Exploro Labs - Privacy Policy

WHO WE ARE

Exploro Labs Ltd is a company registered in England and Wales (company number 11175557) with registered office at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX.

When you use our services, you’ll be required to share some information with us. We want to be upfront about the information we collect, how we use it, who we share it with and the choices we give you to control, access and update your information. For the purposes of data protection legislation, we are the data controller of your personal information. We are registered with the Information Commissioners Office in the UK with reference number ZA491456.

Please read this privacy policy carefully.

Questions, comments and requests regarding this privacy policy are welcomed and should be emailed to us at: privacy@explorolabs.com.

SUMMARY

• We keep to a minimum the information we hold about you.
• We use your data to provide our services to you, respond to your enquiries, manage our relationship with you, meet our legal obligations, and improve our platform.
• We delete your data when it is no longer needed for these things.
• Generally, we do not give your information to third parties, but there are some exceptions.
• You have lots of privacy rights.
• We take security seriously.
• We are happy to answer your questions about any of the information contained in this privacy policy.

THE PERSONAL INFORMATION WE COLLECT AND USE

When you download our application Mandarin Spark (the Platform), a universally unique identifier (UUID) will be assigned to your personal device upon installation. This will include device information such as the model of your device and your IP address. Your IP address is personally identifiable information. The UUID is crucial to the Platform’s functionality and is used to track test results and the Platform’s usage analytics. This data is personally identifiable information, but we anonymise it so that we will never be able to identify you with it. For more information on non-identifiable information please see the section titled ‘Non-Identifiable Information’ below.

When you install the Platform, you will be given the option to create an account. If you do create an account, you will be required to submit certain personal information to us in accordance with this privacy policy. If you do not create an account with us, we will never have access to your personal information unless you contact us and voluntarily provide it.

WHAT PERSONAL INFORMATION WE HOLD

Contact information: when you register for an account with us, we collect your name, age, email address and gender.

Billing information: we provide limited content free of charge. If you decide to make an in-app purchase to unlock more content, the Platform will re-direct you to the Apple App Store billing system where you will be required to provide billing details including your name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). All information entered through your device is encrypted and Apple does not store or have access to the original card number that you add to Apple App Store. For more information, please see https://support.Apple.com/en-gb/HT203027.

Account settings: you can set various preferences and personal details on pages like your account settings page. For example, you can create a study profile which will allow us to provide relevant content to you.

WHOW WE USE YOUR PERSONAL INFORMATION

We process personal information about you:

• to fulfil our contractual responsibility to deliver the services to you; and/or
• to pursue our legitimate interests of providing support and improving the services we offer and developing new service features

Category of personal data	Purpose for processing	Legal basis under the GDPR
Contact details	To enable you to register for an account with us and to personalise our service to you (e.g. through personal greetings etc).	Fulfilment of a contract. Legitimate interests
Billing information	To bill you for our services	Fulfilment of a contract
Account settings	To enable you to personalise your profile and to set preferences. For example, this will enable us to tailor the content to meet your abilities and preferences.	Legitimate interests

NON-IDENTIFIABLE INFORMATION

We will obtain information about you from third parties such as Google to support and enhance the Platform and the user experience. The information obtained in this way will be non-personally identifiable information, such as your UUID and will be used to provide you with advertisements and content tailored to meet your preferences.

The Platform implements a specific opt-in to personalised adverts. If you want to change these settings, you can do so by following the in-app instructions. Please note that opting out does not prevent the display of advertisements to you – they just won’t be based on topics that you like or your demographic. Instead, they’ll be based on factors such as your general location.

We use Google Analytics, a web analytics tool that helps us to understand how users engage with the Platform. It provides us with information relating to the number of users in the Platform, their characteristics and where they come from and it enables us to measure what actions users are taking. The information collected through analytics tools will always be anonymised and will never contain information that can be used to identify you.

We use this information to understand users’ behaviour and to make improvements to the Platform. For more information on who were share your data with, please see our section below on sharing and transferring your personal information.

SHARING AND TRANSFERRING YOUR PERSONAL INFORMATION

We enter into confidentiality and data processing terms with our partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices. We currently share information with the following third parties:

• Google Analytics for Firebase;
• Google Crashlytics;
• Google Firebase A/B Testing;
• Google AdMob; and
• RevenueCat.

For more information relating to how Google uses your personal data, please visit www.google.com/policies/privacy/partners/.

For more information relating to how RevenueCat uses your personal data, please visit https://www.revenuecat.com/privacy/.

We also have to share information or data in order to:

• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable policies, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues; and/or
• protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.

Your personal information may be stored and processed in any country where we engage service providers, including outside the EEA. For example, Google has data servers located in the USA where your information may be stored.

Whilst the USA will have data protection rules that differ from the EEA, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this privacy policy.

RETAINING YOUR PERSONAL INFORMATION

We will hold on to your information for as long as is needed to be able to provide the services to you. Thereafter, we will keep your personal information for as long as it is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly; and/or
• if required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions.

If you hold an account with us, we will retain your personal information until your account is deleted, after which point we will retain anonymous data collected through analytics tools as aggregated data. We do this to enable us to continue improving our services for our users. If you do not hold an account with us, we will retain anonymous data in the same way.

We will not retain your personal information for longer than necessary for the purposes set out in this privacy policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

KEEPING YOUR PERSONAL INFORMATION SECURE

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

CHILDREN

Our Platform is not intended for use by any person under the age of 18.

CONTROL OVER YOUR PERSONAL INFORMATION

Under the General Data Protection Regulation, you have a number of important rights available to you for free. In summary, those include rights to:

• be informed about how your personal information is being used (hopefully this privacy policy explains it all);
• access the personal information we hold about you;
• request that we port elements of your data to another service provider;
• request us to correct any mistakes in your information which we hold;
• request the erasure of personal information concerning you in certain situations;
• receive the personal information concerning you which you have provided to us, in a structured format; or
• object to decisions being taken by automated means concerning you or significantly affect you.

For further information on each of these rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of these rights, please:

• email us at privacy@explorolabs.com;
• let us have information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information. If you are not happy with how we manage your personal information, you have the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

CHANGES TO THIS PRIVACY POLICY

This privacy policy was published on 1st March 2019 and last updated on 26th July 2019. Any changes we make to this privacy policy will be posted on this page.

HOW TO CONTACT US

Please contact us if you have any questions about this privacy policy or the information we hold about you. If you wish to contact us please send an email to privacy@explorolabs.com.