Last updated: March 31, 2020
Contact person: Otto Söderlund, firstname.lastname@example.org, +358 961 8151 80
Personal Data Processed and Sources of Data
Personal data of Users
We collect two types of information concerning the Users as a data controller: (i) User Data; and (ii) Analytics Data.
User Data is primarily received directly from you either in connection with your use of the Services (including when you fill out forms available on the Website) or in connection with your interaction with us. In certain cases, it may also be provided to us by the company or organization on behalf of which you are using the Services (“Customer”). Further, in some cases, personal data may be collected from third party service providers.
We may collect and process the following User Data relating to Users:
- full name
- email address
- organization you represent
- phone number
- payment information (such as payment card number)
- username and password
- other personal data User may voluntarily provide to us when filling out a form or when testing the API Tools
- direct marketing opt-outs and opt-ins
- any direct correspondence with Speechly (e.g. by email)
Analytics Data is collected automatically as you visit or interact with the Website. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with other data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.
We may collect and process the following Analytics Data relating to Users:
- IP address
- device type and model
- device identification number
- operating system
- screen resolution
- browser type and version
- statistical data (fully anonymised)
- voice data
- language settings
- time and date of your visits to the Services
- time spent on the Services
- interaction with the Services
- the URL of the website you visited before and after visiting the Services
- the sections of the Services you visited
Personal data of End-Users
Cookies, Analytics Tools and Social Media Plugins
We use various technologies to collect and store Analytics Data and other information when Users visit our Services, including cookies.
We use Google Analytics to compile Analytics Data and reports on visitor usage. Google Analytics uses its own cookies for the collection of Analytics Data. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on. Please note that the Analytics Data collected by us with Google Analytics is fully anonymised.
Here you can find information on privacy policies of all Google products and services.
Social media plugins
Our Website contains so called social media plugins. When a visitor visits our Website, a link is formed between the visitor’s browser and the server of the provider of the social media plugin. Due to the link, the visitor’s browser may automatically transfer data relating to the Website visitor to the social media plugin provider in question, e.g. the visitor’s IP address and the information that the IP address in question has visited our Website.
If the Website visitor opens the social media plugin while he/she is logged into his/her user account in the social media platform in question, the content of our Website may be linked with the visitor’s user account in that platform. In that case, the service provider in question may be able to connect the visitor’s visit to our Website with the visitor’s personal user account in the social media platform in question.
Purposes and Legitimate Grounds for Processing of Personal Data of Users
Purposes of processing
To provide our Services and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
We process personal data to be able to offer the Services to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User or towards the Customer. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services.
For our legal obligations (legal ground: compliance with a legal obligation)
We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities, such as tax authorities.
For claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our Services and for data, system and network security.
For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Services and for informing Users of changes in our Service. We may also process personal data to market our Services, for example in the form of sending newsletters.
For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding your use of the Services to improve the quality of our service, for example by analysing any trends in the use of our Services. Where possible, we will do this using only aggregated, non-personally identifiable data.
Legal grounds for processing
We process personal data on a contractual basis when the personal data is processed based on a contract between Speechly and the User. Further, with respect to Users acting as representatives of our Customers, their personal data is primarily processed based on our legitimate interest whilst fulfilling our contractual obligations towards the Customer.
We may also process personal data based on our other legitimate interests, for example in connection with quality improvement, analytics, marketing, claims handling and legal processes.
When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.
In certain cases, you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.
Speechly stores personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.
We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
Personal Data Recipients
We do not share your personal data with third parties outside of Speechly’s organization unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside of our 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 Speechly, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.
To authorized service providers
For other legitimate reasons
With explicit consent
We may share personal data with third parties outside of our organization for other reasons than the ones mentioned above, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
Speechly does not store your personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof, or for another individual purpose for which your personal data is being processed. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
Most User Data relating to a User’s user account with the Services will be deleted or anonymized after 6 months have lapsed after the User’s account has been deleted. We delete or anonymize most Analytics Data relating to the visitors of our Website within 18 months.
However, we may store some of the User Data or Analytics Data longer if such processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, legal proceedings or bookkeeping.
Information regarding direct marketing is stored until further notice if you have given us your consent for direct marketing. If you later opt out from the direct marketing, we delete other information regarding the direct marketing, but will retain the information that you have opted out of the direct marketing to ensure compliance with your opt-out request.
Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you.
Right to withdraw consent
In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Services or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our Services.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Services.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The abovementioned rights may be used by sending an e-mail to us on the addresses set out above, including the following information: full name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
Lodging a Complaint
In case you consider our processing 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.
In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).