Privacy Policy | SpellQuiz Learning System

SpellQuiz Privacy Policy

Your privacy is important to us. This privacy policy (the “Privacy Policy”) explains in detail how we collect, share, use and protect personal and non-personal data obtained from individual users (“you” and “your”) through the website https://spellquiz.com (the “Website”) or the services provided through the Website (the “Services”)

General information

Data controller. The entity that is responsible for the processing of your personal data is JNEX APPS INC. having a registered place of business at 205 – 279 Midpark Way S.E, Calgary, AB, T2X 1M2, Canada (“we”, “us”, and “our”). We act as a data controller with regard to your personal data.

About the Website. The Website is an educational platform that provides English spelling tests, quizzes, and practices.

Applicability of the Privacy Policy. This Privacy Policy applies to the personal data which we collect through our Website only. It does not apply to any personal data collected by any third party, such as third-party websites to which our Website links or to any information collected by us offline.

Applicable laws. We process personal data in accordance with the applicable data protection laws, including, but not limited to, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the EU General Data Protection Regulation (GDPR), and the U.S. Children’s Online Privacy Protection Act (COPPA).

Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

Your consent to the Privacy Policy. Your use of the Website is subject to this Privacy Policy. We also encourage you to review the Privacy Policy before submitting any personal data through the Website. In some cases (where required by the applicable law), we may seek to obtain your consent for the processing of your personal data. For example, we may seek your prior consent for the following purposes:

• If we are required by law to do so;
• If we intend to collect other types of personal data that are not mentioned in this Privacy Policy;
• If we intend to use your personal data for the purposes that are not indicated in this Privacy Policy;
• If we would like to disclose or transfer your personal data to third parties that are not indicated in this Privacy Policy; or
• If we significantly amend this Privacy Policy.

Other relevant documents. This Privacy Policy should be read in conjunction with our Terms of Use which can be found at https://spellquiz.com/page/term-of-use#term-of-use.

What personal data do we collect?

Types of collected personal data. We comply with data minimization principles and we collect only a minimal amount of personal data that is necessary for ensuring your proper use of the Website and our Services:

• When you create your user account as a parent (for a free trial), we collect your (i) first name, (ii) last name, (iii) email address, (iv) username, (v) password, and (vi) the country in which you are located.
• When you create your user account as a parent (for paid subscription), we collect your (i) first name, (ii) last name, (iii) email address, (iv) username, (v) password, (vi) the country in which you are located, and (vii) payment details (i.e., credit card or PayPal information).
• When you update your user account, we collect your address.
• When you subscribe to the Services as a teacher and request a free or paid license, we collect your (i) full name, (ii) email address, (iii) phone number, (iv) username, (vi) school contact details, and (vii) any information that you decide to provide us in your comment.
• When you add children to your user account, we collect those children’s (i) full name and (ii) username.
• When you update your user account, we collect your address (optional).
• When you submit a comment on the Website, we collect your (i) name, (ii) email address, (iii) website, and (iv) any information that you decide to provide us in your comment.
• When you contact us through the contact form available on the Website, we collect your (i) name, (ii) email address, and (iii) any information you decide to provide us in your message.
• When you contact us by email, we collect your (i) name, (ii) email address, and (iii) any information you decide to provide us in your message.
• While you are using the Website, we collect your IP address.
• MAC addresses and other device identifiers;

Additional data. We may receive certain additional personal and non-personal data if you upload any content on the Website, participate in a quiz, test, activity, contest, or event, request support, interact with our social media accounts or otherwise communicate with us. Please note that the provision of personal data is optional and you may choose what personal data you would like to share with us. The processing of non-personal data collected through quizzes, tests, and your other activities on SpellQuiz is subject to the section “Non-personal data” of this Privacy Policy.

Sensitive Data. We DO NOT collect, under any circumstances, any special categories of personal data (“sensitive data”) from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation.

Failure to provide personal data. If you fail to provide us with the personal data when requested, we may not be able to perform the requested operation and you may not be able to use the full functionality of the Website, receive the Services, or get our response.

Handling of Student Personally Identifiable Information (PII)

We are committed to protecting the privacy and security of our

students. The Personally Identifiable Information (PII) collected from students

includes, but is not limited to, names, email addresses, and academic records.

This information is collected for the purpose of providing educational services

and fulfilling our administrative duties. SpellQuiz never processes personal

data for commercial purposes, such as sending advertising or making offers for

third parties. SpellQuiz also does not become 'owner' of the personal data we

collect: Student Data is owned and controlled by the School.

What do we use your personal data for?

We respect strictest data protection principles. Thus, we use your personal data only for specified and legitimate purposes explicitly mentioned in this Privacy Policy. In short, we use your personal data solely to enable you to use the Website, provide our Services, maintain the Website, conduct research about our business activities, administrative purposes, and to reply to your enquiries. The detailed description of the purposes and legal bases for processing of your personal data is provided in the table below.

Non-personal data

Types of non-personal data. In addition to the personal data described above, we may collect certain information about your use of the Website and our Services. Such non-personal data does not allow us to identify you in any manner and, therefore, it is not treated as personal data. We capture the following types of non-personal data:

• The operating system and browser you use; if you use a mobile device - the type of device you use, and information about the website you came from;
• The data on your use of our Services, including the parts of our Website you access, the time you spend on each part of our Website, and any searches you make; and
• The patterns, choices, and results of the tests and quizzes completed by you or other activities you undertake on the Website.

Your feedback. If you contact us, we may keep records of any questions, complaints or compliments made by you and the response, if any. Where possible, we will de-identify your personal data. Please note that de-identified personal data is also considered to be non-personal data.

Purposes of non-personal data. We will use non-personal data in furtherance of our legitimate interests in operating the Website, providing the Services, conducting our business activities, and developing new products. More specifically, we collect the non-personal data for the following purposes:

• To analyze what kind of users visit and use the Website;
• To identify the channels through which the Website is accessed and used;
• To examine the relevance, popularity, and engagement rate of the content available on the Website;
• To investigate and help prevent security issues and abuse;
• To develop and provide search, learning, and productivity tools and additional features to the Website;
• To create reports outlining your progress;
• To make suggestions as to what further exercises and practice you might require; and
• To provide you with access to knowledge based upon your education details.

Aggregated data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.

Retention of non-personal data. We may retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping non-personal data after you have deactivated your account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Marketing communication

Marketing communication. From time to time, we may send you messages, such as newsletters, brochures, promotions and advertisements, informing you about our new services. Please note that you will receive such marketing messages or be contacted by us for marketing purposes only if:

• We receive your express (“opt-in”) consent to receive marketing messages; or
• We decide to send you marketing messages about our new services that are closely related to the Services already used by you.

Opting-out. You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you or contacting us directly.

Informational notices. From time to time (if we have your email address), we may send you informational notices, such as service-related, technical or administrative emails, information about the Website and your user account, your privacy and security, and other important matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent.

SpellQuiz does not have any means to send any email or any direct communication to the students. Only teachers and parents can receive emails from SpellQuiz.

Our community

When you engage with our community and post any information, you share such information or media with a public audience. This means it may be available to anyone on or off our Services and may be seen or accessed through online search engines and APIs. It is entirely possible that other users may download or share your content with others on and outside of our Services. Please exercise your due diligence when making any personal data public.

How do we hold your personal data?

Place of storage. Your personal data may be held by us in paper records, on computer systems including email, servers, hard drives and applications, on third party cloud based services or other data storage systems.

Retention of personal data. We will store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy, you request us to delete your personal data, or until you deactivate your account by contacting us - whichever comes first. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it (e.g., we are not obliged by law to store your personal data), we will immediately delete your personal data from our systems.

Retention as required by law. Please note that, in some cases, we may be obliged by law to store your personal data for a certain period of time (e.g., for administration or accountancy purposes). In such cases, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

How do we protect your data?

Our security measures. Although no method of storage is 100% secure, we attempt to use various reasonable organizational and technical security measures, such as SSL, secured networks, encryption, SSH, Json Web Token, limited access to your personal data by our staff, and anonymization of personal data (when possible) to maintain the safety of your data and to protect it against any unauthorized access, loss or misuse.

Handling security breaches. Given the nature of communications and information processing technology and the Internet, we cannot guarantee that your personal data will be secure at all times. We cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a personal data breach occurs, we will inform our local data protection authority without undue delay and immediately take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breaches will be limited to the highest extent permitted by the applicable law.

Third parties. Please also be aware that we may use third-party service providers that provide hosting, data storage and other services (our data processors). These service providers have informed us that they apply security measures they consider adequate for the protection of information within their systems. We will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including your personal data, by third parties.

Information on children

We do not permit children under the age of 16 to create a user account and do not knowingly collect personal data from children under the age of 16 without the consent of a parent. In some cases, parents may submit personal data of their child to their user account (e.g., child’s name). However, the submission of such data is entirely optional and the parents may decide whether or not they would like to submit such information. We do not ask children under age 16 for any information other than the answers to educational questions required for participation in an activity on the Website.

Cookies

Do we use cookies? Yes.

What are cookies? Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your web browser (if you allow it). Cookies enable websites or service providers systems to recognize your browser and capture and remember certain information. Session cookies are temporary cookies that remain in the cookie file of your browser until you leave a website and are only used during your current session on the website. These cookies are generally used to monitor site traffic and are not linked to any personal data. Persistent cookies remain on your hard drive for a longer period.

What cookies do we use? The table below provides an overview of the cookies used by us, including their purposes and expiration time.

Why do we use cookies? We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may use persistent cookies so that we remember your computer when it is used to return to the Website to help customize your experience and we may associate your personal data with such cookies. We may contract with third-party service providers to assist us in better understanding the visitors of the Website. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

Cookie consent. When you visit the Website for the first time, we may ask you to provide us with your consent to our use of cookies.

How to control cookies? You can control your preferences in relation to cookies, including preventing them being stored on your computer, through your Internet browser. Please consult your browser’s provider in order to obtain instructions on this. You can also visit https://www.aboutcookies.org for further information. Please be aware that some parts of the Website may not function properly without cookies.

Google Analytics. We use Google Analytics, the service provided by Google, Inc. (“Google”) to analyze your use of the Website. Google Analytics generates statistical and other information by means of cookies and we use its services to create reports about your use of the Website. Google Analytics cookies are anonymous first-party cookies. Such cookies include cookies entitled “__gat”, “__gid”, and “__ga”. Please note that the use of Google Analytics cookies is anonymous and does not allow us to identify you in any manner. The information generated by cookies about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Please note that your IP address will be anonymized and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245.

Opting-out from Google Analytics. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org.

Do we disclose personal data to third parties?

Disclosure of personal data. In some circumstances, we disclose your personal data to the service providers with whom we cooperate (data processors). For example, we may share your personal and non-personal data with trusted third-party contractors who assist us in operating our Website, providing the Services, and conducting our business. We do not sell, trade, or otherwise transfer your personal data to third parties. The disclosure of your personal data is limited to the situations when such data is required for the following purposes:

• Ensuring the operation of the Website;
• Ensuring the delivery of the Services requested by you;
• Providing you with the requested information;
• Pursuing our legitimate business interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Carrying out our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior consent to such a disclosure.

List of data processors. We will share your personal data only with the third parties that agree to ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The third parties (data processors) that may have access to your personal data include, but are not limited, to:

• Our hosting and cloud storage provider Amazon Web Services;
• Our business analytics service providers Google Analytics and Facebook Pixel; and
• Our technical support provider Golden Team.

Disclosure of non-personal data. We may disclose or use non-personal data and de-identified data for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the Website, responding to lawful requests from public authorities or developing new products and services.

Legal requests. If necessary, we will to disclose information about the users of the Website to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

Successors. In case our business is sold partly or fully, we will provide your personal data to a purchaser or successor entity and require the successor to handle your personal data in line with this Privacy Policy.

Third-party links. Please be aware that there may be links on our Website that link to third-party websites or services. Any information provided on these websites is not subject to this Privacy Policy.

Transfer of personal data outside the EEA

We and some of the third parties listed in above are located outside the European Economic Area (EEA) and, if you reside in the EEA, we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data (e.g., the country in which the recipient is located is white-listed by the European Commission) or we conclude an agreement with the respective third party that ensures such protection (e.g., a data processing agreement based on the Standard Contractual Clauses provided by the European Commission).

Your rights

Access to personal data. If, at any time, you wish to know what personal data we hold about you, please do not hesitate to contact us. We will generally be happy to provide you with the information we hold about you except where it would have an unreasonable impact on the privacy of another individual, the request is frivolous or vexatious, the information relates to legal proceedings, or we are prevented by law from disclosing the personal data, or providing access would prejudice certain investigations.

Corrections to personal data. We take reasonable steps to ensure that your personal data is accurate, complete and up-to-date. We are happy to accept requests to update your personal data, if you demonstrate that the personal data we hold about you is incorrect, incomplete, out-of date, irrelevant or misleading.

Other rights that you have. You also have other rights in relation to your personal data. Subject to any exemptions provided by law, you may ask us to:

• Get a list of purposes for which your personal data is processed;
• Move your personal data to another processor;
• Delete your personal data from our systems;
• Object and restrict processing of your personal data;
• Withdraw your consent; or
• Process your complaint regarding your personal data.

How to exercise your rights? If you would like to exercise your rights listed above, please contact us by email at support@spellquiz.com and explain in detail your request. In order verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to identify you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks. Your requests can be submitted free of charge once per calendar year. If you submit your requests more than once per year, we reserve the right to charge a small administrative fee for providing the requested information.

How to launch a complaint? If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

Changes to our Privacy Policy

This Privacy Policy is subject to amendment from time to time. Amendments will become effective on the date indicated at the top of the emended Privacy Policy. If we have your email address, we will send you a notice about all the changes implemented by us. We encourage you to review our Privacy Policy regularly to stay informed. For significant material changes in the Privacy Policy or where required by the applicable law, we may seek your consent for amendments. Your continued use of our Website constitutes your acceptance of any amendment. If you disagree with the changes to the Privacy Policy, you should cease using the Website.

Contact us

Please feel free to contact us if you have any questions about the Privacy Policy, our privacy and security practices, or would like to exercise your rights listed in the Privacy Policy. You may contact us by using the following contact details:

Phone: 1 587 288 9216

Email: support@spellquiz.com

Postal address: JNEX APPS INC., 205 – 279 Midpark Way S.E, Calgary, AB, T2X 1M2, Canada