PRIVACY POLICY

Greener Grass Oy

Greener Grass Oy (”Greener Grass”, “we” or “us”) respects your privacy and are dedicated to protecting the privacy of persons (“you” or “user”) Greener Grass’s mobile games, Greener Grass webpages and other services provided by Greener Grass on a mobile or other platform as well as all other services provided by us (“Services”). This Privacy Policy helps you to understand what Personal Data we collect, and how we use it.  Personal Data refers to information, which allows a person to be directly or indirectly identified as an individual person.

The Privacy Policy applies to your use of our games, websites and other services and you should read it before using the Services mentioned. If you do not agree to the terms of the Privacy Policy, you should not use the Services. 

If you are a minor in your country of residence, please seek parental consent before using the Services. If you are under 13 or under the age of minority depending on the applicable law, please do not attempt to access or use our Services (if not explicitly otherwise stated in the relevant service) or send any information about yourself to us. Greener Grass will not knowingly collect personal data from anyone under the age of minority. If you believe that we might have any personal data from or about a child under the age of minority, please contact us at contact(at)greenergrass.company

Personal data, data subject, controller and other key terms are defined in the General Data Protection Regulation (2016/679, “GDPR”). The company complies with the GDPR in all processing of personal data in conjunction with other applicable national data protection legislation (“data protection legislation”). We are committed to protecting the privacy of data subjects and to complying with the GDPR, applicable data protection laws and other applicable national laws. Our Services may also contain links to external websites and services operated by other organizations that we do not manage. This privacy policy is not applicable to their use, so we encourage you to review the privacy policies that apply to them. We are not responsible for the privacy policies of other websites or external services (even if you access them using the links on our website). We provide these links only as additional information to better serve you.

  1. Controller and contact information

Greener Grass Oy 

Business ID: 2657088-8

Address: Hatanpään valtatie 34 E, 33100 Tampere, Finland

Email: contact(at)greenergrass.company

  1. Legal basis and purpose of the processing of personal data

We process personal data that is necessary only for the purposes set out below. We process personal data in accordance with the applicable data protection legislation. The legal basis for the processing of your personal data is, where not stated otherwise or another legal basis is otherwise applicable, the performance of the contract for providing our’ Services to you. We can also process personal data for recruitment purposes. We can also process your personal data where we have a legitimate interest to do so, such as for marketing purposes. Where we rely on legitimate interests as a reason and legal basis for processing personal data, we have considered whether or not those interests are overridden by the rights and freedoms of the data subjects and we have concluded that they are not.

Where the processing is such that your consent is required by the applicable legislation, we will state so and obtain your consent, and this will be the legal basis for the processing. However, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If such withdrawal means that we are no longer able to provide the Services to you, we may cease to provide the Services.

Personal data will be processed for the following purposes:

  • Customer service and communication

  • Provision, design and development of the Services

  • Measuring customer satisfaction

  • Marketing, including market research, other marketing promotion and analysis, and the production of statistics and the measurement of marketing effectiveness

  • Improving the user experience of our Services and tracking user traffic

  • Handling inquiries as well as communication related to Services

  • Processing customer order information and monitoring payment status

  • Management of legal obligations (eg accounting and other legislation) and reporting obligations, such as reporting related to tax legislation

  • Prevention of abuse

 

We will use the data gathered during the recruitment process that you have submitted to:

  • evaluate your application;

  • review your qualifications and background;

  • communicate with you in relation to the recruitment;

  • maintain records in relation to recruiting and hiring;

Use of Cookies and similar technologies

A cookie is a string of information or a small text file that a website stores on a visitor’s device, and that the visitor’s browser or operating system provides to "remember" things about your visit. Greener Grass may use cookies to help it identify and track visitors, their usage of the Services, and their access preferences, improving quality, tailoring recommendations, and developing the Services. The cookies will not enable Greener Grass to access and review information stored on a User’s computer. In addition to cookies, Greener Grass may use other existing or later developed tracking technologies. These tracking technologies may set, change, alter or modify settings or configurations on your device. 

Greener Grass may work with third parties who use cookies and other tracking technologies to track the effectiveness of the advertisements that may be placed in the Services. They are used for analyzing advertisement view counts, and are not linked to your Personal Information. They might also allow the advertiser to tailor advertising to you when you visit other websites, and/or set, change, alter or modify settings or configurations on your device.

Users who do not wish to have cookies placed on their computers should set their devices to refuse cookies or tracking before using the Services, with the drawback that certain features of such service may not function properly. 

Please note that some parts of the Services may be country specific, and may not work properly if Greener Grass is unable to tell where You are accessing the Services from.

  1. Personal data processed and sources of information

Personal data collected and processed by Greener Grass is mainly collected directly from you. Greener Grass will only collect such personal data that is relevant for the purposes described in this privacy policy, including information you give to us, and technically gathered information when you use our Services.

While the provisioning of certain personal data is necessary for the use of our services, certain personal data is provided voluntarily. Personal data may be updated and supplemented by collecting data from private and public sources, such as commercially available directories and websites.

Personal data and non-personal data are collected directly from you, such as through registration or by logging the activities in the Services. This data may include:

Category of personal data 

Examples of information content

User information: Information gathered at registration* 

Name, email address, payment information and other customer-identifying information

Client, business partner, prospective business partner or a representative of the aforesaid:

Name, Contact details, Employer or other organization, Role and Information about communication

Technical behavioral data and identification data

Monitoring the data subject’s web behavior and use of Services, for example by means of cookies or similar technical identification data.

Examples of data that can be collected include unique device identifiers, IP addresses, device software version numbers and identifiers, and rough location information via GPS, IP address or mobile networks.

Rights management of the data subject, such as consents and prohibitions

Marketing prohibitions and consents.

Communication and measures relating to the rights of the data subject (see the rights of the data subject below).

Other (additional) information provided voluntarily

Preferences related to the contract or marketing / marketing event. Other additional information provided in contacts or appointments.

Recruitment*

Data gathered for recruitment purposes include:

  • Name, first name, birth date and other contact details

  • Education and work experience information

  • CV, job application and other attachments

  • Other information provided by you

  • Applied position(s)

  • Possible consent to use your application for other positions

If you were requested to take any tests as a part of the recruitment process, such as, but not limited to cognitive ability test, the test result data may be processed as a part of our recruitment decision-making process.

*sections thus marked are necessary to provide the Services and fulfill legal obligations. Furthermore, the blocking or the non-provisioning of certain personal data may affect the proper functioning of the Services or Greener Grass may not be able to provide the Services if said data is not provided. 

If you do not provide Greener Grass the required information, this may mean that We are not able to provide the Services to you, perform the contract necessary for the provisioning of the Services or to comply with Greener Grass’ legal obligations.

In addition to personal data, Greener Grass will collect non-personal data relating to you. This information includes either anonymous or anonymized data or data linked to personal data that is generated during the use of the Services, such as actions in the Services and access times.

  1. Retention of personal data 

The personal data we collect is retained for the period necessary to fulfill the purposes outlined in this privacy policy unless a longer retention period is required by law. Thereafter, the personal data will be deleted within a reasonable timeframe or rendered anonymous. The retention periods depend on the purpose of the processing and type of the information. Personal data and retention periods are listed in the table below:

Personal Data

Retention period or criteria used to determine the period

Information you give to us

As long as necessary to fulfill the purpose personal data has been gathered for or as required by applicable laws.

Technically gathered data

As long as necessary to fulfill the purpose personal data has been gathered for or as required by applicable laws.

Recruitment data

We store and process your personal data for recruitment purposes for a maximum period of 12 months after you have submitted your application. You may at any time withdraw your consent by contacting us at the contact details given herein. In case you withdraw your consent for processing your personal data for further recruitment purposes, we will no longer store or process your personal data for the purpose of possible future recruitment processes. However, we may still store, and process certain personal data used for the initial recruitment process, if we have lawful grounds to store and process such data. 

Greener Grass keeps the personal data for as long as necessary for the performance of a contract and as required by retention requirements set out by applicable laws and regulations. Where Greener Grass keeps the personal data for other purposes than those of the performance of a contract, such as for bookkeeping, Greener Grass keeps the data only if necessary and/or mandated by laws and regulations for the respective purpose.

  1. Recipients of personal data

Greener Grass processes personal data in accordance with applicable data protection legislation. Greener Grass will not disclose personal data to third parties unless there is a justified reason, legitimate interest, or express consent. Personal data may be disclosed to third parties for processing in accordance with this privacy policy in order to ensure the functioning of the service and customer relationships, regulatory obligations, marketing and customer communications.

The personal data may also be disclosed to third parties if required under any applicable law or regulation or order by competent authorities, and to investigate possible infringing use of the services as well as to ensure the safety of the services. In addition, personal data may have to be disclosed in connection with legal proceedings or for similar dispute resolution purposes.

Personal data may be disclosed to third-party service providers in accordance with this privacy policy. Greener Grass may use a variety of service providers and other partners to process data, such as IT-services, accounting and financial service providers, in which case Greener Grass ensures the lawful processing of data through contractual arrangements and by instructing third parties on the processing of data. The third parties may change. These third parties process information only on behalf of and for the benefit of Greener Grass. We will provide more information regarding the processing and third parties upon request. In addition, we may share the personal data in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business and in connection with other similar arrangements.

Some of the services used by Greener Grass for processing personal data operate outside the territory of the European Union or the European Economic Area. Thus, personal data can be transferred regularly outside the European Union (EU) and the European Economic Area (EEA). In case personal data is transferred outside EU/EEA, such transfers are either made to a country that is deemed to provide a sufficient level of privacy protection by the European Commission or transfers are carried out by using appropriate safeguards such as standard data protection clauses adopted or otherwise approved by the EU Commission.

We will provide more information regarding the processing upon request.

  1. Protection of personal data

We use appropriate technical, administrative and organizational security measures to protect personal data against unauthorized access, disclosure, destruction or other unauthorized processing. 

All parties processing personal data have a duty of confidentiality in matters related to the processing of personal data. Access to personal data is restricted to those employees who need it to perform their duties. Employees and other processors of personal data have personal usernames and passwords. We also require our service providers to have appropriate methods in place to protect personal data.

Nevertheless, considering the cyber threats in the modern day online environment, we cannot give full guarantee that our security measures will prevent illegally and maliciously operating third parties from obtaining access to personal data or absolute security of the personal data during its transmission or storage on our systems. 

  1. Rights of the data subjects and supervisory authority

Right to access

You have the right to contact us, and we will inform you what Personal Data We have stored regarding you, and the purposes such data is used for. 

Right to rectification

You have the right to have us correct any incorrect, incomplete, outdated, or unnecessary personal data stored about you by contacting us at the email address provided herein. 

Right to erasure

You may also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from all of our systems. Such copies shall be deleted as soon as reasonably possible.

Right to Object or Restrict Processing

You may object to certain use of personal data when such processing is based on legitimate interest, including direct marketing or profiling. You may opt-out of receiving promotional emails by following the instructions in those emails. If you opt-out, we may still send you non-promotional customer information, such as emails about your account, providing our services and products or our ongoing relationship with you.

You may request that we restrict processing of certain personal data. Your personal data will then only be stored and not processed otherwise; this may however lead to fewer possibilities to use the Services. If such restriction means that we are no longer able to provide the Services to you, we shall be entitled to stop providing the Services.

Right to data portability

You have the right to receive personal data provided by you to us in a structured, commonly used format. We provide no guarantee that this information will be compatible, relevant or useful to any other service.

Withdrawal of consent

You can deny any direct marketing and withdraw your consent regarding electronic direct marketing. You can always withdraw any other consent including parental consent. 

How to exercise your rights

These rights may be used by sending an e-mail to the addresses set out below. Your identity will be verified before the information is given out, which is why we may have to ask for necessary additional details. We will respond to the request within a reasonable amount of time and, where possible, within one month of the request and the verification of your identity. If your request cannot be met, the refusal shall be communicated to you in writing. Greener Grass may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

Right to lodge a complaint with the supervisory authority

In case you consider our processing activities of your Personal Data to be inconsistent with the General Data Protection Regulation (GDPR) (EU) 2016/679, you have the right to complain to the applicable data protection supervisory authorities.

  1. Changes to this privacy policy

Greener Grass may make changes to this privacy policy at any time by giving a notice on the website and/or by other applicable means. The data subjects are highly recommended to review the privacy policy on our website every now and then. If the data subject objects to any of the changes to this privacy policy, the data subject should cease using the services, where applicable, and he/she can request that we remove the personal data, unless applicable laws require us to retain such personal data. Unless stated otherwise, the then-current privacy policy applies to all personal data we process at the time.

This privacy policy has been published on March 14th, 2023, version 1.0