Privacy Statement

Last updated: 25 July 2025

This document is provided in accordance with the Personal Data Act (Sections 10 & 24) and the EU General Data Protection Regulation (GDPR). It describes how personal data is processed in connection with services provided by RogerApp.

1. Data Controller

Playful Pixels Oy
Business ID: 2410516‑5
Address: Kotipolku 5, 02730 Espoo, Finland
Email: [email protected]

2. Contact Person for the Register

Name: Mikko Heilimo
Email: [email protected]

3. Name of the Register

RogerApp User and Customer Register

4. Purpose of Processing Personal Data

Personal data stored in the register is used for:

1. Providing and developing RogerApp services
2. Customer communication and support
3. Fulfilling legal obligations
4. Managing user accounts and subscriptions
5. Marketing (with user consent)
6. Service analytics and improvement

Data is not used for automated decision‑making or profiling without user consent.

5. Legal Grounds for Processing

The processing of personal data is based on:

1. User’s consent (Article 6 (1)(a) GDPR)
2. Contractual necessity (Article 6 (1)(b) GDPR)
3. Legal obligations (Article 6 (1)(c) GDPR)
4. Legitimate interest (Article 6 (1)(f) GDPR), such as customer relationship management

6. Contents of the Register

The register may contain the following data:

1. Name
2. Email address
3. Company name (if applicable)
4. Country
5. VAT ID (if applicable)
6. IP address
7. User account data
8. User settings and consents within the service (e.g., marketing permissions, language preferences)
9. Payment details (processed by a third‑party provider; not stored directly)
10. Consent for marketing (Yes/No)

7. Regular Sources of Data

Personal data is collected from:

1. Users themselves during account creation or usage
2. Contact forms and support interactions
3. Billing and payment systems
4. Website usage and analytics tools

8. Regular Disclosures of Data

Data may be disclosed to:

1. Payment processors (e.g., Stripe)
2. Analytics and customer‑support platforms
3. Authorities upon legal request

We never sell user data. Data is not disclosed to third parties for unrelated marketing.

9. Transfer of Data Outside the EU or EEA

Some third‑party services (such as cloud hosting or analytics) may process data outside the EU/EEA. In such cases, appropriate safeguards—such as Standard Contractual Clauses—are in place to ensure adequate protection.

10. Data Protection Principles

Data is stored securely using industry best practices. Access is limited to designated employees and trusted processors under strict confidentiality. Systems are protected by passwords, encryption, and secure network configurations; both physical and technical access is monitored and restricted.

11. Right of Access and Correction

Users have the right to:

1. Request access to their personal data
2. Correct inaccurate data
3. Withdraw consent at any time
4. Request deletion (“right to be forgotten”)
5. Restrict or object to data processing
6. Lodge a complaint with the Finnish Data Protection Ombudsman

12. Data Retention

Data is retained only for as long as necessary for the purposes stated above or as required by law. User data related to billing may be retained to fulfil accounting obligations.