ChatLicense considers careful handling of your personal data of great importance. We do our utmost to ensure your data is safe with us, in compliance with the applicable legal rules. This Privacy Statement describes how we handle personal data in the context of our services. It tells you which personal data we process, for what purposes, how long we keep data, to whom we pass it on and how you can influence this yourself. This Privacy Policy applies to the ChatLicense mobile apps, website, and related services (“Service”). By using the Service, you agree with ChatLicense’s collection, use, and sharing of your personal information in accordance with the terms of this Privacy Policy.
What is personal data?
Personal data is all data that can be traced back to a person. For example a name, address, date of birth, telephone number and e-mail address. We receive this type of data from you, for example, when you send an e-mail. When you visit www.chatlicense.com you also provide us with personal data, in the form of your IP address or a cookie. When you subscribe to the app, you also provide us with personal data, such as your name, age, gender, postal code and telephone number. As soon as your personal data is shared with ChatLicense by yourself or by a third party, for example the organization where you work, we will process it. Processing includes collecting, storing, consulting, deleting, using and providing data.
Who does ChatLicense process personal data about?
We can process personal data of all persons with whom we have contact, who visit our website or who are users of our app.
Information We Collect
When you use the Service, ChatLicense may collect the following personal information about you.
a. Account Registration
To register for a ChatLicense account, you may provide us with your age, gender, phone number, email address and postal code.
You can manage your ChatLicense account from from your Settings in the app and through the helpdesk.
b. Profile Page & User-Generated Content
Your family’s Administrator registers for your family’s ChatLicense accounts. A profile page will be created for you (“Account”). Your Profile will be populated by information you submit, such as your name, username, and avatar (“User-Generated Content”). Other ChatLicense users in your family account will be able to see your name, username, your progress in ChatCity and your achievements.
c. Activity Data
When you use the Service, we may generate data about your use of the Service, which may include your browser and device data, log data, and IP address. We will also generate data regarding your engagement in educational activities on the Service.
When you use ChatLicense in our app or on our website, some of your activity will be logged to capture and analyze your activity to help us make the ChatLicense experience better. We may record usage patterns (e.g., clicks, mouse movements, scrolling, and typing), tech specs (e.g., browser, device type, operating system, viewfinder size, script errors, and IP address), navigation (e.g., pages visited, referrers, URL parameters, and session duration), and learning activity (e.g., session progress and answers).
d. Cookies
When you access the ChatLicense website, we store certain data from your browser using cookies. A cookie is a piece of data stored on the user’s computer tied to data about the user. We use session ID cookies to confirm that users are logged in. If you do not want your data to be collected by cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. However, cookies may be necessary to provide you with certain features available on the website (e.g., customized information). You can find more information about cookies and how to manage them here.
You can see a list of all cookies used at ChatLicense in our Cookie Statement page. If you do not wish to receive cookies you can set your browser to restrict or block them. All modern browsers allow you to change your cookie settings, typically be found in the ‘options’ or ‘preferences’ menu. In order to understand these settings, the following link may be helpful: www.aboutcookies.org. If you disable cookies you will not be able to use the interactive features of our website. Please note that our cookies may include Targeting Cookies from Google, Facebook, Amazon, and other companies, which these companies may use to track your activities across multiple websites to deliver personalized advertising to you.
e. Google Analytics
We use Google Analytics, which is a web analytics tool that helps us understand how users engage with our website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our site. These reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics by installing Google’s browser add-on available here.
Child Users
Children deserve extra privacy protection. A large part of the users of our app are children. For Child Users (meaning users under the age of 13 or another age of digital consent in a particular country), the parents / guardians are in control as subscription Administrators. We collect the minimum information we need to make ChatLicense work.
Adult parents / guardians act as Administrators, buy the ChatLicense Season subscription and create ChatLicense accounts under that subscription for children and parents/guardians. After setting up the Season subscription, the Administrator invites the Child User through the child’s mobile phone number.
The Administrator can access, change, or delete the personal information about their child.
Child Users do not provide ChatLicense with their profile picture, location or full address information.
Child Users’ Profiles contain no personal information that could be used to publicly identify or contact the child, but only the Child User’s first name, an avatar, and information about their learning progress on ChatLicense.
Child Users’ Profiles are visible only to themselves and family members in the same paid ChatLicenseSeason subscription.
Child Users cannot search for or follow other users, and cannot be searched for or followed by other users.
Child Users in the future may have access to leaderboards.
How We Process Your Information
Carefully. We take appropriate technical and organizational measures. We take security measures to prevent misuse of and unauthorized access to personal data, such as applying access control, firewalls and a secure server. We assume that your data is always confidential and will treat it as such. This also applies to third parties we hire or otherwise appoint to perform work.
ChatLicense may process your personal information according to the following legal bases: to provide products or services you request, to promote ChatLicense’s legitimate interests, to comply with legal obligations, and with your consent. In particular, ChatLicense may process and share your personal information in the following ways:
a. Providing and improving the Service
ChatLicense will process your personal information to provide and improve the Service. For example, we will use the information you provide to maintain your Profile and learning progress, display your Profile to other users under your family’s subscription, personalize learning content, detect and fix bugs, perform research, and provide customer service to you.
ChatLicense may share personal information with third parties that help us provide or improve the Service, including hosting providers such as Microsoft, Amazon Web Services, search engine providers such as Google, support providers such as ZenDesk, and payment processors such as RevenueCat. ChatLicense may in the future also share usage data with third-party vendors that support product features such as program moderation and AI enhancement.
If you redeem a voucher code to gain a ChatLicense subscription, we may share data regarding your usage of ChatLicense with the organization that provided the voucher code to you.
Your mobile devices offers settings that let you make choices about the collection, use, and transfer of mobile app information.
b. Communicating with you
ChatLicense will use your phone number (or when provided, the email address) to send you the following types of messages:
· Essential messages to support the operation of the Service.
· Messages to support the ChatLicense teaching methodology and reinforce learning, such as tips, reminders and progress reports.
· In the future: notifications about friend requests and your friends’ progress on ChatLicense.
· Announcements regarding changes to the Service or products.
· Announcements of new ChatLicense products, services, offers, or research opportunities.
You may opt-out of receiving non-essential messages in your settings.
c. Complying with law and preventing harmful activities
ChatLicense may process and share personal information if necessary to comply with legal requests, such as subpoenas or court orders. ChatLicense may share personal information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity, to assist law enforcement, or to prevent imminent harm. This may include sharing information with other companies, lawyers, agents, or government agencies.
d. Market research
Aggregate demographic and interest data can be used for scientific market research purposes.
e. Other Activities
Personal contact: when contacting us by telephone, e-mail or social media: personal data depending on the type of information you provide.
Within the framework of an agreement: name and address details, possibly company details and financial details.
Applications: when sending application data by e-mail: name and address details, e-mail address, telephone number, CV and possible motivation.
f. Anonymous information
ChatLicense may process aggregated, de-identified, or otherwise anonymous or anonymized information for any purpose. Such information is not considered personal information.
Your Data Subject Rights
You have the following rights in relation to the personal information we hold about you, in addition to any other rights required by applicable law:
· Know what personal information we have collected about you.
· Access a copy of the personal information that we hold about you.
· Know what personal information about you we have shared with third parties.
· Opt out of the sharing of your personal information with third parties.
· Object to our processing of your personal information.
· Request that we limit our use of your sensitive personal information to what is necessary to perform the services you requested.
· Not be discriminated against for exercising your data subject rights.
· Request that we delete any personal information we have collected from you.
· Request that we correct any inaccurate personal information about you.
· Export the personal information you have provided to ChatLicense in a format that can be transferred electronically to a third party.
· Withdraw any consent you previously gave us to process your personal information.
· Delete your ChatLicense account by following the instructions in the Service.
You may update or correct your information in your app settings. You may request to access or erase your personal information. To make any privacy-related request, please email privacy@chatlicense.com. We will respond to your request within one month.
Please note that these rights are not absolute and ChatLicense may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law, or if the request could interfere with a ChatLicense service or prevent us from delivering a service you requested.
Supervision of the processing of personal data
Rules about protecting your personal data are laid down in the General Data Protection Regulation (GDPR). The Dutch Data Protection Authority (AP) ensures that this law is complied with. If you are of the opinion that the provisions of this Privacy Statement are not or insufficiently complied with by us, you can submit a complaint to the Dutch Supervisory Authority “Autoriteit Persoonsgegevens”: Bezuidenhoutseweg 30, 2594 AV The Hague. Telephone +31(0)900-2001201.
Here is a link to the Dutch Supervisory Authority and a list of EEA Supervisory Authorities.
How long do we keep your data?
ChatLicense will generally retain your personal information until your account is deleted. However, ChatLicense may retain certain information longer if necessary to provide our Service, defend our legitimate interests or those of third parties, comply with legal requirements, resolve or defend ourselves in disputes, investigate misuse or disruption of the Service, or perform agreements. We may also retain anonymous data indefinitely.
Third-Party Websites
The Service may contain links to other websites. ChatLicense is not responsible for the content or privacy practices of other websites, including any personal or financial information collected by third-party payment processors. We encourage users to be aware of the privacy policies of other websites they visit. This Privacy Policy applies only to information collected by ChatLicense. Any time you click on a link or submit your personal information to a third-party website, you will be subject to that third party’s privacy policies.
Privacy Policy Updates
We may update our Privacy Policy to reflect changes to our information practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least seven (7) days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that seven (7) day period.
Data Transfer
ChatLicense is based in the Netherlands and processes data in the Netherlands. ChatLicense may transfer the data of users outside the Netherlands to the Netherlands.
ChatLicense will not pass on your data to a company or branch in a country outside the European Union, unless a model agreement has been concluded for this or if you have signed a statement in which you consent to the transfer. Applicable model agreements with parties that are established outside the European Union are:
Supplemental Terms in Certain Jurisdictions
In some jurisdictions, the Service may be subject to supplemental privacy policies or local laws. For users in those jurisdictions, the applicable supplemental privacy policies and local laws will take precedence over this Privacy Policy to the extent they conflict.
Who is responsible for the processing of your personal data?
The entity responsible for processing your personal data for the purposes of the General Data Protection Regulation (“GDPR”) is ChatLicense B.V. (the “Controller”). The Controller is the person who decides whether and, if so, which personal data are processed, for what purpose and in what way.
Contact details
ChatLicense’s headquarters are located in the Netherlands at Aert van Nesstraat 45, 3012 CA Rotterdam.
For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at privacy@chatlicense.com.
Last revised on August 14th, 2023