Name of the register
The Reflect web-based service
The purpose of processing of personal data
Reflect is a service for developing the user’s self-leadership, interaction skills and teamwork. It supports the implementation of the training and training process.
The basis on the processing of personal data
Implementing the agreement, thus realising the Service ordered by the buyer.
The processed personal data
Name of the user, email, date of birth, nationality, gender, language, results of the Reflect exercises, IP address.
The information sources of the personal data
The buyer of the Service provides the user’s email address. HRM Partners or its representative adds the email address and the starting and ending date of the Service to the system. The system automatically forms the name from the email address. The user provides all the additional data. If the user requests feedback on the completed exercises, the data is provided by the person who the user has requested the feedback from.
The location of the personal data and transfer outside of the EU or the European Economic Area
The personal data is stored on servers located in Finland. The email traffic of the system is operated by a partner who is located in the United States. The following data is transferred in email traffic: email address and username. By registering as a user of the Service, the users give their consent to the transfer of their personal data.
The retention period of the personal data
The personal data is stored for the time of implementing the agreement (typically 6 or 12 months). The user receives the information concerning the closing of the account one month before the access right expires. After the access right expires, the personal data will be deleted.
Requesting personal data
The user may download their data.
Deleting personal data
The users may delete their own exercise results. When deleting the exercises or the entire user account, the shared exercises will also be deleted from Reflect from those users they have been shared with. User’s personal data will also be deleted from the interaction tips picked up by other users and the team pictures created by other users.
The users may delete their own Reflect account.
The user may request the deletion of their personal data at any time by email at firstname.lastname@example.org.
Informing the users on the data collection
The Reflect Privacy statement can be found on the Reflect’s account creation and log in page of before creating the account and logging in.