CoSpaces Edu’s Privacy Policy

Last updated: June 2020

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 the websites cospaces.io, edu.cospaces.io, forum.edu.cospaces.io, operated by us (the “Websites”), through the CoSpaces Edu software applications made available by us under https://cospaces.io/edu/ for use on or through computers and the CoSpaces Edu Applications for 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 "CoSpace") consisting of 3D objects, characters, scripts and other assets provided by the platform or imported into it by the user. A CoSpace 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 use CoSpaces Edu, a user must create an account (“User”) at edu.cospaces.io/Auth or through the App. A User is required to choose between two types of user roles: teacher or student.

If a User chooses a teacher role, he or she becomes a “Teacher User”.

If a User chooses a student role, he or she becomes a “Student User”.

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 CoSpace and is not a “User”.

Personal information we may collect from Teacher Users

  • Name (required)
  • Email address (required)
  • Chosen username and password (required)
  • Financial information (required when purchasing CoSpaces Edu Pro License Plans “the Paid Subscriptions”)
  • Profile picture (optional)
  • School or university (optional)

Personal information we may collect from Student Users

  • Email address (if signing up with Apple, Google or Office 365)
  • Chosen username and password (required)
  • School or university (optional)
  • Profile picture (optional)

We may need to collect and process Personal Information from Teacher Users and Student Users 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. The legal basis for processing such data is Art. 6 (1) b) GDPR.

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 Apple, Google or Office 365 account), public databases, joint marketing partners and other third parties.

How we may use personal information from Teacher Users

We and our service providers may use Personal Information from Teacher Users for our legitimate business interests in accordance with Art. 6 (1) f) GDPR, including the following:

  • 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.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Services, identifying usage trends and operating our business activities.

We and our service providers may further use Personal Information from Teacher Users to perform a contract with the Teacher User in accordance with Art. 6 (1) b) GDPR, including the following:

  • For login purposes.
  • To process your payments for the Services.

We and our service providers may further use Personal Information from Teacher Users to comply with our legal obligation in accordance with Art. 6 (1) c) GDPR, including the following:

  • 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 we may use personal information from Student Users

We and our service providers may use Personal Information from Student Users to perform a contract with the Student User in accordance with Art. 6 (1) b) GDPR for login purposes.

We and our service providers may use Personal Information from Student Users for our legitimate business interests in accordance with Art. 6 (1) f) GDPR for our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving or modifying our Services, identifying usage trends and operating our business activities.

We and our service providers may further use Personal Information from Student Users to comply with our legal obligation in accordance with Art. 6 (1) c) GDPR 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 Users 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 CoSpace through the Services. (only for Teacher Users)
  • 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 payment providers we engaged to process your payments when you purchase CoSpaces Edu Pro License Plans
  • 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

How we may collect other information

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

  • Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly. We use this information to pursue our legitimate business interests in accordance with Art. 6 (1) f GDPR to display the Services properly, to ensure the functionality of the Services, to optimize the Services and to ensure the integrity of our systems.
  • 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. We use this information to pursue our legitimate business interests in accordance with Art. 6 (1) f GDPR to optimize the performance of our systems and to adapt the Services.
  • 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.
    We use the information collected through cookies to pursue our legitimate business interests in accordance with Art. 6 (1) f GDPR to gather information about your use of the Services and to adapt the Services to improve your experience, to store your credentials and to improve the performance of your use of the Services.
  • Newsletter: We may use your email address, your name and date and time of your registration to keep you updated about latest developments at Delightex, new features or promotions via email, but only in case you have consented in receiving according newsletters, by registering on the Site.
    We store and use your email address in order to send our newsletter on a regular basis. To send out our newsletters and to manage your subscription, we engaged with a newsletter service provider. We store the remaining information to prevent misuse of your information and to address you personally.
    You can opt-out of our newsletter at any time by responding to the opt-out instructions within the newsletter, or send us an email to the email address posted below. Your personal data will be stored until you unsubscribe to the newsletter.
    LLegal basis for the processing is Art. 6 (1) a) GDPR.
    Our newsletter also contains a web-beacon or tracking pixel, which represent a one-pixel image that is stored on the Site. We use this technology to analyze your using behavior. For this analysis, we link the data that is collected through cookies when you use the Site with a unique ID. These data will be collected and analyzed pseudonymized and will not be linked with your personal data. Hence, it is ruled out that the collected may refer to you directly.
    You are entitled to object the tracking at any time by clicking the link which is provided with every newsletter email or by informing us about your objection via email.
    This information will be deleted after you unsubscribed from the newsletter. The processing is based on Art. 6 (1) f) GDPR.
  • Forum: We operate a forum, where you can exchange with other Users, leave comments and/or contact us for support enquiries (collectively: the “Entries”). It is not required to register to read the Entries of other Users. However, the possibility to participate actively in the forum and create Entries or to reply to Entries is open only to Users, which are logged in.
    When you use the forum, we store all data which is related to your use of the forum including your Entries, private messages, and time stamps of your log-in in order to pursue our legitimate interests to operate the forum. The legal basis of the processing is Art. 6 (1) f GDPR. Providing such information is neither a statutory or contractual requirement nor a requirement necessary to enter into a contract with us. However, if you fail to provide such information, you will not be able to use the forum.
    We retain such information until you delete your account. In this case, your Entries will remain visible for all visitors, but your account information will be anonymized and is no longer retrievable. All other data will be deleted.
    For hosting and operating the forum we use the Discourse software licensed from Civilized Discourse Construction Kit, Inc., 8 The Green Suite #8383 Dover, Delaware 19901, USA (“CDCK”).
    To ensure proper protection of your personal data, CDCK committed itself to the Privacy Shield Principles and is certified under the EU-U.S. Privacy Shield Framework.
  • Contact Form: The Site offers a contact form, which allows you to get in touch with us and to ask questions, make suggestions or give recommendations. When using the contact form, your IP address, your message and the details entered by you, will be transmitted to us.
    We will use this information to pursue our legitimate interests to process your enquiry and to communicate with you. Legal basis for the processing is Art. 6 (1) f) GDPR.
  • Analytics: We use third parties, including Google Analytics a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (“Google”), which uses cookies and similar technologies to collect and analyze information about the use of the Services and reports on activities and trends.
    The information generated by the cookie about your use of the website (including your IP address) may be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is activated on the Site, Google will shorten your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases the unshortened IP address will be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
    Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for us on our behalf and providing other services relating to website activity and internet usage. Our legitimate interest in data processing also lies in these purposes. The legal basis for the use of Google Analytics is Art. 6 para. 1 lit. f GDPR.
    The data sent by us and linked to cookies, user-identifiers (e.g. User-IDs) or advertising-identifiers are automatically deleted after the data will not be required for the analysis any more. Data whose retention period has been reached is automatically deleted once a month. Google will not associate your IP address with any other data held by Google. We do not tie the data to any personally-identifiable information.
    You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, https://www.google.com/analytics/terms/gb.html or https://policies.google.com
    You may refuse the use of cookies by selecting the appropriate settings on your browser, however, as mentioned above please note that if you do this you may not be able to use the full functionality of the website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Site (including your IP address) and from processing this data by Google and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
    Opt-out cookies prevent the future collection of your data when you visit this website. To prevent Google Analytics from collecting data across several devices, you must opt-out on all devices you use. If you click here, the opt-out cookie will be set: cospaces.io/edu/optout.html.
    To ensure an adequate level of data protection, Google committed itself to be bound to the Principles of the EU-U.S. Privacy Shield Framework.

  • Embedded Videos: To embed videos into our services and provide a more dynamic way for you to learn about our services, we use video embedding provided by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (“YouTube”). YouTube uses cookies to remember your user preferences and to provide links to other videos that are relevant to you. We do not set and cannot access the information in YouTube cookies. For more information on this, please reference YouTube’s Privacy Policy.
    Web Fonts: To display the fonts used for the Service in a consistent manner, we use web fonts provided by Google Fonts, a Service provided by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (“Google”).
    If you use the Services, your browser will establish a connection with a Google server to download the fonts and your IP address will be transmitted to Google. If your browser does not support web fonts, the services will be displayed by using standard fonts.
    We use web fonts to pursue our legitimate interests to display our Services adequately. The legal basis is Art. 6 (1) f) GDPR. To learn more about Google Fonts, please refer to the following link: https://developers.google.com/fonts/faq or to Google’s privacy policy available under https://www.google.com/policies/privacy/.
  • 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. 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 Users 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 User, or
  • a Student User
  • a parent of a Student User
  • 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 Users 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 CoSpaces 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 User. We will try to comply with your requests as soon as reasonably practicable. If you think that processing your personal data infringes applicable data protection laws, you may also lodge a complaint with the competent data protection authority.

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 will be stored and processed on servers located in the United States operated by our hosting provider and processed by contractor, which we engaged to organize and manage helpdesk enquiries (the “Helpdesk Provider”).

To ensure an adequate level of protection for your personal information, we have put in place standard contractual clauses adopted by the European Commission with our hosting provider. Additionally, our hosting provider and the Helpdesk Providers committed themselves to the Privacy Shield Principles and certified under the EU-U.S. Privacy Shield Framework to protect your Personal Information.

If you send us a purchase request for the Software and you are located in an area where we partnered with a reseller to distribute the Software in this area, we may also forward your purchase request to the relevant reseller so they can contact you directly. Some of the resellers are located in which are neither parties of the European Economic Area (EEA) nor recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place standard contractual clauses adopted by the European Commission to protect your personal information.

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@cospaces.io 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.

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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.

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