Last updated on 15.5.2018
- Purpose and legal basis for processing personal data: We process your personal data in connection with the SnapSkan service in order to deliver you the service and to also develop SnapSkan further as a service. Provided that you have given your consent, we also use your personal data for marketing purposes.
- Personal data we collect and sources of data: We collect information mainly with the SnapSkan measuring devices and from the users themselves. There are also cameras in the car parks nearby the SnapSkan ramps, and those cameras take pictures of the license plate numbers of the vehicles that drive over the measuring spot.
- Retention of data: Regarding those customers who do not sign up for the service, we delete the personal data we collect with the measuring devices and camera within seven (7) days from the measuring. We delete personal data of registered users as soon as possible after their customer relationship has ended.
- Your rights relating to privacy: SnapSkan users have for example the right to have their personal data deleted and the right to receive a copy of their personal data. If you feel that your rights relating to privacy have been violated in connection with this service, you can make a complaint to the local data protection authority.
1. Purpose and legal basis for processing personal data
NOKIAN TYRES processes personal data of SnapSkan users for the purposes of delivering the service and developing the service. For the purpose of delivering the service, the legal basis for such processing is contract between NOKIAN TYRES and the customer. For the purpose of developing the service, the legal basis is NOKIAN TYRES' legitimate interest to be able to develop its business with regard to this service. These two purposes of processing include for example the following actions:
- managing the service
- sending the users messages concerning the service (mainly the measurement results)
- enhancing and developing the usability of the service
- the development and expansion of the service offerings concerning tyre services
- analyzing how people use the service and personalizing the user experience
- evaluating the different functionalities of the service, tyre sales and other services
- repairing faults in the service
- addressing any possible complaints regarding the service and follow-up actions regarding such complaints
NOKIAN TYRES views that the legal basis for processing is legitimate interest also when the SnapSkan measuring device and the camera connected to it temporarily collect personal data of persons, who do not register as customers. This information does not contain any sensitive data and such data is mainly deleted from the service within seven (7) days from the measuring. NOKIAN TYRES has taken these kind of situations into account and has done a so-called balancing test for the processing of personal data in the SnapSkan service in accordance with data protection legislation. For more information on this, please contact us at email@example.com.
The SnapSkan service includes simple profiling of the users insofar that the literal content of the tyre report depends partially on the measuring results of the tyre treads. The SnapSkan report always includes the measuring information but depending on the measuring results the report may include different recommendations for follow-up actions regarding the tyres.
We process personal data in the SnapSkan service also for the NOKIAN TYRES group's marketing purposes, i.e. in order to inform our users about NOKIAN TYRES' products and services. The legal basis in this case is always the user's consent. You can always withdraw your consent by clicking the link in the marketing messages we have sent you or by contacting us by email at firstname.lastname@example.org.
2. Personal data we collect and sources of data
We collect personal data from the following sources in connection with the SnapSkan service:
- the measuring devices of the service (the drive over ramps in the car parks and handheld devices at the NOKIAN TYRES' or our affiliates' premises)
- cameras which are located in the car parks and that are integrated in the service (photographing the license plate number)
- the service's users themselves
- registers of public authorities / public service providers (e.g. the Finnish Transport Safety Agency Trafi)
- other registers of NOKIAN TYRES and/or its affiliates and client companies
We collect and store the following basic information in the SnapSkan service:
- car registration number
- the measuring results of the tyres
- the exact time and place of the measuring
We collect the information by one of the following two ways: (1) customer drives over the measuring device connected to the SnapSkan service (a drive over ramp in the car park) or (2) the tyre treads are measured at our affiliates' premises by their employees with a handheld measuring device.
The tyres' surface/tyre tread depth measured by the SnapSkan drive over ramp is connected to the correct car by using image data from the camera located nearby the ramp. In principle, the camera takes a photo of each car that drives over the ramp. We have tried our best to direct the camera as such that no pictures are taken of the drivers of the cars. The image is automatically processed so that only the registration number in text format remains after which the original picture is deleted from the service. The registration number will also be deleted within seven (7) days from the measuring if the driver by then has not signed up as a user of the service.
You can register to the SnapSkan service by (a) sending an SMS to the number 18136 or (b) signing up for the service online at: http://www.snapskan.fi. After your registration and in order to deliver the service we will combine the basic information described above with other information that you provide to the SnapSkan service and that we receive from other sources.
The information we collect in the SnapSkan service can be categorized as user data and technical data.
User data refers to data which we collect from the registered users themselves or which is created when the user uses certain functionalities of the SnapSkan service. User information contains for example the user's name, address, email address, log-in information to the service, other user-specific information stored in the service, measurement data of the tyres when this data is connected to other information in the service, information concerning the user's social media profile that's relevant to the service, information regarding products or services that have been bought through the service and feedback regarding the service. We do not actively collect location data but based on the place of the measuring this can be indirectly read from the information.
3. Disclosures of data and international data transfers
We use affiliates mostly in the technical development and maintenance of the SnapSkan service, because of which the affiliate may have limited access to the personal data in the service, depending on the service they are providing.
We may use third-party service providers for the processing of personal data on behalf of us also in support functions that are indirectly linked to the SnapSkan service, such as payment services, debt collection services, data analytics services, advertising and marketing services.
Transferring or disclosing personal data may also be necessary between the NOKIAN TYRES group companies or to a third party company in connection with different mergers and acquisitions, bankruptcy or liquidation proceedings or if we sell all or part of our assets.
If applicable laws so require, we may have to transfer or disclose personal data in the SnapSkan service to public authorities.
In some cases we may also transfer personal data of the users outside the European economic area (EU member states and EEA countries). At the moment the backup copies of the service are stored in data centers which are located in the United States.
NOKIAN TYRES strives to take all available measures to ensure that personal data which is transferred or disclosed within the group and/or to third party affiliates has an adequate level of data protection and data security. Personal data is processed in accordance with applicable legislation when it is transferred or disclosed, and when personal data is transferred outside the EEA.
4. Retention of data
We delete personal data of users who have not registered in the service within seven (7) days from the measuring. We may store a technical backup copy of this information for another seven (7) days.
We delete personal data of registered SnapSkan users as soon as possible after the customer relationship has ended and at latest five (5) years after the user last logged in to the service (passivity), unless applicable laws require NOKIAN TYRES to keep some information for longer.
5. Your rights relating to privacy
You have the following rights under data protection legislation when you use the SnapSkan service (as they are described in and in some cases restricted by applicable laws):
- right to access personal data we process about you and right to have your personal data rectified or deleted from the service
- right to require the restricting of the processing of your personal data in the service and right to object to certain processing in the service
- right to data portability, i.e. right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller
- right to file in a complaint to your national data protection authority (in Finland the Data Protection Ombudsman: http://tietosuoja.fi/fi/), if your lawful rights have been violated in the service
If you have registered to the SnapSkan service you can easily have you personal data deleted by going to the SnapSkan website. With regard to your other data protection rights, please contact us at email@example.com.