PERSONAL DATA THAT WE COLLECT
Information that you provide
Through the registration process, you will provide us with your name, e-mail address together with other contact information such as user name and password. You will also provide us with your payment transaction information if you choose to pay for 365 Days Luxembourgish services.
When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service or sending us messages (“Activity Data”). We also collect technical data about how you interact with our Services; for more information, see Cookies.
Product Research and Development
We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the video, audio or text transcriptions of this feedback together with any additional contact information that you provide us with and will retain this data for two years.
After you have logged in (with user name and password), we collect your, we collect your device type, your device ID, and your IP address.
3. LOG FILES
Each time a page is called up on 365 Days Luxembourgish, access data are saved in a protocol file, the server log. The data recorded in this way contains the following data:
your IP address (by means of which your computer can be unambiguously identified)
the remote host (name and IP address of the computer requesting the page)
the time, the status, the quantity of data transferred and the Internet page from which you accessed the requested page (referrer). 4. INFORMATION OBTAINED BY THIRD PARTIES
To support and enhance the service we offer you through the 365 Days Luxembourgish application, we work with a variety of third-party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook (collectively, “Third Party Advertising Service Providers”). These Third-Party Advertising Service Providers collect and use non-personally identifiable information, such as your mobile device ID, about your visits to and use of the mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.
We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.
You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioural Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.
In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioural advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.
5. USE OF INFORMATION OBTAINED BY 365 Days Luxembourgish
365 Days Luxembourgish may occasionally send you service related and product change announcements through the general operation of the application. We will send you reminder notifications to support the 365 Days Luxembourgish teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our application and to keep our service safe and secure.
For the purpose of optimizing our services, 365 Days Luxembourgish may use or share anonymous data collected through the application, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e-mails by default to keep your data secure and provide our service. You may opt out of any non-essential service e-mails at any time.
We may also use your contact information to send you notifications regarding new services, offers and promotions offered by, if you affirmatively consent to receive such communications.
6. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
365 Days Luxembourgish shares your personal data only when it is necessary to offer the service, legally required, or permitted by you.
We will provide personal data to hosting providers such as Auth0 and Digital Ocean, search engine providers such as Google and analytics providers such as Crashlytics.
These data processors help us bring you our services. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to 365 Days Luxembourgish.
We will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the application or using the 365 Days Luxembourgish name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.
If the ownership of all or substantially all of the 365 Days Luxembourgish application or individual business units, or assets owned by 365 Days Luxembourgish that are related to the services offered, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.
365 Days Luxembourgish will share aggregate or anonymous data collected through the application, including Activity Data, for purposes such as understanding or improving the services.
7. RETENTION of personal data
Every user has the right to obtain information from Group Moraru sarl on the personal data that has been saved in relation to him/her. If the request for information is not conveyed to Group Moraru sarl in writing, hence particularly in the case of enquiries by telephone or email, the user must provide a postal address to which the information can then be sent. In the request for information, the user must additionally provide the following details for identification purposes: user name, first name and surname, maiden name (if appropriate), email address, postal address and date of birth. The information is sent by post to the address provided by the user.
365 Days Luxembourgish will retain your data until your account is deleted, after which point we will retain anonymous data collected through the application, including Activity Data, which may be used by 365 Days Luxembourgish and shared with third parties in any manner.
Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
As a matter of principle, 365 Days Luxembourgish is directed towards users who have reached the age of majority. Any use by minors without the consent of their legal guardians is prohibited. Group Moraru sarl therefore reserves the right to delete all data relating to underage users if no consent from the legal guardians is available.
10. SECURITY of personal data
Group Moraru sarl employs safety precautions to guarantee that your data are protected against loss, modification or misuse. To this end, the 365 Days Luxembourg application works with constantly updated firewalls meeting the industry standard as well as other security systems. At the same time, the user should be aware of the fact that one hundred per cent protection against attacks cannot be guaranteed because of the continual appearance of new viruses and other means of attacking the protected data systems of Internet services. Group Moraru sarl will instigate civil and criminal proceedings against any attack by hackers and the like and will inform the users of any cases in which their data have been compromised.
Group Moraru sarl cares about its users’ privacy and trust.
Group Moraru sarl is located in Luxembourg, 6 rue Marguerite de Brabant L-1254 Luxembourg – Merl.
FURTHER THIRD-PARTY external suppliers
For the purpose of optimizing our services, carrying out advertising activities or for analysing our website for errors and in terms of its performance, we use external service providers in addition to those mentioned under point 6. Such service providers may vary. For the sake of clarity, we have listed below these service providers in tabular format and in each case, we have supplied further information on the processing of data and on any opt-outs.
Facebook registration (Auth0, https://auth0.com/privacy)
Google AdMob (Marketing, campaign measurements, https://support.google.com/admob/answer/6128543?hl=en&ref_topic=2745287, https://policies.google.com/privacy?hl=en)
Last revision made on the 25th of October 2018