“Kaizen Languages” is a service offered by AB Languages Limited, Kemp House, 152 - 160 City Road, London City Road London EC1V 2NX. AB Languages Limited is the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and any relevant local legislation (“Data Protection Laws”).
Through this privacy statement, AB Languages Limited wishes to inform you of how your personal data are processed and in what form some of these data are made accessible for other users. All personal data are treated with the utmost care at AB Languages Limited. All the necessary steps are taken to guarantee the security of these data.
This privacy statement supplements the General Terms and Conditions of Business of Kaizen Languages. Please write to firstname.lastname@example.org if you have any queries relating to this document.
INFORMATION WE COLLECT
1.1. Personal data
When you register with us, we record and save your basic data such as your username and email address together with other contact information such as username and password. We may receive further information from you via the website or if you communicate with us. Your user profile, created on signing up for the App and opting into sharing their data with AB Languages Limited (whether or not the user has chosen to pay for a subscription and become a premium member) contains the following information:
User profile picture (by default this is blank)
‘Fluency’ (the progress through the content within the Kaizen Languages app for each language)
Best streak (the most consecutive days using the App)
Current streak (current number of consecutive days using the App)
‘Last online’ time and date (used to calculate streaks)
Account status (Premium or Trial)
Users are by default opted out of sharing any information with other users. Users can opt in to sharing their progress through the “Kaizen Languages” product with other users. The following registration data is accessible to other “Kaizen Languages” users on opting in:
User profile picture (by default, this is blank)
Language score (the points used in the scoring system within the Kaizen Languages App)
If the user opts in to adding a profile picture, this too will then be available to other users including those who the user hasn’t opted in to sharing their full profile information (for example, whilst the user searches for other users with whom they may wish to add to a leaderboard).
One type of cookie automatically expires after your session has ended. This is called a session cookie. Your user settings, in particular, are saved as session cookies so that Kaizen Languages can always be used in the form you require. Another permanently stored anonymous cookie contains the version number of your Flash player. When you log in, you also have the option of saving your username and password locally in an encrypted form on your computer. You can save this cookie permanently for automatic log in with the function “Log me in automatically on this computer”. In addition to this, user settings, such as language selection, language recognition settings and user IDs for various applications, are saved in both session cookies and permanent cookies by Kaizen Languages in order to facilitate the use of Kaizen languages.
For the Internet Explorer you can find the relevant instructions at http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies,
For Firefox at
For Apple Safari at
For Google Chrome at
However, deactivating cookies will mean that a number of functionalities, e.g. automatically logging in to the website, will no longer operate as intended.
We may use the services of third parties to collect and use anonymous information about your visits to and interactions with our website through the use of technologies such as cookies to personalize advertisements for goods and services. To learn more, or to opt-out of receiving online display advertisements tailored to your interests by our third party partners, visit the Network Advertising Initiative at http://www.networkadvertising.org/choices.
1.3 Log Files
Each time a page is called up or an action in App is completed, access data are saved in a protocol file, the server log. The data record thus saved contains the following data:
The product and version information of the “Kaizen Languages App” used (user agent).
AB Languages Limited uses a standardized webserver log file format for this purpose.
Provided these data are not urgently required for the technical maintenance of the system or for the system security, they are anonymized instantly and the original protocols are deleted. Anonymization takes place by removal or truncation of the IP address by allocating a code not assigned to a user. Any allocation to an identified or identifiable person is therefore no longer possible.
AB Languages Limited therefore uses the protocol data (logs) exclusively in anonymized form for statistical evaluations, hence without any allocation or references to your personal details. In this way, AB Languages Limited determines, for instance, on which days and at which times Kaizen Languages is particularly popular and what volume of data is generated on the Kaizen Languages’ web servers.
Furthermore, AB Languages Limited can detect possible errors through the log files, e.g. faulty links or program errors, and thus use the log files for the ongoing development and refinement of Kaizen Languages. AB Languages Limited does not link the page requests and usage information to individual persons.
1.4 Google Analytics
The Kaizen Languages website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how you use the site. As anonymization is activated for the data we collect, your IP address is truncated by Google within member states of the European Union or in other signatory countries to the Treaty creating the European Economic Area and only then is it transferred to the USA.
Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website in order to compile reports on website activity for the website operator and to provide other services relating to website activity and Internet usage. The IP address transferred by your browser within the scope of Google Analytics will not be combined with other data from Google. You may prevent the saving of cookies by selecting the appropriate settings on your browser; however, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent the data captured by the cookie and relating to your use of the website (incl. your IP address) from being captured and processed by
Google by downloading and installing the browser plugin available at the following link : http://tools.google.com/dlpage/gaoptout?hl=en.
Kaizen Languages uses Google Analytics exclusively in connection with the gat._anonymizeIp(); extension so that IP addresses are only recorded in truncated, i.e. anonymized form.
1.5 Social Plugins
Facebook Social Plugin
Social plugins (“plugins”) from the social network facebook.com (“Facebook”) are used on our website. Facebook is run by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304 in USA.
If you call up a page on our website or the ‘Kaizen Languages App’ (referred to henceforth as ‘the App’) containing such a plugin, your browser will establish a direct connection with Facebook’s servers. The contents of the plugin are transferred by Facebook directly to your browser which incorporates it in the website.
By incorporating the plugin, Facebook receives the information that you have called up the relevant page on our website. If you logged into Facebook, it can match your visit to your Facebook account.
The purpose of capturing data and the quantity of data collected including the way in which they are processed and used by Facebook and your rights in this regard and setting options to protect your privacy can be taken from Facebook’s data protection information at: http://www.facebook.com/policy.php
If you are a member of Facebook and you do not wish Facebook to collect data on you through our website and link them to your membership data stored by Facebook, you must log out of Facebook before visiting our website.
It is also possible to block Facebook social plugins through add-ons for your browser, e.g. through “Facebook Blocker”
1.6 Google Auth
When signing up to register with Kaizen Languages you may sign up with your Gmail account. Google controls your data and we can only see the following data as already provided to Google:
This method of sign up also provides any other fields completed in the sign up process such as (Language, Date of birth, username and user profile picture as provided to Google).
1.7 Facebook Auth
When signing up to register with Kaizen Languages you may sign up with your facebook account. Facebook controls your data and we can only see the following data as already provided to Facebook:
This method of sign up also provides any other fields completed in the sign up process such as (Language, Date of birth, username and user profile picture as provided to Facebook).
1.8 Email Auth
When signing up to register with Kaizen Languages you may sign up with an email address and password combination. This method of sign up provides us only with the email address in sign up and any other fields completed in the sign up process such as (Language, Date of birth and user name).
1.9 Further External Suppliers
We use further external service providers for the purpose of optimizing our services, carrying out advertising activities or for analyzing our website for errors and performance. Such service providers may vary. For the sake of clarity, we have listed these service providers in tabular format at the end of this data protection notice under Clause 8, and in each case we have supplied further information on the processing of data and on any opt-outs.
1.10 Image Uploads
Kaizen Languages users can upload images for their profiles. These images will be visible to other users.
1.11 Newsletters & Emails
We send you emails for a variety of reasons. These may include confirmations of an order or of a registration. However, communication may also concern information about our services, provided you have not revoked your consent for such usage, which you can of course do at any time within the Kaizen Languages App in “Settings/account”, at the bottom of all our email communications you may change your settings or email us at “email@example.com”. Any email messages we send are saved by us and any emails that may be regarded as business letters will not be deleted during the statutory retention period. We also record any email addresses to which a message could not be delivered in order to request an updated email address. Furthermore, in the case of our newsletter emails, we record (e.g. by means of a so-called “tracking pixel”) whether an email is opened and which links in the email are clicked on; we do so to optimize our offers and tailor their design to meet your needs. We use these data to enable us to send newsletter contents to match your profile. If you wish to object to this use of your data, you can do so by canceling our newsletters. We also use service providers from USA for sending our emails.
As well as our website, we also offer apps for various smartphone operating systems. Here too we collect data on the use of the application by means of software from external suppliers for the purpose of detecting and correcting errors and to improve our applications. However, no data are collected in the process from which any external supplier could directly establish any personal connection. In this way we receive aggregated information on how the apps are used and which features are especially popular, and from this information we can draw conclusions for future improvements in product development. You can prevent this analysis by changing this in “settings” on the mobile device on which the app is installed.
In addition, we will also be informed if apps crash - if you have enabled this through your device settings. These so-called crash reports are provided by external suppliers. However, no data are processed from which any external supplier could derive any personal connection.
1.13 Progress Scores
To enable Kaizen Languages’ users to conveniently revise their vocabulary, track lesson practice and review past lessons, all messages and results are saved for the individual user. These data can be viewed by other users only in the form of high scores, which do not indicate which specific words or sentences are being practiced but merely reveal how many exercises have been successfully completed.
2. Purpose of storing the data
The purpose of gathering, saving, processing and using the data is solely to facilitate, maintain and develop the “Kaizen Languages” service provided by AB Languages Limited. This also comprises of winning new customers and sales to existing ones. In particular, part of the ongoing development involves the use of anonymous statistics on the usage of the services.
3. No forwarding of data to third parties
AB Languages Limited does not forward the personal data of its users to third parties unless the user has given his/her explicit consent or there is a legal requirement to forward the data. Personal details may also be passed on to third parties if this is legally permissible, and it is necessary to pass them on for the fulfillment of our contractual obligations towards our customers. In the case of payment processing, the data for processing the payment transaction are forwarded to the payment services provider if you do not supply the data directly. If you send your payment data directly to the payment services provider, we receive only very limited data. In such cases, we are merely informed whether or not the transaction relating to a specific transaction number has actually taken place. In such cases we do not receive your account data. If any third-party rights have been violated (in particular rights relating to copyright, trademarks, names and symbols) by the user, the user data will not be forwarded to the rights holder unless the latter conclusively demonstrates his/her claims to AB Languages Limited.
As a matter of principle, AB Languages Limited is directed towards users who have reached the age of majority.. Any use by minors without the consent of their legal guardians is prohibited. AB Languages Limited therefore reserves the right to delete all data relating to underage users if no consent from the legal guardians is available.
5. Data security
AB Languages Limited employs safety precautions to guarantee that your data are protected against loss, modification or misuse. The user should be aware of the fact that one hundred percent protection against attacks cannot be guaranteed because of the continual appearance of new viruses and other means of attacking the protected data systems of Internet services. AB Languages Limited will instigate civil and criminal proceedings against any attack by hackers and the like and will inform the users of any cases in which their data have been compromised.
6. Information, correction and deletion
6.1. Right to information on stored data
Every user has the right to obtain information from AB Languages Limited on the personal data that has been saved in relation to him/her.
In the request for information, the user must additionally provide the following details for identification purposes: user name, first name and surname, email address and date of birth. The information is sent by email to the email address provided by the user.
If the user alters or corrects the details that he/she has provided and deletes old entries, the data previously entered by the user will be completely deleted automatically. An application for correction or deletion is not required. You can edit your personal data at any time in the “Kaizen Languages” app.
This notwithstanding, the user has the right at all times to demand the correction of any inaccurate data concerning him/her stored with AB Languages Limited. However, the easiest option is for users to correct any such entries themselves.
6.3. Deletion of data
Should the user demand any alteration, correction or deletion of his/her personal data, this may take place by email or within the “Kaizen Languages” App. To ensure correct identification of the user, the request must at least contain the following details:
Navigating to settings, account page then alter, correct or delete data.
The email must come from the email address associated with the “username” to the following email “firstname.lastname@example.org”.
Please note that due to caching systems, search engines, the interposition of proxy servers and the like, deleted data may continue to remain accessible even though they are no longer present within our systems.
The trust of our users is important to us. AB Languages Limited therefore wishes to provide its users with full information on the processing of their personal data at all times. If any queries remain unanswered by this privacy statement or if more detailed information is required on any point, please contact the following address at any time:
WeWork, 3 Waterhouse Square 138-142 Holborn, EC1N2SW, England, EC1N 2SW
8. External suppliers
With reference to Clause 1.9 you will find a list here of further external suppliers used for the website:
TrackJS (https://trackjs.com/privacy/ , https://trackjs.com/ )
Google AdWords (Marketing, campaign measurements, http://www.google.de/intl/de/policies/technologies/ads/)
Google Tag Manager (Marketing, http://www.google.com/policies/privacy/)
Facebook Pixel (http://www.facebook.com/policy.php)