Privacy Policy
Effective Date: September 29th, 2023.
Poikilingo Kids is an interactive mobile learning application where children can create their own avatar and play as themselves through mini-games. It is founded on the principle of helping multicultural families with their bilingual journey, by providing high quality, entertaining and safe learning materials for kids 2 – 6 years old. As a company founded by mothers, we know that you care about how your family’s personal information is used and shared, and we take your privacy and safety very seriously.
At Poikilingo ApS (collectively as data controllers "Poikilingo", "Company", "we", "us", or "our"), we are firmly committed to your privacy as well as the privacy of your children. We want you, as a parent and/or legal guardian (collectively "Parent(s)") to feel safe and have full confidence in our handling of your data, whether you use our mobile application ("App"), websites, or other services or otherwise interact with us (collectively referred to here as our "Services").
In a summary, we are happy to inform you that:
We only collect information needed to offer our Services.
All data collected is encrypted. Encrypted data means it is stored in the safest way possible and not easily accessible by others.
Child Users are blocked from being exposed to any ads or accessing external links. External links will only be available in the Grown-Ups Area, which is only accessible if an Adult passes the parental gate by answering a security question.
All your data can be deleted at any time.
We collect and process your personal data in accordance with all applicable data protection laws and regulations, including, without limitation, the General Data Protection Regulation of the European Union (GDPR) and the Danish Data Protection Act (DPA).
This Privacy Policy describes in more details the ways in which Poikilingo ApS collects, uses, and discloses information about you and the children who use our Services.
By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use, and disclosure of the information that we provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Poikilingo ApS, the Terms available at https://www.poikilingo.com/terms (our “Terms”) and is subject to the provisions of the Terms. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy you should NOT use our Services.
We may modify this Privacy Policy in accordance with applicable law at any given time. We try to always keep the Privacy Policy up to date. If we make a material change to the Privacy Policy, we’ll provide you with appropriate notice in accordance with legal requirements, such as by email. Also, we will solicit and obtain verifiable parental consent if our privacy practices change in a way that such consent becomes needed.
THIS IS A BINDING AGREEMENT BETWEEN YOU AND THE COMPANY. BY USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS IN THIS PRIVACY POLICY AND THE TERMS OF USE. THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION ABOUT COLLECTION OF PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN. PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICES.
Table of Contents
1. General Information On Data Collection
This Privacy Policy explains how the Company may collect, use, and disclose the information we obtain through our Services provided pursuant to the Terms.
As a matter of principle, we process personal data of our users only to the extent that is necessary for the provision of our Services. The processing of personal data of our users is carried out only with the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.
The security of your personal data is high priority for us. We therefore protect your data stored with us by technical and organisational measures in order to effectively prevent loss or misuse by third parties. In particular, our employees who process personal data are bound to data secrecy and must comply with it. To protect your personal data, it is transmitted in encrypted form; for example, we use SSL=Secure Socket Layer for communication via Internet browser. You can recognise this by the lock symbol that your browser displays when an SSL connection is established. In order to ensure the permanent protection of your data, the technical security measures are regularly checked and, if necessary, adapted to the state of the art. These principles also apply to companies that process and use data on our behalf and in accordance with our instructions.
Your Rights
You have the following rights with regard to the personal data concerning you:
Right to information (Art. 15 GDPR),
Right to rectification (Art. 16 GDPR),
Right to erasure (Art. 17 GDPR),
Right to restriction of processing (Art. 18 GDPR),
Right to object to processing (Art. 21 GDPR),
Right to data portability (Art. 20 GDPR).
You also have the right to lodge a complaint about the processing of your personal data by us with the relevant data protection supervisory authority. The Danish Data Protection Agency (Datatilsynet) located at Carl Jacobsens Vej 35, 2500, Valby (www.datatilsynet.dk) is for us the relevant authority in matters of data protection. You have the right to make a complaint at any time to the Datatilsynet. We would, however, appreciate the chance to deal with your concerns before you approach the Datatilsynet, so please contact us in the first instance.
You may withdraw this consent at any time with effect for the future. The lawfulness of the processing of your data until revocation remains unaffected. To assert your rights or for other data protection concerns, you can contact us at any time via the contact channels listed on the bottom of this Policy.
Data Breaches & Notification
Databases or data sets that include personal data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose personal data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.
Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 (1)(a) GDPR serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1)(b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1)(f) GDPR serves as the legal basis for the processing.
2. Information We Collect
We collect information, including personal information, when you:
register with and log in to any Services;
use our Services; and
communicate with us.
We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.
If you make any purchases through our website or application, we may collect certain information regarding your purchase (such as your name and zip code) as necessary to process your order. You will be required to provide certain payment and billing information directly to our payment processing partners, including your name, credit card information, billing address, and zip code.
We collect information that you submit to us through our website or application. For example, when you post comments, make a purchase, send us an email, we will collect the information you include in these submissions, including any personal information.
We collect and process the information you provide, including any personal information, in the context of composing, sending, or receiving messages through our Company’s messaging function and we may collect information about your use of our Services. This includes testimonials, which may contain personal information.
We collect all information that you provide to us, including any personal information, when you contact us for customer support purposes.
Information we collect when you use our website
As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our website according to your individual interests.
Speed up your searches.
Recognize you when you return to our website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small text file containing a string of alphanumeric characters placed on the hard drive of your computer. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the website.
Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. However, if you refuse to accept browser cookies by activating the appropriate setting on your browser, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
Information we collect when you use our Social Media channels
We also process information that you have provided to us via our company pages on the relevant social media websites. Such information may be the username used, contact details, or a message sent to us. We regularly process this personal data only if we have previously expressly requested you to provide us with this data, for example, as part of a survey. These processing operations are carried out by us as the sole data controller.
We process this data on the basis of our legitimate interest (Art. 6, paragraph 1, lit. f GDPR) in contacting people who make enquiries. In addition, we may process such data for evaluation and marketing purposes. This processing is carried out on the legal basis of our legitimate interest and serves our interest in further developing our offer and informing you specifically about our offers. Further data processing may take place if you have consented or if this serves the fulfilment of a legal obligation.
The sole controller of this processing of personal information is the relevant social media website. Further information about the processing of personal information by the relevant social media website can be found at their respective Privacy Policy when following the links below:
Facebook: https://www.facebook.com/privacy/policy/version/20220104/
Pinterest: https://policy.pinterest.com/en-gb/privacy-policy
Instagram: https://www.facebook.com/privacy/policy/version/20220104/
Information we collect when you use our mobile application
Parents are required to create an account in order to access our mobile application. That is necessary so they may download, install and login to the app, and create Child User’s profiles for their child(ren). We ask parents to provide their email address when creating an account on our platform, and to create a password associated with the account. The email address is used as a username, and also for password recovery.
The legal basis for processing of your personal information in the context of customer account registration is the performance of a contract. Your registration enables in particular the conclusion of contracts as well as the maintenance of our customer relationship. The processing of your personal data within the scope of registration is therefore necessary for the fulfilment of a contract or the implementation of pre-contractual measures as well as the successful maintenance of our customer relationship.
In the Poikilingo Kids mobile application we may collect and process information about your location. This location information is being collected based on your IP address and is restricted to the name of your city. Poikilingo application is not using other technologies to determine your location (we do not use GPS, or other sensors). We do not collect location information about your exact whereabouts (i.e. name of the street or accurate address). When we have location information, we may use it to optimize or customize our Services for you and others, allowing us to customize our website, understand and improve the services and develop new products, services, or features.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case at the latest in the event of the termination of your customer account. You have the option to cancel your customer account registration at any time. In this case, your personal data will be deleted unless legal retention periods prevent deletion.
Information when children use our application
In order to access our mobile application, parents are required to create a learning profile for each of their children (the Child Users). That is necessary so the child may do the activities and play the games. Currently, we ask parents to provide:
Child User’s nickname,
Child User’s gender,
Child User’s month and year of birth,
Child User’s native language.
The legal basis for the processing of the Child User’s personal information in the context of creating and maintaining a learning profile is the performance of a contract.
Children need particular protection when collecting and processing their personal information because they may be less aware of the risks involved. Compliance with the data protection principles and in particular fairness is central to all our processing of Child Users’ personal information. Where we process a Child User’s personal information, consent from whoever holds parental responsibility for the child is obtained. Children have the same rights as adults over their personal information. These include the rights to access, request rectification, object to processing and have their data erased.
Who is accountable for your personal information
Data processing on any Services is carried out by:
Poikilingo ApS
CVR DK41942185
Guldringen 27
4320, Osted, Lejre
Denmark
www.poikilingo.com
support@poikilingo.com
You can contact us at any time regarding this and other questions on the subject of data protection via email on support@poikilingo.com.
3. How We Use Information
We use information collected from you to:
Provide, administer, and facilitate your use of our Services, including to display customized content; process or fulfil your request(s) and/or order(s) for products, services, information or features; display consumer surveys, communicate with you concerning your account by:
Responding to your questions or concerns;
Sending you administrative messages and information, those about changes to the Services, and updates to our Terms and Privacy Policy;
Emailing you information or providing in-app messages about rewards programs, new services, new features, promotions, newsletters, which you can opt-out of at any time;
Sending push notifications to your device to provide updates and other relevant messages. You can manage push notifications from the “Settings” area of the mobile application.
Understand and improve the services and develop new products, services or features;
Manage your account preferences, establish your profile and registration information;
Facilitate the technical functioning of our Services, including without limitation to troubleshoot and resolve issues, secure the Services, and prevent fraud and abuse;
Respond to customer support questions and issues and resolve disputes;
Create, review, analyse and share technical information;
Analyse trends and user traffic, track purchases and usage information;
Advertise our Services on third-party websites or mobile applications;
Market, process or fulfil promotions administered or sponsored by us;
Solicit feedback from users;
As required or permitted by law, as we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services;
Identify unique users across devices; or
Tailor advertisements across devices.
We may de-identify and aggregate information collected through the Services and use it for any lawful purpose.
Child User Information
The personal information collected when creating a Child User learning profile may be used as specified below:
Nickname may be used to personalise activities with the Child User’s nickname. For instance, your child's nickname appears in the screen when creating her avatar.
Gender may be used to define some pronouns used to refer to the child in specific languages, such as Spanish and Portuguese. For instance, when welcoming someone in Spanish, you should say “bienvenido” for a boy and “bienvenida” for a girl.
Month and year of birth may be used to personalise activities for the Child User in the month the child has birthday, offering an avatar that grows up and changes appearance, offering games with birthday theme, sending printables to the parents' email.
The native language may be used to provide customised feedback, instructions and encouragement in the native language of the Child User.
We may ask your permission to enable voice features that collect voice data when your child is using our voice tools. Permission is requested for this use within the app, at the point of registration or when the Child User will use a voice activity for the first time. All data collection is visible and clear in the interface. In each case, the legal basis for processing is our legitimate interests and provision of contract.
Information collected from Child Users may be used:
To measure a Child User’s performance in activities including their use of specific functionalities of our products and/or Services, and to adapt a Child User’s learning experience to the Child User’s learning needs.
To analyse, provide progress reports on, or provide an assessment of a Child User’s performance.
Information collected from Child Users is NEVER used to market to Child Users. Specifically, personal information collected from Child Users will never be used to serve targeted advertising, to build behavioural marketing profiles, or be shared with independent third parties for marketing purposes.
Information collected from both Adult and Child Users may be used:
To allow us to assess and improve the Services, its educational content, and other services we provide, including the use of specific functionalities of our products and/or Services, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.
To customize, adapt, and personalize users’ viewing and content-consumption experience, for example by measuring a Child User’s performance in activities and adapting the Child User’s learning plan to his or her learning needs. To maintain and analyse the functioning of the Services.
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 detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, 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.
Storage period
Unless a more specific retention period is stated within this Privacy Policy, your personal information will remain with us until the purpose for processing the data no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal information (for example, retention periods under tax or commercial law). In the latter case, the personal information will be deleted once these reasons no longer apply.
Security
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Please be aware, however, that no information system can be guaranteed to be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us via email support@poikilingo.com.
4. When do We Disclose Information to Third Parties
We will share your information which may include registration information, profile information, shared content, and location information with the following third parties or under the following circumstances or as otherwise described in this Privacy Policy:
If you post information in a Company forum, that information may be viewed by any Site Visitor or Registered User who accesses the forum.
We may share your information with third-party companies that perform services on our behalf, including for payment processing, order fulfilment, video conferencing, scheduling, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), email and hosting services, services that process and administer consumer surveys, and customer services and support. We may also share your information with third-party companies that we partner with to provide certain services to you in connection with the Services. Those partners’ collection and use of information are subject to their privacy policies and other terms. You should review such privacy policies, terms, and other agreements.
We may provide your contact information, registration information, technical information, usage data, or de-identified data to data enrichment services, which match such information with publicly available database information, including contact and social information from other sources, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with you in a more effective and customized manner.
We may provide your non-personal technical information regarding your use of the site and app to Google, Inc. Gordon House, Barrow Street, Dublin, Ireland. for use in Google's Analytics service. This information includes usage statistics, crash information, device model, software versions, and app versions. We share the same non-personal information to analytics services including Google's subsidiary, Firebase. Further information on the data protection of Google be found here.
Our application is built using the game engine Unity, operated by Unity Technologies, 30 3rd Street, San Francisco, CA 94103, United States. This uses software modules and libraries that come from Unity Technologies itself or third parties, and become an inherent part of our application (called a game engine). During the execution of the application, personal information may be processed by Unity itself, including device identification numbers (so-called UDID – unique device identifiers). Data such as the device type, country of app installation, advertising ID, sensor markings, game identification number (app ID) and the checksum of the transmitted data are also processed. Using Unity also means that the services are using “Unity Analytics”, which collects personal data such as IP address and device identification number. Other data collected includes device specifications (device type, device language), usage data, information about in-app behaviour and in-app purchases, custom event data, where applicable. We do NOT have access to individual IP addresses or device numbers. You can find more information about Unity Technologies’ Privacy Policy here.
Our application’s backend infrastructure is hosted on the servers of the Amazon Web Services (AWS) Cloud. For technical reasons, the IP address of the device is transmitted to the server for each request. The IP address is only used by for statistical analysis but it is not stored. Parts of the data are hosted on servers of the AWS Cloud, which is a component of Amazon Web Services and is operated by Amazon Web Services, Inc., P.O. Box 81226, Seattle, WA 98108. Further information on the data protection of Amazon Web Services can be found here.
Our advertising provider, AppsFlyer, whose services we use to advertise our services. Permission for such data use is specifically requested from each parente as they create their parent account. We will share your child's age and language ability together with your (as the parent) email address and country to provide targeted adverts to Poikilingo users and others who might be interested in our Services;
OneSignal Inc., whose services we use to provide our Service to you, such as, for example, sending a message to parents of Child User(s) who have completed a certain lesson a given day. Permission for such data use is specifically requested from each parente as they create their parent account. We use this data to personalize the experience of each user. We do not collect the full name or full data of birth of your child and do not pass personally identifiable child data to these data processors;
We may access, preserve, and disclose your personal information or other account information if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our or others’ rights, property, or safety.
We may provide recordings (which are anonymised and which do not constitute personal data) to third parties for the purposes of research and analysis.
We do not rent, sell, or share personal information about you with other people or non-affiliated companies for commercial use, or for their direct marketing purposes unless we have your permission. The Services may allow you to opt-in to receive communications from third parties. If you give us your permission to share your personal information with such third parties, then you may receive communications from such third parties and you are solely responsible for your engagement with such third parties.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of the Company’s assets, or transition of the Services to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your personal information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable personal information was collected.
5. How we Secure your Children’s Privacy
Poikilingo ApS takes many precautions to protect the online privacy of children. Whenever we refer to “children” in this Privacy Policy, we mean children under the age of 13. Please help us in protecting children’s privacy by instructing them to never provide any personal information (full name, email address, home address, phone number, etc.) without your permission.
Poikilingo ApS follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S.A. law designed to protect the online privacy of children. Therefore currently Poikilingo ApS does not knowingly collect any personal information from children or within the child-directed portions of our Services except as otherwise outlined in this Privacy Policy. If we were to collect and store personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exception that is permitted under COPPA.
Our application does not contain any third party advertising. We try to ensure safeguards against children clicking in links by placing them a parental gate. Poikilingo ApS does not permit behaviourally-targeted advertising to children in the Services where we have actual knowledge that the user is under the age of 13.
If you have reason to believe that a child under the age of 13 has provided personal information to us through our Website or Service, please contact us. You must also be at least 18 years of age to consent to the processing of your personal information.
We may combine non-personal information we collect through these technologies with personal information about you or your child that we collect. For information about our automatic information collection practices, including how you can opt-out of certain information collection, second section in this Privacy Policy, “Information we collect”.
How We Use Your Child’s Information
We use the information we collect automatically through technology and other non-personal information we collect to improve our Services and to deliver a better and more personalized experience by enabling us to:
Estimate our customer (including Children) size and usage patterns.
Store information about the Child’s preferences, which may allow us to customize the content according to individual interests.
Analyse your child's audio recordings, for purposes of statistical analysis, to give us insight into how well our application is working, and how well children are learning languages using our application.
We do not share, sell, rent, or transfer children’s personal information other than as described in this section:
If a Parent opts to share content from the app (for example, reviews and invitations) we will provide the content via shareable links with secure tokens.
We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children’s personal information:
To third parties we use to support the internal operations of our Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
To law enforcement agencies or for an investigation related to public safety.
If we are required to do so by law or legal processes, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others, including protecting the safety of a child; protecting the safety and security of the website or Services; or enabling us to take precautions against liability.
At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s personal information. You can review or delete your child’s personal information directly in the mobile application or by sending us a request via email to support@poikilingo.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
6. How to Access, Change or Delete your Information
An Adult User can review or change the information they provided when registering for the Services, including by adding or removing Child Users learning profiles to the Account, by updating information through the Parent Area of the Services or by emailing Company support. In addition, at any time, Users may contact us to request that we provide for their review, or delete from our records, any personal information they have provided about Child Users associated with their Account, or to cease collecting personal information from those Child Users, as applicable. Please keep in mind that a request to delete personal information may lead to the cancellation of your Account.
When we change or delete any personal information at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.
7. Specific Terms for European Users
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. It is enforceable since 25 May 2018. The GDPR replaces the 1995 Data Protection Directive.
We inform you that the provided data will be processed by Poikilingo ApS, with registered office at Guldringen 27, 4320 Osted, Lejre, Denmark, (hereinafter as the “Controller”) and Danish company registration number CVR DK41942185. You can contact the Controller via email to support@poikilingo.com.
The legal basis for data processing is the user’s consent to it. This consent is requested through Controller’s forms during the account creation.
The people who provide us with any personal data have the following rights:
a. Right of access: The data subjects shall have the right to obtain from the Controller confirmation that their data are processed properly and they shall have the right to access their personal data.
b. Right to rectification of information: The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning his or her.
c. Right to erasure (to be forgotten): The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her.
d. Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
e. Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. Please have in mind that this right will not be enforceable to:
The third parties’ data that you have provided to the Controller.
The data that concern you, but have been provided to the Controller by third parties.
f. Right to object: The data subject shall have the right to object to processing of personal data concerning him or her. You shall be able to object to the commercial communications submitting. You can exercise this right by sending us an email to support@poikilingo.com and clearly express the right you want to exercise.
You also have the right to lodge a complaint about the processing of your personal data by us with the relevant data protection supervisory authority. The Danish Data Protection Agency (Datatilsynet) located at Carl Jacobsens Vej 35, 2500, Valby (www.datatilsynet.dk) is for us the relevant authority in matters of data protection. You have the right to make a complaint at any time to the Datatilsynet. We would, however, appreciate the chance to deal with your concerns before you approach the Datatilsynet, so please contact us in the first instance.
International transfer
We may store information about users on servers located in the United States and we may also store such information on servers and equipment in other countries. If you are accessing our Services from outside of the United States, please know the data and personal information you submit may be transferred to and stored on servers in the United States or other countries.
Poikilingo ApS uses a variety of third-party service providers to help us provide our Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). We hold Data Processing Agreements (DPA) in place with all the third-party services, which guarantee that adequate safeguards are put in place with respect to the protection of such Personal Data as required by EU’s GDPR Data Protection policies. We do not sell personal information to third parties.
8. Specific Terms for Users Located in California, USA
California residents have the right to receive, once a year from us: a) information identifying any third-party company(ies) to whom we may have disclosed (within the previous calendar year) your personal information for that company’s direct marketing purposes, and b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request via email to support@poikilingo.com. Only information required to be disclosed by law will be included in our response.
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information and choices discussed throughout this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
9. Changes to Our Privacy Policy
Because we are always looking for new and innovative ways to help your family’s educational needs in connection with the use of our Services, this Privacy Policy may change over time. The effective date at the top indicates the last time this Privacy Policy was modified. If we modify the terms of this Privacy Policy we will post a notification on our Services. Your continued use of our Services after such changes are made shall constitute your acceptance of such changes and will be subject to the then-current Privacy Policy. If you cease to use our Services after such changes, your discontinued use shall not constitute acceptance of such changes and such changes shall not apply to you. Any revised Privacy Policy will supersede all previous privacy policies.
From time to time, we may desire to use personal information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected personal information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law. Also, we will solicit and obtain verifiable parental consent if our privacy practices change in a way that such consent becomes needed.
10. Contact Us
Poikilingo ApS, located in Denmark, is the operator of the Services. Questions regarding this Privacy Policy and issues related to you or a Child User’s information for which you are responsible should be directed to us via any of the following methods:
Via Mailing address, to Poikilingo ApS. Guldringen 27, 4320, Osted, Lejre, Denmark.
Via email, to support@poikilingo.com.