Mobile Apps Privacy Policy

Feb 2, 2020

Young Learners' English (hereafter referred to as “YLE”) is dedicated to protecting the privacy of our users and handling any personal date we obtain from our users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.

Young Learners' English (hereafter referred to as “YLE”) may use affiliates’ or reputable third parties’ services for the processing of personal data collected on or through our mobile games (“Games”). By using our Games, you are accepting the practices described in this privacy policy.

1. About this Privacy Policy

1.1. This privacy policy (“Privacy Policy”) explains how information about you is collected, used, and disclosed by Young Learners' English (“YLE”) when you play one of our Games. This Privacy Policy is applicable where YLE acts as a data controller with respect to your data. This is the case where we determine the purposes and means of the data processing in our Games.

1.2. The Privacy Policy applies in addition to our terms of use and other policies. In the case of a contradiction between the Terms of Use and this Privacy Policy, this Privacy Policy will prevail.

2. About us

2.1. LRN is recognised as an awarding organisation by Ofqual. LRN is recognised for its portfolio of international English qualifications for those who want to provide evidence of their English Language skills for their professional or personal development. These qualifications are internationally recognised as providing proof of the skills and abilities required by educational institutes, professional bodies and governments. In producing its qualifications the project team drew upon the experience and expertise of academics, professionals working in the pertinent industries and colleagues with a wealth of practice and knowledge of validation, verification, delivery and assessment.

3. What kind of information do we collect?

When you play our Games, we collect (among others) the following information:

3.1Transaction information of payments made;

3.2 Information you post on the Community of the Game;

4. How do we use your information?

4.1. When you play the Game, we use the information that we have about you:

• To provide you with the Game and associated websites, and continuously improve their features;

• To store your gaming history;

• To provide help desk and support services;

• To analyze the functioning of the Game and associated websites;

• To enable in-app purchases;

• To prevent fraud and crime;

• To meet legal and tax obligations.

4.2. Your email address may be used for the following purposes:

• service emails (regarding updates, new design, new features, surveys, (new) games, etc.);

• administrative purposes, such as notification of a violation of our terms of use;

• delivering messages you have allowed us to forward (e.g. from other users in your social network).

4.4. Your personal data will only be stored for a period necessary for your use of the Game for the purposes as described in this Privacy Policy. We will, for example, periodically delete unused game accounts and we regularly review and anonymize unnecessary data.

5. Which partners have access to your data?

5.1. Ad network providers

YLE don't use any Ad Network Providers.

5.2. Payment Service Providers

YLE may also use third-party payment service providers (“PSP”), offering payment transaction services to YLE in order to sell a product or service through our Games. The PSP acts a data controller with regards to the personal data related to the transactions (“transaction data”) processed for the purpose of purchasing the product or service. The transaction data may include your personal details, your payment card details, and the transaction details. Whenever you buy something in our Games (e.g., a virtual game item), the information that you provide to the PSP is subject to their privacy policies, not ours. The legal basis for this processing is the performance of a contract. You explicitly consent that YLE may provide personal information collected from you to a PSP for the purpose of the offering of the payment-transaction service whenever you buy something in our Games and that such PSP may use such data for (statistical) analysis of payment transactions. After you have purchased a product or service, YLE and the PSP have a legal requirement to retain your information for a legally determined period of at least 7 years. YLE shall be allowed to notify a PSP regarding a user that engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person’s rights, or that led to such a user’s suspension or termination of use of the Games. YLE shall be allowed to notify a PSP regarding a user who engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person’s rights, or that resulted in such user’s suspension or termination of use of a Game.

5.3. Partner networks

YLE may use partner network providers who assist us to distribute the Game in order to enable as many gamers as possible to play the Game.

5.4. Developers

After the Game has been launched, it will be continuously monitored and improved to maintain and effectuate the best gaming experience for our gamers. Developers may therefore see and have access to your information, but they will only use this information for game optimization purposes. The legal basis for the processing of this data is contractual necessity.

5.5. Other

We may supply information to other parties if we are required to do so by law or by a ruling from a court of law.

6. Your rights

6.1. Your personal data may be stored by YLE and its business partners. In case the applicable data protection laws provide so, you have the right to access, rectify, and erase the personal data we hold about you and to restrict or object to our processing of your personal data. To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time.

6.2. If you wish to exercise these rights, you can do so by sending a written request to Young Learners' English, detailing your request, (to prevent misuse of requests for information), or sending an email containing your request to: enquiries@lrnglobal.org.

6.3. You can, at any time, opt-out of marketing communication messages you receive from us by clicking the opt-out link in these messages.

6.4. YLE does not knowingly process personal data from anyone under the age of 16 without parental consent. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data. Parents of users under the age of 16: if you wish to have access to your child’s personal data to view, correct, or delete the information that we have collected about your child, please send a written request to Young Learners' English, , detailing your request along with a copy of your passport (to prevent misuse of requests for information), or send an email with all such information to enquiries@lrnglobal.org. After verification, the copy of your passport will be shredded.

6.5 In the event you have any questions or concerns in relation to the processing of your personal data, you can send an email to our Data Protection Officer by email at enquiries@lrnglobal.org. If you are not satisfied with our responses and/or support to resolve your concerns, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) Member State where you work, normally live, or where any alleged infringement of data protection laws occurred.

7. Security

7.1. YLE has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to the Game.

7.2. Although we allow you to set privacy options that limit access to your personal data, please be aware that no security measures are perfect or impenetrable. We are not responsible for the circumvention of any privacy settings or security measures contained in the Games.

8. Miscellaneous

8.1. We reserve the right to amend our Privacy Policy. Amendments will be effective from the moment of publication, so please check regularly to be sure you are familiar with the latest version.

8.2 In the event of a transfer of (one of our) Games to a third party, we may transfer to such third party all personal information that we collected about you in accordance with this Privacy Policy. In such an event, users who have provided email addresses to us will be notified when information about those users is transferred and becomes subject to a different privacy policy.

8.3 This Privacy Policy shall be governed by the laws of the Netherlands and submitted to the exclusive jurisdiction of the courts in the Netherlands.

If you have any additional questions or requests, you may send an email to enquiries@lrnglobal.org.