This U.S. App Privacy Policy (this “Privacy Policy”) describes how Edurino GmbH ("Edurino," "we," “us” or "our") handles personal data that we collect as a controller through our Edurino mobile app (the “App”) in connection with our beta launch of the App in the United States. This Privacy Policy is not intended to cover our data processing activities in other jurisdictions (e.g., Germany, Austria, Switzerland) or via other means. If your child is using our App in Germany, Austria or Switzerland or if you would like to view the privacy policy for our website at edurino.com, please see our DACH privacy policy at edurino.com/policies/privacy-policy.
We've made data protection a priority for our App! We only process limited information that is necessary to run the App so that your child has a wonderful learning time. As far as we request information or names for our users, it is voluntary information. The App adapts the learning objectives and content to the age of your child. Although the age information is also voluntary, it would still be important to ensure optimal game operation.
Index
- Personal data we collect
- How we use your personal data
- How we share your personal data
- Your choices
- Retention
- Other sites and services Security
- International data transfer Children
- Changes to this Privacy Policy
- How to contact us
Personal data we collect
Information you provide to us to create the parent account.
Personal data you may provide to us to create the parent account includes:
- Email address.
- Account password.
Information you or your child provide to us via the App.
Personal data you or your child may provide to us through the App includes:
- User name, such as your child’s first name or a fantasy name.
- Age of your child in years and months.
Other information you may provide to us.
Other personal data you may provide to us in connection with the App includes:
- Marketing information, such as your preferences for receiving communications (such as our newsletters) about our App, other products and services, activities, events, and publications, and details about how you engage with our communications.
Automatic data logging.
When your child uses the App, we and our service providers may automatically log limited information about your child’s device and your child’s interaction with the App, such as:
- Device data, such as your child’s device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
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Online activity data, such as games played, information about your child’s activity in a game, and access times and duration of access for a game.
How we use your personal data
We may use your personal data for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal data to:
- Provide the App and its games to you and your child;
- Personalize the App experience with the user’s name and otherwise personalize the App to the user;
- Adapt and present the leaning methods and media content in the App based on the user’s age;
- Communicate with you, such as by responding to messages that you send to us;
- Understand the user’s needs and interests; and
- Provide support for the App, and respond to your requests, questions and feedback.
Compliance and protection. We may use your personal data to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- Enforce the terms and conditions that govern the App; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Marketing. We and our service providers may collect and use your personal data for marketing purposes. We may send you direct marketing communications (such as newsletters) and may personalize these communications based on your needs and preferences. You may opt-out of our marketing communications as described in the Opt-out of Marketing section below.
Research and development. We may use your personal data for research and development purposes, including to analyze and improve the App and our business.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de- identified data from your personal data and other individuals whose personal data we collect. We make personal data into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de- identified data and share it with third parties for our lawful business purposes, including to analyze and improve the App.
How we share your personal data
We may share your personal data with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the App or our business (such as hosting, information technology, customer support, and email delivery providers). The following service providers may collect or maintain personal information from your child through the App: Playfab, Amplitude, Backtrace.io, Google Could BigQuery, Google Cloud Run
For information regarding any of these service providers’ privacy policies and use of children’s information, please contact us at support_us@edurino.com.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Edurino (including, in connection with a bankruptcy or similar proceedings).
Your choices
Declining to provide information. We need to collect personal data to provide certain services in connection with the App. Otherwise, the provision of your personal data is voluntary to use the App. For example, you may wish to provide a fantasy name instead of your child’s real first name.
Opt-out of marketing. You may opt-out of marketing-related emails, such as our newsletters, by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at the email address below. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Delete your data or close your account. You can close your account via the account deletion option available in the App. If you wish to request deletion of certain of your data, please contact us at the email address below.
Retention
We generally retain personal data to fulfill the purposes for which we collected that data, including for the purposes of satisfying any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal data, we may consider factors such as the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and applicable legal requirements.
When we no longer require the personal data we have collected about you or your child, we may either delete it or anonymize or deidentify it.
Security
We employ technical and organizational safeguards designed to protect the personal data we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal data.
International data transfer
We are located in Germany and may use service providers that operate in other countries. Your personal data may be transferred to Germany, the United Kingdom, the United States or other locations where privacy laws may be different from those in your state, province, or country.
Children
A user of the App who is under the age of 13 (“Child User”) may only use the App with the prior consent of their parent or legal guardian (“Parent”). If we learn that we have collected personal data from a Child User without the consent of the Parent, we will delete the personal data in accordance with applicable law. If you are a Parent of a Child User and would like to withdraw your consent or request that we delete the personal data of the Child User, please contact us at the email address below.
How does a Child User access the App?
A Parent downloads the App and creates their own account. The Parent can then create a user profile for their Child User by inputting a name (either the Child User’s first name or a fantasy name) and the age of the Child User. A Child User can then access the App through their profile.
What information about a Child User is visible to others?
No Child User’s information is made available or visible generally to the public through the App. A Parent may view their Child User’s information through their connected account. Users other than the Parent cannot view a Child User’s information.
Accessing a Child User’s Personal Data
A Parent may review, access, and change their Child User’s personal data by logging into their connected account or contacting us via email. A Child User cannot change the personal data on their profile such as name or age provided by their Parent.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the App after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to contact us
Email: support_us@edurino.com
