1. WHAT THIS POLICY COVERS
If you are accessing the Service from within the European Union (EU) or are an EU citizen, please review the Lawful Bases for Processing Personal Information and Individual Rights sections below for more information on your how your Personal Information will be processed and the rights you have regarding this processing.
2. INFORMATION WE COLLECT AUTOMATICALLY
When you download or use our App or Subscription Service, we may automatically collect certain information about your use of and your computer’s (or other access device, such as a smartphone) interaction with the App or Subscription Service (“Device Information”). Even if you do not subscribe to the Da Vinci Kids Subscription Service from Da Vinci, we may collect Device Information when you use our App and Subscription Service.
A. What Information is Collected?
We may automatically track and collect the following categories of information when you visit our Apps or use our Subscription Service: (1) IP address; (2) Device ID; (3) The type of Internet browser or mobile device used; (4) The operating system of your computer or mobile device; and (5) other similar technical information. Device Information we collect automatically will not be linked with any personal information that you provide to us.
B. How are Cookies Used?
Cookies are small computer files that are transferred to your hard disc and which contain information such as your user name and the activities that you performed while using the App and Subscription Services. We utilize cookies to personalize your experience with the App and the Subscription Services, as well as to store your login information so that you do not need to re-enter it each time you visit the App or access the Subscription Services.
3. INFORMATION YOU PROVIDE TO US
In order for you to use our App or Subscription Services, we may require that you provide your email address information that directly identifies you (“Personal Information”).
We shall use the Personal Information you provide to respond to your questions and to send you messages about the App, as well as for service maintenance and updates.
A. Using the App and Subscription Services
In addition to the Personal Information noted above for registration and sign up purposes, you may provide Personal Information to us while using the App and Subscription Services. If you choose to submit a support inquiry, you may have the option of providing Personal Information such as your phone number or payment information.
4. HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to send you information about the App or the Subscription Services, and to contact you when necessary, including an email to verify your subscription.
We may use your Device Information to personalize and adapt your experience with the App and the Subscription Services, and in our communications with you in order to exhibit content that we believe you may be interested in and which may be consistent with your preferences.
5. HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell, trade, or rent your personal information to others, and will not do so except as required by law or in connection with a merger, asset sale or similar business transaction. We may share aggregated demographic or non-personal information not linked to any personal information regarding visitors and users with our business partners, company affiliates and advertisers. We use third-party service providers (as set out below) to help us operate our business and the Da Vinci Kids App or administer activities on our behalf. We do not use analytics software to collect and send device data to third parties.
We may share your information with our affiliate companies in order to provide you with the Da Vinci Kids App and to help better tailor our services to you.
We may also engage third parties to perform services in connection with the operation of the Da Vinci Kids App, some of whom may process personal information. Each of these third parties is contractually obliged to protect the security of any information we share with them, and limited in their use of the information to the services being provided solely to Da Vinci:
- Apple: Your iOS identifier is shared with Apple in connection with performance of network communications.
- Google Android: Your Android input method editor is shared with Google Android in connection with performance of network communications.
- Amazon (AWS): Your User ID is shared with AWS in connection with User ID searches.
- Internet service provider (ISPs): Your IP address is shared with ISPs to ensure legal or regulatory compliance.
For more information on the processing of your data, please contact us at email@example.com.
6. LAWFUL BASES FOR PROCESSING PERSONAL INFORMATION
If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:
- It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the App, and increasing the security of the App and network infrastructure;
- You have consented to this collection and processing for a specific purpose;
- It is necessary to fulfil our contractual obligations; or
- It is necessary to comply with a legal obligation.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contacts for Individual Rights Requests section. Some examples of our legitimate interests and the information being processed include:
- Network and information security (password, IP address, Device ID)
- Customer Support and fraud prevention (name, email address)
- Improving our products and services (hardware information, activity logs)
Where we rely on our legitimate interests to process your Personal Information, you have the right to object. More information on exercising this right can be found in the Individual Rights section below.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us a firstname.lastname@example.org.
7. INDIVIDUAL RIGHTS
We make certain choices available to you when it comes to your Personal Information and any Device Information that can identify you (“Personal Data”). Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated on our progress.
Review and update your data: You have the right to ask us to update any Personal Data that we have collected. If you want to change your account’s email address, we will take appropriate measures to adapt your account information and ensure your access to the App using the new email address and delete your former email address from our database. For any Personal Data beyond this, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before modifying any Personal Data.
Delete your data: You also have the right to have your Personal Data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all Personal Data about you, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before deleting any Personal Data.
After you delete your Personal Data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.
Restrict Processing: You have the right to restrict how we process your Personal Data in certain circumstances. This is often an alternative to requesting the complete deletion of your data. Rather than requesting we delete all of your Personal Data, you may request that we limit our uses of your Personal Data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your Personal Data and we are working to verify this information, or if you want us to retain your Personal Data in connection to a legal claim but cease processing it.
Data Portability: You have the right to obtain copies of your data in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any Personal Data.
Right to Object: You have the right to object to the processing of your Personal Data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your Personal Data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.
If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.
8. CONTACT FOR INDIVIDUAL RIGHTS REQUESTS
Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.
Physical Mail: Da Vinci Media GmbH, Mehringdamm 55, 10961 Berlin – Germany
If you are an EU citizen or reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.
9. LINKS TO OTHER APPLICATIONS
The Personal Information that we collect about you is stored on a secure, password-protected server. Only authorized personnel have access to your Personal Information. We use cryptography technology that is standard in the industry when receiving and transferring Personal Information. However, despite our best efforts, no transmission over the Internet or cellular phone network, nor any other method of data storage, can be guaranteed to be safe 100% of the time.
11. DATA RETENTION
We may retain your data for the following purposes:
- To develop new features and improve the App and Subscription Services;
- To support subsequent customer service inquiries;
- To improve the safety and security of the App and Subscription Services; or
- Comply with our legal obligations.
We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the App and Subscription Services, which may include maintaining this information beyond when you cease using the App and Subscription Services.
12. OPTIONS FOR ENDING COMMUNICATION
If you no longer wish to receive communications from Da Vinci, you may change your preferences by following the instructions included in each email or message, or by contacting us at email@example.com.
13. DATA TRANSFER AND STORAGE
The App is stored on servers in the United Kingdom (UK). Thus, if you are outside of the EU, the Personal Information that you provide to Da Vinci shall be transferred to the UK. Upon providing your Personal Information, you are agreeing both to the transfer of your Personal Information to the UK and to the storage of your Personal Information in the UK, as well as to the use of your Personal Information in accordance with the ends for which it was originally collected.
14. CHANGES TO THIS PRIVACY CONTRACT
15. CONTACT US
If you have any questions, please contact us by:
Da Vinci Media GmbH