The processing and collecting of personal data by NovaKid shall be in harmony with the directly applicable data protection laws in effect:
The Company is the data controller of any data which constitutes personal data, and which is uploaded when using our services
The Company bound in honor to protect personal data, especially children’s personal data; therefore, the Company will keep confidential the personal data received and take all necessary steps to secure data processing.
‘personal data’: shall mean 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;
‘consent’: shall mean any freely given, specific, informed and unambiguous indication of the will of the Data Subject 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;
‘data controller’: shall mean 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 processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
‘data processing’: shall mean 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;
‘data processor’: shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘third party’: shall mean 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;‘personal data breach’: shall mean a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
‘recipient’: shall mean 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 European 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;
‘supervisory authority’: shall mean one or more independent public authorities provided by each Member State which is responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the European Union;
‘supervisory authority concerned’: shall mean a supervisory authority which is concerned by the processing of personal data because: (a) the controller or processor is established on the territory of the Member State of that supervisory authority; (b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or (c) a complaint has been lodged with that supervisory authority.
Please note that the e-mail address provided does not require the inclusion of personal data, such as your name. You are free to choose an e-mail address that contains information about your identity.
After the Registration you must add the following personal data to your NovaKid Account in order to use our services:
4.1. We process the following personal data for the purpose and on the legal basis of the performance of the contract, product and service fulfillment:
4.2. We process the following personal information based on the legitimate interest of the Company (as the legal basis of this processing) for marketing purposes and to deliver e-mails:
4.3. We process personal data for the purpose and on the legal basis of compliance with legal obligations to prevent fraudulent transactions, monitor against theft and otherwise protect our customers and our business. We also process personal data for the purpose and on the legal basis of legal compliance and to assist law enforcement and respond to subpoenas.
This means that in some cases the data processing is stipulated by the applicable laws and we have an obligation to process and keep this data for the required time. This includes employment data, billing data, data which is necessary to assist law enforcement etc.
4.4. We process the following personal data for the purpose and on the legal basis of the legitimate interests of the Company, to improve the effectiveness of the Website, our services, and marketing efforts, to conduct research and analysis, including focus groups and surveys and to perform other business activities as needed, or as described elsewhere in this Policy:
|Google Analytics and Google AdWords (Google LLC.)||1600 Amphitheatre Parkway Mountain View, CA 94043||United States of America|
|Facebook pixel (Facebook Inc.)||1601 Willow Road Menlo Park, CA 94025||United States of America|
|The Rocket Science Group, LLC (MailChimp)||675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308||United States of America|
|Microsoft Corp||1 Microsoft Way Redmond, WA 98052||United States of America|
|Yandex, LLC.||16, Leo Tolstoy Street Moscow, 119021||Russian Federation|
6.1. NovaKid shall not ensure access for a third party to personal data provided by you without your preliminary consent, except the cases, when data transfer is necessary for the performance of the contract or for enforcing of NovaKid’s legitimate interest or prescribed by law.
6.2. Every teacher working for NovaKid is considered as a data processor according to the regulations of the GDPR. The teachers have access only to the personal data of the children they are teaching in order to minimize the processing of personal data.
6.3. NovaKid may share certain personal information with third party vendors in the EU or in third countries, who supply software applications, web hosting and other technologies or services for the Website and our services (hereinafter: “Data Processor”). The Company will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website and our services. During the service of data process, the Data Processor shall abide under the present Policy, relevant legislations in force, furthermore the provisions of the existing contracts between him and NovaKid.We use the data process service of the following Data Processors:
|Name||Registered seat||Country||Activity (data processing service)|
|Amazon Data Services Ireland Ltd.||1 Burlington Plaza Burlington Road Dublin 4, D04RH96||Ireland||Server service|
|Google LLC (Google Cloud, Google Drive)||1600 Amphitheatre Pkwy, Mountain View,California 94043||USA||Cloud services|
|PayPal (Europe) S.à r.l.||22-24, boulevard Royal L-2449 Luxembourg||Luxembourg||Payment services|
|Stripe, Inc.||510 Townsend Street San Francisco, CA 94103||USA||Payment services|
|Intercom, Inc.||55 2nd Street, 4th Floor, San Francisco, CA 94105||USA||Customer Support Services|
|CM.COM Netherlands B.V.||Konijnenberg 30 4825 BD BREDA||Netherlands||CSMS gateway services|
|IP Telecom Bulgaria LTD (Zadarma.com)||floor 2, 2 Vasil Aprilov, Bourgas, 8000||Bulgaria||Virtual phone systems|
|Atlassian Corporation PLC||341 George Street Level 6, Sydney, NSW 2000||Australia||Software development tool and cloud services|
|Trustpilot A/S||Pilestraede 58, 5th floor, DK-1112 Copenhagen K||Denmark||Consumer reviewing services|
|SMS-CENTRE LTD||155 Arch. Makariou III Avenue PROTEAS HOUSE, 5th floor, 3026 Limassol||Cyprus||SMS gateway services|
6.5. We only transfer personal data collected from individuals located within the EU only with the consent of the individuals to a third-party having a registered seat outside the EU / in the USA in the USA acting as a data processor without the appropriate safeguards set out in the GDPR, or when it is necessary for the performance of the contract. NovaKid will make every effort to ensure that the personal data transferred is safe and secure and that the personal data is processed in a manner consistent with the GDPR
This Policy and NovaKid’ privacy practices are in accordance with the United State’s Children's Online Privacy Protection Act 1998 (“COPPA”) as well as the Council of Europe’s Recommendation CM/Rec(2018)7 of the Committee of Ministers to member States on Guidelines to respect, protect and fulfil the rights of the child in the digital environment (“Guidelines”).
For information on how to protect your child’s privacy online please make sure to read the following documents before Registering on the Website:
8.3. At any time, you can withdraw your consent of NovaKid collecting further personal information from your child and can request that we delete the personal information we have collected in connection with you or your child from our records. You can request the deletion of your data by connecting NovaKid via the chat services after you logged in. Please keep in mind that a request to delete records may lead to termination of your Account Account which disables the accessibility of Online Classes in the future.
8.4. As your and your child’s personal data are processed by the Teachers of NovaKid, we concluded a data processing contract with them in order to prevent fraudulent or inappropriate activities as well as to regulate the Teacher’s data processing activities the providing of our Services. If you think that a Teacher steps over legal and/or ethical limitations during the data processing or he or she processes your data incorrectly or unlawfully, please contact us at firstname.lastname@example.org.
We encourage you to contact us at email@example.com with your questions or concerns, or to request edits to your and your child’s personal information, or to have it removed from our database. Requests to access, change or remove to any personal you provided to us will be handled within 30 days.
For any complaints that we can’t resolve directly, please contact our European Representative Weiszbart and Partners Law Firm (address: 1052 Budapest, Kristóf tér 3. III. flr., Hungary; e-mail address: firstname.lastname@example.org).
If you don’t agree with our decision, you have the right to an effective judicial remedy or to lodge a complaint to any European Data Protection Authority. You also have the right to complain to complain to the EU Data Protection Authority about our collection and use of your personal data. For more information, please contact your local EU Data Protection Authority. The list of European National Data Protection Authorities can be found here.
We will not share any personal data with third parties for their direct marketing purposes to the extent prohibited by California Consumer Privacy Act of 2018 (CCPA). If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
Previous version: 30/09/2021