This Privacy Notice was last updated on 3.4.2020.
This Privacy Notice explains how Fjuul processes your personal data. Your privacy is very important to us and Fjuul is committed to protecting your privacy and to complying with applicable data protection and privacy laws. In case you have any questions concerning data protection at Fjuul, please contact our data protection officer: firstname.lastname@example.org.
OVERVIEW OF HOW FJUUL USES YOUR DATA
The Fjuul App collects data on your physical activities, and using particular algorithms translates this data into universal energy points (so-called Fjuul points). The calculation of Fjuul points is based on the intensity and duration of your activity. This allows you to consistently compare your days and progress, pursue goals that suit your fitness level or ambition, and compare your progress with others. You can use the Fjuul points as currency in selected Fjuul partnership programs, and redeem your points for rewards, either online or offline.
You have control over your personal data and how it’s collected, used, and shared. Depending on your choice, your personal data is used for one or several of the following services.
WORKPLACE WELL-BEING SERVICE
Employees can use Fjuul App to follow their own physical activity and take part in activity challenges. Employers can then reward teams or employees based on reaching defined goals.
Insurance customers who wish to pursue an active lifestyle and gain insurance related benefits can choose a service by an insurance company partnering with Fjuul. From their Fjuul App customers can share with insurance partners selected metrics on which the insurer can reward customers.
WHAT PERSONAL DATA WE COLLECT AND WHY
Personal data provided by you
When you start using the Fjuul App you are requested to register and create a user account (the Fjuul Account). For that purpose we ask you to provide us with your email address that is used to authenticate you, enable you to use the Fjuul App and enable us to communicate with you.
Information on your height, weight, gender and birth date are also required as part of your registration process. This information is needed for optimizing the allocation of Fjuul points and providing personalized services, such as activity guidance, goal setting and coaching.
Personal data collected from fitness devices or applications
The Fjuul App starts collecting data after you have entered the requested information, installed the Fjuul App to your mobile device, and actively enabled collection of data from a mobile phone, sensor, fitness device or application. When you enable collection of data from a fitness device or application, Fjuul starts to receive data collected by that device or application. Data is collected as long as a source device or application is on and you have enabled collection of data from that device or application.
The exact types of personal data collected from a fitness device depend on the features of the devices you use and the data collection choices you have made on those devices. For example, if you have not allowed monitoring of heart beat on your fitness device, Fjuul does not collect data on your heart rate.
The following types of personal data can be collected from most supported devices:
- Type of activity (e.g. running, cycling, swimming, walking)
- duration of activity
- distance covered during activity
- number of steps taken or floors climbed
- estimated consumed calories
- your training goals
- heart rate and heart rate variability
- stress level
- workout intensity
- workout summaries
We also collect the following information relating to your fitness device:
- device type
- device id
- operating system
HOW WE PROCESS AND USE YOUR PERSONAL DATA
We use your personal data to:
Information collected during the registration and the use of the Fjuul App is needed to
- create your Fjuul account and manage its use,
- analyse the monitored physical movements and provide you with services
- enable the conversion of collected fitness data to Fjuul points
Provide you product information and marketing
Contact information might be used for:
- informing you of updates and new features in App
- letting you know of ongoing challenges and benefits
If you don’t want to receive any communication from us, you can anytime opt-out from emails or disable push notifications from your profile when this function is used.
Service and business development and fraud prevention
We analyse the usage of the App and it’s features and collect data of the device you use to be able to:
- develop the Fjuul App’s features and services and the algorithms used
- further develop the usability and user experience
- provide product support
- correct problems and errors
- prevent and investigate fraud and other criminal activities.
LEGAL BASIS OF PROCESSING PERSONAL DATA
Personal data is collected and processed based on your consent and in order to provide you with the Fjuul fitness App service in accordance with the service contract between you and Fjuul. Data processing for marketing activities, for communicating news on use of Fjuul, and for service development and fraud detection activities is based on Fjuul’s legitimate interest to keep you informed of the features of the App and existing reward programs, and to develop the service and resolve problems. You have the possibility to opt-out from receiving marketing and service-related news communications.
You can manage your consents in the Fjuul App. You have the right to withdraw your consent at any time, but this might affect the provision of the service as described below. The following personal data processing activities require your consent:
- Collection of data from a mobile phone, sensor, an external fitness device or application of your choice. The provision of the Fjuul service is not possible without collection of data from an external fitness device or application. Therefore you cannot use Fjuul without consenting to data collecting from an external device or application.
- Disclosure of your Fjuul point count or a report of your fitness activity based on Fjuul point count to a partner (such as an insurance company) in accordance with the terms of a partnership program. You can withdraw your consent for partner disclosure at any time, but this may affect the accumulation of rewards in accordance with the rules of that program.
RETENTION TIME OF PERSONAL DATA
Personal data collection stops when user account is no longer active or it has no active fitness sources connected to it. Data is no longer processed in identifiable form when user account is deleted or deactivated. After this, the data is rendered in anonymous form, which means that all of the identifying information is removed.
Personal data is collected as long as collection from a source device is enabled and the source device is on and your Fjuul Account is active. The account is considered to be active as long as we get new data into the App. To stop transferring data you need to deactivate the Fjuul App from reading from and writing data to Fjuul in your original source device/application (e.g. your phone/fitness tracker/app).
Within 200 days your personal data will be rendered in anonymous form. It is possible that we have to retain your personal data beyond 200 days if it is necessary for complying with applicable laws.
PERSONAL DATA DISCLOSURES
Disclosure of personal data refers to situations where your personal data is provided to another data controller or data processor, such as a service provider. We will comply with applicable data protection laws and applicable criteria for the disclosure of personal data.
In building and maintaining the Fjuul App, we use external service providers. We use Google Analytics service for Firebase. Google Analytics processes data as described at https://policies.google.com/technologies/partner-sites. We also use Google Cloud to store data, including personal data, on their servers in Germany.
Depending on your reason to use the Fjuul App, we share your personal data with the data controllers indicated below and for the following reasons:
Organisations using the Fjuul App to provide their employees with workplace well-being service in accordance with customer agreements
Fjuul only shares this personal data in aggregated form to avoid identification of individual users.
Reward partners, such as insurance companies, in accordance with partnership agreements
Please note that privacy policies of these third parties differ from those of Fjuul. If you choose to provide personal data to these parties, your data is governed by their privacy policies.
Fjuul may disclose minimum required amount of your personal data to competent authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request, or in connection with a merger, acquisition, reorganization or sale of Fjuul.
PERSONAL DATA OF CHILDREN
We do not knowingly collect personal data of children under the age of 13. We request that children under the age of 13 do not register an account and we will take steps to delete any such data if such collection would come to our knowledge.
You can request access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, and you have the right to object to processing of your personal data.
You can modify and correct any personal data you have given when using the Fjuul App by logging into your Fjuul Account.
To request access to, portability or erasure of your personal data, or to delete your Fjuul account, please contact us by using the feedback function or at: email@example.com.
You have the right to lodge a complaint with a supervisory data protection authority. The Finnish data protection authority can be contacted at: www.tietosuoja.fi.
Our systems are firewall protected. We also use encryption techniques and authentication procedures to maintain the security of your personal data and prevent unauthorized access to your Fjuul Account and our systems.
Authorized Fjuul personnel and service providers who are granted access to personal data are required to keep such data confidential.
Your data will only be processed by persons who have the right to do it and who, due to their duties, need to process it. Authorized Fjuul personnel who are granted access to personal data are required to keep such data confidential. Your personal data may also be processed by service providers based on our instructions and in compliance with our Privacy Notice.
Fjuul does not transfer or disclose your personal data outside the EU/EEA without appropriate safeguards.
We use Google Analytics and Firebase, a web analysis service of Google. Google LLC, based in the United States, is certified under the EU-U.S. Privacy Shield Agreement, which ensures compliance with the level of data protection applicable in the EU. You can read more about Privacy Shield here.
UPDATES TO THIS PRIVACY NOTICE
Fjuul reserves the right to update this Privacy Notice from time to time. When we post changes to this Privacy Notice we will modify the date of the update at the top of this Privacy Notice.
HOW TO CONTACT US
Fjuul Vision Oy
Sofiankatu 4c, 00170 Helsinki
SUMMARY: PROCESSING YOUR PERSONAL DATA (Scroll for sideways for full table)
|Type of processing||Purpose of processing||Personal data disclosures||Types of personal data Fjuul processes||Legal basis||Fjuul’s legal role towards you|
Providing you the Fjuul App
|To create and maintain your account, to analyse your fitness data and calculate your Fjuul points, to store your data to achieve all of this|| |
In building and maintaining the Fjuul App, we use external service providers. Currently we use Google Analytics service, Firebase and Google Cloud.
Email address, height, weight, gender, birth date
Type of activity, duration of activity, distance covered during activity, number of steps taken or floors climbed, estimated consumed calories, your training goals, heart rate, heart rate variability,
VO2max, stress level, workout intensity, workout summaries, Fjuul points
Information relating to your fitness device: device type, device id, operating system,
type of activity, duration of activity, distance covered during activity, number of steps taken or floors climbed, estimated consumed calories, your training goals, heart rate
stress level, workout intensity, workout summaries, Fjuul points
Contract between you and Fjuul
|Workplace well-being service (optional)||To provide you with the workplace well-being service||You may choose to provide aggregated personal data to your employer. This data is the aggregated amount of the entire group participating. A comparison diagram is shown when the group has a minimum of 10 participants.||See above||Your consent. |
You can choose to join one of the open challenges. All of the participants will see the aggregated amount of the entire group participating. A comparison diagram is shown when the group has a minimum of 10 participants.
|Reward partners such as insurance partnership (optional)||To provide you with the features necessary to use the insurance related service you have purchased||You may choose to provide aggregated personal data (for instance, activity level, average level of Fjuul points over a 100 day period to an insurance partner whose service you are using)||See above||Your consent||Processor|
|Compliance with legal obligations||Fjuul may disclose minimum required amount of your personal data to competent authorities if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request||Data may be disclosed to competent authorities||See above||Compliance with legal obligations||Controller|
|Service and business development and fraud prevention||To develop the Fjuul App’s features and services and the algorithms used. To provide product support. To correct problems and errors. To prevent and investigate fraud and other criminal activities||No disclosures||See above||Legitimate interest||Controller|
|Transfer of ownership||In connection with a merger, acquisition, reorganization or sale of Fjuul||Data may be disclosed to the buyer or to the new company being formed||See above||Legitimate interest||Controller|
|Marketing and communication||To provide you with information on use and new features of the Fjuul App and new reward programs||No disclosures||Email address||Legitimate interest (you can opt out whenever you want)||Controller|
|Further service development with anonymous data||After personal data it is no longer needed for the purposes specified in this table, we render in anonymous. We use this data for further improving our services, for example, our algorithms for calculating Fjuul points.||Third parties will not receive any personal data||No personal data is processed, only data rendered anonymous||No personal data is processed, only data rendered anonymous||No personal data is processed, only data rendered anonymous|