Pop2Talk Privacy Policy

We collect and process information in our services in three ways:

1. Personal speech data in the game application

2. Personal data on school administration website

3. Personal data on www.pop2talk.com website

 

1 Personal speech data in the Pop2Talk® game application

 

 What personal data do you collect?

We record segments of the player’s speech when the microphone light is on in the word card display. We save the recorded audio and information on what words the player hears and how well the player performs pronouncing words.

 

We save the device and microphone model used in the recording. Additionally, we save game events such as user interface actions and level completion times.

 

For private users, speech and other data are linked to their email addresses. For school users, they are linked to their user account names.

What do you use the data for?

The player’s speech is processed computationally to give a pronunciation score. Collected speech is also used to improve the speech analysis engine. Speech samples will not be published or presented publicly. Statistics on hearing and speaking are used to optimise learning for the player in question as well as for future players. Speech samples and statistics may be used to provide a dashboard view of learning to the player. 

Device information is used to improve the speech processing. Recorded game events are used to improve the game for future players, for example by adjusting the difficulty of levels.

Email address is used to communicate with the user about their account and to provide news and questionnaires relating to the application the player is testing. We will send newsletters only to players who have subscribed to them.

 

What about marketing? Does your game include marketing and purchases?

No. The Pop2Talk® game does not contain advertising or in-app purchases. We do not use data collected from the game application for targeted advertising on any platform

 

How long and where do you store the data?

For private users, all we store speech and data associated with speech and learning for up to 5 years after your last login, or until you request its deletion. The game events are stored for up to 2 years. The storage policy is the same for school users unless requested otherwise by the school and/or minor's guardian. We store data in secure cloud storage within the European Economic Area (EEA). We do our best to secure your data but absolute security is not possible on anything connected to the internet.

 

Will you publish or sell the data?

No, we will not publish or sell your data without your permission. The data will only move together with our company, as might happen if our company is sold and merged into another company.

 

Is there any other data that you collect?

The application store you use may collect data on installations and removals.

The speech processing server stores the public Internet Protocol (IP) addresses of the players. These are used only to prevent misuse of the service and are erased periodically

 

Is there an age limit?

No, but when the players are underaged, we require their guardians’ consent for processing and storing the data. A guardian can also request deletion of their child’s data anytime

Your rights to the data:

Storage and use of personal data are governed by the General Data Protection Regulation GDPR. Speech and other personal data is owned and controlled by Hokema oy. The players (or their guardians) have the right to access, update, and restrict the processing of their data and the right to have their data erased anytime (“right to be forgotten”). For any questions and requests about data processing, storage, access and erasure in the game application and dashboard, please contact mydata@hokema.fi.

This policy applies to teachers' or guardians' speech recordings as well.

This service is not available in the United States until we have a legal clearance of our compliance with the Children’s Online Privacy Protection Act (COPPA). 

 

2 Personal data on school administration website

We collect limited personal information from guardians and school personnel:
Names of schools and email addresses of teachers, guardians’ email addresses and nicknames of players. This data is stored for up to 5 years.

What personal data is collected:

The Pop2Talk® schools website collects limited personal information (email address, school name, role) from teachers and school administrators. The schools website collects nicknames of players and email addresses of guardians. We encourage avoiding the use of full names of children in our services. The website uses cookies to identify user sessions but does not track user actions

 

What personal data is used for:

The personal data is used to control which users have the rights to create new teacher and student accounts for which school, and to control access to the student’s’ gaming and speech statistics.

How and for how long is the personal data stored:

We will store the collected data for 5 years after a player’s last activity or until the user requests its removal. If the data is used in a school for monitoring learning, there can be a delay in removal due to school policies. The collected data is stored in secure cloud storage within the European Economic Area (EEA). We do our best to secure your data but absolute security is not possible on anything connected to the internet.

Transfer of personal data:
Hokema does not have the right to sell copies of personal data to third parties. The data may be transferred in the future in the event of a sale of part or all of our business and in case of merger, acquisition, financing or bankruptcy.   

What non-personal data is collected:

The school administration server logs the public Internet Protocol (IP) address of the user for each connection. This data is used only to prevent misuse of the service and is erased periodically

Your rights to the data:

Storage and use of personal data are governed by the General Data Protection Regulation GDPR. Data is owned and controlled by Hokema. Teachers and students (or their guardians) have the right to access their personal data and the right to have their data erased anytime (“right to be forgotten”). For questions and requests about data processing, storage, access and erasure in the on the schools administration website, please contact mydata@hokema.fi.

 

3 Personal data on the www.pop2talk.com website

We collect names and email addresses from users who have signed up to try the Pop2Talk® game. Also, we collect school names from teachers who have signed up. This data is stored at our website service provider and governed by GDPR and it is used for purposes listed below. 

The pop2talk.com website uses cookies and tracks user actions within legal boundaries with tools provided by the WIX website platform and by Google Analytics. This data is stored at Google and our website service provider WIX.

We will not sell this data. The data will only move together with our company, as might happen if our company is sold and merged into another company. 

What personal data is collected:

We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history.

What personal data is used for:

We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); comments, feedback, product reviews, recommendations, and personal profile.


When you conduct a transaction on our website like subscribe to a newsletter or tell us about your interest in testing, as part of the process, we collect the personal information you give us such as your name, your country, name of your school and email address. Your personal information will be used for the specific reasons stated above only
 

We collect such Non-personal and Personal Information for the following purposes:

  • To provide and operate the Services;

  • To provide our Users with ongoing customer assistance and technical support;

  • To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;

  • To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our partners may use to provide and improve our respective services; 

  • To comply with any applicable laws and regulations

We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes, we may contact you via email, telephone, text messages, and postal mail.

 

Some of the data processing is done with services provided by Wix and Google Analytics.

 

How and for how long is the personal data stored:

Our project is hosted on the Wix.com platform. Wix.com provides us with an online platform that allows us to sell our products and services to you. Your personal information may be maintained, processed and stored by Wix and their authorized affiliates and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and other jurisdictions as necessary for the proper delivery of Wix Services and/or as may be required by law (as further explained below).

Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications.  Third-Party Services may receive or otherwise have access to personal information, in its entirety or part – depending on each of their particular roles and purposes in facilitating and enhancing Wix Services and business, and may only use it for such purposes. 

We may retain your Personal Information (as well as your Users-of-Users’ Information) for as long as our User Account is active. Wix may continue to retain such Personal Information even after deactivation of User Account and/or cease to use any particular Services, as reasonably necessary to comply with legal obligations, to resolve disputes regarding Users, prevent fraud and abuse, enforce our agreements and/or protect legitimate interests. We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.

Wix has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, Wix offers HTTPS secure access to most areas on Services; the transmission of sensitive payment information (such as a credit card number) through designated purchase forms is protected by an industry-standard SSL/TLS encrypted connection; Wix regularly maintains a PCI DSS (Payment Card Industry Data Security Standards) certification. Wix also regularly monitors systems for possible vulnerabilities and attacks and regularly seeks new ways and Third-Party Services for further enhancing the security of Services and protection of Wix Visitors’ and Users’ privacy. 

Regardless of the measures and efforts taken by Wix, we cannot and do not guarantee the absolute protection and security of your Personal Information or any other User Content you upload, publish or otherwise share with us or anyone else. 

We, therefore, encourage you to avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.

In addition to Wix cookies services, we use Google Analytics. See more about Google Analytics policies on www.google.com/policies/privacy/partners/.

Transfer of personal data:
Hokema does not have the right to sell copies of personal data to third parties. The data may be transferred in the future in the event of a sale of part or all of our business and in case of merger, acquisition, financing or bankruptcy.    

Your rights to the data:

Storage and use of personal data are governed by the General Data Protection Regulation GDPR. Data is owned and controlled by Hokema. The website users have the right to access their personal data and the right to have their data erased anytime (“right to be forgotten”). For any questions and requests about data processing, storage, access and erasure in the on the www.pop2talk.com website, please contact mydata@hokema.fi.

Changes to this policy

This privacy policy is subject to periodic review and change. All users who have registered to any of our services with their email address will be notified of updates to the policy.

Contact information 

mydata@hokema.fi


Hokema Oy
A Grid,
Otakaari 5 A
02150 Espoo
FINLAND

Finnish Business Id: 3117633-2

Pop2Talk ©️ 2020 Hokema Oy

  
Finnish Business Id: 3117633-2

www.hokema.fi

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