Privacy Policy

We consider the security of our users’ personal data responsibly, so we strive to protect the confidentiality of Your personal data. We apply certain practices to prevent misuse of Your personal data. We will process Your personal data in strict accordance to the applicable law and only when having lawful reasons for such processing.

You are not obligated to provide us personal data, but without Your certain details, we cannot render You a majority of our services. For example, in case You refuse to provide necessary credentials, we will be unable to ensure interactivity and personalization of communication with You.

When we are in control of methods of collecting Your personal data and can determine objectives for use of personal data, we act as personal data controller as well as the personal data owner in understanding of the Law of Ukraine “On Protection of Personal Data” number 2297-VI dated 01.06.2010 (hereinafter – the Law of Ukraine “On Protection of Personal Data”).

We process Your personal data only if at least single one of the following conditions is met:

• You gave us consent to personal data processing;
• Processing is necessary for rendering services to You within the limits of the Terms you accepted;
• Such processing is required by law.

From time to time we may update this Privacy Policy without prior notice, particularly when required by applicable law. Therefore, we ask You to check the relevance of Your information in the Application preferences.

Personal data is any information of personal nature that allows to identify an individual (personal data subject).

Personal data subject is a natural person to whom personal data relate and who can be identified or who has already been identified by this personal data. The personal data subjects for the use of this Policy are the users of the Services.

Personal data controller is a natural or legal person who defines the purposes and means of personal data processing and has the primary responsibility for its processing and storage. Under Ukrainian legislation, personal data controller is known as “personal data owner”.

Personal data processor is a natural or legal person who processes personal data for the personal data controller on the basis of instructions (directions, orders) of the personal data controller. Under Ukrainian legislation, Personal data processor is known as “personal data manager”.

Processing of personal data is any operation or compilation of operations performed with personal data or bases of personal data with or without the use of automatic procedures, such as its collection, recording, systematization, structuring, storage, modification, organization, viewing, utilization, distribution or any other type of granting access to third parties, including employees of the personal data controller or personal data processor, as well as deletion.

Processing of Your personal data takes place in accordance with the Law of Ukraine “On Protection of Personal Data”. Processing of personal data of subjects, which reside in the EU and/or are the EU citizens, is carried out according to General Data Protection Regulation (EU) 2016/679 (hereinafter – GDPR) and relevant local EU state laws. Depending on Your country of residence, the laws of other countries may affect our legal relationship.

We need Your personal data so that we are able, in particular, but not limited:

• To render You a full scope of Services;
• To authorize You in Application,
• To improve the user experience (via personalization of tasks),
• To display statistics and progress in the user profile,
• For marketing purposes (event notifications, sending relevant information to the user, etc.)

In this case we send You commercial (advertising) messages, we shall ensure a separate consent from You, which is revocable at any time.

We can use push-notification, or other means of communication, to send you information within the scope of Services. Push-notification can be deactivated in Application preferences at any time.

In the list below, You may find out what kind of personal data we process to render You our Services:

To provide and personalize general services and to communicate with You:

Data about user:

• email
• name
• country
• language

Technical specifications:

• device type
• device ID
• operation system type and version
• language settings
• IP address

Info about usage:

• visited sections of the app
• types of games played
• game score
• session duration, etc.
• When storing Your personal data is not necessary for rendering Services to You and is not mandatory by law, we shall eliminate it.

To store personal data, we use DigitalOcean cloud service provider, physically located in data centers in [Germany].

Some personal databases are hosted on our own servers in Germany.

In order for You to use our Services, we need to transfer Your personal data to third parties, which include:

Technical service providers
To render Services involvement of necessary service providers and partners which are crucial.

Marketing partners
We work with third party advertising networks and marketing analytics service providers such as Google, Facebook, Unity etс. (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits to and use of the mobile Application in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

Government agencies
In case required by law, we are obligated to send Your personal data to state organizations, including courts, law enforcement and regulatory agencies, authorized officials.

Links to third party sites
When You use our Services, You may find links to third party websites. Please note that this policy does not apply to use of third-party sites, we are not responsible for ensuring privacy of Your personal data on such websites and encourage You to read their privacy policy (or similar documents).

We will not store Your data longer than necessary to achieve the purposes for which it is processed or to comply with statutory requirements.

In order to set the appropriate storage period, we determine the nature and category of personal data, the purposes for which it is processed, and if such purposes may be achieved through other means.

As a general rule, the maximum period of storing Your personal data is 3 (three) years after the last sign up to the Application.

1) The rights of personal data subjects in accordance with the legislation of Ukraine

Your rights regarding the processing of personal data in accordance with the legislation of Ukraine:

• To know the sources of collection, location of personal data, the purposes of its processing, location or place of residence (location) of the owner or controller of personal data or render a necessary authority to obtain this information to authorized representatives, unless otherwise set by law;
• To receive information of conditions for granting access to personal data, including information of the third parties being provided with personal data;
• To access own personal data;
• To receive a confirmation as to whether own personal data is being processed, as well as receive the contents of such personal data no later than in 30 (thirty) calendar days since the date of receipt of the request, except as provided by law;
• To make a motivated request to the owner of personal data denying the processing of own personal data;
• To make a motivated request to edit or destroy own personal data by any owner or controller of personal data, if this data is processed illegally or is inaccurate;
• To protect own personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or late provision, as well as to protect against the provision of information that is inaccurate or tarnishes the honor, dignity and business reputation of the individual;
• To file complaints of processing of own personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;
• To apply legal remedies in case of violation of legislation on personal data protection;
• To make reservations of the restrictions of the right to process own personal data when giving consent;
• To withdraw consent to the processing of personal data;
• To know the mechanism of automatic processing of personal data;
• To protection against automated decision that has legal consequences for such person.

2) Other rights of personal data subjects under GDPR

In addition to Ukrainian legislation on protection of personal data of there are guarantees of rights of residents of the EU, set by GDPR, as follows:

• The right to information

We are ready to provide the personal data subjects with information about what personal data we process.

If You wish to know what personal data we process, You may request such information from us. You can find the list of data you may request in Articles 13 and 14 GDPR. When applying, You must inform us of Your specific request and sufficient information about Yourself so that we could legitimately accept Your request and provide a response.

Please note that in the event that we are unable to identify You by e-mail, or in the event of reasonable doubt about Your identity, we may ask You to provide proof of identity. Only through this procedure we will be able to avoid the disclosure of Your personal data to a person who may impersonate You.

We will process requests as soon as possible, but at the same time we ask You to remember that providing a complete and legal response to personal data is a complex process that can take up to a month.

• The right to correction

You can update most of the data Yourself by signing into Your mobile application or re-export data from accounts in social networks.

• Withdrawal of consent to the processing of personal data and the right to be forgotten

In case we process Your personal data on the basis of consent to such processing of personal data (including for the purpose of marketing messaging), further processing is may be stopped at any time. Withdrawal of consent to such processing is sufficient.

You can also exercise Your right be forgotten. In the cases listed in Art. 17 GDPR, we shall destroy Your personal data, when except retaining of personal data is required to maintain compliance to the law.

support@kotoenglish.com