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We've updated the terms of our privacy policy, effective 8/23/22.
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Effective Date: August 23, 2022
Thank you for visiting us at the Joy School application, which is owned and operated by Alegra Learning, Inc. (“Company,” “we,” “our,” or “us”). We welcome you and hope you find our application and the related subscription services we provide (collectively, the “Services”) helpful and useful. We always seek to improve our Services to you, and that requires that we collect, store, share, and use information about you and your usage preferences. As we do so, we are absolutely committed to protecting your privacy and the security of your personal information. To that end, we have implemented this Privacy Policy to help you understand not only what Data we collect, store, share, and use, but how and why.
In this Privacy Policy, we use the word “Data” to describe all the information we collect that relates to you and your use of our Services. “Data” is broken into different categories, which we may refer to separately, but when we use the word “Data,” we mean all the different categories described in this Privacy Policy.
CONSENT
By accessing or using the Services, you consent to our use of your Data as described in this Privacy Policy. You may withdraw this consent at any time. However, in some cases, this may result in your inability to receive full access to the Services, and your withdrawal of consent does not limit our ability to use the Data that has been aggregated and anonymized for use by us in connection with our legitimate business efforts in the future. In other words, to the extent the Data is not personally identifiable to you, we may use the Data to help us in our legitimate business interests in the future.
CHILDREN
The Services are directed generally to children 2-12 years old and occasionally continuing on up to children age 13 and older. We only gather information about those children that is strictly necessary for us to effectively provide the Services, and then only with permission from a parent, guardian, or teacher. We do not use cookies or other tracking technologies on student users. We will never sell student information under any circumstances. We never make Data from a child available publicly. If you believe that we have published Data from a person under 13, please contact us at support@joyschoolenglish.com.
INFORMATION WE COLLECT AND HOW WE USE IT
In the course of our relationship with you, we gather different categories of Data. We always have a lawful basis for gathering the Data, but that lawful basis might be different for different categories. Regardless, we never use the Data for any purpose other than the purpose for which we gathered the Data in the first place. This section of our Privacy Policy describes the categories of Data we collect, the lawful basis for collecting that Data, and the uses we make of that Data.
A. Registration Data
B. Personal Data
C. Usage Data
1. Data Description: Usage Data consists of the following:
• Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Services to you.
D. Payment Data
1. Data Description: Payment Data is the information necessary for us to process your payments for premium Services. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:
2. Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you.
3. How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
E. Supplemental Mobile Data
1. Data Description: Supplemental Mobile Data consists of the following:
2. Lawful Basis for Processing: Our lawful basis for processing Supplemental Mobile Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Supplemental Mobile Data we receive from you.
3. How We Use It and Who We Share It With: We only use Supplemental Mobile Data when you specifically authorize it, and we only share it with those parties who are strictly necessary for the purpose you have authorized.
SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we may share your Data as follows.
If we ever plan to use any Data in the future for any other purposes not identified above, we will only do so after obtaining your specific consent.
TECHNOLOGIES WE USE
The technologies we use for automatic Data collection may include the following:
YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR DATA
If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, please follow the instructions below.
We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information- sharing. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes offline, please follow the instructions in this Privacy Policy.
SECURITY AND PRIVACY FOR EU RESIDENTS
The General Data Protection Regulation made effective in Europe on May 25, 2018 (“GDPR”) requires that we clearly describe to data subjects the data we collect and how we use that data. This Privacy Policy does that, and we hope that if you have any questions for us regarding our data collection, you will write us at support@joyschoolenglish.com .
The GDPR also requires that we have a lawful basis for our processing of any personal data about an individual residing in Europe. For an individual browsing our website or otherwise accessing our Services, our lawful basis is our legitimate interest in providing the Services to you in the manner that you desire, and all the Data that we collect from such individuals will be used only for those purposes, as described in this Privacy Policy. For an individual purchasing Products from us, our lawful basis is the contract under which you purchase Products, and the Data we collect from such individuals will be used only in connection with our contractual relationship with you and only in a manner that furthers the purposes of that contractual relationship, as set forth in this Privacy Policy.
For employees and other authorized users operating in their role as administrators or users of our services, our lawful basis is the legitimate interest we have in providing the services to you.
In turn, you, your employees, and your other authorized users agree to be bound by the provisions of the GDPR with respect to any personal data (“Data”) with which you come in contact using Services,
including without limitation the personal data belonging to individuals with whom you communicate or whose personal data you access using the Services. Specifically, you agree that you, your employees, or other authorized users will:
A. Never access, process, transfer, view, use, or store any Data of any third party without express authorization, and then only for purposes directly related to fulfilling your contractual obligations under your agreement with any third party (“Data Secrecy”);
B. Keep all Data strictly confidential and disclose Data only on a strict need-to-know basis to other employees or authorized users only as required for fulfilling an individual’s contractual obligations (“Confidentiality”); however, you agree that you shall not disclose or otherwise make accessible Data under any circumstances to anyone who has not been obliged to Data Secrecy and Confidentiality.
C. Ensure that your obligations of Data Secrecy and Confidentiality are observed forever, both during and after the expiration and/or termination of any agreement with us or any contractual relationship you may have with an employer or other party.
D. Upon our request to provide Company
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality and integrity of student personal information against risks—such as unauthorized access or use, or unintended or inappropriate disclosure—through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
SHARING INFORMATION WITH THIRD PARTIES
You may be able to access websites and other tools and Services from the Services or Products. The privacy policies of these third parties are not under our control and may differ from ours. The use of any Data that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.
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 offering, site or other products and Services used in connection with the Services. The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.
RETENTION
We will keep your information no longer than necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain de-identified data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained information will remain subject to the terms of this Privacy Policy.
AMENDMENT OF THIS PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Any change to this Privacy Policy will become effective on the date that is 30 days from their posting on the Services or sent via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Data that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.
Policy changes will be accompanied with a banner on our website notifying users and providing them the means of acknowledging and accepting the changes.
ACCESS AND ACCURACY
You have the right to access the information we hold about you in order to verify the information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate, this amended information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.
CONTACT US
You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at support@joyschoolenglish.com. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.
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