Privacy Policy

Date of last revision: October 26, 2017

The Platform (as defined below) is made available by Kidimedia BVBA, a Belgian limited liability company with registered seat at Leuvensesteenweg 142, 3070 Kortenberg and registered with the Crossroads Bank for Enterprises under company number 0831.289.505 (hereinafter "Kidimedia" or "we").

Please read this privacy policy (the "Privacy Policy") carefully as it provides you important information on the following:

  • What personal information is collected from you and for which purposes;
  • The measures implemented by us to safeguard the access to and the security of Your Personal Data (as defined below);
  • Your rights to access, rectify and erase your Personal Data and object to the processing of Your Personal Data.

In order to use our Platform, you must first acknowledge and agree to our Privacy Policy. If you do not agree with any of the provisions of this Privacy Policy, please do not use our Platform. If you do not understand any of the provisions of this Privacy Policy, please contact us before using the Platform (support@kidimedia.com).

1. Introduction

Kidimedia recognizes and understands the importance of your privacy and wants to respect your desire to store and access personal information in a private and secure environment. This Privacy Policy applies to our Platform and describes how we manage, store and utilize Your Personal Data. If you are a minor, we encourage you to inform you parents that you want to make use of the Platform and to invite them to read this Privacy Policy before you use the Platform.

Kidimedia is committed to protecting the privacy of Your Personal Data and providing a secure, user-controlled environment for the use of the Platform in accordance with Regulation.

tMAIL is a mobile learning platform created as part of the tMAIL project (http://www.tmailproject.eu) for teacher continuing professional development. It consists of a mobile app and a web server. (the "Platform")It captures data for the purpose of:

  • Assisting the learning process.
  • Researching the effectiveness of mobile learning for teacher continuing professional development and publishing research findings.
  • Publishing automatically generated statistics about tMAIL use.
  • Operating and improving the Platform (specified in section 2)

To assist in the learning process, a user of the app (a "Teacher") may invite a person (a "Teacher Educator"), to use the Platform to view all information related to the Teacher's app use (this includes usage statistics, answers to questions and exercises inside of the app, information related to progress towards the app's learning goals)

For any Personal Data related to you that is processed by us on behalf of your Teacher Educator via our Platform and for which your Teacher Educator determines the purposes and means, your Teacher Educator is responsible for any compliance with the Regulation of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "Regulation") in its capacity as Data Controller.

To research the effectiveness of mobile learning for teacher continuing professional development, a researcher who is part with the tMAIL project (a "Researcher") may use the Platform to view anonymized information related to Teacher app use (this includes usage statistics, answers to questions and exercises inside of the app, information related to progress towards the app's learning goals, feedback on the course material). Researchers won't have access to user names or email addresses. Only anonymized or statistical data will be used for publishing the project results.

For any Personal Data related to you that is processed by us on behalf of the Researcher via our Platform and for which the Researcher determines the purposes and means, the Researcher is responsible for any compliance with the Regulation of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "Regulation") in its capacity as Data Controller.

Kidimedia also processes certain Personal Data relating to you for which we determine the purpose and the means of the processing of such Personal Data. However, this is limited to the Personal Data specified in Section 2 of this Privacy Policy ("Your Personal Data"). Please note that the provisions of this Privacy Policy shall only apply to the processing of Your Personal Data by Kidimedia.

2. Your Personal Data: which Personal Data is processed by Kidimedia on the Platform in its capacity of Data Controller?

We may collect several types of Personal Data from you and store it on our servers located in the European Economic Area such as:

  • Your internet protocol (IP) address;
  • Your e-mailaddress and your name, if you register an account on the Platform (whether as teacher, as teacher educator or as researcher) (an "Account");
  • Information in helpdesk support inquiries;
  • Web behavior information via log files, such as information related to how you use the Platform (i.e. type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and number of clicks) collected through cookies and other automated technology (cfr. Section 4).

Please note that we urge you not to include any Personal Data that would allow to identify you in any manner (including but not limited to your full name, personal image) in your training exercises. If you would choose to include any such Personal Data in your training exercises, please note that this will be on your own risk.

3. For which purposes do we process Your Personal Data?

We will process Your Personal Data for the following purposes:

  • The technical operation, commercialization and exploitation of our Platform including but not limited to collecting user statistics relating to the Platform, crash reporting, analysis of performance quality ;
  • Providing you access to the functionalities of the Platform;
  • Providing you with an optimal, secure and personal user experience of the Platform;
  • Diagnosing technical problems and managing technical support and processing inquiries concerning the Platform;
  • To send you an e-mail with information relating to the functionalities or use of the Platform;
  • Analysis of trends, administer the Website, track user movements on the Platform and gather certain demographic information such as (but not limited to) your country or regio, your operating system and browser version;
  • Administrative acts with regard to your use of the Platform.

Furthermore, you agree that we are free to access, retain and disclose Your Personal Data in the following events:

  • in order to be in compliance with any applicable legislation or regulations;
  • if a law enforcement authority or other government official requests so;
  • to enforce our terms of use or Privacy Policy;
  • the investigation of any suspected or actual fraudulent or illegal activity;
  • to protect your safety and/or rights.

4. Cookies

Cookies are small pieces of data that a website asks your browser to store on your computer or other device. This enables a site or service provider’s systems to recognize your browser and capture and remember certain information. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.

We use the following cookies:

  • Necessary cookies: These cookies are essential to visit and use our website, or to use certain parts or functionalities of it. For instance, these cookies allow you to log in securely, and to switch between different pages of the site without having to login again on every page. They are required to make sure your personal information on the Platform is only accessible by you.
  • Functional cookies: Functional cookies are cookies that make using our Website more user-friendly or personalized. For instance, these cookies remember your preferences, or keep track of whether you’ve already taken a survey, so we don’t keep asking you the same questions over and over.
  • Improvement cookies: We use these cookies to gather information about how our Website is being used, with the goal to improve its functionalities. For instance, there are cookies that track which blog posts are most popular, or how many unique visitors access a particular tutorial.

Most internet browsers are initially set up to automatically accept cookies. Please note that you can change the settings to block cookies or to alert you when cookies are being sent to your computer or device. There are a number of ways to manage cookies. Please consult your browser instructions or help screen to learn more about how to adjust or modify your browser settings.

If you disable the cookies that we use, this may impact your experience of our Platform, for example you may not be able to visit certain areas of the Platform.

5. Security

We take appropriate technical and organizational measures against any unauthorized or unlawful processing of your Personal Data or its accidential loss, destruction or any unauthorized access thereto. These measures are proportional to the nature of Your Personal Data and the potential risks.

6. Do we disclose any information to third parties?

Other than as expressly set out in this Privacy Policy, we do not sell, transfer, or otherwise disclose Your Personal Data or optional anonymous usage statistics to any Third Parties without your prior consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law.

We may also share Your Personal Data with trusted Third Parties who help us to provide, understand, commercialize and improve our Platform in accordance with the purposes set forth in Section 2. We do not authorize these Third Party service providers to use or disclose Your Personal Data except as strictly necessary to perform any services under our supervision in accordance with this Privacy Policy or to comply with any applicable legislation. Such Third Party service providers will act as Data Processors to process Your Personal Data on behalf of us for the purposes set forth herein. We engage to only use Data Processor who can provide sufficient guarantees to implement appropriate technical and organisational measures in such a manner that any processing of Your Personal Data will meet the requirements of the Regulation. We seek to provide such Third Party service providers with solely those elements of Your Personal Data that is necessary to provide their specific service.

Such Third Party service providers could include (but are not limited to):

Product Company Privacy policy
Google Analytics Google Inc. https://www.google.com/analytics/terms/
Bugsnag Bugsnag Inc. https://docs.bugsnag.com/legal/terms-of-service/

In the event of a full or partial merger with, or acquisition of all or part of Kidimedia, we may transfer Your Personal Data to a Third Party. In such event, we shall impose this Third Party to use Your Personal Data strictly consistent with this Privacy Policy. In any event, such Third Party service providers shall be obliged to treat Your Personal Data in accordance with this Privacy Policy. However, we cannot be held liable for any damages, whether direct or indirect, that may result fro the misuse of Your Personal Data by such Third Party service providers.

7. Your rights

Right of access

If you are concerned or have any questions about Your Personal Data, you have the right to request access to the Personal Data which we hold or process about you.

We will then provide you with all information relating to Your Personal Data that are being processed and on the source of such data. We shall also provide you with a copy of Your Personal Data undergoing processing. For any further copies requested by you, we shall charge you a fee of 10 EUR for administrative costs.

Right to rectification and erasure

You have the right to obtain the rectification of any inaccurate Personal Data relating to you or to have any incompleted Personal Data completed free of charge. Furthermore, you shall also have the right to obtain the erasure of Your Personal Data without undue delay if one of the following grounds apply:

  • Your Personal Data have been unlawfully processed;
  • Your Personal Data are no longer necessary in relation to the purpose for which they were collected or otherwise processed; or
  • you have withdrawn your consent on which the processing of Your Personal Data is based.

Please note that if you are a subscriber to our mailing list, you can make changes at any time to certain Personal Data by clicking the hyperlink included in your sign-up confirmation email.

Right to object to data processing

You may withdraw at any time your consent to the processing of Your Personal Data by Kidimedia free of charge and without reasoning (including but not limited to the processing of Your Personal Data for direct marketing purposes).

Right to data portability

You have the right to receive a copy of Your Personal Data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data Controller. Where technically feasible, you have the right to have Your Personal Data transmitted directly to another Data Controller.

To exercise any of the abovementioned rights, please contact us at support@bookwidgets.com and provide us with any proof of your identity. We will process any requests as soon as possible and at the latest within one month of the receipt of your request.

8. Data retention and deletion

We do not process Your Personal Data any longer than is necessary for the purposes set forth in this Privacy Policy. However, we do store Your Personal Data as long as your Account is active or when the processing of Your Personal Data is necessary to allow you to make use of any of the functionalities of the Platform. Upon removal of your Account, we will delete Your Personal Data as soon as possible.

9. Third Party applications or websites

You acknowledge and agree that certain content or services provided by Third Parties may be made available to you via the Platform. You agree that such linked content or services may have their own privacy policies for which we cannot be held responsible. We do not in any way review or endorse the privacy practices of such Third Parties.

10. Updates or changes to our Privacy Policy

Occassionally, we may change our update this Privacy Policy to allow us, for instance, to use or share Your previously collected Personal Data for other purposes. If we would use Your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on our Website indicating that the Privacy Policy has been changed or updated and request you to agree with the updated or changed Privacy Policy.

11. Definitions

For the purpose of this Privacy Policy, the following definitions shall apply:

  • Data Controller shall mean the physical or legal person, which, alone or jointly with others, determines the purposes and means of the processing of Personal Data;
  • Data Processor shall mean the physical or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller;
  • Personal Data shall mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • Platform shall mean the mobile learning SaaS platform named "tMAIL" composed out of the tMAIL mobile learning app and the tMAIL web server which is used to monitor the use of the tMAIL app;
  • Researcher shall mean any person involved the tMAIL project who examins the data for the purpose of reaching the project goal;
  • Teacher shall mean any person who uses the tMAIL app;
  • Teacher Educator shall mean the person a Teacher explicitly invited through the mobile learning app to assist you in his learning;
  • Third Parties shall mean any physical or legal person or entity other than Kidimedia;
  • Website shall mean the website available on https://tmail-project-eu.appspot.com.