Privacy statements of Traficom's mobile applications

Grounds for and purpose of the data processing

Bittimittari.fi is a service for measuring the speed and quality of internet connections that can be used via a browser and on devices running on Android and iOS operating systems. The aim of the service is to provide all internet users with a clear, informative and easy-to-use tool for measuring the speed and quality of their internet connections. The service does not require or offer registration, i.e. the creation of a user account.

As a secondary aim, the use of the service provides Traficom with information about the quality of internet connections for the purpose of carrying out the agency’s statutory duties. For example, Traficom uses the location data that users’ devices report to the service in a generalised form to examine the functioning of Finnish broadband networks. According to section 304, subsection 1, paragraph 6 of the Act on Electronic Communications Services, Traficom’s duties include collecting and publishing information about the availability, quality and prices of network services and communications services. Traficom also uses anonymised measurement data about users’ internet connections for statistical purposes on the basis of the Act.

The service involves the processing of the IP addresses of users’ devices and, with user consent, the location data of devices. In addition to this, the quality survey feature of the browser version of the service involves processing postal address data that the user can opt to provide.

The processing of personal data on the Bittimittari.fi service by Traficom is based on the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (Article 6(1)(e) of the EU General Data Protection Regulation). Additionally, the processing of the location data of users’ devices carried out in connection with the use of the mobile application is based on unambiguous user consent (Article 6(1)(a) of the EU General Data Protection Regulation). Users can manage their consent via their devices’ application-specific settings or delete the application from their devices. The mobile application can be used to carry out individual measurements even if a user does not consent to the processing of his or her device’s location data. However, this may affect the comprehensiveness of measurement results.

The browser version of Bittimittari.fi does not use cookies, but technology similar to cookies is used to store data. The data stored in the browser version (i.e. a browser-specific identifier, the results of individual measurements that make up the measurement history and the selections made by the user concerning the view “What do these results mean?”) is stored in the browser’s local storage. The measurement history is an essential element of the Bittimittari.fi service, allowing the user to view his or her previous measurement results. Users are informed of the technology and the data collected with it.

Data content

The data undergoing processing

in the mobile application, the location data of the user’s device based on consent.

In addition to this, the quality survey feature of the browser version of the service involves processing postal address data that the user can opt to provide, but this data is not stored on the service.

Data sources of the dataset (where data is received from)

The personal data undergoing processing are received from the devices of the users of the Bittimittari.fi service during the use of the service. In the context of the quality survey feature of the browser version of the service, users can opt to provide their address data for the purpose of adding it to a quality report. The service does not require registration.

Retention period of personal data

The personal data processed on the service are saved in connection with the measurements carried out by users on a results server maintained by Traficom, where they are stored for 90 days. After this, the anonymised measurement data is transferred for long-term storage from the results server to Traficom’s VISA information system, where the measurement data is stored in accordance with Traficom’s information management plan for the purpose of carrying out the duties defined in section 304 of the Act on Electronic Communications Services.

Data processing

Recipients and recipient groups of personal data (Disclosure)

As a rule, the controller does not disclose personal data from the service.

Processing of personal data on behalf of the controller

There are two processors who process personal data on behalf of Traficom: Twoday Oy (business ID 1988069-3), which provides the service, and CSC – IT Center for Science (business ID 0920632-0), which is responsible for the connections and measurement servers of the service.

Transfer of personal data to third countries outside of the EU/EEA

No data from the Bittimittari.fi service is transferred outside of the EU/EEA, and no third countries outside of the EU/EEA have access to the data.

Automated decisionmaking and profiling

The processing does not involve automated decision-making.

Rights related to the processing of personal data

About exercising rights

You can exercise your rights by submitting a request to Traficom by email or post. The controller’s contact details are listed in this privacy statement under the section ‘Controller’s contact details’.

The right to lodge a complaint with the supervisory authority

If you believe that your personal data is being processed in violation of legislation, you may lodge a complaint with the Office of the Data Protection Ombudsman. Office of the Data Protection Ombudsman PO Box 800, FI-00531 Helsinki tietosuoja(at)om.fi tel. +358 29 566 6700.

Right of access 

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed. If processing takes place, the data subject has the right to access the personal data.

According to the General Data Protection Regulation, the right to obtain a copy of personal data undergoing processing shall not adversely affect the rights and freedoms of others (Article 15(4)). However, the use of the Bittimittari.fi services does not provide Traficom with any measurement data that the agency could attribute to individual users.

Right to rectification

The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate or incorrect personal data.

However, the use of the Bittimittari.fi services does not provide Traficom with any measurement data that the agency could attribute to individual users.

Right to object

In situations where the processing of personal data is based on public interest, the exercise of official authority vested in the controller or the legitimate interest of the controller or a third party, the data subject has the right to object to the processing of personal data concerning him or her.

However, the use of the Bittimittari.fi services does not actually provide Traficom with any measurement data that the agency could attribute to individual users.

If a data subject uses his or her right to object, the controller must stop the processing of the personal data, unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

Data is not processed for the purpose of direct marketing.

In situations where personal data is processed for statistical or research purposes, the data subject may object to the processing on grounds relating to his or her particular situation, in response to which the controller must stop processing the data subject’s data, unless the processing is necessary for performing a task carried out for reasons of public interest.

Right to restriction of processing

The data subject has the right to obtain from the controller restriction of processing in the situations mentioned in the General Data Protection Regulation.

However, the use of the Bittimittari.fi services does not provide Traficom with any measurement data that the agency could attribute to individual users.

Right to data portability

This right does not apply to the processing operations in question insofar as personal data is not processed on the basis of consent or agreement.

However, the use of the Bittimittari.fi services does not provide Traficom with any measurement data that the agency could attribute to individual users.

Right to erasure (right to be forgotten)

This right does not apply to the processing operations in question insofar as the processing of personal data on the Bittimittari.fi service by Traficom is based on the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The user can personally erase the data stored on his or her device. However, the use of the Bittimittari.fi services does not provide Traficom with any measurement data that the agency could attribute to individual users.

Right to withdraw consent

This right does not apply to the processing operations in question insofar as personal data is not processed on the basis of consent. The user of the mobile application is free to decide whether to consent to the processing of his or her device’s location data when using the mobile application. This consent is not mandatory, as individual measurements can be carried out even without device location data. The user can manage the consent given to the mobile application via his or her device’s application-specific settings. The user is free to withdraw his or her consent for the processing of location data at any time via his or her device’s application-specific settings or by deleting the application from his or her mobile device.

6.11.2024