Data controller: DuoCards s.r.o., limited liability company existing under the laws of Czech Republic, with its registered office at Hluboká 91/18, Štýřice, 639 00 Brno, Czech Republic, ID No.: 08212571, registered in the Commercial Register at the Municipal Court in Brno under No. C 112470 (“we”).
Welcome to DuoCards! We are here to improve your language with our flashcard app DuoCards (the „App„). Our App is available on Google Play and App Store and also may be accessed via website https://duocards.com/en/.
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”).
By this privacy policy, we would like to inform you about how we process your personal data and provide you with all relevant information required by the GDPR.
PERSONAL DATA PROCESSED
We process personal data mainly during usage of our App. For better clarity, we divided personal data into these categories:
- E-mail address and contact info such as your e-mail address, contact detail that you provide us with via contact form on our website.
- User account content such as information you provide us when you sign up in the App, password (hashed), communication, your progress in the App, answers, created content and other information you provide us.
- Purchases information, such as payments made and records of payments made.
- Communication data such as information about communications with you, such as e-mails, chats via Chatbot, content of contact forms, etc.
- Usage data, such as launches, taps, clicks, scrolling, views, listens, information about how you interact with the App, your activity in the App, IP address, device name, operating system version, other device information etc.
- Diagnostics data, such as crash logs, launch time, energy use, technical information about your device.
- Cookie data such as data obtained from cookies and similar technologies that we use. We collect this data mainly to ensure the basic functioning of the App, its stability and security, and to improve the user experience.
Please, do not use our App to upload any sensitive information about you, such as health data, genetic data, biometric data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning sexual orientation.
The App is not designated for children. The App is not addressed to anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
Personal data is obtained directly from you or your device while using our App. There is an exception that we may collect personal data also from other sources. When you use Google Login or Apple Login (or other available logins) when registering account, we will use Google or Apple services (or other services) to authenticate you and enable you to share E-mail address and contact info with us (our App).
PURPOSES OF THE PROCESSING OF PERSONAL DATA
We process your personal data as a data controller for the processing purposes, legal bases and periods set out below.
Provision of the App functionalities
We primarily process personal data to provide you with our App and to treat you as a customer, when you download the App and agree with our Terms & Conditions, register your account through third-party services, or when you purchase our paid services connected (via payments methods available in the App). Personal data is processed to authenticate you as the user, enable our features, share information with friends, ensure functionality of our App. As part of this, we may also send you messages about the performance of a contract, new product and service releases, payment reminders or approvals, etc.
For this purpose, we process these categories of personal data:
- E-mail address and contact info
- User account content
- Purchases information
- Communication data
- Usage data
- Diagnostics data
- Cookies data
The legal basis for this processing is the performance of the contract between you and us and the need to take steps at your request before entering the contract.
The data are processed for the duration of the mutual relationship and for the period necessary for the performance of the obligations under such contract. When you decide to delete your account (which is available in the App), we will delete all information about your User account content, Usage data, E-mail address and contact info, if not needed for fulfillment of legal obligations.
Registering an account is not required and you may also use our App without registration. In such case, we may still process Usage data, Diagnostics data and User account content that is gathered through usage of our App. The legal basis is performance of the contract and personal data are processed until you delete the App or request deleting data through the App.
Improving our App and analytics
We may process data about how you use our App, what features you use most, effectiveness of features etc., so that we can better understand how you use them and trends in their use and then improve and further develop them to your satisfaction.
For this purpose, we process these categories of personal data:
- User account content
- Usage Data
- Diagnostics data
- Cookies data
The legal basis for this processing is our legitimate interest in improving our App, and the data is processed for a maximum of 3 years from the date of collection.
Internal records, statistics, and protection of our rights
We may process your data for the purposes of keeping internal records within our company, recording paid subscription, producing statistical reports, protecting our rights and legal claims, and to ensure that only you use our App in accordance with their terms.
For this purpose, we process these categories of personal data:
- E-mail address and contact info
- User account content
- Purchases information
- Communication data
- Usage data
- Diagnostics data
- Cookies data
The legal basis for this processing is our legitimate interest in keeping internal records, statistics, and the protection of our rights. The data is processed until a maximum of 10 years after the termination of the concluded contract (or longer in the event of a dispute).
Newsletters
We may process the data you provide when you register in our App to inform you about DuoCards, services or promotions, news, announcements, etc.
For this purpose, we process these categories of personal data:
- E-mail address and contact info
The legal basis for this processing is our legitimate interest in supporting and promoting our products and services. The data is processed until a maximum of 3 years after the last e-mail we have sent you.
In addition to objecting to the processing of data for this purpose, you may opt out of receiving any newsletters at any time by using the unsubscribe links provided in the footer of each message sent.
Fulfilling legal obligations
We may also process your personal data in order to comply with our legal obligations, particularly in the area of tax and accounting. At the same time, we need to be prepared to provide cooperation to state authorities if we are required to do so by law.
For this purpose, we process these categories of personal data:
- User account content
- E-mail address and contact info
- Purchases information
The legal basis for this processing is the fulfilment of our legal obligations. The data is processed for the period required by law.
Mutual communication
We may also process your personal data in order to answer your questions and other messages made via our Contact form.
For this purpose, we process these categories of personal data:
- E-mail address and contact info
- Communication data
The legal basis for this processing is our legitimate interest to answer your questions and ensure our communication. If you are our customer, your personal data may be also processed for the purpose of fulfillment of the contract. The data is processed for the period required to answer your questions.
App operation and security (a necessity)
We process your personal data for the operation of the App and its security, i.e., for the presentation of information in the App, the internal functioning of the App, your identification as a user when using and repeated visits to the App, and for ensuring your security.
For this purpose, we process your:
- Usage data
- Diagnostics data
- Cookie data
The legal basis for this processing is our legitimate interest in the proper functioning and safe operation of our App. Data are processed, as a rule, for the duration of your visit to the App, for a maximum of 1 year from the date of collection.
Analysis of App traffic (analytics)
We may also process Cookies data for the purpose of analytics, which facilitates us to make more detailed analyses of your visits of the App (analytical cookies), in which case your personal data may also be transferred to third parties. The legal basis for processing here is thus your consent given via pop-up field when using App. The personal data is processed until your consent is withdrawn, but in any case, until a maximum of 1 year after your visit to the App.
We use Google Analytics and cookies connected with other Google services (such as YouTube). List of cookies is available here. Here are also YouTube API Services terms: https://www.youtube.com/t/terms.
SHARING OF PERSONAL DATA
We may share personal information with third parties who help us provide our App to you. These parties are so-called personal data recipients and may process your personal data:
- Amazon Web Services EMEA SARL which provides us with Amazon SES for sending e-mails (mainly in connection with contract and newsletters). Data may be also shared with Amazon.com, Inc. which is registered under Data Privacy Framework here.
- Apple and Google, according to from which store you download the App and whether you share your information from those services.
- AppsFlyer UK Ltd., the company is seated in the UK and there is adequacy decision for such sharing.
- Google Ireland Limited providing us with analytics, technical, security services. Even if the data are shared with Google LLC, the company is registered under Data Privacy Framework here.
- Heroku, Inc., providing us with hosting and storage services. The company is registered under Data Privacy Framework here.
- Sentry.io, that helps us with collection of the Diagnostics data and error reporting. The company is registered under Data Privacy Framework here.
In addition to this, if we process your personal data for fulfilling legal obligations, we may share your personal data with certain third parties as data controllers for this purpose where we are obliged to do so under applicable legislation (in particular, administrative authorities, police authorities and judicial authorities). Similarly, we may be obliged to share your data with persons who claim to have been harmed by your conduct.
Where we share your personal data with controllers and processors in third countries (outside the EEA), we only do so where there is a decision by the European Commission that a particular country outside the EEA provides an adequate level of data protection, including where controllers or processors have adopted additional data protection measures such as Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SC
Cs).
YOUR RIGHTS IN PROCESSING AND THE POSSIBILITY OF EXERCISING THEM
Just as we have rights and obligations when processing your personal data, you have certain rights when processing your personal data as set out in the following paragraphs. You have the right to:
- request access to your personal data;
- withdraw your consent;
- request rectification of your personal data;
- request erasure of your personal data;
- request restriction of the processing of your personal data;
- request portability of your personal data;
- object to the processing of your personal data; or
- lodge a complaint with the relevant supervisory authority.
In all matters related to the processing of your personal data, whether it is a question, the exercise of rights, sending a complaint to our hands, etc., you can contact us via our Contact form or at info@duocards.com.
Your request will be processed without undue delay, at most within 1 month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further 2 months. We will, of course, always inform you of any such extension and the reason for it.
You also have the right to lodge a complaint with the supervisory authority as described below.
Right of access
You have the right to obtain confirmation from us as to whether or not we are processing your personal data.
If we process your personal data, you also have the right to request access to information about the purpose and scope of the processing, the recipients of the data, the duration of the processing, the right to rectification, erasure, restriction of processing and to object to the processing, the right to lodge a complaint with a supervisory authority and the sources of the personal data (this information is already provided in this document).
You can also ask us for a copy of the personal data we process. We provide the first copy free of charge; further copies may be subject to a fee. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.
Right to withdraw consent
You have the right to withdraw your consent to the processing of personal data at any time. However, the withdrawal of consent does not affect the lawfulness of the processing prior to such consent, nor does it lead to the termination of the processing of personal data that has already been anonymized.
Right to repair
You have the right to request us to correct inaccurate personal data concerning you. Depending on the purpose of the processing, you may also have the right to have incomplete personal data completed, including by providing an additional declaration.
Right to erasure (right to be forgotten)
You have the right to request the deletion of your personal data in cases where:
- we no longer need your personal data for the purposes for which it was collected or processed;
- you withdraw the consent on the basis of which the personal data was processed and there is no further reason for processing it;
- you object to processing and there are no other overriding reasons for processing, or you object to processing for direct marketing purposes;
- personal data is processed in violation of the law.
However, you cannot exercise this right where the processing is necessary for compliance with our legal obligations or tasks entrusted to us in the public interest or for the establishment, exercise, or defense of legal claims.
Right to restriction of processing
You have the right to request restriction of the processing of your personal data in cases where:
- you contest the accuracy of your personal data; in this case, you may request a restriction of processing until the accuracy of the personal data has been verified;
- the processing is contrary to the law and instead of erasure, you request a restriction of the processing of personal data;
- we no longer need your personal data for the purposes for which it was collected or processed, but you require it for the establishment, exercise, or defense of legal claims;
- you have objected to the processing of your personal data; in this case, you may request a restriction of processing until it is verified that our legitimate interests prevail.
Right to portability
You have the right to obtain a copy of your personal data that we process by automated means on the basis of your consent or for the performance of a contract. We will transmit this data in a commonly used and machine-readable format to you or to a controller designated by you, if technically feasible. The scope of the data provided may be limited so as not to interfere with the rights and freedoms of others.
Right to object
You have the right to object to the processing of your personal data that we process on the basis of our legitimate interest. We will stop processing your data if there are no other overriding reasons for processing or if the processing is not necessary for the establishment, exercise, or defense of legal claims or if you object to processing for direct marketing purposes.
RIGHT TO FILE A COMPLAINT
In addition to the possibility of exercising your rights with our company, you can also file a complaint with the relevant supervisory authority, which is the Office for Personal Data Protection located at Pplk. Sochora 27, 170 00 Prague 7.
CHANGES TO THIS INFORMATION
This processing information is effective as of 01. 01. 2024. We are entitled to change this processing information from time to time, in particular due to changes in our processing activities or in the legal regulation of personal data protection. The current version of this processing information is always available on our website.
