Effective Date: August 23, 2022
INFORMATION WE COLLECT AND HOW WE USE IT
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.
SECURITY AND PRIVACY FOR EU RESIDENTS
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
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.
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 email@example.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.