Privacy Policy www.Jumblepad.com

 

Through this page, Jumblepad will let you know what information we collect, why we collect data and your rights. According to the General Data Protection Regulation (AVG, dated 2016/679), we as a company are responsible for processing personal data when we need that data for our work to serve you. The information that we can link directly or indirectly to one of our customers/suppliers or other contacts is defined as personal data or simply data. 

 

1. WHAT PERSONAL DATA WE PROCESS

We process the following personal data when you use our services:

- name (first name and last name)

- email address

- passwords to access our services

- group, class or organisation

- subjects)

- photos/pdf-documents/audio files that you have chosen to upload

- IP address

- answers/texts related to modules

- credentials

- payment method (s) for trainer accounts

 

We automatically collect the following personal data when you use our service:

- information about your use of our services

- content that you share, upload, or create using our service

technical data, including the URL from which you visit our website, IP address, unique device ID, network and computing capacity information, browser type, language, and information about identification and operating system.

 

If you do not wish to provide us with the aforementioned personal data, we cannot provide you with the requested service. We must transfer your personal data processing to deliver our services to you and maintain our contractual relationship.

 

2. WHY WE PROCESS YOUR DATA

We process your data for the following purposes:

- Managing your account and making the service accessible and personalised to you.

- To improve your user experience and to further fulfil our obligations to you as a user.

- Sending notifications and messages by email or by other means.

- Notifying about updates to the service, privacy policy or other contractual agreements.

- Improve and develop our services and analyse your use of our service.

- Maintain the security of the technical functions of our services and prevent misuse.

- Fulfillment of contractual agreements, including the protection of our rights, property and safety.

- Comply with requirements in applicable mandatory law.

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4. LEGAL GROUNDS

We process personal data based on the following legal grounds:

- For the agreement's implementation - We process your data to provide the services as set out in the agreement concluded between us or make the necessary arrangements to respond to user requests. 

-Legitimate interest - When processing your data is based on our justification of administering, maintaining, and improving our website and services to you and answering your questions orally, digitally, or in writing. You have the right to object to the processing of Personal Data based on legitimate interest. If we receive your objection, we will inform you why we consider ourselves legitimately interested weighted against yours as an individual.

 

5. DISCLOSURE OF PERSONAL DATA

Jumblepad is built on a technical platform provided by a start-up company with data storage in America and Europe.

 

We do not share, sell or otherwise disclose your personal information to third parties, other than in the following situations:

- Service providers employed by us to perform tasks on our behalf to provide service are not entitled to use your data for reasons other than those necessary to perform the tasks requested by us.

 

You can obtain more information about disclosures by contacting us at info@jumblepad.com.

 

We work with specific companies that may receive your abovementioned personal data from us:

- Google, via Google we keep track of our visitor numbers, statistics and demographic analyses

- Firebase / Heroku are our data and data storage servers with European host servers

- Google Suite to answer your emails and schedule appointments.

Of these parties, Google, Firebase, Heroku and Google Suite are located outside the EU.

 

6. LEGAL REQUESTS AND PREVENTION OF DAMAGES

A legitimate request from a government agency may require us to make personal data public. When it is necessary to comply with a law or court order, we reserve the right to access, read, store and disclose personal data; to enforce our terms of use and other agreements to fit; or to the rights, property or safety of Jumblepad, employees, users of the service or others.

 

7. COOKIES, BEACONS AND OTHER TECHNOLOGY

We collect information using technology such as cookies, beacons and local storage (for example, in your web browser or your device). For information on how we use this type of technology, please refer to our cookie policy.

 

8. RETAINING DATA

We keep your data for two years (730 days) if you are a registered user (trainer) from the last login date. Then we delete your account and personal data. Personal data can still be stored in backup up files for 30 days after deletion, after which we delete them permanently and do not re-create them.

 

If you are a student and use Jumblepad on behalf of your trainer/school, Jumblepad manages your data. If the trainer assigned to you does not delete any data beforehand, we send your data to a temporary archive in our database, where your data remains archived for one year. The data is not visible in the archive and these are not used. The data will be deleted after one year in the archive. Personal data can still be stored in backup files for 30 days after the deletion, after which they are permanently erased.

 

9. CHILDREN

Currently, our services are not for persons under the age of twelve (12-years is the age where children transfer from primary school to secondary education grade). If you are a parent or guardian of a person younger than twelve (12) years of age and know that the child provides us with personal data without your consent, please contact info@jumblepad.com to exercise your rights of access, rectification, deletion and restriction of processing and objection to exercise.

 

10. YOUR RIGHTS

You retain all rights related to your data that Jumblepad processes. You have the absolute right to object to the processing of your data for direct marketing. The withdrawal of your consent will not affect the lawfulness of the processing based on the consent before the withdrawal. We can continue to process personal data based on other legal grounds, except for direct marketing.

 

You have the right to view information about the processing of your data or request that we correct, supplement, delete, or process your data limit. You have the right to receive a copy of the personal data that we process about you. For any additional copies you request, we can charge a fee based on an administration fee of € 25. If the processing is based on the legal grounds for consent or performance of the contract, you have the right to data portability. This means that you can receive the personal data you have provided to us in a structured, commonly used and machine-readable format.

 

If we process your data on behalf of your school organisation, please consult your school or organisation for advice on your rights to personal data.​

 

11. CONTACT INFORMATION

To enforce your rights, as described in Section 10, or if you have any questions about our processing of personal data, you can contact us by sending an email to info@jumblepad.com. Please provide your full name to ensure that your request is handled promptly and the email address associated with your account. Also, keep in mind that you must sign the request for information to receive your data when you send a request by letter.

 

If you would like to make a complaint or raise concerns about our data processing, please contact us at info@jumblepad.com.

 

12. CHANGE OF CONTROL

If there is a change of control in our business, we may transfer your data

to the new owners to continue to provide the services.

 

13. CHANGES TO THIS PRIVACY POLICY

Jumblepad reserves the right to make changes to this in its sole discretion privacy policy. In the event of a change, we will inform you via our website or email if there are any extensive changes. If we require your consent for the changes, we will appropriately ask you to obtain your consent.