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© Copyright 2019. Utelias Technologies, Oy 

Privacy

Privacy Policy

Elias Robot App is a service developed and maintained by Curious Technologies Ltd and designed for learning language and communication skills.

Curious Technologies Ltd (hereinafter ”Curious”, ”we”, “us”, “our”) provides Elias Robot website, Elias Robot web application and Elias Robot installation package for Softbank Robotics humanoid robots Nao V5, Nao6 and Pepper. By “Application”, we are referring to the Elias Robot Web Application, Elias Robot Website and Elias Robot installation package for humanoid robots. By ’Privacy Policy’, we mean this privacy policy. Reference to ’User Terms’ shall mean this Privacy Policy together with the Terms & Conditions available at www.eliasrobot.com.

 

Our Privacy Policy explains what data we process, how we do that and how the data subjects may use their rights (e.g. right to object, right of access). 

 

Elias Robot processes the collected personal data with due care and in accordance with all applicable laws and regulations.

 

Please take the time to read this Privacy Policy, because it forms a part of the User Terms for the Application. By using our Application, you agree to this Privacy Policy. If you do not agree to the User Terms or any part thereof, please do not use our Application.

 

This Privacy Policy constitutes the description of data file as set out in Personal Data Act, paragraphs 10 and 24.

 

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website www.eliasrobot.com.

 

This Privacy Policy only covers data processing carried out by Elias Robot. The Privacy Policy does not address and we are not responsible for the privacy practices of any third parties. 

 

Elias Robot’s Contact details

Name: Curious Technologies Ltd

Company ID in the Finnish Trade Register: 2863158-4

Address: Siltavuorenpenger 7, 00170 Helsinki, Finland

E-mail address: info@eliasrobot.com

www.eliasrobot.com

 

What types of data we collect

We collect two types of information from the users of our Application (“Users”): (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.

 

We may collect and process the following User Data from Users: (i) first and last name; (ii) contact details, (iii) e-mail address, (iv) information that Users provide when rating our services or giving feedback on our services, (v) other data on Users which the User enters to the Application. 

 

We and/or our authorized third party service providers, may automatically collect Technical Data when Users visit or interact with our Application. If you’re logged in to our Application, some of the following information could be associated with your account:

  • Your IP or proxy server IP

  • Basic domain information

  • Your Internet service provider is sometimes captured depending on the configuration of your ISP connection

  • Your device and operating system information

  • The date and time of your visit to the Application

  • The length of your session

  • The parts of the Application you have accessed

  • The number of times you access our Application 

 

Cookies in Elias Robot website

We use various technologies to collect and store information when Users visit the Elias Robot website, including cookies. Cookies allow us to calculate the aggregate number of people visiting our web-sites and monitor the use of the websites. This helps us to improve our websites and better serve our users. We also use tracking and analytics cookies to see how well our services are being received by our users. 

 

Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. Please note that some parts of our sites and services may not function properly if use of cookies is refused. For more information about cookies and how to delete them, visit www.allaboutcookies.org. 

 

Our Application uses Google Analytics and other web analytics services to compile reports on visitor usage and to help us improve our sites and services. For an overview of Google Analytics, please visit http://www.google.com/analytics/. It is possible to opt-out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout.

 

How is personal data collected?

We collect User Data solely if it is directly provided to us by the User. 

By using the Application, you consent to us collecting and using personal data provided via the Application in accordance with this Privacy Policy and Terms of Use. You are likely to provide personal data when you contact us via website (name, email address), subscribe to a newsletter or email list, submit feedback, enter a contest, fill out a survey, or send any other electronic communications to us.

 

If you choose not to provide personal data, we may not be able to provide you with our services.

 

How do we use personal data?

We may use personal data to:

  • Provide you with services as described in the Application

  • Customize our services and websites

  • Carry out technical analyses to determine how to improve the Application and services we provide

  • Update you with operational news and information about our Application and services, such as notifying you about changes to our Application, website disruptions or security updates

  • Monitor activity on the Application

  • Manage our relationship with you by e.g. responding to comments or queries submitted on the Application, or by asking for your feedback

 

  

User’s responsibility

Users shall be liable for the data and content they submit to the Application. Users shall be liable to ensure that they are entitled to submit the data to the Application.

 

When may we disclose personal data?

We only share personal data within the organisation of Elias Robot if and as far as reasonably necessary to perform and develop our services.

 

We do not share personal data with third parties outside of Elias Robot’s organization unless one of the following circumstances applies:

 

It is necessary for the purposes of this Privacy Policy 

To the extent that third parties need access to personal data to perform the services, Elias Robot has taken the appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations. 

 

For legal reasons

We may share personal data with third parties outside Elias Robot’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Elias Robot, our users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.

 

For other legitimate reasons

If Elias Robot is involved in a merger, acquisition or asset sale, we may transfer data to the third party involved. However, we will continue to ensure the confidentiality of all data. We will give notice to all customers and Users concerned before the data are transferred or become subject to a different privacy policy.

 

With explicit consent

We may share data with third parties outside Elias Robot’s organization for other reasons than the one mentioned before, when we have the data subject’s explicit consent to do so. The data subject has the right to withdraw this consent at all times.

 

Aggregate or anonymous information about you may be shared with advertisers, publishers, business partners, and other third parties.

 

Transfers outside Europe

We do not regularly transfer our users' data from our register outside the EU and the EEA. However, we may transfer the data outside the EU or the European Economic Area when our affiliate partner is located outside these areas. In these cases, we will take appropriate safeguards to ensure the rights and freedoms of the data subjects in accordance with applicable data protection laws, such as the EU General Data Protection Regulation (679/2016).

 

The transfer of personal data outside the European Union or the European Economic Area will always take place on any of the following legitimate grounds:

  • The European Commission has decided that an adequate level of data protection is ensured in the recipient country;

  • Elias Robot has taken appropriate safeguards to transfer personal data using standard data protection clauses approved by the European Commission. The registrant then has the right to obtain a copy of these standard terms by contacting us at support@eliasrobot.com; or

  • The data subject has expressly consented to the transfer of his or her personal data, or there is another legitimate reason for the transfer of the personal data.

For example, a Service Provider providing us with a Service may transfer personal data to the United States in connection with the provision of the Service. In this case, appropriate safeguards for the protection of personal data have been put in place, with the service provider committing itself to US-EU agreement, so-called Privacy Shield, or using the standard privacy policy clauses accepted by the EU Commission. Read about the Privacy Shield Arrangement here 

 

Purposes and legitimate grounds for the processing

 

Purposes

There are several purposes for the processing of personal data by Elias Robot:

 

To provide our services and carry out contractual obligations 

Elias Robot processes personal data in the first place to be able to deliver services via Application to its customers and Users and to run, maintain and develop Elias Robot’s business. If Users contact our customer service, we will use the provided information in order to answer questions or solve complaints. 

  

For customer communication 

Elias Robot may process personal data (name, email address) to contact customers and Users regarding our services and to inform customers and Users of changes to our services and products. Data may also be used for research and analysis to improve our services and websites. 

 

For quality improvement and trend analysis

Elias Robot may process information about the use of the services to improve the quality of our services e.g. by analyzing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally identifiable data.

 

Legitimate grounds for processing

Elias Robot processes personal data to perform our contractual obligations and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to maintain and develop our businesses. 

 

How do we store personal data?

We store personal data on secure servers that are managed by us and our service providers. Personal data that we store are subject to security and access controls, including username and password authentication as well as data encryption where appropriate. However, please remember that no method of transmission over the Internet or method of electronic storage is completely secure. We will use the best possible methods to protect personal data.

 

Storage period

Elias Robot does not store personal data longer than is legally permitted and necessary for the purposes of providing our services. The storage period depends on the nature of the information and the purposes of the processing. The maximum period may, therefore, vary per use. In general, Elias Robot deletes all personal data of Users when the relevant user relationship ends and when the User no longer uses the Application.

 

How can you access your personal data?

You have the right to make a request to access information we hold about you and to request corrections of any errors in that information, as set out below. To make an access or correction request, contact info@eliasrobot.com.

 

Data Subjects’ rights

Right to access

Elias Robot offers access for the data subjects to the personal data we process. This means that the data subject may contact us and we will inform what personal data we have collected and processed regarding the said data subject and the purposes such data are used for. 

 

Right to correct

Data subjects have the right to have incorrect/imprecise, incomplete, outdated, or unnecessary personal data we have stored about the data subject corrected or completed by contacting us.  

 

Right to deletion

Data subjects may also ask us to delete the data subject’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.

 

Right to object

Data subjects may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our services or for compliance with a legal obligation. Data subjects may also object any further processing of personal data after prior given consent. 

 

Data subjects have the right to prohibit us from using data subject’s personal data for direct marketing purposes, market research and profiling by contacting us.

Right to restriction of processing

Data subject may request us to restrict processing of certain personal data

  

Right to data portability

Data subjects have the right to receive personal data from us in a structured, commonly used format.

 

How to use the rights

These rights may be used by sending a letter or e-mail to us on the addresses set out above, including the following information: name, address and phone number. We may request the provision of additional information necessary to confirm the identity of the data subject. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case data subject considers our processing activities of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

 

Information you make public or give to others

If you make personal data available to other people, we don’t control or accept responsibility for the way that information is used or managed. Before making any information publicly available or giving your information to anyone else, think carefully.

 

When do we need to update this policy?

We may need to change this Privacy Policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. Changes to this Privacy Policy are effective when they are posted on the Application. 

 

How can you contact us?

If you have any questions about our privacy practices, please contact us at info@eliasrobot.com.