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.
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).
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:
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.
What do we use your personal data for?
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:
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:
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.
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:
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.
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 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.
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.
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:
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.
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).
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:
How to exercise your rights? If you would like to exercise your rights listed above, please contact us by email at firstname.lastname@example.org 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.
Phone: 1 587 288 9216
Postal address: JNEX APPS INC., 205 – 279 Midpark Way S.E, Calgary, AB, T2X 1M2, Canada