Privacy Notice for Path to 100 Websites and Internet Services

Effective as of 29 July 2019

Path to 100, a Wärtsilä initiative, inclusive of its affiliates, is committed to respect Your privacy and to comply with applicable data protection and privacy laws. The purpose of this Privacy Notice is to explain how Path to 100 and its authorised partners and affiliates (“Path to 100”, “We” or “Us”) process Your personal data related to Path to 100’s website and internet services (“Websites”, “Site”, “Community Network”, “Social Media”).

“Personal data” shall mean any information that can be directly or indirectly used to identify You or another individual. processes Your personal data in accordance with the General Data Protection Regulation (EU 2016/679) and other applicable personal data legislation.

“Content” shall mean any information which You have uploaded to the Site or its related Social Media for sharing with the Community Network in furtherance of the goal of having a networked community of experts as part of the mission and vision of the Path to 100 initiative.

In the following, We provide information on the kinds of data We collect on these Websites and the purposes for which We use such data.

Collected personal data

Data provided by You:

In connection with registration to our services, contact inquiries, subscriptions, surveys, polls or other such relationship, We collect personal data that You have provided to us at the time of the operation with Path to 100, including e.g.:

Contact details (e.g. name, address, telephone number, e-mail address, city of residence and country of origin)

Username in relation to online services (if You choose to be a fully registered member on the site)

Possible feedback and inquiry messages provided by You

Any other information that may be provided or uploaded by You to the Site, such as but not limited to: professional website or online portfolio and profile links on relevant social media, academic or white paper and case studies, images (infographics, headshots, logos or other), video or audio (podcast, MP3)

Observed data about Your online usage:

When visiting the Websites, observed data about Your online usage is collected. The data includes e.g.:

Data collected using cookies and other similar technologies, such as the pages browsed by the user, the sites the user accessed the Website from, the device model, individual device and/or cookie identifier, the channel through which the service is accessed (web browser, mobile browser, application), browser version, IP address, session identifier, session time and duration, geographical location data, date and time, screen resolution, operating system, clicks, scrolling and mouse movements.

Purpose of processing

The purpose of processing Your personal data is to ensure an efficient and secure use of Our Websites and services; such as but not limited to:

Develop Our Websites for a better quality and broader scope of services

Provide customized services and content recognizing your specific needs and interests

Enable access to Your user account(s)

Communication between Us and You and reply to Your contact requests, inquiries and feedback

Provide marketing and public relations and other news or information regarding Path to 100 initiatives, speaking engagements, site updates, community network notifications, or webinars via targeted e-mails or other interpersonal communication

Conduct research and collect statistics on web analytics (e.g. what sections of Our Websites the users visit and how much time they spend on the Websites)

Legal basis for processing

The legal basis for processing Your personal data is:

Performance of a contractual relationship between You and Us (e.g. contacting You in relation to subscriptions and registrations and sending newsletters based on Your subscription, notification of changes to the Community Network on the Website, processing and publication of material which You have submitted as a part of the Community Network)

Legitimate Interest of Path to 100 (e.g. observing Website usage that you engage in, to ensure an efficient and secure use of Our Websites, to develop our initiative, to provide customised content to make Our resources and Community Network more relevant to You, and to provide outreach material, disseminate User Generated Content, media alerts, marketing material and to collect statistics)

Your consent

Your consent will be asked in relation to using website cookies. You will find additional information on how cookies are used in the Cookie Notice.

Your consent will be asked before providing any e-mail marketing material or media alerts to You.

Your consent to be a part of the Community Network of Path to 100 Experts, and Your consent to share any material You upload as a part of that Community Network

Your consent in communications with other members of the Community Network

Sources of personal data

Your personal data is either collected from You at the time of registration, contact inquiry or newsletter subscription etc. We may also access personal data that You have provided to Path to 100 by other means, e.g. interaction with our Social Media accounts or which you have shared via User Generated Content via the Community Network and any shared documents which you have uploaded to the Website.

Furthermore, Your personal data may be received from online technologies, such as cookies, in order to apply filtering, observe usage and develop Our websites and services.

You will find additional information on how cookies are used in the Cookie Notice.

Storing personal data

We handle Your personal data that You have provided to Us (such as profile and contact details) separately from observed data about online service use and derived data, typically in separate databases. Observed or derived data about service usage is always stored using identifiers that are typically randomly generated and thus users cannot be personally identified from the identifiers.

Your personal data is stored as long as necessary in relation to the purposes for which the personal data was collected, unless there is a legal obligation to retain the personal data longer (e.g. in case of an ongoing legal proceeding).

Disclosure and transfer of personal data

Path to 100 may handle Your personal data only according to the defined purposes of processing.

Moreover, processing of personal data may be outsourced to Our suppliers, consultants and other service providers to enable the performance of services for Us. Furthermore, personal data can be disclosed to third parties in the following situations:

We may disclose to our advertisers segment data about observed users for the purpose of targeting advertisements. Advertisers shall not combine this data to an identified user’s personal data without the user’s consent

We may also disclose personal data to authorities or to other parties based if required to do so by law

Data may be transferred to third parties for scientific or historical research purpose, provided that the information has been anonymized so that the data subject can no longer be identified

In accordance with the service specific descriptions of personal data files information may be disclosed for direct marketing purposes, as well as opinion polls and market research studies and other similar studies in accordance with applicable personal data provisions

In some cases, the recipients of personal data may be located outside of EU/EEA, in which case We will ensure that sufficient level of data protection is maintained through appropriate safety measures, e.g. by using EU commission’s standard contractual model clauses.

Your rights

Path to 100 is committed to providing You choices and control over data processing. In this section we list different ways of influencing data collection and processing.

Right to access, rectification, erasure, restriction, to object and to data portability

You have the right to check what kind of personal data has been collected about You. Upon Your request we will modify, remove or supplement any incorrect, unnecessary, incomplete or outdated personal data. You may also have a right to restrict the processing of Your personal data or when the processing is based on Our legitimate interests, to object the processing on grounds relating to Your particular situation. If Your personal data is being processed automatically based on Your consent or in connection with a contract between You and Us, You may request Your personal data to be provided in a structured, commonly used and machine-readable format and Your personal data to be transferred to another data controller, when technically feasible.

Your Content

From time to time, as part of the Community Network on the Website, You may upload a variety of Content for sharing with the Website and other Community Network members.  These may include, but are not limited to: PDFs, Documents of any type, Slide Deck Presentations, Audio Files (MP3 files, Podcast, other audio recordings), Videos (any file type or webinar recording), Images (pictures, infographics, headshots, logos, or any other image or scan type).

During Your time as a Community Network member of Path to 100 and its Website, You are able to delete, remove, or edit any and all of Your Content which you have uploaded.

You may choose to share this Content with other members of the Community Network or with Path to 100 as you see fit.

Uploading of Your Content to the site implies that You have authorisation, standing, and license to share these materials with the Site for Site use or for any purpose related to the dissemination of such Content materials to the Community Network and You are therefore authorised to upload them; therefore, Path to 100 and the Website, and all partners and vendors thereof, are able to rely on this authority as You are the content owner.

Path to 100 and the Website, and any all associated media partners and vendors, will seek Your permission first to publish any uploaded picture, logo, or Content outside of the Path to 100 Website.

Right to withdraw consent

If the processing of Your personal data is based on Your consent, You have the right to withdraw Your consent to such processing at any time.

Opt-out from direct marketing

You have the right to prevent Your information from being used for direct marketing purposes.  You can opt-out from receiving marketing material by using the contact details provided below, or in the event of e-mail marketing, directly from the e-mail material.

Right to file a complaint

You have the right to lodge a complaint with a competent data protection authority in relation to Our processing of Your personal data.

Privacy Notices

The applicable Privacy Notice related to processing of Your personal data depend on the data subject category to which You belong to.

If You are a person providing Your personal data for e.g. purposes of inquiring about Path to 100 initiatives or subscribing to Path to 100 newsletters, please see Path to 100’s Customers Privacy Notice.

In some cases, Path to 100 has a legal obligation to process Your personal data. You can find some of the reasons related to such processing in Path to 100’s Statutory Privacy Notice.

Updating the Privacy Notice

We reserve the right to update this Privacy Notice as We regularly need to develop Our business processes, related policies, and follow up the changing personal data legislation. We encourage You to review this Privacy Notice from time to time for any amendments.

Contacting Path to 100

If You have any questions regarding this Privacy Notice or the use of Your personal data in Path to 100, please contact Us at: