CoSpaces Edu’s Privacy Policy

Last updated: November 19, 2018

We understand that privacy is important and are committed to providing you with a safe and comfortable environment to work in. To ensure this, we make sure to strictly follow our privacy practices and would like you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and through HTML-formatted email messages that we send that link to this Privacy Policy (collectively, including the Websites and Apps, the “Services”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

    WHAT IS COSPACES EDU?

    CoSpaces Edu is a 3D visualization platform that can be used through most web browsers (at edu.cospaces.io) and through the CoSpaces Edu Apps. Teachers and students use the platform to create their own 3D visualizations (referred to as "Space") consisting of 3D objects, characters, scripts and other assets provided by the platform or imported into it by the user. A space can be viewed by anyone it is shared with and can even be experienced in virtual reality or augmented reality.

      ACCOUNT TYPES

      In order to be able to create a space a user (“accountholder”) must create an account at edu.cospaces.io/Auth or through our App. An accountholder is required to choose between two types of user roles: teacher or student.
      If an accountholder chooses a teacher role, he or she becomes a “teacher accountholder”.
      If an accountholder chooses a student role, he or she becomes a “student accountholder”.

        PERSONAL INFORMATION WE MAY COLLECT

        “Personal Information” is information that identifies an individual or relates to an identifiable person. Our information practices are different with respect to the account type.

        We do not collect any Personal Information from a person who merely views a space and is not an “accountholder”.

          Personal information we may collect from teacher accountholders

          • Name (required)
          • Email address (required)
          • Date of birth (required)
          • Country of residence (required)
          • Financial information (required when purchasing CoSpaces Edu Pro License Plans “the Paid Subscriptions”)
          • School or university (optional)
          • Biographical information (optional)
          • Chosen username and password (required)
          • Profile picture (optional)
          • Interests (such as arts, biology, chemistry, history, music, law etc.) (optional)
          • Teaching level (such as kindergarten, grade level, higher education, etc.) (optional)

          Personal information we may collect from student accountholders

          • Email address (if signing up with Google or Office 365)
          • Chosen username and password (required)
          • Date of birth (required)
          • Country of residence (required)
          • School or university (optional)
          • Profile picture (optional)
          • Interests (such as arts, biology, chemistry, history, music, law etc.) (optional)
          • Grade level (optional)

          We may need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.
          If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

          How we may collect personal information

          We and our service providers may collect Personal Information from accountholders in a variety of ways, including:

          • Through the Services: We may collect Personal Information through the Services, e.g., when you create an account, register your credit card information and other financial data that we/our payment processors need to provide the Services, or populate your profile.
          • Offline: We may collect Personal Information from you offline, such as when you contact customer service.
          • From Other Sources: We may receive your Personal Information from other sources, such as Google or Microsoft (if you choose to register using your Google or Microsoft account), public databases, joint marketing partners and other third parties.

          How we may use personal information from teacher accountholders

          We and our service providers may use Personal Information for our legitimate business interests, including the following:

          • For login purposes.
          • To respond to your inquiries and fulfill your requests.
          • To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
          • To send you marketing communications that we believe may be of interest to you, subject to your consent if required by applicable law.
          • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
          • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
          • To process your payments for the Services.

          How we may use personal information from student accountholders

          • For login purposes.
          • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
          • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

          How personal information may be disclosed

          The Personal Information of accountholders may be disclosed:

          • To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services.
          • To identify you to anyone with whom you share a space through the Services. (only for teacher accountholders)
          • By you, on profile pages and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
          • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
          • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

          OTHER INFORMATION

          Other information we may collect

          “Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

          • Browser and device information
          • App usage data
          • Information collected through cookies, pixel tags and other technologies
          • Demographic information and other information provided by you
          • Aggregated information

          If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

          How we may collect other information

          We and our third party service providers may collect Other Information in a variety of ways, including:

          • Through the Services: We may collect Personal Information through the Services, e.g., when you create an account, register your credit card information and other financial data that we/our payment processors need to provide the Services, or populate your profile. Offline: We may collect Personal Information from you offline, such as when you contact customer service. From Other Sources: We may receive your Personal Information from other sources, such as Google or Microsoft (if you choose to register using your Google or Microsoft account), public databases, joint marketing partners and other third parties.
          • Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App based on your device number.
          • Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information only to support the internal operations of the Services, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
            If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.
          • Analytics: We use third parties, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to http://www.google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
          • IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.
          • From you: Information such as communications preference may be collected from you when you voluntarily provide it.
          • By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.

          How we may use and disclose other information

          We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

            THIRD PARTY SERVICES

            This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
            In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

              SECURITY

              We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

                CHOICES AND ACCESS

                Your choices regarding our use and disclosure of your Personal Information

                We give teacher accountholders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email.
                We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

                  How you can access, change or suppress your Personal Information

                  If you are:

                  • a teacher accountholder, or
                  • a student accountholder whose age is 16 or older, or
                  • a parent of a student accountholder under the age of 16 and you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.

                  In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Teacher accountholders may also delete their account by selecting “Delete My Account” when logged into the Services. You may also delete, when logged into the Services, any content or information that you have posted to the Services in the form of spaces that you have created. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or repurposed by another accountholder. We will try to comply with your requests as soon as reasonably practicable.
                  Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

                  RETENTION PERIOD

                  We keep your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you and provide our Services to you; (ii) as required by a legal obligation to which we are subject to; (iii) or as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

                    CROSS-BORDER TRANSFER

                    Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
                    If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at http://ec.europa.eu). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).

                      SENSITIVE INFORMATION

                      We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

                        UPDATES TO THIS PRIVACY POLICY

                        We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

                          CONTACTING US

                          If you have any questions about this Privacy Policy, please contact us at info@delightex.com or

                          DelighteX GmbH
                          Elsenheimerstr. 45
                          80687 Munich
                          Germany

                          Because email communications are not always secure, please do not include sensitive information in your emails to us.