Privacy policy

Belssy d.o.o. we care deeply about your privacy and your families’ privacy. We will never share your
data with a third party and we follow both the European (GDPR) and US (COPPA) privacy laws
protecting children’s data.
1.1 The Policy
In addition to the ElssyApp Website Terms that govern your use of the Website, the Applications and
other parts of the Platform, this supplemental privacy policy (“Privacy Policy”) sets out:
a) the information we collect about you when you visit our Platform including our Website, use
our Applications and other products or services, or otherwise interact with us;
b) how we use, share, store, and secure the information; and
c) how you may access and control the information.
In this Privacy Policy, “personal information” refers to any data, information, or combination of data
and information that is provided by you or any Designated User(s), or through your use of our Website,
Applications, other parts of our Platform and other products or services, that relate to an identifiable
individual.
If you are a parent or guardian of a Designated User under the age 13 (or between 13 and 16 and not
of the age of consent in your country) you consent to us retaining personal information of that
Designated User by allowing that Designated User access to your User Account.
1.2 Owner contact details
Please contact us in the first instance if you have any questions, concerns or complaints in relation to
this Privacy Policy and/or the use by us of your personal information.
1.3 What information we collect about a Member (Adult)
1. We collect the following types of information about our Parent Members, Designated Users and
other users (without a User Account) which our Platform collects and through our third party
providers:
a) account and profile information that you provide when you register for a User Account for you
and any Designated User, for example first name; last name; phone number; address; email
address; password; IP address country; state; ZIP/Postal code; city; billing address; house
number; language; geographic position; unique device identifiers for advertising; (collectively,
“Account Data”);
b) information you provide through support channels, for example when you or a Designated
User report a problem to us or interact with our support team, including any contact
information, documentation, or screenshots (collectively, “Support Data”);
c) communication, marketing, and other preferences that you set when you set up your User
Account or profile, or when you or a Designated User participate in a survey or a questionnaire
that we send out (collectively, “Preference Data”);
d) d)information about you and any Designated User’s device or connection, and information we
collect through cookies and other data collection technologies (please read our Cookies Policy
below for details)
e) Information about your use and use by a Designated User of or visit our Platform including
behavioural data and other data communicated while using the Platform (collectively, “Usage
Data”).
2. We collect the above information when you provide it to us or when you use or visit our Platform.
We may also receive information about you from other sources, including third-party service
providers.
We do not collect sensitive data or special category data about you. This includes details about your
race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual
orientation.
If:
a) you have given us consent to use your personal information for a specific purpose, or
b) as a parent or guardian with a User Account, you have, on behalf of a Designated User [(being
a minor under the age of 16)], given us consent to use the Designated User’s personal information
for a specific purpose,
you have the right to withdraw such consent at any time by contacting us, but please note this will
not affect any use of your information that has already taken place.
1.4 How we use the information we collect
1. We only use your personal information where the law allows us to. We use your personal
information only where:
a) we need to perform the contract we have entered into (or are about to enter into) with you,
including to set up a User Account and operate our Platform and other products or services,
to provide customer support and personalised features, and to protect the safety and security
of our Platform;
b) we need such information for internal research and development purposes;
c) it satisfies a legitimate interest which is not overridden by your fundamental rights or data
protection interests, for example for reporting a Designated User’s performance to his or her
Parent Member (parent or guardian) or research and development, and in order to protect
our legal rights and interests;
d) you’ve given us consent or “opted in” to do so for a specific purpose, to send you direct
marketing materials or publish your information as part of our testimonials or customer stories
to promote our products or services with your permission; or
e) we need to comply with a legal or regulatory obligation.
2. We do not in any circumstances use personal information of a Parent Member or a Designated User
for marketing purposes by our group or any third parties.
3. We do not share your personal information with any company outside our group for marketing
purpose unless with your express specific consent to do so.
1.5 How we share information we collect
1. We may share personal information on aggregated or de-identified basis with third parties for
research and analysis, profiling, and similar purposes to help us improve our Platform and
other products and services.
2. If you use any third-party software in connection with our Platform or other products or
services, for example any third-party software that our Platform integrates with, you might
give the third-party software provider access to your account and information. Policies and
procedures of third-party software providers are not controlled by us, and this Privacy Policy
does not cover how your information is collected or used by third-party software providers.
We encourage you to review the privacy policies of third-party software providers before you
use the third-party software.
3. Our Platform may contain links to third-party websites over which we have no control. If you
follow a link to any of these websites or submit information to them, your information will be
governed by their policies. We encourage you to review the privacy policies of third-party
websites before you submit information to them.
4. We may share your information with government and law enforcement officials to comply
with applicable laws or regulations, for example when we respond to claims, legal processes,
law enforcement, or national security requests.
5. If we are acquired by a third party as a result of a merger, acquisition, or business transfer,
your personal information may be disclosed and/or transferred to a third party in connection
with such transaction. We will notify you if such a transaction takes place and inform you of
any choices you may have regarding your information.
1.6 Use of Data Processors
Data processors are third parties who process your personal information on our behalf. We have
contracts in place with our data processors. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will not share your personal
information with any organisation apart from us.
1.7 Your rights
1. Any user of the Platform has the right to:
a) be informed of what we do with your personal information;
b) request a copy of personal information we hold about you and any Designated User(s);
c) require us to correct any inaccuracy or error in any personal information we hold about you;
d) request erasure of your personal information (note, however, that we may not always be able
to comply with your request of erasure for record-keeping purposes, to complete transactions,
or to comply with our legal obligations);
e) object to or restrict the processing by us of your personal information including processing
carried out under the lawful bases of a public task or legitimate interests and for the purposes
of direct marketing;
f) withdraw your consent at any time where we are relying on consent to process your personal
information (although this will not affect the lawfulness of any processing carried out before
you withdraw your consent).
2. You may opt-out of receiving marketing materials from us. Please note, however, that even if
you opt-out from receiving marketing materials from us, you will continue to receive notifications
or information from us that are necessary for the use of our Platform and other products or
services.
3. As a security measure, we may need specific information from you to help us confirm your
identity when processing your privacy requests or when you exercise your rights.
4. We will respond to all legitimate requests within one (1) month. Occasionally, it may take us
longer than a month if your request is particularly complex or if you have made a number of
requests.
1.8 Changes to this Privacy Policy
We may amend this Privacy Policy from time to time by posting the updated Privacy Policy on our
Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound
by the revised Privacy Policy.
1.9 Disclaimer of Liability
Users of the application enter the content themselves and no one but them has access to their
individual contents. The application is designed solely for learning and it is prohibited to enter non-
applied content and the users commit themselves that the content within the application is in
accordance with the laws. Belssy d.o.o. does not have any liability in relation to the content entered
into the application by the user.
The use of photographs from your own gallery is allowed and falls under the responsibility of the user.
Also, your own photos are stored in the user application on the device used to access the application
and are not visible to other users or employees.
Because the app is intended for primary school children, parental supervision of the use of the app is
required.

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