Effective Date (last updated): 25/09/20

The entities responsible for processing the data collected, under a co-responsibility regime as joint controllers, are:

    • Kapturall Solutions, S.L. (hereinafter, “Kapturall”) with Spanish tax identification no. (NIF) B95733358, corporate address at C/ Marqués de Zuya, 32, 48993, Getxo, Vizcaya (Spain), administrative address at Calle Carbonero y Sol 1, 2º Izq – 28006 Madrid (Spain), with contact e-mail “privacy@cloudchampion.es”, as owner of the website accessible through the URL https://www.cloudchampion.fi/ (hereinafter, “Cloud Champion Websites”); and
    • The user’s preferred Microsoft distributor from a list of available distributors that participate in Cloud Champion in your specific country (hereinafter, the “Distributor”). Such list is included under Section 4 of this Privacy Policy.

“We” or “our” refers to both Kapturall and Distributor

The present Privacy Policy regulates the collection and processing of personal data provided by users when accessing, navigating and using the functionalities of Cloud Champion. Kapturall and the Distributor knows that you care about how the personal data we receive about you is used and shared, and we take your privacy seriously. This Privacy Notice describes Kapturall’s privacy practices in relation to information that we collect through the Cloud Champion Websites operated by us from which you are accessing this Privacy Notice (collectively, the “Cloud Champion Websites”), through our social media pages and apps located at https://www.facebook.com/CloudChampionFinland , https://twitter.com/CloudChampionFI , and https://www.linkedin.com/company/cloud-champion-finland/ (collectively, the “Cloud Champion Social Media Pages”), as well as through e-mail messages that we send to you that link to this Privacy Notice (collectively, including the Cloud Champion Websites and the Cloud Champion Social Media Pages, “Cloud Champion”). “You” or “user” refers to any individual who visits or otherwise uses Cloud Champion.

This Privacy Notice does not apply to the practices of third parties that Kapturall does not control, or to individuals that Kapturall does not employ or manage.

You can request a copy of this Privacy Notice by contacting us at privacy@cloudchampion.es

1. What types of information does Cloud Champion collect?

  • Personal Data. “Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, company tax ID, job function, expertise, role, postal address, telephone number, e-mail address, browser and device information (including IP address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other individuals to us in connection with Cloud Champion, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
  • Other Information. “Other Information” is any information that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Cloud Champion Websites and for other purposes described below.

2. How do We collect information?

We collect Personal Data and Other Information in a variety of ways, including:

  • Through the Cloud Champion Websites: We collect information through the Cloud Champion Websites, e.g., when you register to use Cloud Champion, when you register to attend a webinar, contact us, request support to close a sales opportunity, download content (e.g. whitepapers) or when you update your profile in your private area.
  • Through your browser or device: Certain information is collected by most browsers automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the sites (such as the apps) you are using. Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access Cloud Champion, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Cloud Champion uses IP Addresses to calculate usage levels of the Cloud Champion Websites, help diagnose problems with its servers, administer the Cloud Champion Websites, and for monitoring the regions from which you access to Cloud Champion Websites.
  • Through Cookies and other similar technologies: “Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s device to enable the individual to more easily communicate and interact with the Cloud Champion Websites. When you visit Cloud Champion Websites, we may send one or more cookies to your device. They enable us to store information about your device which helps us, amongst other things, to provide you with a good experience when you browse Cloud Champion Websites and enhance the level of services and functions provided. We also use third parties to serve third party advertisements that may be of interest to you, based on information collected about your use of Cloud Champion Websites and other websites. To do so, these companies may place or recognize a unique cookie or similar on your browser. Cloud Champion recognizes automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. Please review our Cookies Policy for more information.
  • By aggregating information: Aggregated Personal Data does not personally identify you or any other user of the Cloud Champion Websites (for example, we may aggregate Personal Data to calculate the percentage of our users who have a particular telephone area code).

3. What are the purposes and legal basis of our processing of the Personal Data?

We use Personal Data for the following purposes:

  • To respond to your inquiries and fulfill your requests, such as to send you requested materials, as well as information and materials regarding products and services of Microsoft and its distributors.
  • To send administrative information to you, for example, information regarding changes to the terms, conditions and policies of the Cloud Champion Websites.
  • To send you marketing communications, including via e-mail and SMS in compliance with applicable laws and in accordance with your preferences, that we believe may be of interest to you.
  • To promote training sessions, content, marketing materials for download, etc. about Microsoft products and/or distributor services or promotions aimed at selling Microsoft products.
  • To manage your profile within the platform, including showing you reports and information related to your consumption of trainings and materials from Cloud Champion.
  • To personalize your experience on Cloud Champion Websites by presenting products and offers tailored to you.
  • To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Data, so we suggest that you read these rules carefully.
  • For our business purposes, such as data analysis, audits, developing new products, enhancing, improving or modifying Cloud Champion Websites and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect your privacy, (g) to protect our rights, safety or property; and (h) to allow us to pursue available remedies or limit the damages that we may sustain.
  • The legal basis for collecting and using the Personal Data described above is based on your consent to do so, the necessity to process the Personal Data to perform a contract with you or in order to enter into a contract with you upon your request. In some cases, we may also have a legal obligation to process the Personal Data.
  • You may withdraw your consent for our processing of your Personal Data at any time.
    If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

4. How we will share your Personal Data?

We may share your Personal Data with the following third parties:

Microsoft Ireland Operations Limited:

Cloud Champion will share your Personal Information with Microsoft Ireland Operations Limited (hereinafter, Microsoft) who will process your Personal Data according to the Microsoft privacy policy found in https://privacy.microsoft.com/fi-fi/privacystatement

The legal basis for collecting and using the Personal Data described above is based on your consent to do so and the necessity to perform a contract with you.

Microsoft distributors:
When you register in Cloud Champion, you may select your preferred Microsoft distributor from a list of available distributors that participate in Cloud Champion in your country. The distributor you select will provide you their services, trainings, marketing and sales materials and support through Cloud Champion. The active distributors in Cloud Champion as of the date of last update this Privacy Policy are:

    • ALSO Finland Oy with tax ID FI0998639-8 and address at Kalevantie 2 D, 33100, Tampere (Finland)
    • Arrow ECS Finland Oy with tax ID FI15408025 and address at Stella Business Park / Terra-talo; Lars Sonckin kaari 16, 02600, Espoo (Finland).

Due to the nature of Cloud Champion, the participating distributors may vary, since new distributors may be added to or withdrawn from the list based on their interest in participating.
Cloud Champion and the distributor you select, when appropriate, will process your Personal Data in a co-responsibility regime in order to provide you with the services and functionalities available through Cloud Champion.

The distributor you select, when appropriate, will process your Personal Data as joint controller only to provide information and services focused on promoting and selling Microsoft products, coordinating its activity with Cloud Champion.

The legal basis for collecting and using the Personal Data described above is based on your consent to do so.

The distributor you select will keep your Personal Data while you remain registered on Cloud Champion and said distributor is still participating in Cloud Champion. Your Personal Data will be stored and processed by the distributor until you cancel your Cloud Champion registration or until you decide to select another distributor in Cloud Champion and de-select your previous distributor. In both cases, the distributor will keep personal data blocked for a maximum period of five years in order to meet possible legal obligations, or for any other applicable maximum period pursuant to relevant legislations.

Protection of Cloud Champion and others:
We release Personal Data as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other companies and organizations for the reasons given in the last bullet point under Section 3 above.

5. How do we use and disclose Other Information?

We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we would use or disclose it in the same way that we use and disclose Personal Data.

In some instances, we may combine Other Information with Personal Data (such as combining your name with the name of your organization). If that combination permits you to be identified, we will treat the combined information as Personal Data for as long as it is combined.

6. How does Cloud Champion secure my Personal Data?

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware that no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Questions, concerns and complaints” section below.

7. How can I access, correct, amend or remove my Personal Data?

If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Data about you that has been collected and stored by us in the context of Cloud Champion’s services, or have it transferred to another organization, please notify us at privacy@cloudchampion.es so that we may consider and respond to your request in accordance with applicable law. If you would like to object to the processing of your Personal Data for direct marketing purposes, please use the mechanisms outlined in Section 9 (“What choices do I have?”).

For your protection, we only implement requests with respect to the Personal Data associated with the particular e-mail address that you use to send us your request, and we need to verify your identity before implementing your request. We will respond to your request within a maximum of 30 calendar days.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such access, change or deletion.

At any time, you may submit a claim to the Spanish Data Protection Agency to enforce your rights (www.aepd.es).

8. For how long will we process your Personal Data?

We will process your Personal Data during the period the service is provided and you remain registered in the Cloud Champion websites. Once the relationship with Kapturall ends as a consequence of the cancellation of the subscription to the platform, personal data will be kept blocked for a maximum period of five years in order for us to meet possible legal obligations.

9. What choices do I have?

You can always opt not to disclose your Personal Data. However, if you elect to do so, we will likely be limited in responding to your inquiry or providing services to you.
You can opt-out of receiving marketing messages from Cloud Champion by unsubscribing through the unsubscribe or opt-out link in an e-mail, or by unsubscribing via the Cloud Champion Preference Center at https://www.cloudchampion.fi/my-account/preference-center/ , or by sending an e-mail to privacy@cloudchampion.es. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you important administrative messages.

10. Can children use Cloud Champion’s Sites?

Cloud Champion Websites are not intended for minors under the age of 18. Cloud Champion does not knowingly nor specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any personal data. If you believe that we have mistakenly or unintentionally collected such information, please notify us at privacy@cloudchampion.es so that we can delete the information from our servers.

11. Sensitive information

We do not process any sensitive information via Cloud Champion. Accordingly, please do not send us or disclose any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through Cloud Champion Websites or via other means.

12. Changes to this Privacy Notice

We may amend this Privacy Notice from time to time. The “Effective Date” legend at the top of this page indicates when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Cloud Champion Websites.

13. Questions, concerns or complaints

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your Personal Data as a data controller, please contact us by e-mail at privacy@cloudchampion.es, or by post at: Calle Carbonero y Sol 1, 2º Izq – 28006 Madrid, Spain. ATTN: Privacy, Legal.

You have the right to lodge a complaint with a supervisory authority, including with the Spanish Data Protection Agency (www.aepd.es). In any event, we encourage you to contact us previously since we will take any privacy complaint very seriously and any complaint will be assessed by an appropriate company representative with the aim of resolving any issue in a timely and efficient manner. We expect that you will cooperate with us during this process and provide us with any relevant information that we may need to solve the issue.

14. Language applicable to this Privacy Policy

The language applicable to this Privacy Policy is Spanish. Any version of this Privacy Policy in a different language is offered for the convenience of the User and to facilitate its understanding. However, this Privacy Policy will always be governed by its Spanish version located in https://www.cloudchampion.es/politica-de-privacidad. In case of contradiction between the Privacy Policy in any other language and its Spanish version, the Spanish version will prevail.