Thanks for using Zizzle App or visiting one of our websites. At Zizzle, we respect your privacy rights.
Zizzle eLearning Inc. is the data controller of your information. Please see the “Name and Address of the Controller” section below for additional details. As such, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject (“you”)
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Zizzle eLearning Inc.
150 State Street
84111 Salt lake city
Phone: +1 801 230 2816
3. Information We Collect
3.1. Information You Choose to Provide Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
In order to use certain features within Zizzle App (for instance to store your individual learning progress), you need to create a user account. When you create or update your user account, we collect and store the data you provide, like your email address.
Equally, certain features on our website require you to submit your email-address. This applies to the subscription to our newsletter on our Website and the use of the form that enables a quick electronic contact, as well as direct communication with us (contact form). In addition, we offer users the possibility to leave individual comments on individual blog contributions on our blog (comment function). A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties. By using the above features, we collect and store the data you provide, like your email address.
Name, Address and Phone Number:
When you submit a contact request through the contact form, or when you contact us by e-mail, or when you complete a purchase, we may collect and store the data you provide such as your name, address and phone number to facilitate communication.
If you make purchases, you must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information and billing address. For security, Zizzle eLearning Inc. does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Other Data We Collect through the Comment Function:
If you leave a comment on the blog published on our website, the comments made by you are also stored and published, as well as information on the date of the commentary and on your chosen pseudonym.
3.2. Information We Collect through Automated Means
Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate your individual browser from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services.
General Data and Information we collect through our Website and App
Our website and Zizzle App collect a series of general data and information every time you access the website or use our app. This general data and information are stored in the server log files, including:
The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
Our website and Zizzle App also collect a series of usage data every time you access the website or use our app.
On our website, this may include information about which sub-pages were visited, how often and for what duration a sub-page was viewed, click data or date and time. Within Zizzle App, this may also include how you interact with our services, such as which characters you have learned. The data listed above is collected through the use of server log files and tracking technologies.
4. What We Need Your Information for
E-Mail Address, Name, Address and Phone Number
We use data you voluntarily provide us, such as E-Mail Address, Name, Address and Phone Number to facilitate communication with you. Among others, we may
General Data and Information
When using the general data and information we collect automatically, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website/app correctly, (2) optimize the content of our website/app as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
We use the usage data we collect automatically to analyze the traffic on our website and within Zizzle App. This allows us to evaluate the use of our website and to generate reports, which show the activities on our websites and within Zizzle App in order to carry out a cost-benefit analysis of Internet advertising and related services. The data is also vital to improve our services and develop new products, services, and features.
The data we collect and store about which characters you have learned and similar learning data also enables our users to carry their learning progress across devices. It also allows us to offer the Spaced Repetition function in Zizzle App.
We inform our users and business partners regularly by means of a newsletter. The newsletter may only be received if (1) you have a valid e-mail address and (2) you have registered for the newsletter shipping. A confirmation e-mail will be sent to your e-mail address for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter as well as notifications necessary in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. You can choose to opt out of the newsletter at any time by licking the unsubscribe link in any email you receive from us, or by contacting us at firstname.lastname@example.org.
Our Newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Using this technology, we may see if and when an e-mail was opened, and which links in the e-mail were called up. We collect and store this data in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to your interests.
5. Who We Share Your Data with
We share certain data about you with other students, companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
Third parties we share your data with include:
Our website uses Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google“. Google Analytics employs so-called “cookies“, text files that are stored to your computer in order to facilitate an analysis of your use of the site.
The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.
We use Google Analytics with an IP anonymization feature on our website. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from member states of the European Union or signatory states to the Agreement on the European Economic Area.
Google will use this information to evaluate your usage of our site, to compile reports on website activity for us, and to provide other services related to website- and internet usage. Google may also transfer this information to third parties if this is required by law or to the extent this data is processed by third parties on Google´s behalf.
Google states that it will in never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.
Google also offers a disabling option for the most common browsers, thus providing you with greater control over the data which is collected and processed by Google. If you enable this option, no information regarding your website visit is transmitted to Google Analytics. However, the activation does not prevent the transmission of information to us or to any other web analytics services we may use. For more information about the disabling option provided by Google, and how to enable this option, visit http://tools.google.com/dlpage/gaoptout?hl=de.
You can find additional information regarding use of data for advertising purposes by Google, as well as information regarding options and objection on the website of Google https://www.google.com/intl/en/policies/privacy/partners/ (“How Google uses data when you use our partners' sites or apps“), http://www.google.com/intl/en/policies/technologies/ads/ (“Advertising“), http://www.google.de/settings/ads and http://www.google.com/ads/preferences.
Google-Adwords and Remarketing
For purposes of promotion, our website may employ the Google ad tool "Google-Adwords". As part of this, our website employs the analysis service "Conversion-Tracking" from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.
If you access our site by way of a Google ad, a cookie is placed on your computer. These so-called "conversion cookies" cease to be active after 30 days and are not used to identify you personally. If you visit certain pages of our website while the cookie is still active, we and Google know that you, as user, have clicked on ads placed on Google and were redirected to our site. Google uses the information obtained through "conversion cookies" to compile statistics for our website. These statistics tell us the total number of users who have clicked on our ad as well as which pages of our site were then accessed by each user. However, neither we nor other advertisers who use "Google-Adwords" receive any kind of information that can be used to personally identify users. You can prevent the installation of "conversion cookies" by making the appropriate change to your browser settings, for example by setting your browser so that the automatic placement of cookies is deactivated or by blocking cookies from the domain "googleadservices.com“.
Facebook Social Plugins
Our website employs components provided by facebook.com. Facebook is a service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA.
Each time our website receives an access request equipped with a Facebook component, the component prompts your browser to download an image of this Facebook component. Through this process, Facebook is informed precisely which page of our website is being visited.
When you access our site while logged into Facebook, Facebook uses information gathered by this component to identify the precise page you are viewing and associates this information to your personal account on Facebook. Whenever you click on the “Like“ button, for example, or enter a comment, this information is transmitted to your personal account on Facebook and stored there. In addition, Facebook is informed of your visit to our website. This occurs regardless of whether you click on a component or not.
If you wish to prevent the transfer to and storage of data by Facebook about you and your interaction with our website, you must first log out of Facebook before visiting our website. The data protection policies of Facebook provide additional information, in particular about the collection and use of data by Facebook, your rights in this regard as well as the options available to you for protecting your privacy: https://www.facebook.com/about/privacy/
You can find an overview of Facebook plugins at https://developers.facebook.com/docs/plugins/.
You can opt-out of remarketing by the following link and changing your ad preferences: https://www.facebook.com/settings?tab=ads
Use of Twitter
Our website employs components provided by Twitter. Twitter is a service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA.
You may change your data privacy settings in your account settings, at http://twitter.com/account/settings.
We use MailChimp to send our newsletter to our subscribers. MailChimp is a service provided by The Rocket Science Group, LLC, 512 Means Street, Suite 404, Atlanta, GA 30318, USA.
The data stored when you registered for the newsletter (email address, name, IP address, and time and date of registration) will be sent to a server operated by The Rocket Science Group in the United States and stored there in accordance with its Safe Harbour Agreement.
We trust in the reliability and data security of MailChimp. MailChimp is certified by the EU-US Privacy Shield and obligated to comply with the European General Data Protection Regulation. Furthermore we have concluded a „Data-Processing-Agreement“ with MailChimp. This is a contract in which MailChimp obligates itself to protect the data of our users and in particular to not hand over any data to third parties.
Further information about the data protection offered by MailChimp can be found at: http://mailchimp.com/legal/privacy/.
We use the Strikingly online platform that allows us to sell our products and services to you. Strikingly is a service provided by Strikingly Inc., 167 Acalanes Dr, Sunnyvale, CA 94086, USA.
Additionally, we use Strikingly Analytics to evaluate your usage of our site, to compile reports on website activity for us, and to provide other services related to website- and internet usage. Strikingly may also transfer this information to third parties if this is required by law or to the extent this data is processed by third parties on Google´s behalf.
Your data may be stored through Strikingly’s data storage, databases and the general Strikingly applications. They store your data on secure servers behind a firewall.
Amazon Web Services
We use Amazon Web Services (AWS) to host some of the data within Zizzle App, including the audio files. AWS is a service provided by Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, United States.
When you access data hosted by AWS, including audio files, within Zizzle App, AWS may receive your IP address to deliver the requested content. The data is sent to a server operated by Amazon Web Services in the United States and stored there in accordance with its Safe Harbour Agreement.
AWS delivers an industry-leading network of state-of-the-art data centers located around the world, including in the United States of America and Australia. We trust in the reliability and data security of AWS. AWS is certified by the EU-US Privacy Shield and obligated to comply with the European General Data Protection Regulation. Furthermore we have concluded a „Data-Processing-Agreement“ with AWS. This is a contract in which AWS obligates itself to protect the data of our users and in particular to not hand over any data to third parties.
For more details of AWS's privacy and security processes, please visit http://aws.amazon.com/privacy/ and http://aws.amazon.com/security/. By using the service, you consent to your personal information being transferred to our servers as set out in this policy.
Other Third-Party Services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
You can find more information about the privacy policies of third party services used by our website by clicking the following links:
6. How Long We Keep Your Information
We process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
8. Your Rights as a European Union Citizen
a) Right of confirmation
You have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access
You have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If you wish to avail yourself of this right of access, you may contact the controller at any time.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by us, you may contact us at any time. We shall promptly ensure that the erasure request is complied with.
Where we have made personal data public, taking account of available technology and the cost of implementation, we shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that a data subject has requested erasure. We will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, you wish to request the restriction of the processing of personal data stored by us, you may at any time contact us. We will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, you may at any time contact us.
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Zizzle eLearning Inc. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If Zizzle eLearning Inc. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Zizzle eLearning Inc. to the processing for direct marketing purposes, Zizzle eLearning Inc. will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Zizzle eLearning Inc. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you may contact us at any time.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, Zizzle eLearning Inc. shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If you wish to exercise the rights concerning automated individual decision-making, you may contact us at any time.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If you wish to exercise the right to withdraw the consent, you may contact us at any time.
9. Legal basis for processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.
Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
Last update: May 22th, 2018