Privacy Tom Hope April 13, 2022
Privacy statement

The use of the App entails various types of personal data being processed for various purposes. Personal data is information which is directly or indirectly referable to a natural living person, e.g. name and email.

Capeesh may collect the following information, including personal data, about You, the “Data Subject”;

Registration and user data: When creating a user account with Capeesh and when using the App, You are required to provide the following information; email address. Please note that Capeesh is unable to provide the full use of the App unless You provide the above stated personal data.

Usage information: When You use the App certain information will be collected automatically, including (i) information about Your interactions with the App; (ii) the details of the queries You make; (iii) content You post, upload and/or contribute to the Service; (iv) technical data, which may include your device name, language and operating system.

Capeesh will process the information described in the Section above for the following purposes: (a) to administrate Your account (b) to send You alerts or messages by email or otherwise, including to provide You with marketing of products and services and to inform You about updates of the App or of the Agreement, (c) to improve and develop the App or new services and products and to analyze Your use of the App, (d) to ensure the technical functioning of the App and to monitor and prevent use of the App in breach of the Agreement, (e) to enforce the Agreement, including to protect the rights, property and safety of Capeesh and other persons, and (f) to fulfil requirements by law.

Capeesh may not be able to provide the Service in full unless the above-stated information is provided by the Data Subject.

Cookies

A cookie is a small text file that a website asks to place on Your computer, mobile phone, or other devices when You visit a website. A cookie can help the website provider to recognize Your device the next time You visit the website, provide You with access to certain functions on the website and/or register Your surf patterns. There are other technologies such as pixel tags, web bugs, web storage and other similar files and technologies that can do the same thing as cookies. The term “cookies” in this Agreement refers to cookies and all such similar technologies.

Capeesh.com web domain uses the following cookies for following purposes:

Essential operational cookies: These cookies are necessary for Capeesh to operate the Service as You have requested. For example, they allow Capeesh to recognize You and then provide You with the Service accordingly.

Functional cookies: Capeesh uses these cookies to operate certain functions of the Service in line with the choices You make. These cookies mean that when You continue to use or come back to the Service, it is provided as You have previously requested, e.g. remembering Your username and how You have customized the Service.

Third party cookies: Capeesh may allow our partners to use cookies on the Service for the same purposes identified above. Capeesh may also use service providers acting on our behalf to use cookies for the purposes identified above.

Most web browsers allow You to manage Your cookie preferences. You can set Your browser to refuse cookies, or delete certain cookies. Generally, You should also be able to manage similar technologies by using Your browser’s preferences.

Please note that if You choose to block cookies, this may impair or prevent due to the functioning of the Service.

More information about the use of cookies and how to block them can be found on: cookies.org, www.allaboutcookies.org, www.youronlinechoices.eu.

GDPR

What data do we need and why?

Capeesh is the so-called ‘controller’ of the personal data you provide to us. To operate our service, we ask you to register with your email, a password for login, and a username to display in-game.

Your email address will only be used to let you log in, and to provide you with a method of recovering a password if lost. You can also opt-in to receive news and information about our language learning games and lessons, either on the registration page or on your profile page.

We use Google Analytics to track statistics over data traffic. We do not send any personal information to Google Analytics.

We do not store any location data.

How do we protect your data?

Your personal data may be processed by our team in Norway for the purpose of maintaining and improving our service. It is stored in the EU on servers hosted by Microsoft Azure, and will not be transferred outside the EU.

We do not share your personal information with any 3rd party unless required by law, or otherwise specifically agreed to.

What are your rights?

You have the rights to view, change or delete your personal information from your profile page at any time. If you encounter any problem or have any complaint, please don’t hesitate to contact us at [email protected]

Processing of personal data in general

When using our language learning software Capeesh via our app, we collect and process certain personal data in the framework of the services we deliver.

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Processing of personal data when using Capeesh

Capeesh allows employers (e. g. entrepreneurs, companies, free-lancers, merchants etc.) to provide their employees access to Capeesh, so that they can acquire or improve language skills for professional purposes. To this end, the employer closes a contract with us as „client“.
If your employer provides you access to Capeesh for you to take part in a Capeesh language course for professional training purposes, we will disclose certain information about your use of the software and about your achievements to your employer.

What information does my employer receive about me?

We regularly draft reports (hereinafter “Reports”) about the use of Capeesh by employees of our clients. Such Reports include the following information:

  • course content and language (e. g. “Spanish for responding to motor vehicle accidents”)
  • accomplished course units (number)
  • number of days the software has been used (number)
  • the actual dates when the service has been used (dates)
  • duration of use (in minutes)
  • time of day when the service has been used (time)
  • term of the provided access (e. g. from March. 1 st 2022 till Dec. 12 th 2023)

The above-mentioned information relates to

the last week and the last month preceding the drafting of the Report and the entire term since the access of each employee has been activated; and

the e-mail address provided by each employee when registering

This means that, exemplifying, your employer could receive the following information:
[email protected] has been spending 600 minutes during 7 days on Capeesh over the last week/the last month/since registration, thereby completing 30 learning units of the course “Veien til arbeid” in Norwegian.”

Purpose of processing

Thanks to the processing of personal data described your employer intends to promote the development and improvement of language skills of its employees. To this end, your employer must gain knowledge of the involved employees’ learning progress at regular intervals. Furthermore, your employer can draw conclusions about Capeesh’s suitability as a language learning tool.

Legal basis of processing

This form of processing of personal data is based on the employment relationship. Within its scope, the employer may process personal data relating to employees. The legal basis thereto is the employment contract pursuant to art. 6 par. 1 lit. b) GDPR.
The described Reports are drafted exclusively on the employer’s behalf. We as “Capeesh” do not have any interest in the Reports. We process the personal data contained therein separately from all further personal data collected and processed by Capeesh, only for the purpose of transferring it to the client.

Controller and processor

With regard to the data processing activities described in this statement, your employer qualifies as “controller”, while Capeesh only acts as “processor” within the meaning of art. 28 GDPR. We have closed the required agreement with your employer.

Retention time

We only retain the mentioned personal data on your employer’s behalf and in principle only as long as your access to Capeesh is active. In no case will we retain such data after your employment relationship has come to an end.

Which rights do I have?

Also with regard to this form of processing you are entitled to all rights granted by the GDPR and further applicable legislation. Please find out the details in our privacy statement.

Is this all I should know with regard to the Reports?

All processing activities we perform on your employer’s behalf in connection with your personal data are outlined in this statement. If, within the framework of your employment relationship or according to another legal basis your employer should process your personal data further or differently, he/she, as the controller, will inform you about this extensively. The same applies to any further information about the processing activities described in this statement that your employer is required to disclose according to art. 13 GDPR (e. g. information about the appointed data protection officer, if any).

Is there anything else I should know?

Unless explicitly specified otherwise in this statement, Capeesh’s privacy statement shall apply to the use of the language learning software.