Privacy Policy
Last updated: March 26, 2025
Welcome to Finlern, an educational platform based in Finland. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services. We are committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR), the Finnish Data Protection Act (1050/2018), and other applicable Finnish and EU privacy laws.
Please read this privacy policy carefully. By accessing or using our website, you agree to be bound by the terms and conditions of this policy.
Data Controller Information
The data controller for your personal data is:
Finlern
Valkeakoski 37600
Pirkanmaa, Finland
Email: info@finlern.fi
We are registered with the Finnish Data Protection Authority (Tietosuojavaltuutetun toimisto) and comply with all applicable Finnish and EU data protection laws.
Information We Collect
Personal Information
- Name and contact information
- Email address
- Phone number
- Payment information
- Communication preferences
- Educational background and progress
- Language learning preferences and goals
- Course enrollment and attendance records
Usage Data
- IP address
- Browser type and version
- Operating system
- Pages visited
- Time spent on website
- Learning progress and assessment results
- Interaction with learning materials
- Communication logs with teachers
Legal Basis for Processing
We process your personal data based on the following legal grounds under GDPR Article 6:
- Contract performance (Article 6(1)(b)) - For providing our educational services
- Legal obligation (Article 6(1)(c)) - To comply with Finnish educational and tax laws
- Legitimate interests (Article 6(1)(f)) - For improving our services and preventing fraud
- Consent (Article 6(1)(a)) - For marketing communications and optional features
How We Use Your Information
Primary Uses
- Provide and maintain our educational services
- Process your payments and maintain financial records
- Send you important updates about courses and services
- Respond to your inquiries and support requests
- Track and report your learning progress
- Issue certificates and educational documentation
Secondary Uses
- Improve our website and learning platform
- Analyze usage patterns for service enhancement
- Prevent fraud and ensure platform security
- Comply with Finnish educational regulations
- Generate anonymous statistics for reporting
- Conduct research on learning effectiveness
Information Sharing
We do not sell or rent your personal information to third parties. We may share your information with:
- Service providers who assist in our operations
- Payment processors for secure transactions
- Legal authorities when required by law
- Business partners with your explicit consent
Data Security
We implement appropriate security measures to protect your personal information, including:
- Encryption of sensitive data
- Regular security assessments
- Access controls and authentication
- Secure data storage and transmission
Your Rights Under GDPR
As a data subject under GDPR, you have the following rights:
- Right to access (Article 15) - Request a copy of your personal data
- Right to rectification (Article 16) - Correct inaccurate data
- Right to erasure (Article 17) - Request deletion of your data
- Right to restrict processing (Article 18) - Limit how we use your data
- Right to data portability (Article 20) - Receive your data in a machine-readable format
- Right to object (Article 21) - Object to processing based on legitimate interests
- Right to withdraw consent (Article 7) - Revoke consent at any time
To exercise these rights, please contact us at info@finlern.fi. We will respond within one month, as required by GDPR. If you are not satisfied with our response, you have the right to lodge a complaint with the Finnish Data Protection Authority (Tietosuojavaltuutetun toimisto).
Data Retention
Account Information
Retained as long as your account is active. If you delete your account, we remove your email and profile data within 30 days, unless required by Finnish law to retain it longer (e.g., for tax purposes).
Educational Records
Course completion records, certificates, and educational documentation are retained for 50 years as required by Finnish educational regulations.
Financial Records
Payment information and financial records are retained for 6 years as required by Finnish accounting laws.
Usage Data
Retained for up to 12 months for analytics, then anonymized or deleted in accordance with Finnish data protection guidelines.
International Data Transfers
Finlern uses Firebase, hosted by Google, which may process data in the EU or US. We ensure compliance with GDPR requirements for international data transfers through:
- Standard Contractual Clauses (SCCs) for transfers to third countries
- Additional safeguards as required by Finnish data protection laws
- Regular assessment of third-party data processors
- Implementation of appropriate security measures
Children's Privacy
Finlern is intended for educational use and may be used by individuals under 16. We comply with GDPR Article 8 and Finnish data protection laws regarding children's data:
- We process data of users under 16 only with verifiable parental consent
- Teachers or admins must ensure proper consent is obtained
- We implement additional safeguards for children's data
- We provide clear information about data processing to both children and parents
Changes to This Privacy Policy
We may update this policy to reflect changes in our practices or legal requirements. We'll notify you via email at least 30 days before significant changes take effect. Any changes will comply with Finnish data protection laws and GDPR requirements.
Contact Information
For data protection inquiries, you can also contact the Finnish Data Protection Authority:
Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto)