Privacy Policy 02.2019

This Policy is effective as of and was last updated on March 18, 2019 and is applicable to all users of the website www.smart-prep.com (“Website”) and/or web app www.app.smart-prep.com (“Web App”).

Hsquared Education GmbH (“Company”) respects the privacy of its users whether they use the Website to purchase SMARTPREP Products or simply to view the Website and/or Web App. The following privacy policy of Hsquared Education GmbH (“Privacy Policy”) is designed to inform you, as a user of the Website and/or Web App, about the types of information that Hsquared Education GmbH, Auenstraße 100, 80469 Munich, Germany (“Company”) may gather about or collect from you in connection with your use of the Website and/or Web App. It is also intended to explain the conditions under which the Company uses and discloses that information, and your rights in relation to that information. 

To learn more about our compliance and approach to the General Data Protection Regulation, known as GDPR, please visit our GDPR page here.

 

  1. Who is responsible? 

Hsquared Education GmbH, Auenstraße 100, 80469 München, Germany is responsible data controller for processing of personal data on this Website/Web App and in context of Services used and Products purchased through the Website. If you have any questions please contact us at:

info@smart-prep.com

or mail us at:

Hsquared Education GmbH
Auenstraße 100
80469 München
Germany 

 

  1. Personal Information We Collect

2.1 Which personal information do we collect?

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers email address, and phone number).  We refer to this information as “Order Information.”

Also, we save the data you provide when creating an account on our Website or on the Web App. We refer to this information as “User Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking  about Device Information, Order Information and User Information.

2.2 How do we use your personal information?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use Order Information:

  • To communicate with you;
  • To screen our orders for potential risk or fraud; and
  • To, with your consent and in line with the preferences you have shared with us, provide you with information or partner updates relating to our products or services.

We use User Information:

  • To communicate with you;
  • To provide our service;
  • If it is vital to the integrity or security of the service;
  • To analyze or evaluate the quality of the service provided; and
  • To, with your consent and in line with the preferences you have shared with us, provide you with information or partner updates relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

2.3 How do I withdraw my consent?

If, after opting in you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by using automated unsubscribe procedures, if existent, or by contacting us at:

info@smart-prep.com

or mailing us at:

Hsquared Education GmbH
Auenstraße 100
80469 München
Germany

2.4 Data and Third-Party Providers

We may share your Personal Information with third parties to help us use your Personal Information, as described above.

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.

In particular, remember that certain providers may be located or have facilities that are located in a different jurisdiction than either you or us. So if you select 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.

Once you leave our website or are redirected to a third-party website or application, you are no longer protected by this Privacy Policy or governed by our Website’s Terms of Service.

2.5 How do we disclose personal data?

We do not sell or rent your Personal Data processed via our Site. However, we may disclose your information to:

  • Service Providers. If necessary, we disclose the Personal Data we process to third-party vendors, service providers, contractors or agents who support us in providing our services to you. Their use of your data is governed by Data Processing Agreements we have in place with them.
  • In Response to Legal Process. We disclose the Personal Data we process in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
  • To Protect Us and Others. We disclose the Personal Data we process where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
  • Aggregate and De-Identified Information. We share aggregate and de-identified information with third parties for marketing, advertising, or research purposes.

Some recipients listed above may be located in countries outside of the EEA that do not offer the same level of protection with respect to personal data as required in the EEA and where there is no adequacy decision by the European Commission. We take a variety of steps to help ensure your rights and protections travel with your Personal Data. If you have any inquiries about our handling of your Personal Data please contact us at:

info@smart-prep.com

or mail us at:

Hsquared Education GmbH
Auenstraße 100
80469 München
Germany

 

  1. Website

3.1 Where is our Website hosted?

Our Website is hosted on Shopify Data Processing USA Inc. in the USA as data processor. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

For more insight, you may also want to read Shopify’s Terms of Service here or Privacy Statement here

 

  1. Web App

4.1 Where is our Web App hosted?

Our Web App is hosted on Hetzner Online GmbH in Germany. They provide us with the server that allows us to make available our Web App to you. 

For more insight, you may also want to read Hetzner's Terms of Service here or Privacy Statement here.

 

  1. Links

When you click on links on our Website and/or Web App, they may direct you away from our Website and/or Web App. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

 

  1. Security

We have implemented safeguards to help protect the privacy of your Personal Data you transmit through use of our Site. However, no information transmitted online or stored electronically is 100% secure. We encourage you to use caution when disclosing information online. Often, you are in the best situation to protect yourself online. You are responsible for protecting your username and password from third-party access, and for selecting passwords that are secure. 

 

  1. Cookies

7.1 Use of Cookies

As part of our Website and/or Web App, we use so-called “Cookies” or other instruments to analyze the usage of our Website and/or Web App. Cookies are small files that are stored on the hard drive of your computer, and which send us certain information. This information includes your computer’s internet protocol (IP) address, your browser, the complete uniform resource locators (URL) clickstream (the order in which you visit pages on our Website and/or Web App), the date, the time and duration of your visit as well as the cookie-number.

Cookies and similar instruments enable us to recognize you the next time you visit our Website and/or Web App and help us adapt our Website to your needs. We also use Cookies to measure the frequency of Website and/or Web App hits, monitor the general navigation of our Website and/or Web App and, where necessary, create encrypted user profiles. 

When you visit our Website and/or Web App, we will ask you to consent to the use of cookies in context of your visit of the Website and/or Web App. If you do not wish that cookies are placed on your computer, please do not use the Website and/or Web App or turn off the “accept cookies” function of your browser. Note, however, that you will not be able to use all functionalities of our Website and/or Web App if cookies are turned off. 

7.2 What Cookies do we use?

Here is a list of Cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of Cookies or not.

7.2.1 Cookies on our Website

We are using Shopify as a platform to power our Website. Please check their Cookie Policy page to learn more about the types of cookies and other tracking technologies that may be placed on your device when using our Website.

7.2.2 Cookies on our Web App

*Cookie Banner*
Name: complianceCookie
Purpose: stores whether the user has accepted the terms (clicked ok) from the cookie banner
Category: strictly necessary
Lifespan: 14 days

*Google Analytics cookies*
Names: _ga, _gid
Purpose: google analytics tracking (anonymise IP enabled)
Category: functional cookies
Lifespan: 2 years, 24 hours

*User Device ID*
Name: smtp-device-id
Purpose: stores a unique id of the device used by the user, used to know how many devices are used simulateously (limited to 2)
Category: strictly necessary

*User Session*
Name: smpp-credentials
Purpose: holds the currently logged in user session tokens
Category: strictly necessary

*Last flashcard visited*
Name: smpp-last-flashcard-(USER_ID)
Purpose: Holds the id of the last flashcard visited by the user, to allow the user to continue where he left off
Category: strictly necessary

*Last subject visited*
Name: smpp-last-subject-visited-(USER_ID)
Purpose: Holds the id of the last subject visited by the user, to allow the user to continue where he left off
Category: strictly necessary

*Tutorial popup*
Name: smpp-hide-tutorial-popup
Purpose: stores whether the user has seen the tutorial popup
Category: strictly necessary

*Add to home screen popup*
Name: smpp-shown-notif
Purpose: stores whether the user has seen the add to home screen popup
Category: strictly necessary

7.3 Use of Google Analytics

We makes use of Google Analytics on our Website and/or Web App and point out the following on demand of the company Google Inc.: This Website and/or Web App uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics also uses "Cookies", which are text files placed on your computer, to help the Website and/or Web App analyze how users use the Website and/or Web App. The information generated by the Cookie about your use of the Website and/or Web App (including your IP address) will be transmitted to and stored by Google on servers in the United States. Please note that on this Website and/or Web App, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking). This means that Google will truncate/cut off the last octet of the IP address for users from Member States of the European Union or the European Economic Area before storing it. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use 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 and/or Web App. By using this Website and/or Web App, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

Please note that on this Website and/or Web App, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking).

7.4 Controlling Cookies

You can control and/or delete cookies as you wish by checking your browser settings on each device - for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.  

 

  1. Social Media

8.1 Use of Facebook Social Plugins

This Website and/or Web App uses social plugins (“plugins”) from the social network facebook.com, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, United States (“Facebook”). The plugins are identifiable by one of the Facebook logos (white “f” on blue tile or a “thumbs-up” sign) or the description “Facebook Social Plugin”. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins

The functions assigned to the Facebook links, in particular the transfer of information and user data, do not become active just by visiting our Website and/or Web App, but only when you activate the respective buttons.
Only when you click on the button, it becomes active and the Facebook plug-ins are activated. Your browser then sets up a direct link to the Facebook servers.
Facebook then gets the information that you have accessed this Website and/or Web App with your IP address.
If you are logged in on Facebook, your visit can be associated to your Facebook account.
If you interact with the plug-ins, for example, if you click on the 'Like' button or post a comment, the corresponding information is transmitted directly from your browser to Facebook and saved there.

As the transmission is direct, we obtain no information as to the data transferred.
For information on the purpose and extent of data capture by Facebook and the further processing and use of the data by Facebook as well your rights in this regard and setting options for the protection of your personal privacy, please refer to the Facebook data protection information at http://www.facebook.com/policy.php.

8.2 Use of Google “Add”-Button

Our Website and/or Web App uses the “Add” button from the social network Google Plus, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”). The button is identifiable by the “Add″ sign on a white or coloured background.

The functions assigned to the Google links, in particular the transfer of information and user data, do not become active just by visiting our Website and/or Web App, but only when you activate the respective buttons
Only when you click on the button, it becomes active and the Google plug-ins are activated. Your browser then sets up a direct link to the Google servers.
Google then gets the information that you have accessed this Website and/or Web App with your IP address.
If you are logged in on Google, your visit can be associated to your Google account.
If you interact with the plug-ins, for example, if you click on the '+1' button or post a comment, the corresponding information is transmitted directly from your browser to Google and saved there.

As the transmission is direct, we obtain no information as to the data transferred.
For information on the purpose and extent of data capture by Google and the further processing and use of the data by Google as well your rights in this regard and setting options for the protection of your personal privacy, please refer to the Google data protection information at https://policies.google.com/privacy.

8.3 Use of Tweet-Button by Twitter

Our Website and/or Web App uses the “Tweet” button from the social network Twitter, which is operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, United States ("Twitter"). The button is identifiable by the blue bird and the word ”Tweet“ or “Follow” on a light blue background. With the help of this button, you can share a post or page of this Website and/or Web App.

The functions assigned to the Twitter links, in particular the transfer of information and user data, do not become active just by visiting our Website and/or Web App, but only when you activate the respective buttons.
Only when you click on the button, it becomes active and the Twitter plug-ins are activated. Your browser then sets up a direct link to the Twitter servers.
Twitter then gets the information that you have accessed this Website and/or Web App with your IP address.
If you are logged in on Twitter, your visit can be associated to your Twitter account.
If you interact with the plug-ins, for example, if you click on the 'Tweet' button or post a comment, the corresponding information is transmitted directly from your browser to Twitter and saved there.

As the transmission is direct, we obtain no information as to the data transferred.
For information on the purpose and extent of data capture by Twitter and the further processing and use of the data by Twitter as well your rights in this regard and setting options for the protection of your personal privacy, please refer to the Twitter data protection information at http://twitter.com/privacy.

8.4 Use of Fancy-Button by Fancy

Our Website and/or Web App uses the “Fancy” button from the social network Fancy, which is operated by Fancy, Spring Street, New York, NY 10012, United States ("Fancy"). The button is identifiable by the dark gray bell-shaped icon on a white background. With the help of this button, you can share a post or page of this Website and/or Web App.

The functions assigned to the Fancy links, in particular the transfer of information and user data, do not become active just by visiting our Website and/or Web App, but only when you activate the respective buttons.
Only when you click on the button, it becomes active and the Fancy plug-ins are activated. Your browser then sets up a direct link to the Fancy servers.
Fancy then gets the information that you have accessed this Website and/or Web App with your IP address.
If you are logged in on Fancy, your visit can be associated to your Fancy account.
If you interact with the plug-ins, for example, if you click on the 'Fancy' button or post a comment, the corresponding information is transmitted directly from your browser to Fancy and saved there.

As the transmission is direct, we obtain no information as to the data transferred.
For information on the purpose and extent of data capture by Fancy and the further processing and use of the data by Fancy as well your rights in this regard and setting options for the protection of your personal privacy, please refer to the Fancy data protection information at https://fancy.com/about/terms-privacy.

8.5 Use of Pinterest-Button by Pinterest

Our Website and/or Web App uses the “Pinterest” button from the social network Pinterest, which is operated by Pinterest Inc., 808 Brannan Street, San Francisco, CA 94103-4904, United States ("Pinterest"). The button is identifiable by a white round P on a red background. With the help of this button, you can share a post or page of this Website and/or Web App.

The functions assigned to the Pinterest links, in particular the transfer of information and user data, do not become active just by visiting our Website and/or Web App, but only when you activate the respective buttons.
Only when you click on the button, it becomes active and the Pinterest plug-ins are activated. Your browser then sets up a direct link to the Pinterest servers.
Pinterest then gets the information that you have accessed this Website and/or Web App with your IP address.
If you are logged in on Pinterest, your visit can be associated to your Pinterest account.
If you interact with the plug-ins, for example, if you click on the 'Pinterest' button or post a comment, the corresponding information is transmitted directly from your browser to Pinterest and saved there.

As the transmission is direct, we obtain no information as to the data transferred.
For information on the purpose and extent of data capture by Pinterest and the further processing and use of the data by Pinterest as well your rights in this regard and setting options for the protection of your personal privacy, please refer to the Pinterest data protection information at https://policy.pinterest.com/privacy-policy.

 

  1. Do Not Track 

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

  1. Your Statutory Rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at:

info@smart-prep.com

or mail us at:

Hsquared Education GmbH
Auenstraße 100
80469 München
Germany

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

 

  1. Data Retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

 

  1. Age of Consent 

By using this Website and/or Web App, you represent that you are at least the age of majority in your country, state or province of residence, or that you are the age of majority in your country, state or province of residence and you have given us your consent to allow any of your minor dependents to use this Website and/or Web App.

For users residing in the US: We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). This Website and/or Web App does not knowingly collect personal information from children under the age of 13 years. Our Website and/or Web App, Products and Services are all directed to people who are at least 13 years old or older. 

 

  1. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it frequently so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. Changes and clarifications will take effect immediately upon their posting on the Website and/or Web App. Unless Company obtains your express consent, any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect, and not to information collected under any earlier Privacy Policies. Company again encourages visitors to frequently check this page for any changes to its Privacy Policy. The revision date will be clearly marked at the top of this Privacy Policy.

If our Company 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. 

 

  1. Questions and Contact Information 

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at:

info@smart-prep.com

or by mail at:

Hsquared Education GmbH
Auenstr. 100
80469 Munich
Germany

 

Munich, March 2019