Privacy Policy

We are committed to protecting the privacy of our users.

The data we process can be categorized into data that the user has given, observed data of service use, and data derived or calculated with the use of analytics.

We use data to deliver and personalize services, customer service, product development and to serve you more interesting advertisements.
We believe in the benefits of data and want to give our users control and choice over the processing of personal data.
With your consent, we can offer you location-based services which are based on the location of your device e.g. local events and potential business contacts.

MEP is committed to protecting the privacy of its customers and users of its product and service according to the EU General Data Protection Regulation GDPR (917/2014) and other applicable laws. We adhere to the following industry self-regulatory frameworks, such as the direct marketing guidelines of the Finnish Direct Marketing Association (DMA), and the self-regulation framework for online behavioural advertising of the Interactive Advertising Bureau (IAB).

The user of our products and services accepts this privacy policy statement by using our services. If the user does not accept these terms, the user does not have any right to use our services.

Information XR Presence collects

We collect information about users for the purpose specified in later of this privacy statement. The purpose for data collection defines what information is collected from the user in each situation.

Personally identifiable information may include, but is not limited to: contact details, such as name, address, telephone number, email address interests and actions on topics and events contacts and matches, chat messages.

The registration data required for a digital account, such as username, nickname, password and any other individual identifier demographic data, such as age, gender, rank or profession and native language customer account information, such as invoicing and payment details, product and order information, customer feedback and contacts, competition responses and subscription cancellation data preferences and interest information provided by the user permissions and consents information provided to surveys and research any other information collected with the user’s consent

Observed data about online service use: information about the service transactions of a registered customer, such as use and browsing information of  the digital  product or service properties through the digital account of the user. Service usage data is linked to an identifier, which is typically a randomly generated sequence of numbers. attributed to a digital account, such as the XR Presence Account, information collected using cookies and other similar technologies, such as the pages browsed by the user, the sites the user accessed XR Presence’s websites, the device model, individual device and/or cookie identifier, the channel  through which the service is accessed (web browser, mobile browser, application), browser version, IP address, session identifier, session time and duration, screen resolution and operating system. Location data, such as coordinates calculated using GPS, WLAN connection points or mobile network base stations if the user has given his or her express permission for this purpose. Data that is derived from observed data and/or information given by the user by using analytics and patterns such as calculating possible interests of the user or otherwise segmenting the user to a specific group of users.

Data in our marketing register:

Our marketing registers contain information about a person’s name, title or profession, age, gender, native language, contact details, and possibly an additional attribute of the person. We can store user’s information in our marketing register for example when their subscription has ended or if the user has given us their contact details for example in connection to a competition.

On form which sources are my information collected

Personal data is mainly collected at the point of subscription or registration, or later during the customer relationship. We may also use online technologies described below to collect observed data about how people use our digital products and services.

Additional sources of information include the Robinson’s register maintained by the DMA, the Finnish Population Information System, and other similar public or private registers.

For which purposes is my data collected?

We only handle personal data for predefined purposes, mainly to the following:

To provide and maintain our Service by notifying You about changes to our Service, allowing You to participate in interactive features of our Service when You choose to do so, providing customer support, gathering analysis or valuable information so that we can improve our Service, monitoring the usage of our Service, detecting, preventing and addressing technical issues and providing You with news, special offers and general information.

Product development: Data helps us to continuously develop the user experiences and features of our products and services. We also carry out surveys and  consumer studies to improve our customer insight. Data is also used to create statistical reporting to help make fact based decisions for business development purposes.

Special offers, purchases and customer relationship management: In accordance with GDPR and given consents, we use data to help customers find attractive offers on our services, to enable online purchases of our users, and to provide customer support that is as personal and seamless as possible.

Targeted digital advertising: We use data to segment our users to display targeted digital advertisements to make them more relevant for users. Targeting segments are created based for example based on the user’s areas of interest, demographic data and location.

Storing and combing my data

We handle the personally identifiable information that the user has given to us (such as profile and contact details) separately from observed data about online service use and derived data, typically in separate databases. Observed or derived data about service usage is always stored using identifiers that are typically randomly generated and users cannot be personally identified from the identifiers.

If the user has created a XR Presence Account we may for the purposes mentioned earlier, enrich the account data with the observed data collected about online use of our services. Combining data for the purposes of marketing and targeting of digital advertising requires user’s consent. For example if user brings product purchase and / or subscriptions to be managed on the account we can target advertisements based on the subscription history.

For how long my data will be stored?

We store user information only for as long as is necessary in order to fulfil the purposes set out in Section 3 above, in accordance with the applicable legislation.

A person’s digital account is typically valid for eighteen (18) months.  If the user has not logged in to his or her digital account during that time period, the user is requested to renew his or her user rights. If the user does not renew his or her user rights, or the user’s customer relationship or other reason for handling personal data are no longer valid, the user’s personal data will be deleted, transferred to a permanent marketing register, or anonymized into such a format that it is no longer possible to identify the person.

The user’s nickname and content provided by the user may remain visible in some services, such as discussion forums and public commenting platforms, even after the termination of the user’s actual customer relationship with XR Presence. In addition, we may be obligated to store some of the user’s personal data in order to comply with accounting laws or other imperative legal provisions, even after the termination of the customer relationship.

Who can handle my personal data?

Companies within XR Presence and its parent group can handle personal data according to EU General Data Protection Regulation GDPR. We may also outsource the handling of personal data to a third party supplier or vendor, in which case we ensure through contractual measures that the personal data is handled appropriately and in compliance with GDPR.

We typically store our data in the EU or the EEA. If any data is transferred outside the EU or EEA, we will ensure that the country to which the data is transferred is approved as having a sufficient level of privacy protection by the European Commission, or by using standard contractual model clauses approved by the European Commission. Third party suppliers processing data on our behalf must handle personal data in compliance with this privacy statement.

We only transfer information to third parties for their independent use in cases presented later in this document.

Transferring or disclosing my data to third parties

We will not sell, lease out or disclose personal data of an identified user to third parties for their independent purposes, except for the situations shown below.

We can disclose user’s data to third parties if the user has given his or her express consent for such transfer.

We may disclose to our advertisers segment data about observed users for the purpose of targeting advertisements. Advertisers shall not combine this data to an identified user’s personal data without the user’s consent.

We may also disclose personal data to authorities or to other parties based if required to do so by law.
Data may be transferred to third parties for scientific or historical research purpose, provided that the information has been anonymized so that the data subject can no longer be identified.
In the case of mergers, acquisitions, or other kinds of re-arrangements of our business operations, personal data may be transferred to buyers and their advisors.
In accordance with the service specific descriptions of personal data files information may be disclosed for direct marketing purposes, as well as opinion polls and market research studies and other similar studies in accordance with the Personal Data Act.
If user has given consent to the electronic direct marketing of XR Presence partners can XR presence disclose information about the user to these carefully selected partners for marketing purposes.

Protecting my personal data

We use technical and organisational measures to protect personal data against unauthorised access, transfer, deletion or other handling that may compromise information security. Such methods include the use of firewalls, encryption technologies and safe server rooms, proper access control systems, the controlled provision of user rights and supervision of their use, providing instructions for data processors, and the thorough selection of competent subcontractors who comply with industry standards for information security management.

Cookies and how they are on MEP's websites

We may use cookies and other similar online technologies, such as the browser’s local data storage, to collect data from a user’s terminal. Cookies are small text files that the browser saves in the user’s device. Cookies often contain an anonymous individual identifier, which we can use to measure how many different browsers are visiting our websites, and how our online services are being used.

More information about our practice regarding our Cookies Policy will be available, when they are taken in use.

Third parties collecting information about visits to XR PResence websites

Third parties refer to parties other than XR Presence and its Parent Company, such as advertisers, advertising networks or providers of online measurement and analytics services, who may collect data from XR Presence’s sites. These third parties may place their cookies on the user’s browser when the user visits our services, for example, in order to offer targeted digital advertisements to the user, or to compile statistics about the number of visitors on different sites. In this case, the user’s browser will call the third party’s servers for the delivery of the advertisements, and the third party can view, edit or set its cookies as if the user was on its website. XR Presence has contractual measures in place to ensure that such  third parties follow the applicable legislation and relevant self-regulatory guidelines.

Our services may contain social plugins, such as Facebook’s like buttons or LinkedIn profile links. Although Facebook’s social plugin buttons may be displayed in some of our sites and services, their content comes directly from Facebook. When the user visits our service, the Facebook plugin recognises that the user is logged in to Facebook, in which case the site displays tailored content in the plugin, as if the user was on Facebook.com. If the user is not logged in to Facebook, social plugins will not show any tailored content. Facebook may collect information about users’ visits according to its privacy policy. Facebook will not transfer the information collected to XR Presence, unless the user has given his or her express consent for this purpose.

Users can read the service terms and privacy policies of third party social networking services on their sites.

LinkedIn Privacy Policy
https://www.linkedin.com/legal/privacy-policy

Twitter Privacy Policy
https://twitter.com/en/privacy

Facebook Terms of Use
https://www.facebook.com/terms.php

Our services may also contain links to non-XR Presence websites other than those listed above. However we are not responsible for the privacy policies nor for the content of such third party websites. We recommend that users read the privacy statements of each website.

More information about third-party cookies is available, when they are taken in use.

Privacy policies applying to the use of MEP's applications on mobile devices or tables

Users may download XR Presence’s applications such as Social WebXR through the online stores of mobile device providers such as the Apple App Store and Google Play. The privacy policies of these providers apply in addition to XR Presence’s privacy statement. Users should familiarise themselves with the terms and privacy policies provided by device platforms.

Apple’s Privacy Policy
https://www.apple.com/legal/privacy/en-ww/
Google Play Terms of Service
https://play.google.com/intl/en_us/about/play-terms.html

Google’s Privacy Policies
https://policies.google.com/privacy

Using location data of my device

Information about the location of the user’s device can be used to offer location-based services, such as local weather reports, and to present targeted digital advertisements, provided that the user has given his or her express consent to the utilisation of location information, or expect if the location information is processed anonymously, without attribution to any identifiers.

Location information is determined using available positioning technologies, such as GPS and WLAN connection points and mobile network base stations. The user may revoke his or her consent for location data use at any time.

Influencing my privacy

We are committed to providing our users choices and control over data processing. In this section we list different ways of influencing data collection and processing.

Direct marketing consents

Users have the right to prevent their information from being used for direct sales or marketing purposes, and for electronic direct marketing purposes. Users can opt-out by contacting our customer service, or in the event of e-mail marketing, directly from the e-mail.

Right to verify your information

Users have the right of check what kind of personal data has been collected. Upon the user’s request, we will modify, remove or supplement any incorrect, unnecessary, incomplete or outdated personal data. Users may update and/or check their personal data by contacting our customer service.Preventing the use of cookies

Users can prevent the use of cookies by changing their browser settings. Preventing cookies may have an impact on the way our services function.Creating a new cookie profile by clearing cookies

Users can clear their cookie history from their browser settings. By regularly deleting cookies from the browser, users can change the identifier on the basis of which a specific online user profile is generated. Clearing cookies will not complete prevent information from being collected; however it does resets the user’s online profile based on new cookies.

Preventing third party online behavioral advertising

Through the below described choices the user can prevent targeting of advertising based on their online behavior. After opting out, the user will see as many advertisements as before but they will not be selected according to the user’s areas of interest.

Users can opt-out from data collected from the use of the application for the purposes of delivering targeted advertisements from the application settings. This will prevent the device’s individual identifier from being sent and any information about the use of the application from being used for targeted advertisements.
Also third parties such as advertisers and advertising networks can target advertisements based on user’s interest profile.  If the user does not want third parties to target advertisements according to the user’s interest profile, the user can opt-out from such online behavioural targeting using the links below.
Adtech targeting can be prevented  here .
Improve Digital targeting can be prevented  here .
Google targeting can be prevented  here .
Other third-party targeting can be prevented  here

More information about the targeting of advertisements based on the use of cookies and similar technologies is available on the  Your Online Choices  site.

Consent for the use of location information
Users are asked to provide their consent for the use of location data on applications and services. Location consent can be revoked using the device or application settings.

This privacy statement is subject to changes

We are continuously developing our services and reserve the right to change this privacy policy statement by informing our users of such changes in our services. Changes may also be based on changes in legislation. We recommend that users read our Privacy Policy statement on regular basis to keep track of changes.

We will update the Privacy Policy and the Portal when there are new features added to the account.

On contacting you

The primary point of contact is the service-specific customer care service desk. Contact details to the customer care service are available on the website of each corresponding service.

Users may also send any questions related to this privacy statement and any concerns regarding the use of online technologies for targeting of advertisements to:

XR Presence Oy
Pikku Roobertinkatu 9, Helsinki, 00130, Finland
(3228067-6)

Data Privacy Issues:
info@xr-presence.com

The handling of the data is monitored by the Office of the Data Protection Ombudsman of Finland.
https://tietosuoja.fi/en/

Derived data:
Jukka Viitanen
CEO, XR Presence Oy
jukka.viitanen@xr-presence.com