Last updated: 10 March 2023
The data controller for your personal data is ALPA Kids OÜ, registry code 14547512, address: Laki tn 19, Tallinn 12915, Estonia (“ALPA Kids” or “we” or “us”).
1. The data we collect and how we use it?
1.1 ALPA Kids Platform usage information
We continue to develop and improve the ALPA Kids Platform, the digital learning games offered and strive to make them more user-friendly and enjoyable. In order to do this, we need to know which information and digital learning games are of the greatest interest to users of the ALPA Kids Platform, how often users visit and browse the ALPA Kids Platform, which web browsers and/or devices are used, etc.
When you visit the ALPA Kids Platform or use the digital learning games, certain data may be collected without your knowledge using various technologies such as cookies, web tags and web beacons, and navigation data (log files, server logs, clickstream data, website scripts). Some of this information is sent automatically by your web browser or mobile device – for example, the URL of the website you are browsing or have previously visited, the IP address of your computer or mobile device and the version of the web browser you are currently using – as well as the time you arrived at the ALPA Kids Platform and the websites you specifically visit on the ALPA Kids Platform.
The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the services to you (or the company you represent) on the ALPA Kids Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the ALPA Kids Platform and the services we provide.
1.2 Information related to the learning path service
In order to access and use the ALPA Kids Platform’s personalised learning path service, we may ask you to provide the nickname, age, gender and native language of the selected service user for the purpose of creating a personalised avatar for the service user (in particular if the user is a child).
The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the personalised learning path service to you (or the company you represent) on the ALPA Kids Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the ALPA Kids Platform and the personalised learning path service we provide.
1.3 Transaction data
When you place an order on and/or through the ALPA Kids Platform (for example, using the Google Play Store or App Store) for the purchase and use of a paid digital learning game, a personal learning path service, or any other service or product offered on the ALPA Kids e-shop, we may collect information about your payments and transactions and other information related to the transaction, such as the first name and surname and the date of birth of the person placing the order, the name of the organisation being represented (if the order is placed on behalf of a legal entity), telephone number, e-mail address and other contact details, payment method, bank account number and holder, bank name, delivery address and other relevant information relating to the order.
The legal basis for the collection of transaction data is the performance of a contract between us and you as an individual, or our legitimate interest where the contract is between us and a company you represent.
We also process the personal data we collect to comply with our obligations under applicable accounting and tax laws. In this case, the processing of personal data is based on the legal provisions that require us to process personal data.
1.4 Queries and answers
If you send us a query via the ALPA Kids Platform, we will process your contact details and the content of the query in order to respond to it.
The legal basis for the collection of this information is our legitimate interest in responding to your queries about us and the services we provide.
1.5 Data relating to legal requirements
Where necessary, we may process personal data in order to pursue our legitimate interest in bringing, prosecuting or defending legal claims arising out of any contract between us and you (or the company you represent).
1.6 Direct marketing
If you consent to receive push notifications and/or e-mails from the ALPA Kids Platform mobile apps by entering your e-mail address, we may use the push notifications from the mobile apps and/or your e-mail address to send you news, offers and other marketing communications.
The legal basis for sending you direct marketing content is your consent or our legitimate interest in promoting the ALPA Kids Platform and providing you with information about ALPA Kids and the services offered on the ALPA Kids Platform. You have the right to withdraw your consent to receiving direct marketing materials at any time by contacting us by e-mail at firstname.lastname@example.org and/or by opting out of receiving push notifications on the ALPA Kids Platform mobile app. You may also opt-out of the use of your e-mail for direct marketing by clicking the opt-out link in the message you have received from us.
What are cookies?
Cookies are small text files that the ALPA Kids Platform may store on your device during your visit. Cookies can be used to remember your choices and preferences to make it easier for you to use the ALPA Kids Platform, so that you do not have to re-enter them on each visit or each website.
What kind of cookies do we use?
Cookies help us:
- provide you with a better user experience when visiting the ALPA Kids Platform;
- enable you to set personal preferences;
- collect statistics on the use of the ALPA Kids Platform; and
- measure the effectiveness of advertising.
We use the following types of cookies on the ALPA Kids Platform:
Functionality cookies are necessary to enable you to navigate the ALPA Kids Platform and use its features.
Statistical cookies collect anonymous statistics about how users use the ALPA Kids Platform mobile applications. Statistical cookies may, for example, help us to understand how users browse and use the ALPA Kids Platform mobile applications and which parts of it are most used. Statistical cookies are stored on your device and used only with your consent.
How long will cookies stay on my device?
Cookies fall into two categories, depending on how long they stay on your device.
Session cookies are only created for the duration of the session and are kept on your device until you close the browser or mobile app. Session cookies are not stored on your device’s hard drive.
Persistent cookies are stored on your hard drive until you delete them or they expire. We can retain data from persistent cookies for a maximum of 2 years.
How do I manage cookies?
2. Transmission and publication of personal data
We will do everything in our power to keep your personal data safe, and we demand strict security and confidentiality from our employees and partners.
We may disclose your personal information:
– to your trusted service providers who provide services to us or to you as processors under our instructions. We will always control and be responsible for the use of your personal data;
– to public authorities, where required to do so by law or where a lawful request for information is made to us by a public authority; and
– in relation to our merger, acquisition or sale of our business or a part thereof.
– Google Analytics, which provides us with analytics services to track users’ navigation and usage data on the ALPA Kids Platform mobile applications;
– AWS SageMaker, which provides us with an analytics service to analyse the personalised learner service user’s usage data on a specific digital learning game selected in the ALPA Kids Platform mobile app for learning analytics purposes;
– Facebook SDK, which provides us with a service to analyse users’ mobile app downloads from the ALPA Kids Platform;
– Google Play Store, App Store and Payment Centre AS, which provide us with payment services to enable you to make payments on and/or through the ALPA Kids Platform to subscribe to and purchase digital learning games, any services and products available in our e-shop.
We may further disclose your personal information:
– to ALPA Kids employees responsible for customer care and supporting customer relationships, as well as to employees in accounting, IT maintenance, business analysis and planning functions;
– to suppliers of the IT systems and cloud service providers we use to manage our customer interactions, and to our auditors;
– to banks;
– to our processors and other persons involved in the performance of the contract;
– to parties helping us to exercise our rights under the contract (debt recovery service providers, legal advisers, courts, credit reference agencies, etc.);
– to parties involved in any merger, acquisition or sale of all or part of our assets.
We do not transfer your personal data outside the European Union or the European Economic Area.
3. How long do we retain your personal data?
Certain personal data may be retained after the end of the customer relationship if required or permitted by applicable law. For example, we will keep basic accounting documents (such as copies of contracts and invoices) for 7 years from the end of the relevant financial year, as required by applicable law. We will retain your personal data relating to the contract for 10 years from the date of termination of the contract, subject to a maximum limitation period in case of intentional breach.
When the retention of your personal data is no longer required by law or necessary for the exercise of the rights or obligations of either party, we will permanently delete your personal data, unless you have instructed us otherwise and we have entered into an agreement for longer-term data retention.
5. Your rights
You have the right to access the personal data we process by requesting access to it. To the extent permitted by law, you have the right of access to, and the right to rectify, update, amend or erase your data.
Where the processing of personal data is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing of personal data that was carried out on the basis of consent prior to the withdrawal.
Subject to the conditions set out in the legislation on the protection of personal data, in certain cases you have the right to request the restriction of the processing of your personal data and also to object to the processing of certain personal data.
Subject to the conditions set out in the data protection legislation, you have the right to data portability, i.e. the right to receive your personal data in an organised form in a commonly used machine-readable format and to transfer it to another controller at your own discretion.
For requests to exercise any of the above rights, please contact us at email@example.com.
If you feel that we are not processing your personal data properly, you have the right to lodge a complaint with your national data protection authority. In Estonia, this is the Data Protection Inspectorate. Contact details for the Data Protection Inspectorate can be found here: https://www.aki.ee/en.
We use appropriate organisational, technical and organisational security measures (including physical, electronic and administrative) to protect personal data against loss, destruction, misuse and unauthorised access or disclosure. For example, we only give access to your personal data to authorised employees and contractors who need them to perform their duties.
Please note that while we strive to take reasonable measures to protect the security of your personal data, no system can completely eliminate all possible security risks.
7. ALPA Kids contacts