LONG DO WE KEEP PERSONAL DATA?

We retain personal data only for a period that is necessary to achieve the purposes for which personal data is processed. In general, we observe the following criteria for retaining and deleting personal data:

  • Cuckoo Workout service’s users personal data is retained for the duration of using the Cuckoo Workout service and thereafter for a maximum period of 2 years following the last login.
  • Customer contact person’s or representative’s personal data is retained during the validity of our business relationship and thereafter for a period necessary in order to manage and defend potential legal claims as well as comply with legal obligations (such as accounting and tax obligations).
  • Electronic marketing subscriber’s personal data is retained until the subscription is withdrawn.

More specific information regarding personal data storage periods is available in section 4 of this privacy policy.

7.   DATA TRANSFERS OUTSIDE THE EU/EEA

We always strive to process personal data mainly within the European Economic Area. However, some of our service providers may be located outside the EU/EEA. With such service providers, we ensure that service providers use appropriate safeguards when processing your personal data outside the European Union/European Economic Area. Such safeguards include, for example, data transfer agreements on international transfers of personal data, including standard data protection clauses adopted by the EU Commission. If you wish to learn more about transfers of your personal data and the safeguards applicable to transfers, please contact us at info@cuckooworkout.com.

8.   AUTOMATED DECISION-MAKING AND PROFILING

We may use automated decision-making, including profiling, for example to target marketing online or to develop the user experience of our services. Based on your online browsing behaviour or the user’s choices, we can categorize you into a specific group based on the way we consider you to be interested in using our services. We consider that the automatic decision-making and profiling that we undertake does not cause any legal effects or otherwise significant effects for you under data protection legislation.

9.   THE RIGHTS OF THE DATA SUBJECT

Under data protection legislation, you have certain rights in relation to the processing of your personal data. The users of the Cuckoo Workout service are able to exercise their rights through the added functionalities to the service by visiting the profile or settings. If you are unable to exercise your rights using these functions, please make a request to exercise your rights by contacting us at info@cuckooworkout.com.

You have the right to:

Access your personal data

You have the right to access personal data we process about you. We will provide you with this information unless we have lawful reasons not to share this data or if sharing the data would adversely affect the rights and freedoms of others.

Rectify and update your personal data

You have the right to rectify your personal data, which we process about you. The users of the Cuckoo Workout service are able to update personal data within the service. However, you may also ask us to correct or complement your incorrect or incomplete personal data if you are unable to do this yourself.

Delete your personal data

Under certain circumstances you have the right to request that your personal data is deleted. However, we cannot delete your personal data if we are, for example, obligated under law to store the data.

Withdraw your consent

To the extent we rely on your consent to process personal data, you have the right to, at any time, withdraw your consent.

Object to the processing of your personal data

You have the right to object to the processing of your personal data based on a legitimate interest for reason which concerns your particular situation. In such a situation, we will stop using your personal data where the processing is based on our legitimate interest, unless we can show that our interest overrides your privacy interest, rights and freedoms or that the use of your personal data is necessary in order to manage or defend legal claims.

Restrict the use of your personal data

You have the right under certain circumstances to request that the processing of your personal data is restricted. If the processing of your personal data has been restricted, we may only, besides storing the data, process your personal data with your consent, or in order to establish, exercise or defend legal claims or to defend rights of others.

Transfer your personal data

You have the right to request a copy of the personal data that we store about you in a structured, commonly used and machine-readable format (data portability). The right to data portability, compared to the right to access, only comprises such personal data you yourself have provided to us or which we process based on certain legal grounds, such as your consent.

Lodge a complaint with the supervisory authority

If you consider the processing of your personal data to be incompatible with applicable data protection legislation or feel that we have not enforced your rights, you may lodge a complaint with the competent supervisory authority. The Office of the Data Protection Ombudsman shall be the competent supervisory authority in Finland.

10.   COOKIES

We use cookies on our website. A cookie is a small text file sent to the user’s device and stored there. We use both session-specific cookies and permanent cookies.

  • Session-specific cookies remain on the user’s device for the duration of the session and typically exit after the user closes his or her web browser.
  • Permanent cookies remain on the user’s terminal until the expiration period of the permanent cookie expires or until the user itself deletes the cookie from the browser settings.

We may also use third-party cookies on our website that enable third-party plug-ins to be used. These cookies are set by Google Analytics, YouTube, Google Search Console, Google Adwords, Google Tag Manager, Vimeo, Intercom, Adroll and Nextroll. You can use your browser to disable third-party cookies if you do not want a third party to collect information about you. In this case, the website activity may be limited, and some activity may be inaccessible.

Adroll and Nextroll are digital marketing tools that collect personal data for targeted marketing. If you wish, you can opt out from the tracking cookies used by these tools at https://www.youronlinechoices.com/

We use cookies on our website for the following purposes:

  • Managing and protecting the website, services and related IT systems
  • Measuring and developing the use of our website
  • Implementation of online advertising

You can read more about these purposes under section 4 of this privacy policy.

11.      UPDATING THE PRIVACY POLICY

We may update this privacy policy as needed, for example, if we process personal data for new purposes, share personal data with new recipients, or other essential changes occur in the processing of personal data. We will always notify you of any update to this privacy policy in an appropriate manner and always publish the latest versions on this page.

12.      CONTACT

If you have any questions regarding the processing of your personal data, please do not hesitate to contact us. See below for contact details.

Controller:

Cuckoo Networks Ltd

2612255-9

Fredrikinkatu 34 A16, 00100 Helsinki, Finland

info@cuckooworkout.com

Contact person:

Veera Lehmonen, +358 44 992 3744

Fredrikinkatu 34 A16, 00100 Helsinki, Finland

veera@cuckooworkout.com

 

Last updated: 15.2.2021