Antidote COVID-19 – mobile application privacy statement

Antidote COVID-19 mobile application is intended to inform about the COVID-19 pandemic and the vaccination campaign against it. In addition, it aims to counter false information and unfounded fears about vaccinations in general. Even though the application’s information content is verified by the World Health Organization (WHO) it does not supersede any advice by health authorities. Antidote COVID-19 mobile application is recommended for ages 10 and up.

This privacy statement concerns in the Antidote COVID-19 mobile application

As the record-keeper for the application and any personal information gathered through it, the software company Psyon Games ltd (“Psyon”) is strongly committed to protect the privacy of its users and strives to protect their personal data in accordance with this privacy statement (“statement”). This statement concerns the personal data of Antidote COVID-19 mobile application users, as it is collected and processed by Psyon.

Personal information and data sources for Psyon

Using the mobile application does not require registration, nor does Psyon collect personal data upon registration. Psyon does not intentionally collect data from minors. Users under 16 years of age are instructed to choose “Refuse and Continue” for analytics data collection when they start using the application. Normally,  Psyon does collect some personal data via the mobile application to facilitate further application development: 

  • Psyon uses analytical tools as part of the mobile application. These can process, among other things, users’ IP addresses. Such tools include:
    • GameAnalytics is used for analyzing internal events within the mobile application, and to help develop the operations and player experience with the said application even further. More information on how GameAnalytics processes personal data can be found here.
    • Google Firebase is used for analyzing internal events within the mobile application, and to help develop the operations and player experience with the said application even further. Also, it enables programmed advertising within digital channels. More information on how Google Firebase processes personal data can be found here.
    • Facebook, which is used to collect demographic data. Psyon uses this data only in non-personified format. More information on how Facebook processes personal data can be found here.
    • Google Play Services are used to collect device information such as version numbers, error messages and the like on Android devices. More information on how Google Play Services processes personal data can be found here. 
    • Apple, which is used to collect device information, such as version numbers, error messages and the like regarding iOS devices. More information about how Apple processes personal data can be found here.
  • The mobile application can be used to conduct user surveys. Their replies are transferred to Psyon. 

Psyon makes no attempt at identifying users from the data and attempts to aggregate and minimize the data so that individual users cannot be identified from it. 

Legal basis and purpose of data processing

Psyon’s right to collect and process personal data (see above) is based on Psyon’s right to produce a mobile application for its users, observe and rectify mistakes in the said application and to develop it further over time. In addition, user survey results are used to determine the success of the health information distribution effort and to improve the end-user experience.

Psyon uses analytical tools that go beyond the monitoring of internal events and user experience only if the user has consented to it by turning the application analytics on before playing the game. Users may withdraw this consent at any time by turning the application analytics off.

Personal data collected by Psyon is only used for the purposes stated above. In very limited circumstances, Psyon may also process personal data in other ways as required by law.

Sharing personal data with third parties

Psyon may share collected personal data (see above) with third parties when this is required to meet justified business needs or to comply with applicable legislation. Psyon may also share this limited personal data with specified third parties, including:

  • Business partners and contractors offering services to Psyon
  • Analytics and search engine service providers assisting Psyon in the development and optimization of the mobile application
  • If Psyon buys or sells its business or assets, it can hand over personal data related to the said business or assets to potential buyers or sellers 
  • If a third party acquires Psyon or a significant portion of its assets, personal data held by Psyon may be part of the transferable assets
  • If Psyon has an obligation to hand over or share user data to meet a legal obligation, comply by its own user agreements, or to comply with other agreements in order to protect the rights, property and security of Psyon, its clients or other concerned parties. This includes exchanging data with other businesses and organizations for countering fraud and performing regulatory risk management, as well as exchanging information with legal and health authorities in order to report a negative effect or a product flaw.     

Psyon may use a contractor to process personal data (a so-called personal data handler). When Psyon hands over the processing of personal data to a contractor, Psyon will carefully select and validate the said contractor and monitor it properly to ensure the safety of any personal data to be processed. 

Transferring data outside the EU or EEA

Some of the corporations, partners, service providers and mobile analytics companies involved in processing the personal data collected by Psyon are located in countries outside the European Economic Area (“ETA”). In this case, data protection laws are not guaranteed to be at the same level as otherwise. Psyon ensures that during data transfers to such recipients, appropriate security measures are taken and the applicable legislation and other regulations are followed. Information on applicable protections is available via channels listed under “contact information”.

How does Psyon store collected personal data

Psyon protects collected personal data with adequate and reasonable physical, administrative and technical safeguards against loss, abuse, unlawful access, handover, alteration and deletion. Although Psyon will do its utmost to protect collected personal data, Psyon cannot guarantee that loss, abuse or alteration will not occur. There is a risk involved with any transfer of personal data and no information transfer over the Internet can be absolutely secure.

User rights

Individuals within the EU have certain registered rights, which may also include restrictions. These right include: (i) right to demand access to one’s own personal data and request corrections or deletions; (ii) right to request limits to the processing of personal data or oppose processing entirely; (iii) right to transfer personal data from one system to another; and (iv) right to withdraw consent for the processing of personal data.

If the user wants to apply any of these rights, the user may contact Psyon using the contact information given later in this document. Within the EU, an individual has the right to file a complaint about the processing of their personal data to their local Data Protection Supervisor.

How long does Psyon store personal data

Personal data collected by Psyon is stored only for as long as deemed necessary to carry out the purpose for which it was collected. The need to preserve personal data is evaluated regularly as part of Psyon’s validation processes, in accordance with the local legislation and other regulatory requirements, as well as Psyon’s legitimate business interests.

Other important information

Antidote COVID-19 mobile application can provide links to third-party websites. The privacy statement does not apply to the said websites and users should check the legal and privacy policy statements for any website they visit.

How to reach Psyon Games ltd

User may contact Psyon to exercise registered rights, make queries or send complaints regarding Psyon’s handling of personal data. Psyon will make every effort to reply to all requests, queries and demands within thirty (30) days.

Psyon Games ltd. reserves the right to bypass repeated communications containing unreasonable demands or that can otherwise be construed as intentional disruptions of business.

Contact information

Psyon Games ltd address is Matarankatu 2, 40100 Jyväskylä, Finland

If the user has questions on how Psyon handles personal data, they may email to dpo@psyongames.com

Important notes

Finnish Data Protection Supervisor oversees the legality of personal data collecting and the application of personal data protection rights. To receive more information on privacy protection or if the user cannot resolve a problem directly with Psyon and wants to file a complaint, the user can do so by contacting the Finnish Data Protection Supervisor using the following contact information. Email: tietosuoja@om.fi  telephone: 029 56 66700. Also check www.tietosuoja.fi.

This privacy statement comes into effect in February 2021.

Antidote COVID-19 Terms of Service Agreement

These terms of service concern the use of Antidote COVID-19 mobile application by Psyon Games ltd. The mobile application is intended to inform about the COVID-19 pandemic and the vaccination campaign against it. In addition, it aims to counter false information and unfounded fears about vaccinations in general. Even though the application content is verified by the World Health Organization (WHO), it is not meant for diagnosing an illness and does not supersede any advice by health authorities. Antidote COVID-19 mobile application is recommended for ages 10 and up.  

The user must agree to these terms of service prior to using the mobile application. By installing and using the mobile application the user confirms that the user is of legal age or otherwise meets the age requirements set by applicable laws. Additional information on how Psyon handles personal data is available on a privacy policy statement attached to these terms of service.    

Psyon reserves the right to alter these terms of service and the privacy policy statement at any time. Changes to either terms of service or the privacy statement come into effect as soon as they have been released as part of the mobile application. By continuing to use the mobile application, the user is consenting to any changes. If the user does not accept these terms of service, the user must stop using the mobile application immediately.

License to use the mobile application

Psyon grants the user a restricted, cancelable, non-exclusive, non-transferable and non-licenseable permission to use this mobile application free-of-charge for personal non-commercial aims. Using the application does not require registration. User has no right to use the mobile    application for other purposes. 

This license is in effect until further notice. User may reject the license at any time by uninstalling the application from the user’s mobile device.   

Using this application in a manner at odds with these terms of service, applicable laws or good conduct is prohibited and can result in immediate termination of the license and possible legal repercussions. User accepts that the user will under no circumstances:

  • Copy, alter, edit, sub-license, distribute or otherwise commercially utilize the application, its parts, content, assets or the personal user license;
  •  Undertake any other measures that Psyon considers to be at odds with the intended purpose and planned operation of the mobile application;
  • Bypass or edit any of the security and privacy features, such as access rights or restrictions;
  • Cause disturbance or otherwise interfere with the operation of the mobile application in a way that hinders other users’ ability to use the mobile application;
  • Reverse-engineer, translate or otherwise try to acquire the source code unless this is specifically allowed by law, or try to obtain any other information about the mobile application by means Psyon has not specifically allowed.  

Psyon reserves the right to define what sort of actions it considers to be at odds with these terms of service, or the purpose and planned operation of the mobile application.

Updates and removal of the mobile application

Mobile applications are changing and developing by nature. Psyon reserves the right to edit the mobile application and its content at any time without notifying the user. Using the mobile application may require that the user accepts repeated updates to the application.  

Psyon reserves the right to cease providing or supporting the mobile application or its parts at any time without notifying the user. In this case, user’s license to access the mobile application or any of its parts ceases immediately.

Ownership and intellectual property of the mobile application

All rights to the mobile application, its content, appearance and assets, such as ownership, copyright and other intellectual property rights, belong to Psyon. Psyon also claims all rights not specified to be licensed in these terms of service.      

No extended warranty

With the responsibilities outlined in “limitation of liability”-clause, the mobile application is delivered as is, including any faults and omissions and without a warranty of any kind. Psyon cannot guarantee that the mobile application and its content (i) meets the user’s demands, (ii) works in all possible environments; (iii) is available and usable without interruptions or interference; (iv) is flawless and complete; or (v) does not contain viruses or other harmful parts. 

User is responsible for acquiring the devices, software and operational data connections required by the mobile application, as well as all the incurring costs. 

Limitation of liability

Within the bounds of applicable laws, Psyon is not responsible for any direct, indirect, circumstantial or other damage or injury to the user, including the loss of income or profit, the loss of data, any disruption of business and other immaterial losses in any way caused by or resulting from the mobile application or these Terms of Service.  

User agrees to fully answer for and defend Psyon against any claims, demands, compensations or losses, including reasonable attorneys’ fees by a third party due to the use of the mobile application in a way that is at odds with these terms of service, applicable laws or good conduct. However, the above does not apply if the transgression of rights is not connected to the user’s intentional or careless action.  

Nothing in this terms of service agreement may restrict the user’s legal rights. Even if some limitations are not in effect due to legislation, all other parts of the agreement remain binding.

Applicable law and conflict resolution

These terms of service are applicable under the Finnish Law, except for the clauses on law court selection. Conflicts are to be resolved primarily by negotiations between the involved parties. If no agreement is reached, the matter is resolved in a fully authorised Finnish Court. User may also take the matter to the Consumer Dispute Board (www.kuluttajariita.fi). Prior to taking the matter to the Consumer Dispute Board, the user must contact Consumer Advice (www.kuluttajaneuvonta.fi). User may also take the matter to the European Online Dispute Resolution (http://ec.europe.eu/odr).

Contact information

dpo@psyongames.com

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