JUNCTION OY PRIVACY POLICY

Junction is fully GDPR compliant and we treat your personal data with the utmost care

and respect. It's important for us that you understand what data we collect about you,

how we use it, and what your rights related to your data are.

JUNCTION OY PRIVACY POLICY

GENERAL INFORMATION ON DATA PROCESSING ACTIVITIES RELATING TO THE

OPERATIONS OF JUNCTION OY

Junction Oy (“the Company”, “we”) organizes hackathon events and competitions both

in physical format and online as well as technology conferences, speaker events, and

other possible meetups (“Event”) and provides the www.hackjunction.com,

www.hackjunction.org, www.hackjunction.net, www.hackjunction.fi, www.junction.fi,

heltech.org websites (“Websites”) relating to such Events. For these purposes the

Company may collect and process personal data of the users of the Websites and the

participants, applicants and other visitors of the Events.

The purpose of this Privacy Policy is to clarify and inform the applicants, participants,

and other visitors of the Events and the users of the Websites (all the individuals

mentioned above referred to as “Users”) on how their personal data is processed and

stored.

In this Privacy Policy, the Websites and the services offered on the Websites are

collectively referred to as the “Services".

This Privacy Policy may be updated if required in order to reflect the changes in data

processing practices or otherwise. These Policies may be modified by Junction Oy from

time to time, such modifications to be effective upon posting by Junction Oy on the

Websites. It is User’s responsibility to periodically check-up these Policies for changes.

Continued participation in the Event and/or continued use of the Website by User

following the posting of changes will imply that User accepts and agrees to the changes.

The current version of this Privacy Policy can always be found on the Websites.

Additionally, you may be reading these Policies on a service provided by a third party, in

this case the version of Policies may be outdated, to make sure, the latest version can

always be found on the Websites.

Please note that this Privacy Policy only covers data processing carried out by Junction

Oy as data controller. Our third-party licensees organizing Junction or JunctionX events

are typically the controller of the participant data collected in relation to such events.

1. CONTROLLER’S CONTACT DETAILS

Name: Junction Oy

Business ID: 2823785-1

Correspondence address: Puumiehenkuja 5A, 02150, Espoo, Finland

E-mail: hello@hackjunction.com

Contact person:

Name: Hugo Hämynen

Telephone: +358 44 2412549,

E-mail: hugo.hamynen@hackjunction.com

2. PERSONAL DATA PROCESSED AND SOURCES OF DATA

User data and analytics data

We collect two types of information from the Users: User Data and Analytics Data.

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 User

Data. In such situations, Analytics Data can also be considered to be personal data

under applicable laws and we will treat the combined data as personal data.

Junction Oy may collect and process User Data received from the Users via

registration/application forms and profile information completed on the Websites,

hereinafter referred to as “Platform”, or by other sources such as email and third party

service providers. User Data can also be received from the Users on the phone or in

person at the Events.

We may receive or generate ourselves the following User Data:

First name

Last name

Phone number

Date of birth

Email

Postal address

Pictures

Nicknames

Roles and responsibilities in the company the User represents

Information regarding skills, education and professional background

CV’s and other certificates

Customer feedback received via email or in person

Information relating to approvals and rejections of the User’s Event applications

Information relating to the Submissions developed during the Events

Other actions and performance in the participated Events

Data transfer consents and prohibitions

Marketing opt-ins and opt-outs

Any other information provided by the User on the Website or at the Event especially

related to event attendance

In addition to the information mentioned above, we collect information relating to

allergies and special diets. This information is collected and processed solely when the

User has given explicit consent for such proceeding for the special purpose of

organizing dining for the User and it is deleted after the Event without separate request

by the User and is available only to such part of the staff of the Events which is

responsible for or directly involved in organizing dining for the User and no others.

In addition to the above mentioned, we obtain User Data from registers maintained by

the authorities and customer default registers as well as other reliable private and public

registers.

Analytics Data we gather in connection with the use of our Website includes for

example the following data: (i) your IP address; (ii) device and device identification

number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi)

language setting. In addition we may gather analytical data of your actions in the

Events, for example reviews of other Event participants and their teams projects.

Cookies

We use various technologies to collect and store Analytics Data and other information

when the Users visit the Websites, including cookies and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify

visitors of the Websites and facilitate the use of the Services and to create aggregate

information of our visitors. This helps us to improve the Services and better serve our

Users. The cookies will not harm your device or files. We use cookies to tailor the

Services and the information we provide in accordance with the individual interests of

our Users.

The Users may choose to set their web browser to refuse cookies, or to alert when

cookies are being sent. For example, the following links provide information on how to

adjust the cookie settings on some popular browsers:

Safari

Google Chrome

Internet Explorer

Mozilla Firefox

Please note that some parts of the Services may not function properly if use of cookies

is refused.

A web beacon is a technology that allows identifying readers of websites and emails

e.g. for identifying whether an email has been read.

Web analytics services

The Websites use Google Analytics and other web analytics services to compile

Analytics Data and reports on visitor usage and to help us improve the Services. 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. For an overview of Hotjar, please visit Hotjar. It is possible to opt-out of Hotjar

from Hotjar opt-out.

3. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL

DATA

Purposes

There are several purposes for the processing of personal data by the Company:

To provide and develop the Services and to organize and develop the Events

We process personal data in the first place to be able to offer the Services to the Users,

to organize the Events as well as for User verification. We process personal data for the

evaluation and selection of potential applicants and team members for the Events.

We also process the personal data provided by the Users in order to develop the quality

of our Services and Events, for instance by analyzing the employment histories of the

Users and the programs the Users have applied to.

For customer communication and marketing

We process personal data for the purpose of maintaining our customer relationships

with the Users, for instance by contacting the Users regarding the Services and Events.

We also process personal data of the Users in order to inform the Users of changes

relating to the Services and the Events. We use personal data for marketing and

advertising the services and products provided by us, e.g. to customize the User’s

experience by providing the User with targeted offers and advertising information based

on the information gathered from the User during his/her previous visits to the Services

and to the Events.

If the User contacts us to give feedback with respect to our Services or Events, we will

use the provided information for answering questions and solving possible issues.

For the recruitment and headhunting purposes

We process User Data for the purpose of providing such data to our partners of the

Events for recruitment and headhunting purposes. Other such purposes can be related

for example to awarding participants and their teams.

Legitimate grounds for processing

We process personal data to perform our contractual obligations towards the Users with

respect to the Users registered on our Websites and Users having applied or registered

as participants or attendees in the Events. Furthermore, we process personal data

based on our legitimate interest. Our legitimate interest is based on running, maintaining

and developing our business, improving the customer or visitor experience of the Users

as well as on performing direct marketing. When choosing to use your data on the basis

of our legitimate interests, we weigh our own interests against your right to privacy and

e.g. provide you with easy to use opt-out from our marketing communications and use

pseudonymized or non-personally identifiable data when possible.

In some parts of the Services, the Users may be requested to grant their consent for the

processing of personal data. In this event, Users may withdraw their consent at any

time.

4. TRANSFERS TO COUNTRIES OUTSIDE EUROPEAN ECONOMIC AREA

The Company stores the Users’ 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 the User’s domicile.

If the country of destination is not one that the EU Commission considers offers an

adequate level of protection, we will take steps to ensure that the Users’ 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.

More information regarding the transfers of personal data may be obtained by

contacting us on address mentioned in this Privacy Policy.

5. RECIPIENTS

We only share personal data within Junction Oy if and as far as reasonably necessary

to perform and develop our Services and the arrangements relating to the organization

of the Events. We do not share personal data with third parties outside of Junction Oy

including companies or other entities which are part of the same group of undertakings

as Junction Oy is unless one of the following circumstances applies:

For legal reasons

We may share personal data with third parties outside Junction Oy 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 the Company, the Users or the public in accordance with the law.

When possible, we will inform the Users about such transfer and processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for

us (such as web analytic, software, data storage and other IT, event management and

ticketing, financial management, payment and money transfer service providers). Our

agreements with our service providers include commitments that the service providers

agree to limit their use of personal data and to comply with privacy and security

standards required by relevant laws and regulations and at least as stringent as the

terms of this Privacy Policy.

With explicit consent

We may share personal data with third parties outside Junction Oy for other reasons

than the ones mentioned before, when we have the User’s explicit consent to do so. For

instance, in connection with the application process to the Events on the Websites

where the User may for example grant us his/her consent to share some User Data with

partners of the Events for recruitment purposes and/or continuing projects created at

the Events. For avoidance of doubt, explicit consent may be acquired for other purposes

than the ones mentioned above. The User has the right to withdraw the above

mentioned consents at all times.

6. STORAGE PERIOD

Junction does not store your personal data longer than is legally permitted and

necessary for the purposes of providing the Services and Events or the relevant parts

thereof. The storage period depends on the nature of the information and on the

purposes of processing. The maximum period may therefore vary per use.

We will store the User Data collected in connection with the registration or application

process for as long as the User in question is a registered user of our Services,

subscriber of our newsletters or an applicant or participant of our Event or otherwise

interacts with Platform.

We will delete or anonymise all the User Data within a reasonable time and at the latest

after 5 years after the end of the latest Event you have participated in or interaction in

Platform, save for when we are required by law, claims handling or accounting

standards to store some of such information in the form of personal data.

Please note that if you are a registered User of our Services, we will store your User

Data relating to your application for as long as you have a user account on the Website.

A registered User may, at any time, delete his/her user account. Thereafter, we will

delete or anonymise all your User Data within a reasonable time, save for when we are

required by law, claims handling or accounting standards to continue storing some of

such information in the form of personal data.

We will store Analytics Data of registered users of our Services for the duration of the

registration period and thereafter for a reasonable time, but no longer than 24 months

for the purposes specified in this Privacy Policy.

We will store Analytics Data of unregistered users of our Services for a reasonable time,

but not longer than 24 months for the purposes specified in this Privacy Policy.

7. USERS’ RIGHTS

Right to access

The Users have the right to access the personal data relating to them and processed by

the Company. This means that the Users may contact us, and we will inform what

personal data we have collected and processed regarding the said User and

communicate the purposes such data are used for.

Right to withdraw consent

In case the processing is based on a consent granted by the User, the User may

withdraw the consent at any time. The withdrawal of consent does not affect the

lawfulness of processing based on consent before its withdrawal.

Right to rectify

The Users have the right to have incorrect, imprecise, incomplete, outdated, or

unnecessary personal data we have stored about the User corrected or completed. By

contacting us on the addresses indicated above, the User may update e.g. his/her

contact details or other personal data.

Right to deletion

The Users may also ask us to delete the Users’ personal data from our systems. We will

comply with suchrequest unless we have a legitimate ground not to delete the data.

Such legitimate ground may be based on e.g. applicable legislation.

Right to object

You may 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

organization of the Events 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 the

Services or to participate in the Events.

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 the Services or to participate in the Events.

Right to data portability

The Users have the right to receive their 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 above mentioned rights may be used by sending a letter or an e-mail to us on the

addresses set out above. We may request the provision of additional information

necessary to confirm the identity of the User. We may reject requests that are

unreasonably repetitive, excessive or manifestly unfounded.

8. DIRECT MARKETING

The User has the right to prohibit us from using the User’s 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.

9. LODGING A COMPLAINT

The User can lodge a complaint with the local supervisory authority for data protection,

in case the User considers the Company’s processing of personal data to be

inconsistent with the applicable data protection laws. In Finland, the local supervisory

authority is the Data Protection Ombudsman (www.tietosuoja.fi).

10. INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the

personal data we collect and process. Measures include for example, where

appropriate, encryption, pseudonymization, firewalls, secure facilities and access right

systems. Our security controls are designed to maintain an appropriate level of data

confidentiality, integrity, availability, resilience and ability to restore the data. We

regularly test the Websites, systems, and other assets for security vulnerabilities.

If, despite our security measures, a data breach occurs that is likely to negatively impact

the privacy of our users, we will promptly notify the affected users, other relevant

parties, and, when required by applicable data protection laws, the appropriate

authorities.