Privacy Policy

1 Introduction

We are committed to protecting your privacy. This document informs you of our policies regarding the collection, use and disclosure of personal data when you, or a minor under your legal guardianship, use our services.

Playvation Ltd complies with the General Data Protection Regulation (“GDPR”) (EU) 2016/679. This privacy policy (“Privacy Policy”) describes what information we collect when you use our services, why we collect it and what we do with it.

Moomin Language School is a digital service (“Service”) developed for early foreign language learning. The Service is owned and provided by Playvation Ltd (“us”, “we” or “our”). Our applications include a mobile application (“Mobile Application”) called Moomin Language School and web applications (“Web Applications”, “Websites”) at web domains moominls.com, playvation.com and foxling.com.

2Definitions

In this Privacy Policy the following words and expressions shall have the meanings respectively set out opposite to them:

“Personal Data” means to information that is being collected and recorded in electronic or physical format that could, with reasonable effort, be used to identify an individual.
“Data Subject” means any natural person whose Personal Data is being collected, held or processed.
“Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Data Processor” means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
“Registered User” refers to a natural person who is accessing our Service or Applications through individual user account.
“Student” refers to any Registered User who is using our Service for the purpose of learning a language.
“Subscription” refers to a contract to acquire license to use the Service.
“Subscriber” refers to the customer (natural or legal person) who has acquired the Subscription.

3Data controller and data processor

The Data Processor under this Privacy Policy is Playvation.

The Data Controller under this Privacy Policy is the Subscriber or Playvation, whatever the case may be. The Data Controller under this Privacy Policy is the Subscriber where you are:

  1. Registered User who is working as an employee or a contractor to an organization (e.g. kindergarten or a school); or
  2. a legal guardian or a minor Registered User who is using the Service through Subscription by purchased by an organization (e.g. kindergarten or a school).

In all other scenarios Data Controller is Playvation.

4 The purpose for processing personal data

We collect, store and process Personal Data for marketing, selling, providing and developing our Services. By accepting this Privacy Policy and by using our Service or accessing our Websites, you agree to the collection and use of Personal Data in accordance with this Privacy Policy.

We will not use or share Personal Data with anyone except as described in this Privacy Policy. We may employ third parties (companies or individuals) to market and sell our Service to perform Service maintenance and distribution related tasks (such as providing technical support), or to assist us in analysing how our Websites and Service are being used. These third parties may have access to your Personal Data, but only to perform aforementiond tasks on our behalf. These third parties are obligated not to disclose or use Personal Data for any other purpose.

5 Content of the register and regular sources of the information

We collect Personal Data in two ways: information that you or the Data Controller provide to us directly, and information that we collect automatically when you or a minor under your legal guardianship use our Service and Applications.

The information that the you, a minor Registered User under your guardianship or the Data Controller provide to us directly could be used by us to identify an individual. This information is being collected and stored when the you or the Data Controller create or update Personal Data on our Applications. This type of personally identifying information includes, but is not limited to name, email address, photo and country of residence. We do not sell Personal Data to anyone. We may disclose your Personal Data to our contractors and sub-contractors for the purpose of developing and/or providing the Service, on condition that they have signed a confidentiality agreement with us, effectively obligating them to treat Personal Data as confidential information. Also, the you can always refuse to provide us with personally identifying information with the caveat that it may prevent you or a minor Registered User under your legal guardianship from using some features of our Service.

The information that we collect automatically refers to information that our Applications and your web browser send us automatically, without your direct and explicit submission. This information is by nature primarily of the non-personally identifying type.

The personally identifying data that your web automatically sends us whenever you access our Websites is the public Internet Protocol (“IP”) address of the device being used for accessing such websites. Non-personally identifying information that your web browser sends us include information such as your browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, cookies and other statistics.

When you or a minor Registered User under your legal guardianship use our Mobile Application, we collect certain non-personally identifying information automatically, including, but not limited to, the type of mobile device used, the mobile device’s unique device ID, the operating system and other statistics. Personally, identifying data that our Applications send us automatically is limited to the device’s public IP address.

Whenever a Student uses our Mobile Application, we also collect Student-specific, learning process related information. This information may include any and all information received by our Mobile Application from input devices through the operating system. These input devices may include but are not limited to touch screen, keyboard, mouse or microphone. The learning process related information will be used for providing and developing the Service, as well as for visualizing Students’ learning progress in its original and processed format.

6 Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from our Websites and stored on your computer’s mass storage.

We use cookies on our Websites to collect Personal Data. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if the cookies are not accepted, the you may not be able to use some parts of our Websites.

7 Personal data and minors

Our Service does not directly address anyone under the age of sixteen (16) without the consent of a legal guardian.

We do not require Personal Data from person under the age of sixteen (16). If you are a legal guardian of a minor and you are aware that Personal Data of minor under your legal guardian has been provided for us without your consent, please contact us at the address below. If we become aware that we have collected Personal Data from person under the age of sixteen (16) without verification of parental consent, we shall take immediate steps to remove such data from our servers.

8Communication

We may use Personal Data to contact you with newsletters and/or content notifications regarding the use and development of our Services. You may opt out of receiving any, or all, of these communications by clicking the unsubscribe link found at the bottom of each message.

9 Regular destinations of personal data and international transfer

All information that you provide for us, including Personal Data, may be transferred to — and maintained on — our database servers located outside of your country, state, province, or other governmental jurisdiction, where the data protection laws may differ from those in your jurisdiction.

We transfer, store and process Personal Data in data centers located in European Economic Area.

10 The principles of how the data transfer and storage is secured

The security of Personal Data is important to us, but please remember that no method of transmission over the Internet, or method of storage is 100% secure.

All Personal Data is encrypted in transit and at rest. All interactions between Our servers and Applications use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. Our Services and servers are developed and maintained by competent professionals.

11 The right to access personal data and theright to correct personal data

You have the right to access the Personal Data stored by us from you or from a minor under your legal guardianship (“Data Subject Request”). The Data Subject Request must be signed, in writing and sent to us at the contact address below. The Data Subject Request may also be presented in person at our registered headquarters. The identity of the individual presenting the Data Subject Request shall be verified. The Personal Data shall be provided to the requester within sixty (30) days from receipt of the Data Subject Request.

You have the right to demand the correction of incorrect or incomplete data by notifying the Data Controller.

12 Deletion of personal data

The Personal Data will be permanently deleted one (1) calendar month after the deletion of the Registered User’s account or after we receive your written request for deletion of your Personal Data.

Some Personal Data may, however, be stored beyond the one (1) month period. Such data comprises of the your billing information. This type of data shall be stored until all accounts are settled.

Non-personal data collected from you, or a minor under your legal guardianship may be stored indefinitely. This data shall, however, will be permanently anonymised in such a way that individual cannot be identified from the data.

13 Provision of personal data and the consequences of not providing personal data

As described in this Privacy Policy, Personal Data is processed in order to provide and develop our Services. If the Personal Data is not provided, we cannot provide our Services in full or ensure their development.

14 The right to notify the supervisory authority

If you notice failures or errors on our behalf with respect to the processing of Personal Data, we request that you contact us immediately.

You have the right to contact the local data protection authority.

15 Third parties’ privacy policies

Our Websites may contain links to other sites that are not operated by us. If you click on a thirdparty link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

All paper copies, if any, containing Personal Data are stored in restricted areas in locked archives. Papers copies are shredded or burned before being disposed.

We have no control over, and assume no responsibility, for the privacy policies or practices of any third-party services or sites.

16 Changes to this privacy policy

We may update our Privacy Policy from time to time without prior notice to or consent from you. We advice you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are published on our Websites.

Additionally, we will update changes to the Change Log section in this Privacy Policy.

17Contact us

If you have any questions about this Privacy Policy, you can contact our data protection officer at privacy@playvation.com.

Written inquiries can be sent to:

Playvation Ltd
Lapinlahdenkatu 16
00180 Helsinki
Finland

18 Change Log

2020-04-12 Updated the purpose for processing the personal data to cover and allow digital marketing. Updated the company’s contact information.
2018-10-23 Added Definitions section and clarified the roles and the responsibilities of data processor and data controller.
2018-06-05 Updated content of the register and regular sources of the information.
2018-05-25 The complied legislation updated.
2018-02-06 Clarified the disclosure terms of personal data to third parties.
2018-01-15 Updated the company’s contact information.
2017-05-19 Added change log to this privacy policy to improve transparency and readability of this document.