Privacy Policy / Notice

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1. Introduction

This Privacy Notice describes how Pro-Insight Finland Oy (“Proinsight”, “we”, “us”) processes personal data in connection with the Proinsight service.

This Privacy Notice supplements Proinsight’s General Terms & Conditions. In the event of any conflict, the General Terms & Conditions shall prevail to the extent they concern the processing of personal data.

2. Data Protection Roles

2.1 Controller and Processor

• The Customer organization acts as the data controller

• Proinsight acts as the personal data processor

This means that:

• The Customer decides what personal data is entered into the service

• Proinsight processes the data to provide the service in accordance with the Customer’s instructions

This division of roles is described in more detail in Section 5 (Customer Data & Data Protection) of the General Terms & Conditions.

3. What Data Is Processed

3.1 Customer Data

Proinsight processes the following data in connection with the use of the service:

• user data (name, email address, identifiers)

• organizational structure (e.g. teams, units)

• goals, plans, and strategy documentation

• survey responses and dashboard data

• inputs and outputs of AI features

Note: The Customer is responsible for the data entered into the service and for ensuring its lawfulness.

3.2 Special Characteristics of Personal Data

The service is designed primarily for organizational-level management, not individual assessment.

The Customer is responsible for managing any related data protection risks (e.g. through organizational data structures and usage practices).

4. Purpose of Processing

Personal data is processed for the following purposes:

• providing and maintaining the service

• delivering strategy and management tools

• generating analyses and reports

• producing AI-assisted content

• customer support and service development

5. Legal Basis

As Proinsight acts as a processor:

• the legal basis for processing is determined by the Customer (controller)

Typical legal bases include:

• contract

• legitimate interest

• legal obligation

6. Data Processing and Retention

6.1 Retention

• Data is stored for the duration of the service use

• User accounts are pseudonymized within 90 days after termination of the agreement

• Other data may be retained in accordance with the General Terms & Conditions

6.2 Anonymized Data

Proinsight may use:

• fully anonymized

• aggregated

data for:

• research

• service development

Such data cannot be linked to an individual or a specific organization.

7. Data Transfers and Sub-processors

7.1 Sub-processors

Proinsight uses subcontractors to provide the service, including:

• cloud/hosting providers

• Microsoft

• Anthropic

• Gamma

7.2 International Transfers

Data may be transferred outside the EU/EEA, including to the United States.

Transfers are based on:

• contractual safeguards

• security commitments of service providers

8. Use of Artificial Intelligence

8.1 AI Features

Proinsight uses artificial intelligence, for example, to:

• generate action plans

• produce analyses

• support reporting

8.2 What Data May Be Sent to AI

The following types of data may be processed via AI services:

• measurement and analysis data

• organizational data provided by the Customer

• data that the Customer has allowed to be used for AI purposes in normal service use

Proinsight does not transfer data to AI services in a form that is directly identifiable to a specific Customer or organization (e.g. Customer name combined with data), unless this results from the Customer-defined data within the service.

8.3 AI and Data Use

• data is not used to train AI models

• AI functions as an underlying capability of service features

9. Security

Proinsight applies:

• access control mechanisms

• encrypted data transmission

• technical and organizational security measures

Complete security cannot be guaranteed, and the Customer is responsible for its own user environment.

10. Cookies

Proinsight uses the Cookiebot service for cookie management.

Cookies are used for:

• service functionality

• analytics

• improving user experience

Users may:

• accept or reject cookies via Cookiebot

• modify cookie settings at any time

11. Data Subject Rights

As the Customer acts as the controller:

• data subject rights (e.g. access, rectification, deletion)
  → must be directed to the Customer

Proinsight:

• assists the Customer in fulfilling these rights to a reasonable extent

12. Changes

Proinsight may update this Privacy Notice.

The current version is available within the service or on the website.

13. Contact Details

Pro-Insight Finland Oy
tommi.sipila@proinsight.fi