INFORMATION WE COLLECT FROM YOU
When you visit our Websites, we collect information about you, such as details abouthow you use and interact with such Websites. We may use the information we collectaboutyouforanumberofpurposes,includingforoperatingandoptimisingtheWebsites, in connection with promoting our books and services, and for research oranalysis.
1. Technical Information
We collect the data necessary for you to use the Websites and for us to maintain andanalyze the functioning of the Websites and to personalize the content of our products.We automatically obtain certain information about your computing device, including:
- IP address; Country code;
- Language; Locale (specific location where a given language is spoken);
- Time zone;
- Network status (WiFi, etc.), browser plug-in types and versions;
- Technical device information (e.g. device model and name, operating system name and version, screen size, mobile phone carrier, Internet service provider);
- Information we collect via the use of pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emails.
- Information we collect via the use of tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates to be able to evaluate how many users have downloaded the app.
Although some of this information (such as IP address) may uniquely identify your device, this information does not identify you personally. Some legislation (such as US and EU) may treat information that uniquely identifies your device as personal information.
2. Website Usage Information
When you use the Websites, we collect additional information from you by using persistent identifiers that permit identification of your device.
The information we collect includes: Website usage, including log information, thatlets us know how you use the Websites and the resources that you access (forexample, information about how and when you use the Websites, or what device youuse to access the Websites); and Characteristics obtained by your use, such as dataabout pages of our Websites that were viewed during your visit, any actions ormovements within the Websites and movements to/from the website from/to anotherwebsite, date and time, page response times, download errors, length of visits tocertain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
3. Classical Personal Information
If you wish to delete your personal information that we received from you, pleasesend an e-mail to email@example.com and your personal information will bedeleted from our database.
HOW WE USE YOUR INFORMATION
We use the information we collect from you for delivering our services and Websitesand to operate our business.We use it also for improving our services and Websites,for enhancing security and for analytics and research purposes to make sure weprovide you with the best experience. In addition, we use your information topromote our services, products, Books and Websites, for providing customer supportand for complying with our legal obligations.
- Delivering our services: developing, delivering and improving our products,services, and content, tailoring our products and services, determining yourage in order to decide whether you can pre-register for any new products orservices, enter into any promotion and to show you age-appropriate content,using your IP address to determine which country you are based to decide theage limit for the pre-registration for games depending on applicable laws,understanding and analyzing trends in connection with usage of the Websites,administering the Websites, and customer communications.
- Promoting our Books and Services: when you use our Websites we may promote our Books and other services, including new products.
- Analytics and research: Understanding and analyzing trends in connection with the usage of Website, auditing, learning about user behavior on the Websites (how often you use the Website, the events that occur on the Website, aggregated usage, performance data etc.). We also use information collected from pixel tags in marketing emails that we send to you (where we have your consent to do so) to measure open, click through and read rates and allow us to improve our emailing campaigns. We also use information collected from tracking links in marketing emails that we send to you (where we have your consent to do so) to measure click through and install rates to be able to evaluate how many users have ordered the book.
- Security: We use your information for enhancing the safety and security of our Websites, products and services.
- Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
- Our legal obligations: We use your information when we are required to do so by law.
Your browser settings may allow you to automatically transmit a “Do Not Track”signal to online services you visit. Note, however, there is no industry consensus asto what site and app operators should do with regard to these signals. Accordingly,we do not monitor or take action with respect to “Do Not Track” signals or othermechanisms. For more information on “Do Not Track,”visit http://www.allaboutdnt.com.
SURVEYS AND CONTESTS
We are conducting surveys and online contests in order to improve our services andyou may freely decide whether you would like to take part in it or not. From time totime we may conduct an e-mail survey or an online contest and collect classicalpersonal information, demographic information, usage information and othermaterials that you voluntarily submit to us for the purposes of internal analysis,marketing and brand development. Participating in a survey or an online contest iscompletely voluntary. We will use the information to make our services moreappealing to users. Collected information gathered via surveys shall be anonymizedand aggregated. We may use your information gathered via contests for thepurposes of performing the contest and to contact you as per such contest’s termsand conditions.
HOW WE SHARE YOUR INFORMATION
We cannot provide all services necessary for the successful operation of the Websitebyourselves.Wemustthereforesharecollectedinformationwiththirdparties,including analytics providers, and other third party service providers that support theWebsite, including Third Party Social Networks (collectively referred to as “Partners”).We may share information that can be used to personally identify your device (e.g. IPaddress)forthepurposesofdeliveringourservices,displayingadvertisements,promoting our books and services and conducting analysis and research.We alsoreservetherighttodiscloseyourinformation(includingpersonallyidentifiableinformation) when we are legally required to do so, to disclose your information in ananonymous and aggregated manner, meaning you could not be personally identifiedfrom it.
We may share such information to:
- Our cloud service providers: We store information we collect from you onservers provided by our third party cloud service providers such as MicrosoftAzure, Amazon and Backblaze;
- Our other service providers: We use third party service providers, such asSendy to send you marketing emails, where we have your consent to do so,and to measure open, click through and read rates and allow us to improveour emailing campaigns.
We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Website. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.
We reserve the right to disclose your information (including personally identifiableinformation) in response to law, legal process, litigation, and/or requests from publicand governmental authorities within or outside your country of residence. We mayalso disclose information about you if we determine that for purposes of nationalsecurity, law enforcement, or other issues of public importance, disclosure isnecessary or appropriate. We may also disclose information about you if wedetermine that disclosure is reasonably necessary to enforce our terms andconditions or to protect our operations, users or user experience. Additionally, in theevent of a reorganization, merger or sale we may transfer any and all information(including personally identifiable information) we collect to the relevant third party.
If you have given us consent for marketing emails, we will use your personalinformation for marketing analysis and to provide you with promotional updatecommunications by email about our products and services. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all ourmarketing and promotional update communications to you, or by sending us anemail to firstname.lastname@example.org.
THIRD PARTY SOCIAL NETWORKS
HOW OUR PARTNERS MAY USE YOUR INFORMATION
THIRD PARTY TERMS AND CONDITIONS
Please note that your access to and ability to use and interact with the Websites maybe subject to certain third party terms and conditions and privacy policies, includingbut not limited to application stores, mobile software platforms, online gamingplatforms, social networking services, statistics services providers and paymentproviders.
Our Websites may contain links to third party websites, products, or services. Pleasenote that while using such third party offerings, you are using sites, products, andservices developed and administered by people or companies not affiliated with orcontrolled by us. We cannot control the actions of those people or companies, thecontentof theirsites,productsor services,theuseofinformationyouprovidetothem, or any products or services they may offer. Our link to such third parties doesnot constitute our sponsorship of, or affiliation with, those people or companies. Noris such linking an endorsement of such third party’s privacy or information securitypoliciesorpracticesortheircompliancewithlaws.Informationcollectedbythirdparties, which may include such things as location information or contact details, isgoverned by their privacy practices. We encourage you to learn about the privacypractices of third parties with which you interact.
We consider ourselves to be family oriented, however we have decided to voluntarilyimplement higher child protection standards even though our products and servicesare not directed to, and we do not knowingly collect personal information fromchildren under 13 or under the age of digital consent according to EEA and UK dataprotection legislation, with the sole exception of persistent identifiers as describedbelow. If we learn that we have collected personal information other than persistentidentifier of a child under the age of 13 or under the age of digital consent accordingto EEA and UK data protection legislation, we will take all reasonable steps to deletethe information as soon as possible. If you become aware that your child hasprovided us with personal information without your consent, please contact usat email@example.com.
Werecognizetheimportanceofsafeguardingchildren’spersonalinformationcollected online. The only personal information we collect on Websites from childrenunder 13 or under the age of digital consent according to EEA and UK data protectionlegislation are persistent identifiers (such as IP address and cookies). Such persistentidentifiers are used and shared with third parties solely for providing support for theinternal operations meaning to deliver and optimize our Websites, place contextualadvertisement (solely through embedded video gallery), to authenticate users of orpersonalizethecontentonourWebsitesandBooks,tomaintainoranalyzethefunctioning of the Websites and Books, personalize the content of the Websites andBooks, to perform network communications to protect the security or integrity of theuser or the Websites and Books, to ensure legal or regulatory compliance.
In an instance that a child submits a personal information to us, we will retain suchinformation only so long as reasonably necessary to fulfill the activity request, or as
required by law. In the event we discover we have collected information from a childinamannerinconsistentwithCOPPA’srequirements,wewilleitherdeletetheinformation or immediately seek the parent’s consent for that collection.
OPT-OUT OF ANALYTICS
You have certain rights in connection with your personal information and how wehandle it, i.e. you have a right to obtain information about whether we hold personalinformation about you, to access personal information we hold about you, to obtainthe correction, update, amendment or deletion of your personal information and toturn to supervisory authority. Some of these rights may be subject to someexceptions or limitations.You can exercise these rights at any time by sending yourrequests regarding your personal information to firstname.lastname@example.org.
Your rights include:
- Right to object. In some cases you have the right to object to the processingof your personal information that is processed on the grounds of legitimate interests (seeLegal Basesbelow). You are always free to opt out from the future collection of your personal information by us and our Partners by stopping with the use of our Websites and services.
- Right of access. You have a right to know what information we hold aboutyou and in some cases to have the information communicated to you. If youwish to exercise this right please contact us by letting us know that you wishto exercise your right of access and what information in particular you wouldlike to receive. We reserve the right to ask for reasonable evidence to verifyyour identity before we provide you with any information. Please note that wemay not be able to provide all the information you ask for. Where we are notable to provide you with information that you have asked for, we will explainto you why. We will try to respond to any request for a right of access as soonas possible, but we will always do so within 1 month of receipt of your requestand verification of your identity.
- Right to correct personal information. We try to keep the information thatwe hold about you accurate and up to date. Should you realize that any of theinformation that we hold about you is incorrect, pleasecontact us email@example.com we will correct it as soon as we can.
- Data deletion. You have a right to request deletion of the personalinformation that we hold about you. Should you wish to do that,pleasecontact us firstname.lastname@example.org. We reserve the right to ask toprovide us additional information to verify your identity before we can startprocessing your request. Once we receive all information we need in order tobe able to identify you, we will delete your personal information yourequested us to delete as soon as possible, but we will always do so within 1month of receipt of your request and verification of your identity. Please notethat we may still retain some or all of that information, for example forcomplying with our legal obligations and protecting or enforcing legal rights.We may also retain your information in an anonymised form.
- Data portability. In some circumstances, you have the right to request thatwe provide you with the personal information which you have provided to us,so you can transfer this information to another data controller. Should youwish to do that, pleasecontact us email@example.com.
- Restriction of processing. In some cases, you may have the right torequest a restriction of the processing of your personal information.
- Right to withdraw consent. Where the processing of your personalinformation by us is based on consent, you have the right to withdraw thatconsent without detriment at any time by contacting firstname.lastname@example.org.
- Right to file a complaint. You have the right to file a complaint against us.To do so, contact the supervisory authority in your country of residence.
We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under Data Protection Laws.
The legal bases that we rely upon are the following:
- Contractual Necessity. This covers information that is processed by us inorder to provide you with service that you have requested – and that we haveagreed – to provide to you, that is to deliver and improve our services, toprovide customer support and to process your information in relation to onlinecontests.
- Legitimate Interests. This covers information that is processed by us for thepurposes that can be reasonably expected within the context of your use ofour services to pursue our legitimate interests in order to ensure you have thebest experience when use our Websites and services, to make sure yourinformation is secure and to provide to you our services free of charge or at alow cost. We pay special attention to your data protection rights making surethat your data protection rights are not overridden by our legitimate interests.We rely on our legitimate interests for data processing for analytics andresearch, for our own promotion purposes and contextual advertisingpurposes in embedded video gallery.
- Consent. Where we ask for your consent to use your data for a particularpurpose, such as to send you marketing emails with promotional updatecommunications, we will make this clear at the point of collection and we willalso make clear how you can withdraw your consent. We will ask for youconsent before conducting any surveys.
- Legal Obligation. This covers information that is processed by us to complywith a legal obligation.
We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across boarder and from your country to other countries around the world. Please note, that not all of these countries have the same data protection laws as your own country, but wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.
We will transfer your personal information outside EEA only when the transfer is based on one of the following safeguards:
- To a country with adequate data protection. We will transfer your personal information outside EEA to a country that ensures an adequate level of protection in accordance with EEA data protection legislation.
- Based on standard contractual clauses. We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via
- Based on an approved certification mechanism. We will transfer yourpersonal information to our Partner outside EEA, if our Partner is certified byan approved certification mechanism pursuant to EEA data protectionlegislation. For instance, to our partner that is certified to comply with theprinciples for data protection under the US-EU Privacy Shield Framework(“Privacy Shield”) (you can view the entities certified under Privacy Shield atwww.privacyshield.gov).
We store your information for as long as needed to provide you with our services. Wemay store information longer, but only in a way that it cannot be tracked back toyou. We delete the information as soon as we do not need them for providing ourservices.
last updated October 10, 2019.