Terms of use of the Koronavilkku mobile app

These terms of use apply to the Koronavilkku mobile app (the ”app”) maintained by the National Institute for Health and Welfare (“THL”). The purpose of the app is to provide an information system to help to break chains of covid-19 infection among contacts who have potentially been exposed to coronavirus. Maintenance and use of the app is laid down in the Communicable Diseases Act (1227/2016).

These terms of use constitute an agreement between THL and the app user on the use of the app. The user of the app must accept these terms of use in conjunction with deployment whereupon these terms are binding on the user. Use of the app is voluntary. Use of the app is limited to the geographical territory of Finland.

The app is provided for use through the Apple App Store, Google Play Store and possibly other app stores. This requires users to comply with the terms of use of the service provider concerned as well as these terms of use.

1. Licence content

The app user has the right to use the app in accordance with these terms of use. The licence is non-exclusive and non-transferable.

The licence is valid indefinitely. The licence ends when the user removes the app. THL has the right and obligation to end maintenance of the information system and to delete the data it contains once there is no longer a need to break covid-19 infection chains. In this case, the app licence ends automatically.

The app user is responsible for obtaining the devices, software and data communication connections required to use the app. The user is also responsible for the costs of these and the functioning of the devices, software and connections. The user is responsible for use of the app in a data secure user environment.


2. Personal data

The user must grant the app the necessary rights to use the app. Such rights allow the pseudonymous codes of those people in close contact with the user to be tracked and stored in the user’s phone via Bluetooth technology, and for the user’s pseudonymous code to be stored in the phones of others using the app. The app does not collect other personal data nor information about the user’s location or movements. The user may at any time withdraw consent for use of the app by removing the app from their device, whereupon the obligations under these terms of use also terminate automatically.

The processing of personal data in conjunction with the use of the information system is laid down in chapter 4a, sections 43a-43h of the Communicable Diseases Act (1227/2016).

Personal data is processed in conjunction with the information system to break covid-19 infection chains and to reach and inform app users and people who have been potentially exposed as well as for statistical purposes necessary for monitoring the covid-19 pandemic and evaluating the functioning of the information system. Personal data is not used for other purposes.

The following personal data is processed in conjunction with the information system:

  1. the user’s pseudonymous codes
  2. the pseudonymous codes of other users the user comes into close contact with, the necessary information related to these contacts, contact length and time, and the strength of the Bluetooth signal to the mobile device;
  3. the pseudonymous codes of users who have reported their infection;
  4. alert of potential exposure received by the user;The information referred to in points 1,2 and 4 above are stored in the user’s mobile device. The information referred to in section 43, subsection 2(3) of the Communicable Diseases Act is stored in the back end system to allow users of the mobile app who have possibly been exposed to infection to be reached.

The information referred to in points 1 to 4 above is removed and destroyed within 21 days of being saved. The information is removed and destroyed at the latest when the information system is removed from use in accordance with section 43a, subsection 5 of the Communicable Diseases Act.

The app user does not need to notify a physician of an alert received through the information system.

The processing of personal data in conjunction with use of the information system is described in more detail in the privacy notice published by THL at https://koronavilkku.fi/en/privacy/.

THL may use subcontractors to enable the service provided through the app. THL commits the subcontractors it uses to comply with these terms of use and with the requirements of processing personal data and information security under data protection legislation. Subcontractors do not process personal data for other purposes. Kela and Sotedigi Oy process personal data on behalf of the controller. Solita Oy, which supplied the app, does not process personal data.

3. Intellectual property rights

All intellectual property rights and title to the app are the property of THL or the THL licensor. The app may use open source software.

4. Limitations of liability

Under the Communicable Diseases Act, THL provides, approves and maintains the information system consisting of the mobile app and associated back-end system to reach persons who may have been exposed to coronavirus. THL strives to provide the app to users as error-free as possible. However, THL shall not be liable for any malfunction or incomplete operation caused by technical, data transmission or other similar reasons nor for any errors or loss attributable to the user breaching these terms of use or otherwise by the user. Nor shall THL be liable for any data transmission problems or errors caused by third parties due to breaching these terms of use or otherwise by the user. THL shall not be liable for the accuracy of publications, links or other similar information notified by third parties relating to the application.

THL provides the app to users ”as is” and does not guarantee that the app will function in accordance with users’ requirements or that the app will work in all operating environments.

THL shall not be liable for any direct or consequential loss, including the destruction or disappearance of data, caused by use of the app or interpretation of the data contained in the app unless otherwise required by mandatory legislation.

THL shall not be liable for any third party claims against the user. THL shall not be liable for its obligations under these terms of use where this concerns a circumstance of force majeure beyond THL’s control.

5. Modification to and validity of the terms of use

THL is responsible for maintaining the app and reserves the right to modify at any time the content of the app. THL reserves the right to amend these terms of use. App users will be notified in good time of any amendments. To be able to continue using the app after amendment to the terms of use, users must accept the amended terms in the app.

6. Applicable law and disputes

These terms of use shall be governed by Finnish law. Any disputes shall be resolved in Helsinki District Court.

7. Contact information

National Institute for Health and Welfare
P.O. Box 30, FI-00271 Helsinki, Finland
tel. +358 29 524 6000
The person responsible for the Koronavilkku app is Aleksi Yrttiaho
first name.last name@thl.fi