The General Data Protection Regulation (GDPR), which applies from 25 May 2018, creates consistent data protection rules across Europe. It applies to companies that are based in the EU and global companies that process personal data about individuals in the EU.
The GDPR relies on many of the principles and is built on former EU data protection rules but with a wider scope, more prescriptive standards and substantial fines.
Studytracks is gathering data but principally to improve the experience of the users. Our business model is focused on subscription rather than on large data collection and analysis.
Please read this policy carefully before registering to the Application. We have also produced a brochure and a short track to provide you with the key elements regarding our Data Policy in a more accessible way.
You can download them here
Brochure Data Policy
Studytracks (we, us, our) is committed to protecting and respecting your privacy.
Minimum age requirement of our users
In light with GDPR, Studytracks requires everyone to be at least 13 years old before they can create an account (in some jurisdictions, this age limit may be higher). Creating an account with false info is a violation of our terms. This includes accounts registered on the behalf of someone under 13.
However, someone under 13 Years old can still register with the parental approval. At the registration step, a verification code will be sent to the provided email of the parents or the guardians. If they agree to the registration, the user will need to fill in this code to effectively create his account.
1. Scope of Policy
Studytracks mobile application and Progressive Web Applicaiton software (App) available via a web browser or for download on the iTunes and Google Play app-stores, once you have downloaded a copy of the App onto your mobile handset, tablet, and/or other relevant device.
This policy sets out the basis of which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. Information We May Collect from You
We may collect and process the following data about you:
a. Information you give us.
You may give us information about you by filling in forms on the App and our website, or by corresponding with us (for example, by e-mail or chat). This includes information you provide when you download and register to use the App, subscribe to any of our services, share data via the App's social media functions, enter a competition, promotion or survey, and when you report a problem with the App, our services, or our website. The information you give us may include your name, address, e-mail address and phone number, username, password and other registration information, personal description and photograph.
In order to register, you will need to provide :
- Email or Facebook ID
- Password (encrypted)
- Exam level you want to study
You will also be able to fill in the following information on the App, but it’s not mandatory at all, only if you want us to better communicate with you :
- Date of Birth
- Picture of your choice or Avatar
For users registered via a school, only the relevant school staff will be able to decide which information is given about the student. In order get the best out of Studytracks, they will often provide Studytracks with the Lastname and Firstname of pupils and school email address. This enables them to correctly identify the student and analyse their results and progress via the school dashboard. However, the data will be deleted at any time should the school want to.
b. Information we collect about you and your device.
Each time you use our App we may automatically collect the following information:
Technical information: the type of mobile device you use and the version of the mobile operating system. For instance iPhone 7 with IOS 11
Information depending on your use of the App :
- Tracks listened and how many times
- Tests completed
- Score at the tests
- Sharing of the App on social media
- List of points obtained with your activity on the App
- Free Version or Premium user
- Date and Hours of the last access
c. Information we receive from other sources.
We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
In particular, the advertisement on the Free version is managed by a company called Kiip http://www.kiip.me/. They show via the SDK advertisement on the App following a completion of event under a form of a reward. Basically, if you complete a track, you may have a reward appearing. If you want to collect the reward, Studytracks draw your attention to the fact that this company will need to collect data from you in particular, your email address in order to reward you. They display, on our app, their own terms and conditions. You may want to consider if their policy is appropriate for you or chose to not participate to the reward scheme and not give them with your email address. However, Kiip does not have access to your personal data, they only know that a user has completed a track. We do not transfer any data to Kiip. This is strictly and opt in service between the user and Kiip.
For avoidance of doubts, there are no advertisement served to users.
5. Uses Made of the Information
We use information held about you in the following ways:
Information you give to us.
- We will use this information to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- with your express agreement, to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; users will receive the communication as well as their parents or guardians should they were under the minimum age.
- to notify you about changes to the App and our service; and
- to ensure that content on the App is presented in the most effective manner for you and for your device.
For avoidance of doubts, we do any promotional communication to users registered via their school.
Information we collect about you.
- We will use this information to administer the App and for internal operations, including troubleshooting;
- to analyse how you are using the App, to assess your progress and to display your ranking compared to the other users
- to enable teachers who subscribed their class to assess the activity and the progress of their pupils
- to improve the App to ensure that content is presented in the most effective manner for you and for your device;
- to allow you to participate in interactive features of the App;
- as part of our efforts to keep the App safe and secure; and
- With your express agreement, to make suggestions and recommendations to you and other users of the App about goods or services that may interest you or them.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you.
We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
6. Disclosure of Information
We may share your information with selected third parties including:
Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
Analytics providers that assist us in the improvement and optimisation of the App.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Studytracks or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
7. Storage of Your Personal Data
The data that we collect from you is stored in the US and European Economic Area (EEA). It may however be accessed or processed by some of our staff operating outside the EEA. These staff may be engaged in the fulfilment of your requests and the provision of support services.
By submitting your personal data, you agree to this storing and processing.
All information you provide to us is stored on our secure servers.
Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.
Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards. You are responsible for keeping a password that you have chosen confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Should a data leakage occur, Studytracks will endeavour to make you aware as a matter of urgency and not later than 72h after the event.
Certain services available via the App include social networking to share the App in particular. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
8. Your Rights
GDPR introduced a series of rights. You can exercise your right by contacting us at firstname.lastname@example.org.
- Right of access: you have the right to access your personal data and supplementary information. The right of access allows individuals to be aware of and verify the lawfulness of the processing.
- Right to rectification: The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete. You can make a request for rectification verbally or in writing.
- Right to erasure: The GDPR introduces a right for individuals to have personal data erased. The right to erasure is also known as ‘the right to be forgotten’. You can make a request for erasure verbally or in writing. You can also delete your account and all the data on the App in the Profile/Settings section
- Right to data portability: The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. You can obtain your data and move, copy or transfer them.
- Right to object: Individuals have the right to object to: direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
You have the right to ask us not to process your personal data for marketing purposes. At the registration, we will ask you if you want to receive promotional information from us. You will also have the possibility to opt out from marketing emails at any time.
The App and our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or Studytracks service are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
10. Contacting Studytracks
Last updated: September 2019