1. SPOTILLA APP OWNERSHIP  

The Spotilla app is owned by Atmotics Oy (FI3276157-6). Contact details of Atmotics Oy can be found on the footer of this privacy policy sheet. Atmotics Oy does not claim ownership to the data viewed, edited or provided by the users. The data is owned by the company in a contract with Atmotics Oy (”data controller”)  Each app‐user is individually authorized by the data controllers the log in to the spesific customer enviroments existing within Spotilla. Atmotics Oy acts onlys as a data processor.  The person downloading the Spotilla app or using the web‐based portal is mandated by the data controller to access, view, edit, delete or otherwise use the data that the individual data controller has chosen to store in Spotilla service.  

2. WHAT DATA IS COLLECTED  

The Spotilla app only collects data that the users inserts into the Spotilla‐service and it collects the location of the user in spesific NFC‐Read events that the user makes, if the users has given permission for this. The user account consists of the users name, e‐mail and password information. The backend services of Spotilla gather log‐information about different events within the service, such as login attempts etc, which are used purely for the operation of the service. These logs do not include any personal data.  The spesific information that the data controllers decide to store into Spotilla service is the responsibility of the individual data controllers. Atmotics Oy does not control, claim ownership or know what data the data controllers store into Spotilla service. Each data controller is responsible for the lawful basis that they have for using Spotilla to store data.

3. LEGAL BASIS FOR COLLECTING DATA  

By using the application the user gives Atmotics Oy right to acts as the data processor of the information that the user provides to the service. The service works only by the user logging into the service and providing the data, the app does not collect any data passively.  The data controllers who have authorized the app user to use their spesific instance of the Spotilla service are responsible for the data the users uses and creates within Spotilla. The data controllers control the different rights of users to see data and perform actions with it.  Atmotics Oy is not responsible for the legal rights of the data controllers to use Spotilla in any spesific data use cases.  

4. FOR WHAT PURPOSES DATA IS COLLECTED                                   

The data is collected per the use case of the data controllers. Atmotics Oy only collects operational data needed for the running of the service and acts as a data processor. Each individual data controller is responsible for the data they collect.  

5. THIRD PARTY ACCESS TO DATA  

The data stored in Spotilla is accessable only by the data controller and whoever the data controller has agreed to work on its behalf in the upkeep of the data (such as Spotilla mobile app users, according to the indivdual user permissions the data controller has given them). Atmotics Oy never gives access to any data controller data to external parties. Subcontractors of Atmotics Oy participate in the development of the system, but they never have access to raw data. As a data processor Atmotics Oy or it’s subcontractors developing the system never give data to any third parties.  

6. THIRD PARTY ACCESS TO DATA  

The users of Spotilla can make requests to see, request or rectify the data in Spotilla directly to the data controller. Atmotics Oy as the data processor does not provide information to users about their data.  

7. INFORMING ABOUT CHANGES IN THE PRIVACY POLICY  

If the privacy policy regarding Spotilla service changes, Atmotics Oy informs all the data controllers about the issue and works in accordance with them to also notify the end users. The data controller is ultimately responsible for making sure, that the users it has mandated to use the data they store in Spotilla are aware of the data protection issues regarding the information these users can see, edit, add or delete.  

This privacy policy is valid from 1.2.2019 onwards