LAST UPDATED: SEPTEMBER 17, 2026
This Privacy Policy covers our activities outside the Focus Tiger Services, such as our website, sales and marketing, and recruitment. Processing of personal data when you use the Focus Tiger Services is described in our Focus Tiger Services Privacy Policy.
1 GENERAL
This Focus Tiger privacy policy (“Privacy Policy”) describes how SILTA Education Oy (“we”, “us”, “our” or the “Controller”) collects data subjects’ (“you”, “your” or the “data subject”) personal data and how and for which purposes the personal data are processed. The Privacy Policy also describes how personal data are transferred to third parties and how you can exercise your rights related to the processing of your personal data.
This Privacy Policy applies to visitors of our website, current and prospective customers, representatives of suppliers and other stakeholders, job applicants, and employees. The Controller processes the personal data in compliance with applicable data protection legislation, including the General Data Protection Regulation (EU 2016/679) and the Data Protection Act (1050/2018). Terms which are not defined in this Privacy Policy shall have the same meaning as in the relevant applicable data protection legislation.
The processing of personal data described in this Privacy Policy does not involve any automated decision-making. Where the processing is based on legitimate interest, you are entitled to request further information regarding the applicable legitimate interest by contacting us using the contact details set out in Section 2 of this Privacy Policy.
2 CONTACT INFORMATION OF THE CONTROLLER
SILTA Education Oy (Business ID: 3241267-5)
Office address: Haartmaninkatu 4, Building 14, FI-00290 Helsinki, Finland
Postal address: Kadetintie 3 B 21, FI-00330, Helsinki, Finland
Email address: privacy@focustiger.io
3 PROCESSED PERSONAL DATA, PURPOSES, AND LEGAL BASIS
3.1 Website. We process the personal data of visitors of our website www.focustiger.io (“Website”) for the purpose of administrating, protecting and improving the Website, and for statistical analysis. Personal data related to your use of the Website is collected directly from you, as well as generated automatically by your device used to access the Website. Your personal data may also be processed if you book a meeting with us or if you contact us through a contact request form on the Website.
| Categories of personal data | Legal basis |
|---|---|
| Website use • IP address • Consent information | Legitimate interest. The processing is based on our legitimate interest to administrate, protect and improve the Website, and to conduct statistical analysis. Consent. Where the processing of your personal data is not based on our legitimate interest, it will be processed on the basis of your consent only. |
| Contact form • Identity data (name, company name) • Contact information (email) • Other information shared by you (any information included in your communication) | Legitimate interest. The processing is based on our legitimate interest to respond to and manage contact requests received through the Website. |
Your personal data submitted through the contact request form is processed until the contact request has been handled, after which the data is either retained in accordance with sections 3.2 (Customers) and 3.3 (Marketing) of this Privacy Policy or deleted. Personal data collected in connection with your visit to the Website is processed only for the duration of your visit; session-related data is deleted when you close your browser. Use of cookies is further defined in a separate cookie policy, which can be found on the Controller’s website.
3.2 Customers. We process the personal data of our customers for the purpose of maintaining and managing the customer relationship, facilitating invoicing and payment administration, delivering and performing the services agreed upon with the customer, communicating with the customer regarding the services, and developing and improving our services. Personal data related to the customer relationship is collected directly from you or from the company you represent.
| Categories of personal data | Legal basis |
|---|---|
| • Identity data (name, company name, job title) • Contact information (email and phone number) | Legitimate interest. The processing is based on our legitimate interest to process personal data in connection with the provision of services, the management of the customer relationship and the development of our services. |
Your personal data will be processed for only as long as necessary for the purposes described herein, which generally is for as long as the customer relationship exists, and for no longer than two (2) years from the last active interaction thereafter. Further information on personal data processed in connection with our services is available in the service-specific privacy policy (https://focustiger.io/privacy-policy/).
3.3 Marketing. We process the personal data of our current and prospective customers for the purposes of communication, marketing and event organisation, as well as for targeting of said activities. Personal data related to marketing activities is collected directly from you or from the company you represent.
| Categories of personal data | Legal basis |
|---|---|
| • Identity data (name, company name, job title, work history) • Contact information (email, phone number) • Other information (special dietary requirements and any other additional information provided by you in relation to our events) | Legitimate interest. The processing is based on our legitimate interest to market and communicate our services. Consent. Where the processing of your personal data is not based on our legitimate interest, it will be processed on the basis of your consent only. |
Your personal data will be processed only for as long as necessary for the purposes described herein. Where processing is based on consent, data will be retained for as long as the consent remains valid. Where processing is based on the customer relationship, data will be retained for as long as the relationship is active and for no longer than two (2) years from the last active interaction thereafter.
3.4 Stakeholders (including agents, subcontractors, vendors, service providers and other counterparties). We process the personal data of the representatives of our stakeholders to administer our stakeholder relationships and facilitate day-to-day activities. Personal data related to the stakeholder relationship is collected directly from you or from the stakeholder you represent in the context of our relationship with the relevant stakeholder.
| Categories of personal data | Legal basis |
|---|---|
| • Identity data (name, company name) • Contact information (email, phone number) • Other information shared by you (any information included in our communication with you). | Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest in being able to administer our stakeholder relationships and facilitate e.g. day-to-day activities. |
Your personal data will be processed for as long as necessary for the purposes described herein, which generally is for as long as you are the representative of our stakeholder or for as long as we have an ongoing business or other relationship with the stakeholder you represent.
3.5 Job Applicants. We process the personal data of job applicants for the purposes of managing the recruitment process, including collecting and reviewing application materials, conducting interviews, evaluating candidates, and communicating with applicants. Personal data related to the recruitment process is generally directly collected from you. However, personal data may also be collected from external recruiters or references nominated by you.
| Categories of personal data | Legal basis |
|---|---|
| • Identity data (name) • Contact information (address, email, phone number) • CV and application information (information provided in your CV and application letter) • Evaluation data (your suitability for the position) • Reference information (if provided by you) | Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest in carrying out the recruitment process. Consent. Where the processing of your personal data is not based on our legitimate interest, it will be processed on the basis of your consent only. This may be the case if we request you to participate in a suitability assessment as part of the recruitment process. |
Your personal data will be processed for as long as necessary for the purposes described herein, which generally is for the duration of the recruitment process and for three (3) months thereafter, unless you have given your consent to a longer retention of your personal data. If you are selected for the position, your personal data will be processed in accordance with section 3.6 (Employees) of this Privacy Policy.
3.6 Employees. We process employees’ personal data to manage the employment relationship and fulfil the employer’s statutory obligations, to comply with the obligations under employment contracts, to provide benefits, and to conduct and develop business operations. Personal data related to your employment is generally collected directly from you. In addition, personal data may be collected from government agencies and in some cases our service providers.
| Categories of personal data | Legal basis |
|---|---|
| • Identity data (name, social security number, gender, birthday, job title) • Contact information (address, email, phone number) • Payroll-related information (bank account, tax card information, salary and payment information) • Work performance and ability information (absence, work ability, health and occupational safety-related information) • Skill and professional background-related information (including information provided during recruitment process) • Benefit information (lunch and recreational benefits, food allergies and dietary restrictions) | Legal obligation. The processing of personal data is necessary in order to comply with the statutory obligations imposed on the employer, including but not limited to the Employment Contracts Act (työsopimuslaki, 55/2001), Accounting Act (kirjanpitolaki, 1336/1997), and other applicable legislation imposing obligations on the employer. Legitimate interest. Where the processing of your personal data is not based on a legal obligation, it is necessary for our legitimate interest in managing the employment relationship and performing the employment contract. |
Your personal data will be processed for as long as necessary for the purposes described herein, which generally is for the duration of the employment relationship and for at the most ten (10) years thereafter.
4 TO WHOM THE DATA IS DISCLOSED
Personal data may be disclosed to the following categories of recipients, if required to fulfil the purposes of the processing: IT and cloud service providers, accounting and financial administration service providers, marketing and communications service providers, recruitment service providers, third-party integration service providers (where you have connected optional integrations), and other service providers acting as data processors on our behalf. In such cases, contractual measures are taken to ensure that the personal data is processed and protected appropriately and in accordance with applicable laws and this Privacy Policy. Personal data may also be disclosed to competent authorities where required by applicable law.
5 TRANSFER OF DATA OUTSIDE OF EU OR EEA
In connection with our operations, we may use service providers that transfer personal data outside the EU or EEA.
In all such cases, we ensure that personal data shall be transferred only to third countries in respect of which the European Commission has determined that an adequate level of data protection exists, or where the transfer outside the EU or EEA is subject to the European Commission’s Standard Contractual Clauses and, where required, appropriate supplementary technical and organisational safeguards have been implemented. Where an international transfer of personal data is based on the European Commission’s Standard Contractual Clauses, you, as a data subject, shall have the right to obtain a copy of the applicable clauses by contacting us at the address indicated in Section 2 of this Privacy Policy.
6 DATA SECURITY
The Controller follows good data management practices, a high level of due diligence and strict security measures for the protection of personal data.
The Controller and all third-party service providers involved in the processing of personal data implement appropriate technical and organisational measures to protect personal data against unauthorised use and accidental or unlawful destruction, alteration, disclosure, transfer or other unlawful processing.
Access to personal data is limited only to those persons who need it in order to carry out their tasks.
7 OBLIGATION TO PROVIDE PERSONAL DATA
In certain situations, the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. The personal data we collect is, depending on the use case, necessary for us to fulfil our legal obligations, deliver and perform our services, manage customer and stakeholder relationships, carry out recruitment processes, and administer employment relationships as described in this Privacy Policy. If the required personal data is not provided, we may be unable to fulfil these purposes; for example, we may not be able to comply with our statutory obligations, enter into or perform an agreement, process your application, or otherwise provide our services to you.
8 RIGHTS OF THE DATA SUBJECT
The data subject has the rights under data protection legislation described below in this Privacy Policy. Please note that the specific application of these rights in each individual situation will depend on the purpose and context for which the personal data is processed.
The data subject is requested to send any requests concerning their rights by e-mail to: privacy@focustiger.io
In general, we will not charge a fee from the data subject for processing the request. However, if the data subject’s requests are manifestly unfounded or unreasonable, for example because of their repetitive character, we may charge the data subject a reasonable fee based on the administrative costs of processing the request.
8.1 Right of access by the data subject and right to obtain a copy of personal data
The data subject has the right to obtain confirmation as to whether their personal data is being processed, as well as information on the processing of personal data as defined in data protection legislation. In addition, the data subject has the right to obtain a copy of the personal data being processed.
8.2 Right to review and rectification
The data subject has the right to review what information concerning them is processed. The data subject has the right to request the rectification of incorrect or inaccurate personal data.
8.3 Right to erasure
The data subject has the right to obtain the erasure of personal data concerning them without undue delay, when
- the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based and where there is no other legal ground for the processing;
- the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
- the personal data has been unlawfully processed; or
- the personal data has to be erased for compliance with a legal obligation in Union or Member State law.
8.4 Right to restriction of processing
Restricting the processing of personal data means that the personal data subject to the restriction may be processed, in addition to being stored, only:
- with the consent of the data subject;
- for the establishment, exercise or defence of a legal claim;
- for the protection of the rights of another natural or legal person;
- for reasons of important public interest of the Union or of a Member State.
The data subject has the right to obtain from the controller restriction of processing, if
- the accuracy of the personal data is contested by the data subject, in which event the processing is restricted for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of a legal claim.
8.5 Right to object
The data subject has the right to object, on grounds relating to their personal situation, to the processing of personal data if the processing is based on a legitimate interest. In such cases, the Controller ceases the processing, unless the processing is allowed under an exception in accordance with the General Data Protection Regulation.
In addition, the data subject has the right to object to direct marketing at any time, without reason.
8.6 Right to withdraw consent
Where the processing of personal data is based on the data subject’s consent, the data subject has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. However, the personal data of the data subject may be retained if the retention of the personal data is necessary to comply with a legal obligation imposed on the controller.
8.7 Right to data portability
The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller, where technically feasible.
8.8 Right to lodge a complaint with supervisory authority
The data subject has the right to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to them infringes the applicable data protection regulation. The competent supervisory authority in Finland is the Office of the Data Protection Ombudsman (tietosuojavaltuutetun toimisto), P.O. Box 800, FI-00531 Helsinki, tietosuoja@om.fi, www.tietosuoja.fi.
9 CHANGES TO THIS PRIVACY POLICY
We may update the Privacy Policy due to changes in data processing or applicable law. The latest Privacy Policy is always visible on our Website.
