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The revised privacy policy is effective from July 14, 2020, and complies with the:

• European Union General Data Protection Regulation (EU GDPR),
• United Kingdom General Data Protection Regulation (UK GDPR),
• The California Consumer Privacy Act (CCPA),
• Brazilian ‘Lei Geral de Proteção de Dados' (LGPD).

WHAT THIS POLICY COVERS

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:

• What information we collect about you
• How we use information we collect
• How we share information we collect
• How we store and secure information we collect
• How to access and control your information
• How we transfer information we collect internationally
• Other important privacy information
• Cookies & tracking notice

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with LearningChess (for example, contacting LearningChess support), unless a different privacy policy is displayed. This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

When we refer to ‘LearningChess', ‘we', or ‘us' in this policy, we mean i-Mobile Solutions Ltd., which controls the information LearningChess collects when you use the Services. LearningChess offers collaborative tools, including our web, desktop, and mobile products, which help you stay organized, We also offer related services, like support. We refer to all of these products, together with our other services and websites as ‘Services' in this policy.

Our Privacy Policy was written in English. Should any translated version of the Privacy Policy be in conflict with the English version, the English version shall govern.

WHAT INFORMATION WE COLLECT ABOUT YOU

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information you provide to us

We collect information about you when you input it into the Services or otherwise provide it directly to us.

• Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information when you register for the Services. We keep track of your preferences when you select settings within the Services. We store the passwords encrypted, which means that they can never be decrypted, nor by us.
• Content you provide through our products: The Services include the LearningChess web, desktop and mobile products you use, where we collect and store content that you post, send, receive and share. This content includes any information about you that you may choose to include. Examples of content we collect and store include: lesson solutions, puzzle solutions, achievements.
• Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, sweepstakes, activities or events.
• Information you provide through our support channels: The Services also include customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. You open a support ticket by contacting us, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
• Payment Information: We collect certain payment and billing information via secure payment processing services when you register for certain paid Services. For example, we collect buyer's name and address, which are necessary for the lawful taxation.

Information we collect automatically when you use the Services

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

• Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the visited LearningChess pages, lessons, puzzles, achievements.
• Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
• Cookies and Other Tracking Technologies: LearningChess and our third-party partners, such as analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies and Tracking Notice below, which includes information on how to control or opt out of these cookies and tracking technologies.

Information we receive from other sources

We receive information about you from third party services, such as Facebook, PayPal or Bank transfer, or LearningChess partners.

• Facebook: When you use the Facebook registration or Facebook login option in our website, Facebook provide us with your email, first name and last name. The email is necessary, because it is your unique identifier in our system.
• PayPal: When you purchase one of our products through PayPal, PayPal provide us with your billing information: name / company name, address and email, which are necessary for the lawful taxation.
• Bank Transfer: When you purchase one of our products via bank transfer, we receive your billing information: name / company name which are necessary for the lawful taxation.
• LearningChess Partners: We work with a global network of partners who provide consulting, implementation, training and other services around our products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as billing information, billing and technical contact information, company name, what products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.

HOW WE USE INFORMATION WE COLLECT

How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.

• To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. For example, language you provide in your account to set up your language for the Service.
• For research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful to you. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. For example, we used information collected about how users solve the tasks in the lessons, how effectively solve the puzzles. We also test and analyze certain new features with some users before rolling the feature out to all users.
• To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages.
• To market, promote, and drive engagement with the Services: Depending on your settings, we send you LearningChess newsletters time-to-time. These communications are part of the Services and you can opt out of them. You can control whether you receive these communications as described below under 'Opt-out of communications.'
• Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
• For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.
• To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
• With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
• Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
  • We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • You give us consent to do so for a specific purpose; or
  • We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

HOW WE SHARE INFORMATION WE COLLECT

We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.

Sharing with other Service users

When you use the Services, we may share certain information about you with other Service users in the following cases:

• Community Forums: Our websites offer a publicly accessible blog. You should be aware that any information you provide in these websites - including profile information associated with the account you use to post the information - may be read, collected, and used by any member of the public who accesses websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services. To request removal of your information from publicly accessible websites operated by us, please contact us as provided below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

Sharing with third parties

We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.

• Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
• Links to Third-Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
• With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
• Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect us, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

HOW WE STORE AND SECURE INFORMATION WE COLLECT

Information storage and security

We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.

How long we keep information

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

• Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
• Managed accounts: If the Services are made available to you through an organization (e.g., your school), we retain your information as long as required by the administrator of your account.
• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

HOW TO ACCESS AND CONTROL YOUR INFORMATION

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.

Your Choices:

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (coach or teacher, see 'Notice to End Users' below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

• Access and update your information: Our Services and related documentation11 give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings (My Account) and modify content that contains information about you using the editing tools associated with that content.
• Delete your information: Our Services give you the ability to delete all information about you from within the Service. For example, you can remove your email address, registration IP address, first name and last name using the Delete Account function under the My Account menu, Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
• Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your newsletter preferences within your Service My Account menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.
• Turn off Cookie Controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
• Send 'Do Not Track' Signals: Some browsers have incorporated 'Do Not Track' (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.

HOW WE TRANSFER INFORMATION WE COLLECT INTERNATIONALLY

International transfers of information we collect

We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

• International transfers to third parties: Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside.

OTHER IMPORTANT PRIVACY INFORMATION

Notice to End Users

Our products are intended for both personal use and use by organizations. Where the Services are made available to you through an organization (e.g. your school), that organization is the administrator of the Services and is responsible for the end-users and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator (coach), as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.

In some cases, administrators can also: • reset your account password; • restrict, suspend or terminate your access to the Services or your account; • control your ability to edit, restrict, modify or delete account information; • change your account information, including profile information or username, login name associated with your account; • access information in and about your account; • access or retain information stored as part of your account; anPlease contact your organization or refer to your administrator's organizational policies for more information.

Our policy towards children

The Sign Up and Unlock Course functions are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, blog or by sending you an email notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

Contact Us

Your information is controlled by i-Mobil Solution Ltd. If you have questions or concerns about how your information is handled, please contact us with your inquiry, as set forth below.

i-Mobil Solution Ltd.

Lorantffy Street 22.

Budapest

1022 HUNGARY

Cookie policy

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