Last Updated: November 3, 2020
What Information Is Collected?
Personally Identifiable Information: We collect Personally Identifiable Information (as defined below) only when you provide such information directly to us in connection with the Service. We ask for Personally Identifiable Information when you register for a User account with the Service, register for a Babylon20 class, or if you correspond with us (in which case we will also retain our responses). We may also retain any messages you send through the Service, and may collect information you provide in User Content you post to the Service. We may receive Personally Identifiable Information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Zoom or Google, etc., that third party may pass certain information about your use of its service to Babylon20 . If you reside or are located in the EEA, it can also include your IP address or device identifier. This information could include any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our websites or Service. "Personally Identifiable Information" means any information that may be used to identify an individual, including, but not limited to, a first and last name, home or other physical address, “Sensory Information” such as audio or visual information of a living person, an email address, phone number or other contact information. By using paid aspects of the Service, you may be required to share billing and payment information with our third-party payment processor, and you expressly agree to the use of your billing and payment information by any such third-party payment processor.
Non-Personally Identifiable Information: We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual ("Non-Personally Identifiable Information"). We may collect, use, and disclose the following types of Non-Personally Identifiable Information:
Analytics information: We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser's width and height, and other information that assists us in improving the Service. We may collect and use this analytics information together with your Personally Identifiable Information to build a broader profile of our individual Users so that we can serve you better.
Cookies information: When you visit the Service, we may send one or more cookies -- a small text file containing a string of alphanumeric characters -- to your computer that uniquely identifies your browser and lets Babylon20 help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.
Log file information: Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Clear gifs/web beacons information: When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users anonymously. In addition, we may also use clear gifs in HTML-based emails sent to our Users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
How Is Such Information Used?
Personally Identifiable Information: We may use the Personally Identifiable Information we collect or receive to communicate directly with you. We will occasionally email you updates about technology, announce new features, remind you of events, or inform you about other important news. You always have the option to unsubscribe to these messages. We also use your Personally Identifiable Information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices, feedback emails from tutors). You may not opt out of Service-related emails. Sensory Information is used by Babylon20 to help improve the quality of the lessons and for internal research purposes.
Is The Information Shared or Disclosed?
Personally Identifiable Information: We will not rent or sell your Personally Identifiable Information to third parties outside Babylon20 and its controlled subsidiaries and affiliates without your consent, except as noted below:
Who you may choose to share your Personally Identifiable Information with: Any Personal Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content or Sensory Information by participating vocally during a class, becomes to the public. If you remove information that you posted to the Service or request the Sensory Information be deleted by Babylon20, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. We may use a third-party service provider to manage payment processing. By using paid aspects of the Service, you agree to share your billing and other payment information with any such third-party payment processor for the purpose of processing your payments.
What happens to your Personally Identifiable Information in the event of a change of control: We may buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, User Content, and other User information (and Non-Personally Identifiable Information) related to the Service will likely be among the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
Non-Personally Identifiable Information: We may share Non-Personally Identifiable Information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.): (i) in any manner permitted for Personally Identifiable Information; and (ii) with our third-party business partners. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
Updating or Deleting Your Personally Identifiable Information: You have certain rights in relation to your Personally Identifiable Information. By emailing firstname.lastname@example.org you can get access to your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data, excluding Sensory Information. Users have a right to delete their Sensory Information, but not receive a copy of their Sensory Information, unless consent of all users who provided Sensory Information is granted. Also, copies of Sensory Information may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information when it was made public. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com. If you reside or are located in the EEA, you have the right to request that we:
provide access to any Personally Identifiable Information we hold about you;
prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
update any Personally Identifiable Information which is out of date or incorrect; delete any Personally Identifiable Information which we are holding about you;
restrict the way that we process your Personally Identifiable Information;
provide your Personally Identifiable Information to a third party provider of services; or
provide you with a copy of any Personally Identifiable Information which we hold about you. We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Site or a third-party to recognize you and make your next visit easier and the Site more useful to you. Essentially, cookies are a user’s identification card for the Babylon20 servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow Babylon20 to serve you better and more efficiently, and to personalize your experience on our Site.
Cookies can be "persistent" or "session" cookies.
When you use and access the Site, we may place a number of cookies files in your web browser.
We use both session and persistent cookies on the Site and we use different types of cookies to run the Site:
Essential cookies. Necessary for the operation of the Site. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts, or offer Site features. Analytical/performance cookies. Allow us to recognize and count the number of visitors and see how visitors move around the Site when using it. This helps us improve the way the Site works.
Functionality cookies. Used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Targeting cookies. Record your visit to the Site, the pages you have visited, and the links you have followed. We will use this information to make the Site and the Service more relevant to your interests. We may also share this information with third parties for this purpose.
In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Site and refine marketing efforts. Tracking cookies. Follow on-site behavior and tie it to other metrics allowing better understanding of usage habits. Optimization cookies. Allow real-time tracking of user conversion from different marketing channels to evaluate their effectiveness. Partner cookies. Provide marketing conversion metrics to our partners so they can optimize their paid marketing efforts.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use some or all of the features we offer. You may not be able to log in, store your preferences, and some of our pages might not display properly.
We know that children deserve extra privacy protection. That’s why we treat child users differently to ensure their parents are in control and we only collect the bare minimum information we need to make Babylon20 work.
In order to use Babylon20, children under 18, must have their parents send an email to firstname.lastname@example.org. Parents need to include their children’s age, country of residence, and a user name for the child that is not the child’s legal name. Do not disclose your child's legal name. We do not need to know this. We will compare your child's age info to the local standard of child online consent depending on the country they are in. We refer to users under this age as “child users”. Child users are permitted to have user accounts but we ask them to provide their parent’s email address instead of their own.
After registration we will send an email notifying the parent about Babylon20’s privacy and information practices regarding child users, including what personal data we collect and how we use, share, and protect that personal data. The email also explains how parents can request that Babylon20 access, change or delete the personal data about their child.
Other Web Sites and Services
EU Data Subjects
This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, Norway and, where applicable, Switzerland).
Babylon20 is the data controller of Personal Data provided to, or collected by or for, our Website and the Service, but we may act as data processor on behalf of our customers for Personal Data that we process on their behalf when providing the Service.
Subject to applicable law, you have the following rights in relation to your Personal Data:
Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies of the data, we may need to charge a reasonable fee.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for direct marketing and otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue.
Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that produce a significant legal effect on you, unless such profiling in necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to unsubscribe.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting via email@example.com.