Privacy Policy — Processing of Location Data

This policy describes how Lapland Host Oy processes cleaners’ location data in the Turnlap application. Processing is based on the EU General Data Protection Regulation (GDPR) and the Finnish Act on the Protection of Privacy in Working Life (759/2004).

1. Data controller

Lapland Host Oy
Pohjolankatu 12, 96100 Rovaniemi
Business ID: 3543315-6
Email for data protection matters: [email protected]

Processor (GDPR Art. 28): the Turnlap service is provided by Lepoku Oy (Business ID 3648958-1, Rovaniemi, Finland, [email protected]).

2. Purposes of processing

Location data is processed for the following purposes:

• Verification of working time and work performance: to confirm that a cleaning was carried out at the correct property at the correct time
• Support for payroll: objective recording of shift start and end times and travel times
• Mileage log and mileage allowance: calculating the length of a GPS-tracked journey for mileage allowance purposes
• Customer service quality assurance: makes it possible to verify that a cleaning was completed before the guest arrives

3. Legal basis for processing

Processing is based on GDPR Article 6(1)(f) — the legitimate interest of the data controller. The legitimate interest is the assurance, described above, of operational activity, payroll and service quality. We have assessed (balancing test) that this legitimate interest is not overridden by the cleaner’s interests, rights or freedoms, because:

• Location tracking takes place only in defined situations (section 5) — only individual points are stored on the server, not continuous route tracking
• The cleaner has been informed of the processing in advance
• The cleaner has the right to object to the processing (see section 8)
• Accuracy minimisation: only a GPS point is stored on the server, not a route or speed data. During a GPS-tracked mileage-log journey the device follows location for the duration of the journey in order to calculate the distance, but route points are neither sent nor stored — only the start and end point and the distance in kilometres

The balancing test (LIA) and the data protection impact assessment (DPIA) are documented separately (docs/tietosuoja/: LIA-oikeutettu-etu-paikannus, DPIA-tyontekijoiden-paikannus) and are available on request from the service provider ([email protected]). The opt-out is enforced both in the application and at the database level, in all location-related tables.

4. Personal data processed

• Cleaner identifier (cleaner_id) and name
• GPS coordinates (latitude, longitude) and GPS accuracy in metres
• Timestamp and event type: start/end of the working day, start/end of a cleaning, start/end of a maintenance visit, a mileage-log task (log point), and the start and end point of a GPS-tracked journey
• The associated property or shift

5. Data sources

Data is collected from the cleaner’s mobile-device browser (navigator.geolocation) in the Turnlap application in the following situations:

• "Start day" and "End day" (working day)
• "Start cleaning" and "Done" (cleaning shift)
• "Start visit" and "End visit" (maintenance ticket)
• Logging a mileage-log task (one point)
• GPS-tracked mileage-log journey: the device measures location for the duration of the journey (watchPosition) to calculate the distance on the device; only the start and end point are stored on the server

The browser separately asks the user for permission to use location. If location tracking has been switched off in the profile, the database resets the coordinates at the moment of writing, in all of the tables listed above, regardless of the app version.

6. Retention period

Precise GPS coordinates are retained for 90 days from the event. After this, the coordinates are automatically anonymised (deleted), but the timestamps and events are retained for payroll and accounting purposes (the Accounting Act requires that supporting records be retained).

7. Recipients and disclosure of data

• Lapland Host Oy (supervisors and payroll): access to location data for their own employees
• Technical provider: Supabase Inc. (database, servers located in the EU — Frankfurt)
• Data is not disclosed to third parties for marketing or other purposes

8. Data subject rights

Under the GDPR, the cleaner has the right to:

• Access their own data — download your own data (including coordinates) in JSON format from the profile page, or ask your supervisor
• Request rectification of data if you notice an error
• Request deletion of data — you can request deletion of your location history from your profile page; the coordinates are deleted immediately on request (timestamps are retained for payroll purposes)
• Object to processing on grounds relating to your particular situation (Art. 21) — you can switch location tracking off from your profile page. Note that if you do, shift start and end times will only be recorded as timestamps, without location verification
• Receive data in a portable format (Art. 20)
• Lodge a complaint with the Data Protection Ombudsman at tietosuoja.fi if you feel that the processing infringes your rights

9. Automated decision-making

Location data is not used to make automated decisions concerning employment. The shift algorithm does not use GPS coordinates as an input; travel times are estimated from property addresses. Decisions are made by a supervisor.

10. Transfer of data outside the EU

Data is stored on Supabase’s Frankfurt (Germany) servers within the EU. Data is not currently transferred outside the EU.

11. Data security

• Data is encrypted in transit (HTTPS/TLS)
• Data is encrypted at rest in the database
• Access is restricted on a role basis (RLS rules in Supabase)
• Changes to location data (anonymisation, handling of deletion requests, data-request extracts) are recorded in the audit log. Read access is restricted by RLS rules; individual read events are not separately logged

12. Changes to this policy

This policy may be updated. Material changes are announced to cleaners in the Turnlap application before they take effect, and the cleaner is asked to acknowledge the new version.

Updated: 12 September 2026 · Version 2026-09-12-v3