Privacy Notice & Cookie Policy

    Purpose of Privacy Notice – In Brief

    This privacy notice is intended for individuals who want to know what data is collected about them and how the collected data is used. Trainers’ House Plc (“TH”) complies with the General Data Protection Regulation (GDPR), the Data Protection Act, and the Information Society Code, supervised and guided by the Data Protection Ombudsman, as well as all laws applicable to the use of cookies, monitored by the Finnish Communications Regulatory Authority. Please read this privacy notice carefully to understand what data is collected about you, how it is used, and what rights you have regarding data collection.

    Purpose of Privacy Protection – In Detail

    Trainers’ House collects personal data from users of its website Trainershouse.fi (“the site”). This privacy notice applies to the Trainershouse.fi website. TH also acts as a data controller on behalf of its subsidiaries regarding the personal data you and other site visitors provide to TH when visiting the website or otherwise, or that TH collects automatically from visitors to the site.

    Your privacy and the protection of your personal data are of utmost importance to us. TH is committed to complying with applicable data protection legislation and requirements in all personal data processing. The ways and purposes for handling your personal data are explained in detail in this privacy notice.

    This privacy notice will be updated as needed. We review this notice when new features are added to the site. The latest version is always available on this page.

    This privacy notice covers the following areas:

    • Purpose of Privacy Protection – In Brief
    • Purpose of Privacy Protection – In Detail
    • Why Does TH Process Personal Data?
    • What Personal Data Does TH Process?
    • Sources of Data
    • Legal Basis for Processing Personal Data
    • Processing of Personal Data by Third Parties
    • International Data Transfers
    • Retention Period of Personal Data
    • User Rights
    • Who Is the Data Controller and How Can I Contact Them?
    • Why Does TH Process Personal Data?

    TH collects and processes your personal data:

    • To enable you to use the website
    • For site maintenance and development
    • To improve the user experience by collecting information on your visit using cookies and other analytics technologies
    • For communication and marketing purposes

    Additionally, TH processes personal data for site security, as well as for the prevention and investigation of misuse.

    What Personal Data Does TH Process?

    TH processes only the personal data necessary for the purposes defined in this privacy notice. The personal data processed by TH can be categorized as follows:

    • Information related to the TH account, such as username and password
    • Identification details, such as title, first name, and last name
    • Contact details, such as phone number and email address
    • Observed and derived data from site usage, for example: time of visit; the page from which the user navigated to the site; pages visited on the site; browser type, IP address, and browser version (e.g., Mozilla Firefox); operating system and device interface; and similar technical information. TH uses cookies and similar technologies to collect this data. You can read more about these technologies in our Cookie Policy.
    • Data related to the newsletter user profile, such as services of interest to the subscriber; date and time of newsletter subscription; content, clicked links, IP address; browser type and version, and device type.
    • Recruitment: The purpose is to receive, process, and store job applications from candidates interested in employment at Trainers’ House Plc. Applicants can submit applications for specific positions or leave open applications. HR personnel may also match applications to other suitable positions.

    Data Sources

    Personal data is collected directly from users when they visit our website or interact with TH in other ways. To the extent that data on registered individuals (mainly TH employees) is displayed on our site, the information is imported or copied from our other internal systems.

    Personal data may also be collected or updated as needed from our partners, authorities, or companies providing personal data services (e.g., contact update services). This mainly applies if a user has subscribed to our newsletter.

    Legal Basis for Processing Personal Data

    For the Performance of a Contract (employees or customers):

    • Data related to the TH account
    • Identification details
    • Contact details

    For the Execution of Recruitment (job applicants):

    • Basic applicant data (name, contact details, date of birth)
    • Educational and work experience data
    • Applicant’s preferences regarding the desired position
    • Information describing the applicant’s experience and skills 
    • Additional information provided voluntarily by the applicant

    Legitimate Interest to maintain and develop the website as well as to communicate and market TH’s activities:

    • Processed personal data for communication and marketing purposes
    • Observed and derived data from website usage
    • Data related to the newsletter user profile
    • For ensuring site security and prevention and investigation of misuse

    Processing of Personal Data by Third Parties

    TH transfers only the personal data necessary for the purposes defined in this privacy notice:

    Service Providers 

    TH uses partners for hosting and providing the website and for data processing as specified in this privacy notice. TH transfers your personal data to these partners only to the extent they need access to the personal data in order to provide services to TH, for the purposes defined in this notice.

    Our website may use social media plug-in features from service providers, such as Facebook’s Share button, in which case the content is provided directly by Facebook. Links to such service providers’ privacy policies can be found in our Cookie Policy.

    Our websites may use cookies from service providers, such as Google Analytics cookies, which enable the preparation of statistics and analysis of website usage. More information about the cookies we use and how to change your cookie settings is available in our Cookie Policy.

    Legal Reasons

    We may disclose your personal data to third parties if access to the data or its processing is necessary to i) comply with applicable laws and/or a court order; ii) detect, prevent, or address misuse, security risks, or technical issues.

    International Data Transfers

    The website’s server is located in the EEA. We strive to use only providers and services located in the EU or EEA for all services related to our website. However, some services may be provided using operators or servers located in third countries, and in such cases your personal data may be transferred outside the EU or EEA in compliance with applicable legislation at all times. If transfers occur to third countries that do not guarantee an adequate level of data protection, they are secured using appropriate safeguards, such as the European Commission’s or supervisory authority’s standard contractual clauses or binding corporate rules. You can request information about these international transfers and the safeguards we use by contacting the person mentioned below.

    Retention Period of Personal Data

    Personal data is retained as long as necessary to fulfill the purposes for processing described in this privacy notice, as long as the legal basis for processing remains valid.

    For example, after an employment relationship ends, an employee’s contact details are removed from our site. Other users’ data is retained as long as our legitimate interest can reasonably be considered to exist. The existence of a legitimate interest is defined, for example, by the use of our online services and the mutual communication between us. Generally, user data is stored for one year after the last login or use of the site, after which the data is deleted. Job applicant information is stored in the applicant register for a specific position for three (3) months, after which it is archived for two (2) years and may be revisited during subsequent recruitment processes. TH may, at its discretion, delete job applications with incomplete information.

    User Rights

    About Rights in General and Their Implementation

    The EU GDPR guarantees the data subject several rights, which the data subject may use to determine the processing of their personal data in many situations. The data subject may exercise the following rights with respect to TH, insofar as TH acts as a data controller for the relevant personal data:

    Right of Access and Right to Rectify Incorrect Data

    You have the right to ask TH to confirm whether your data is being processed and to access the data processed about you. If necessary, TH may ask you to specify your request, such as by providing additional details regarding delivery of the data. Additionally, you have the right to request correction of incorrect data or to supplement incomplete information TH processes about you.

    Right to Request Erasure of Data

    You can ask TH to delete your personal data from our systems. TH will take the requested measures unless there are justified reasons not to, such as a legal obligation to continue processing the data. Note that the information may not be immediately deleted from all backup or similar systems, but it will be deleted during regular database maintenance.

    Right to Object to Data Processing

    You may also request restrictions on the processing of your personal data if your data is processed for purposes other than to deliver our service or fulfill a legal obligation. You may also object to the processing of your personal data, even if processing was based on your previous consent. Objection to personal data processing may lead to limited access to our website. You have the right to refuse electronic direct marketing by following the instructions included in every marketing message we send.

    Restriction of Processing

    If you dispute the accuracy or legality of the personal data we have registered, or have objected to processing in accordance with your rights, you may request that we restrict the processing of your personal data to storage only. In such cases, processing is limited to storage until the accuracy of the data is verified or it is determined whether our legitimate interests override your interests.

    If you do not have the right to request erasure of your data from our records, you may instead request that the data processing be limited to storage only. If the processing of data concerning you is necessary only for the establishment of a legal claim, you may also request that any other processing be limited to storage only. We may process your data for other purposes if required by a legal claim or if you have consented.

    Right to Data Portability

    You have the right to receive your personal data from us in a structured and widely used format in order to transfer it to another data controller, when TH’s processing is based on your consent or on a contract between us.

    Who Is the Data Controller and How Can I Contact Them?

    You can exercise your rights by contacting TH’s Data Protection Officer (saku.keskitalo@trainershouse.fi). The extent of your rights depends on the legal basis for processing your data, and exercising your rights requires identification.

    Data Controller: Trainers’ House Plc (also acting as the data controller for its subsidiaries) Itämerentalo, Tammasaarenlaituri 3 00180 Helsinki

    Register Administrator Arto Heimonen Chief Executive Officer Email: arto.heimonen@trainershouse.fi Phone number: +358 40 4123 456

    Data Protection Officer Saku Keskitalo Contact: saku.keskitalo@trainershouse.fi

    Right to Lodge a Complaint

    If you believe your personal data has been processed in violation of data protection legislation, you have the right to lodge a complaint with the supervisory authority regarding the data controller’s personal data processing. In Finland, complaints are made to the Data Protection Ombudsman, following their instructions. More information can be found on the Data Protection Ombudsman’s website: https://tietosuoja.fi/en

    Cookie Policy Trainers’ House

    Trainers’ House (“TH”) uses cookies and similar technologies on its website.
    This Cookie Policy explains in more detail how cookies are used.

    A cookie is a small data file that a website stores on the user’s device via the web browser. Each time the user’s browser retrieves pages from the company’s servers, information is sent back to the user’s device. Using JavaScript and server logs, we compile statistics such as the number of users, country of use, time of use, the browser used, and the content visited on the site. Cookies do not damage your device.

    Cookies are used to speed up, analyse, and develop the website, as well as to tailor content for each user.

    The Trainershouse.fi website uses two types of cookies: first-party cookies (set by TH) and third-party cookies (set by entities other than TH through the trainershouse.fi website).

    First-party cookies enable the site’s core functionality. They also include web analytics cookies that provide information on how visitors use the site, helping us improve the service.

    Third-party cookies refer to cookies set by entities outside TH. These third parties may place cookies on a user’s device when visiting our site, for example to generate statistics on visitors across different websites.

    We have categorised the cookies used on our website according to their purpose.

    Strictly Necessary Cookies

    These cookies (one or more) ensure that the website operates correctly (e.g., chatbot functionality) and do not store information that can personally identify the user. These cookies may also identify a session and ensure the privacy of its communication.

    • Giosg
    • investis.com

    Performance and User Experience Cookies

    These cookies (one or more) collect information about how the website is used (statistics) so that we can improve your user experience.

    • Google Analytics

    Targeting Cookies

    These cookies (one or more) allow us to offer more relevant and personalised content to users, as well as to provide and target information about the company’s services (e.g., marketing).

    • Google Analytics (first-party)
    • HubSpot (first-party)
    • Giosg (first-party)
    • leadthebeat.com (first-party)
    • investis.com (third-party)

    Additionally, the company uses social media plug-ins such as Facebook’s Share button, which enable website content to be shared on social media. These social media services process personal data in accordance with their own privacy terms. You can read more about these in the following services’ privacy policies:

    • Facebook Data Policy
    • Twitter Privacy Policy
    • LinkedIn Privacy Policy
    • Instagram Privacy Policy
    • WhatsApp Privacy Policy
    • Google Privacy Policy

    Managing and Clearing Cookies

    By clearing cookies from your browser regularly, you can reset the identifier used to create behaviour-based user profiles. This does not stop data collection or the targeting of digital advertising, but it resets targeting based on your previous behaviour.

    Here are browser-specific links for clearing cookies:

    • Firefox
    • Safari
    • Chrome
    • Internet Explorer

    You can prevent the use of cookies by adjusting your browser settings so that cookies are not allowed. Restricting cookies may negatively affect the functionality of the website.

    You can also block third-party advertising targeting entirely via the Your Online Choices website:
    http://www.youronlinechoices.com/fi/tietoa-selainkayttoon-perustuvasta-mainonnasta

    For more information regarding the use of personal data, you may contact the company’s Data Protection Officer:
    Saku Keskitalo – saku.keskitalo@trainershouse.fi