Privacy Policy

Privacy policy

 

This privacy policy ("Policy") describes how CrystalClearSoft SA on behalf of the STOP Consortium (Erasmus+ project# STOP-2019-2-HR01-KA205-061028) hereinafter "we", "us" or "our", collects, protects and uses the personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide on the STOP game.

 

It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ e  or manage.

 

Automatic collection of information

 

We process only minimal user data, only as much as it is absolutely necessary to maintain the game. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding game usage. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

 

Collection of personal information

 

We receive and store any information you knowingly provide to us when you create an account, on the game When required, this information may include the following:

 

  • Username and Password
  • Email
  • Birthday
  • Country

 

Use of device’s camera(s)

 

The STOP app is an AR educational game and uses the device’s camera(s) only to locate the educational content (images) prepared and included in the game. No image capturing or screen recording takes place within the game.

 

Users who are uncertain about what information is mandatory are welcome to contact us. Managing personal information

You can delete certain Personal Information we have about you. The Personal Information you can delete may change as the game changes. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or  permanently delete your account, you can do so on the settings page of your account on the game.

 

Storing personal information

 

We will retain and use your Personal Information for the period necessary to comply with our  legal and contractual obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

 

Use and processing of collected information

 

In order to make our game available to you, or to meet a legal and/or a contractual obligation, we need to collect the above-mentioned Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested services.

Processing your Personal Information depends on how you interact with our game, where you are located in the world and if one of the following applies: (i) You have given your consent for one or more specific purposes. This, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; (ii) Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) Processing is necessary for compliance with a legal obligation to which you are subject; (iv) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. Regarding the STOP app/game, this third party is the STOP consortium and the purposes of using the app and processing Personal Information are solely educational and statistical.

 

Note that under some legislations we may be allowed to process information until you object  to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

Information transfer and storage

 

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis 

of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.

 

The rights of users

 

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

 

The right to object to processing

 

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. Following the directives of the STOP project, CrystalClearSoft may not and shall not extend the usage of Personal and Sensitive User Data for serving advertising and if any such event occurs erroneously, you can object to that usage at any time without providing    any justification. 

 

How to exercise these rights

 

Any requests to exercise User rights can be directed to CrystalClearSoft and the STOP Consortium through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by CrystalClearSoft and the STOP Consortium as early as possible.

 

Privacy of children

 

We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our game without their permission. If you as a legal guardian have reason to believe that a child under the age of 13 has provided Personal Information to us through our game, please contact us. 

 

In general, as a user you must be at least 16 years of  age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

 

By ticking the related box during your subscription, you assure us that the information you provided regarding your birthday is accurate (at least regarding year and month so we can detect your age). The purpose of collecting this information is solely for offering the suitable content for your age and for pure statistical reasons not related to your identity.

 

If you are a minor, you may only use this game with parental/guardian consent.

Information security

 

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our game cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

 

Data breach

 

In the event we become aware that the security of the game has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with authorities as we are obliged to. In the event of a data breach, we will make all reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the game, send you an email, mail you     a letter.

 

Legal disclosure

 

We will disclose any information we collect, use or receive if required or permitted by law, such  as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

 

 

Changes and amendments

 

We may update this Privacy Policy from time to time in our discretion and may notify you of any material changes to the way in which we treat Personal Information. When changes are made, we may send you an email to notify you. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the game after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Data in a manner materially different than what was stated at the time your Personal Data was collected.

 

Acceptance of this policy

 

You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the game, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the game.

 

Contacting us

 

If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you send an email to dataprotection@ccseducation.com. You may also contact the consortium of the STOP project at info@erasmusstop.eu

 

This document was last updated on November 20, 2021