Privacy Policy

Last updated: 2024-11-02

Secret SaaS OÜ may collect personal information about users of the websites and other domains operated by Secret SaaS OÜ and about users of our iPhone and Android mobile applications (“Secret SaaS OÜ Platform”). The collection and use of personal data allows us to provide you with the services offered through the Secret SaaS OÜ Platform, including Secret SaaS OÜ digital learning games, for the purpose of providing Secret SaaS OÜ games and courses targeted at users, as well as to enable you to purchase products offered through the Secret SaaS OÜ e-shop, to subscribe to digital learning games and other services offered through the Secret SaaS OÜ Platform, and to provide you with a better user experience on the Secret SaaS OÜ Platform. Secret SaaS OÜ collects and uses personal information in accordance with this Privacy Policy (“Privacy Policy”), which describes, among other things, the types of personal information that Secret SaaS OÜ collects, the purposes for which we use that information, and who has access to the personal information.

The Secret SaaS OÜ Platform Privacy Policy has been prepared and personal data are processed in accordance with the General Data Protection Regulation (EU) and the Personal Data Protection Act of the Republic of Estonia.

Please read this Privacy Policy attentively as it contains, among other things, important information about your rights as a data subject.

Data controller

The data controller for your personal data is Secret SaaS OÜ, registry code 14889603, address: Asunduse 15 - 58, Tallinn - 11416, Estonia (“Secret SaaS OÜ” or “we” or “us”).

1. The data we collect and how we use it?

For the purposes of this Privacy Policy, “personal data” means any data relating to an identified or identifiable natural person.

1.1 Secret SaaS OÜ Platform usage information

We continue to develop and improve the Secret SaaS OÜ Platform, the digital learning games offered and strive to make them more user-friendly and enjoyable. In order to do this, we need to know which information and digital learning games are of the greatest interest to users of the Secret SaaS OÜ Platform, how often users visit and browse the Secret SaaS OÜ Platform, which web browsers and/or devices are used, etc.

When you visit the Secret SaaS OÜ Platform or use the digital learning games, certain data may be collected without your knowledge using various technologies such as cookies, web tags and web beacons, and navigation data (log files, server logs, clickstream data, website scripts). Some of this information is sent automatically by your web browser or mobile device – for example, the URL of the website you are browsing or have previously visited, the IP address of your computer or mobile device and the version of the web browser you are currently using – as well as the time you arrived at the Secret SaaS OÜ Platform and the websites you specifically visit on the Secret SaaS OÜ Platform.

We use tools and instruments provided by various partners to collect and analyse data on the use of the Secret SaaS OÜ Platform and the digital learning games we offer. For a list of our partners, see Section 2 of the Privacy Policy.

The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the services to you (or the company you represent) on the Secret SaaS OÜ Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the Secret SaaS OÜ Platform and the services we provide.

1.2 Information related to the learning path service

In order to access and use the Secret SaaS OÜ Platform’s personalised learning path service, we may ask you to provide the nickname, age, gender and native language of the selected service user for the purpose of creating a personalised avatar for the service user (in particular if the user is a child).

As part of the provision of the Secret SaaS OÜ Platform personalised learning path service, we will additionally collect digital learning game usage data from the service user’s interaction with the Afrin Apps Platform in order to enable Secret SaaS OÜ to conduct learning analytics to better understand, personalise and optimise the service user’s learning methods. In addition to the data set out in Section 1.1 of the Privacy Policy, the digital learning game usage data that we collect when providing the personalised learning path service includes information about the various choices you make both when choosing a particular digital learning game and within that particular game, the duration of the game, the results and other data related to the digital learning game.

We use tools and instruments provided by various partners to collect and analyse information related to the Secret SaaS OÜ Platform personalised learning path service, including usage data of the selected digital learning game. For a list of our partners, see Section 2 of the Privacy Policy.

The legal basis for the collection of personal data is the performance of a contract or pre-contractual activity between us and you (or the company you represent) for the purpose of providing the personalised learning path service to you (or the company you represent) on the Secret SaaS OÜ Platform, or our legitimate interest where a contract has been or will be entered into between us and the company you represent, and/or our legitimate interest in further developing the Secret SaaS OÜ Platform and the personalised learning path service we provide.

1.3 Transaction data

When you place an order on and/or through the Secret SaaS OÜ Platform (for example, using the Google Play Store or App Store) for the purchase and use of a paid digital learning game, a personal learning path service, or any other service or product offered on the Secret SaaS OÜ e-shop, we may collect information about your payments and transactions and other information related to the transaction, such as the first name and surname and the date of birth of the person placing the order, the name of the organisation being represented (if the order is placed on behalf of a legal entity), telephone number, e-mail address and other contact details, payment method, bank account number and holder, bank name, delivery address and other relevant information relating to the order.

The legal basis for the collection of transaction data is the performance of a contract between us and you as an individual, or our legitimate interest where the contract is between us and a company you represent.

We also process the personal data we collect to comply with our obligations under applicable accounting and tax laws. In this case, the processing of personal data is based on the legal provisions that require us to process personal data.

1.4 Queries and answers

If you send us a query via the Secret SaaS OÜ Platform, we will process your contact details and the content of the query in order to respond to it.

The legal basis for the collection of this information is our legitimate interest in responding to your queries about us and the services we provide.

1.5 Data relating to legal requirements

Where necessary, we may process personal data in order to pursue our legitimate interest in bringing, prosecuting or defending legal claims arising out of any contract between us and you (or the company you represent).

1.6 Direct marketing

If you consent to receive push notifications and/or e-mails from the Secret SaaS OÜ Platform mobile apps by entering your e-mail address, we may use the push notifications from the mobile apps and/or your e-mail address to send you news, offers and other marketing communications.

The legal basis for sending you direct marketing content is your consent or our legitimate interest in promoting the Secret SaaS OÜ Platform and providing you with information about Secret SaaS OÜ and the services offered on the Secret SaaS OÜ Platform. You have the right to withdraw your consent to receiving direct marketing materials at any time by contacting us by e-mail at support@learnwithparam.com and/or by opting out of receiving push notifications on the Afrin Apps Platform mobile app. You may also opt-out of the use of your e-mail for direct marketing by clicking the opt-out link in the message you have received from us.

1.7 Cookies

What are cookies?

Cookies are small text files that the Secret SaaS OÜ Platform may store on your device during your visit. Cookies can be used to remember your choices and preferences to make it easier for you to use the Secret SaaS OÜ Platform, so that you do not have to re-enter them on each visit or each website.

What kind of cookies do we use?

The Secret SaaS OÜ Platform uses cookies to store your IP address and browsing information, including information about the websites you visit and the time you spend on them, as well as information about the device you use and your preferences for using the Secret SaaS OÜ Platform.

We also use cookies to track web traffic, application and user activity on the Secret SaaS OÜ Platform – we use this information to analyse visitor behaviour and provide a better user experience.

Cookies help us:

provide you with a better user experience when visiting the Afrin Apps Platform;

enable you to set personal preferences;

collect statistics on the use of the Secret SaaS OÜ Platform; and

measure the effectiveness of advertising.

We use the following types of cookies on the Secret SaaS OÜ Platform:

Functionality cookies: Functionality cookies are necessary to enable you to navigate the Secret SaaS OÜ Platform and use its features.

Statistical cookies: Statistical cookies collect anonymous statistics about how users use the Secret SaaS OÜ Platform mobile applications. Statistical cookies may, for example, help us to understand how users browse and use the Secret SaaS OÜ Platform mobile applications and which parts of it are most used. Statistical cookies are stored on your device and used only with your consent.

How long will cookies stay on my device? Cookies fall into two categories, depending on how long they stay on your device.

Session cookies: Session cookies are only created for the duration of the session and are kept on your device until you close the browser or mobile app. Session cookies are not stored on your device’s hard drive.

Persistent cookies: Persistent cookies are stored on your hard drive until you delete them or they expire. We can retain data from persistent cookies for a maximum of 2 years. Cookies will only be stored on your device with your consent, except for cookies that are only necessary for the technical functioning of the Secret SaaS OÜ Platform. Please note, however, that if you do not consent to the use of cookies, you may not be able to use certain features of the Secret SaaS OÜ Platform. Please also be advised that third parties (such as advertising networks and web traffic analysers and other external service providers) may use cookies over which we have no control.

How do I manage cookies? You can manage and/or delete cookies at your discretion – see www.youronlinechoices.com for more details. You have the option to delete all cookies on your device, and most web browsers can be set to refuse cookies. However, if you do so, certain preferences may need to be manually re-entered each time you visit and some services and features may not function.

2. Transmission and publication of personal data

We will do everything in our power to keep your personal data safe, and we demand strict security and confidentiality from our employees and partners.

We may disclose your personal information:

– to your trusted service providers who provide services to us or to you as processors under our instructions. We will always control and be responsible for the use of your personal data;

– to public authorities, where required to do so by law or where a lawful request for information is made to us by a public authority; and

– in relation to our merger, acquisition or sale of our business or a part thereof.

As of the “last updated” date indicated in the header of this Privacy Policy, we use the following processors for the relevant purposes:

– Google Analytics, which provides us with analytics services to track users’ navigation and usage data on the Secret SaaS OÜ Platform mobile applications;

– Google Play Store, App Store and lemonsqueezy, which provide us with payment services to enable you to make payments on and/or through the Secret SaaS OÜ Platform to subscribe to and purchase digital learning games, any services and products available in our e-shop.

– Facebook SDK and Firebase Analytics, which provides us with a service to analyse users’ mobile app downloads from the Secret SaaS OÜ Platform;

– Firebase Crashlytics, which provides us with a service to analyse users’ mobile app crashes on the Secret SaaS OÜ Platform;

– Firebase Cloud, which provides us with a service to send push notifications, user authentication of the Secret SaaS OÜ Platform mobile applications;

We may further disclose your personal information:

– to Secret SaaS OÜ employees responsible for customer care and supporting customer relationships, as well as to employees in accounting, IT maintenance, business analysis and planning functions;

– to suppliers of the IT systems and cloud service providers we use to manage our customer interactions, and to our auditors;

– to banks;

– to our processors and other persons involved in the performance of the contract;

– to parties helping us to exercise our rights under the contract (debt recovery service providers, legal advisers, courts, credit reference agencies, etc.);

– to parties involved in any merger, acquisition or sale of all or part of our assets.

We do not transfer your personal data outside the European Union or the European Economic Area.

3. How long do we retain your personal data?

We will only retain your personal data for as long as necessary to achieve the purposes described in the Privacy Policy or as required by law. Most of your personal data will be stored until the end of the customer relationship between you and Secret SaaS OÜ.

Certain personal data may be retained after the end of the customer relationship if required or permitted by applicable law. For example, we will keep basic accounting documents (such as copies of contracts and invoices) for 7 years from the end of the relevant financial year, as required by applicable law. We will retain your personal data relating to the contract for 10 years from the date of termination of the contract, subject to a maximum limitation period in case of intentional breach.

When the retention of your personal data is no longer required by law or necessary for the exercise of the rights or obligations of either party, we will permanently delete your personal data, unless you have instructed us otherwise and we have entered into an agreement for longer-term data retention.

4. Updating the Privacy Policy

We may update this Privacy Policy from time to time. We will notify you on the Secret SaaS OÜ Platform when we update the Privacy Policy. This Privacy Policy was last updated on the “last updated” date above.

5. Your rights

You have the right to access the personal data we process by requesting access to it. To the extent permitted by law, you have the right of access to, and the right to rectify, update, amend or erase your data.

If your personal data are deleted at your request, we will only retain copies of them if this is necessary to protect our legitimate interests and those of third parties, to comply with instructions from public authorities, to resolve disputes, to troubleshoot problems or to enforce contracts we have entered into with you. Please note, however, that certain personal data are strictly necessary or required by law in order to achieve the purposes described in this Privacy Policy. You will not be able to delete this information.

Where the processing of personal data is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing of personal data that was carried out on the basis of consent prior to the withdrawal.

Subject to the conditions set out in the legislation on the protection of personal data, in certain cases you have the right to request the restriction of the processing of your personal data and also to object to the processing of certain personal data.

Subject to the conditions set out in the data protection legislation, you have the right to data portability, i.e. the right to receive your personal data in an organised form in a commonly used machine-readable format and to transfer it to another controller at your own discretion.

For requests to exercise any of the above rights, please contact us at support@learnwithparam.com. If you feel that we are not processing your personal data properly, you have the right to lodge a complaint with your national data protection authority. In Estonia, this is the Data Protection Inspectorate. Contact details for the Data Protection Inspectorate can be found here: https://www.aki.ee/en.

6. Security

We use appropriate organisational, technical and organisational security measures (including physical, electronic and administrative) to protect personal data against loss, destruction, misuse and unauthorised access or disclosure. For example, we only give access to your personal data to authorised employees and contractors who need them to perform their duties.

Please note that while we strive to take reasonable measures to protect the security of your personal data, no system can completely eliminate all possible security risks.

7. Secret SaaS OÜ contacts

If you have any questions about this Privacy Policy or the personal data we process about you, please contact us at support@learnwithparam.com.