1. General
At Gammakite , (the company that develops the FullChinese apps and website) we care about your personal data, so we have prepared this Privacy Policy to explain how we collect, use and share it. This Privacy Policy (“ Privacy Policy ”) details the personal data Gammakite , Inc. (“ Gammakite ”, “ we ”, “ us ” or“ our ”) receives about you, how we process it and your rights and obligations in relation to your personal data. Gammakite , Inc., a Delaware Company, is the data controller for the purposes of the General Data Protection Regulation (“ GDPR ”)and any relevant local legislation (“ Data Protection Laws ”). By using or accessing the Service, you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “ Terms and Conditions ”), located at www.fullchinese.com/terms.html. We may update our Privacy Policy to reflect changes to our informatio n practices. If we do this and the changes are material, we will post a notice that we have made changes to this Privacy Policy on the Website for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at t he bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 - day period. If you are an employee, worker or contractor of Gammakite , the information about how we handle your personal information is availab le in the Gammakite internal knowledge base. 2. Information We Collect
This Privacy Policy explains how we collect, use and share your personal data. Information you provide Through the registration process, you will provide us with your name, e - mail address (or parent’s e - mail address ), language level . You will also provide us with your payment transaction information if you choose to pay for Gammakite services. We use cookies to record current session information, but do not use permanent cookies. You are required to re-login to your source control system account after a certain period of time has elapsed to protect you against others accidentally accessing your account contents. General Activity Data When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service (“ General Activity Data ”). We also collect technical data about how you interact with our Services. Low Level Activity Data In the future, we may give you, in an opt-in manner, the option to turn on a low-level activity tracking for a limited amount of time (not to exceed one day). This activity tracking could record your interaction with the application such as how many words you flag, how many dictionary entries you consult, for how long. This low-level activity data is collected for the purpose of improving the application and the language learning method. Your opt-in button, given inside the app, can also be used to withdra w your consent at any time. This data will not be shared with any third party without your explicit prior consent. When you use the Service, you will submit information and content to your profile. We will also generate data about your use of our Services including your engagement in educational activities on the Service (“ General Activity Data ”). We also collect technical data about how you interact with our Services. Learning Data Learning data is the data that’s generated when you flag words, sentences, modify dictionary entries, upload texts or text samples for your own personal study , perform quizzes . This data is stored such that you can keep personalizing your language learning environment. This data is not shared with anybody and is also not used for any other purpose without your explicit consent. This explicit consent can be withdrawn at any point. If you use the app as part of a class, you will have the option of sharing certain type of content with your teacher but only after your explicit consent. This includes which word you flag or which translation you enter for some specific language segments. This explicit consent can also be withdrawn at any point. Research and Development Data We may contact you to participate in product research activities such as interviews or surveys . When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We could ask you to record the video, audio and text transcriptions of this feedback together with any additional contact information you provide and will retain this data for two years. You can request at any point that this data be discarded. Please contact us at [email protected] to: Request more information about the research activities you have volunteered for. Opt-out of being contacted for research activities. Request a copy of any research related data you have provided to us. 3. Cookies
When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). When you use our mobile Application, we collect your device type, your device ID, and your IP address. In addition, we store certain information from yo ur browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. If you do not want information collected through the use of cookies, th ere is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the Website (e.g., customized delivery of information). You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. 4. Information Obtained by Third Parties
To support and enhance the Service, we work with a variety of third-party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Oath, and Unity (collectively, “ Third Party Advertising Service Providers ”). These Third-Party Advertising Service Providers collect and us e personal data about your visits to and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and likely interests or better understand ad effectiveness . Aggregate demographic and interest data will also be used for market research purposes. We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout You can opt - out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self - Regulatory Pr inciples for Online Behavioral Advertising using their respective opt - out tools. The NAI's opt - out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found herehttp://www.aboutads.info/choices/ In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you. 5. Use of information obtained by Gammakite
Gammakite may occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the Gammakite teaching methodology by reinforcing the learning cadence and help maintain your learning streak. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure. Gammakite may use or share anonymous data collected through the Servi ce, including Activity Data without limitation. As a business, it is critical that we perform our contract with you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service e - mails by default to keep your data secure and provide our Service. You may opt out of any non - essential service e - mails at any time. We may also use your contact information to send you notifications regarding new services, offers and promotions offered by Gammakite if you affirmatively consent to receive such communications. 6. Sharing your personal data with third parties
Gammakite shares your personal data only when it is necessary to offer the Service, legally required, or permitted by you. We will provide personal data to hosting providers such as Amazon Web Services, search engine providers such as Google, analytics providers such as Crashlytics, and support providers such as ZenDesk. These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to Gammakite. We will be required to access and disclose personal data in response to lawful requests, such as su bpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illega l activity perpetrated through the Service or using the Gammakite name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies. If the ownership of all or substantially all of the Gammakite business, or individual business units or assets owned by Gammakite that are related to the Service, were to change, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section. Gammakite will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service. 7. Data subject rights and data retention
You can manage your account settings at https://www.Gammakite.com/settings/account to update, amend, and correct your information. You also have the following rights in relation to the personal data we hold about you, unless provided otherwise by local law: To request access to, or erasure of, the personal data we hold about you. To request us to restrict the processing of the personal data we hold about you. To object to us processing personal data relating to you Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time. To export the personal data you have provided to Gammakite in a format that can be transferred electronically to a third party. To del ete your account with Gammakite by following the instructions available through the Service. Gammakite will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by Gammakite and shared with third parties in any manner. Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons , compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. 8. Third party websites and links
Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non - personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. In addition, Gammakite would like to inform you that anytime you click on links (including advertising banners), which take you to third party websites, you will be subject to the third parties’ privacy policies. Our Services contain links to other sites operated by third parties. Gammakite does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to p rocess payments for in - app purchases. Gammakite ’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy. 9. California privacy rights
Residents of California have the right to: Know what personal information we collect about you and from where we collect it. Access a copy of the personal information we hold about you. Understand how we process your personal information and how it may be shared. Opt out of having your personal information shared with certain third parties. Request we delete your Gammakite account and personal information To make such a request, please send an email to [email protected] 10. EU - U.S. Privacy Shield And Swiss - U.S. Privacy Shield
Gammakite complies with the EU - US Privacy Shield Framework and the Swiss - US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (including I celand, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. Gammakite has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visithttps://www.privacyshield.gov/ Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected] . If requested to remove data, we will respond within a reasonable timeframe. We will provide an individual opt - out choice, or opt - in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected] Gammakite ’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Gammakite remains responsible and liable under the Privacy Shield Principles if third - party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Gammakite proves that it is not responsible for the event giving rise to the damage. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Gammaki te is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Gammakite may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In compliance with the EU - US and Swiss - US Privacy Shield Principles, Gammakite commits to resolve complaints about your privacy and our collection or use of your personal data. Gammakite has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visithttps://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of BBB EU PRIVACY SHIELD are provided at no cost to you. If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and Gammakite does not address it satisfactorily, Gammakite commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the a dvice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate juri sdiction. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD. Contact details for the EU data protection authorities can be found athttp://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 athttps://www.privacyshield.gov/article?id=ANNEX-I-introduction. 11. Children under age of digital consent
Gamm akite provides some features and services intended for use by children. Gammakite uses age - gating to restrict what services are available to children depending on the age of the user and the applicable laws of their country. For example, a 15 year old child in Germany will require parental consent to use the Service, whereas a 12 year old child in the United States of America would receive a restricted service but not require parental consent. Children within the European Union Each European Union (EU) member state is permitted to legally define its own digital age of consent between 13 and 16. Gammakite checks the age and country of the user to determine if the user is able to consent to the Service. If consent of a parent/guard ian is required, the user will input the e - mail address of an adult who will receive a request to approve the child’s account registration. In the absence of a country specific Act of Law, the age of consent will be set at 16. These EU child users will receive the following service restrictions: they will not be able to use the service until their parent/guardian has provided consent for the child to do so. After the parent/guardian has given consent, they child will be allowed to access the full Gammakite service. Where Gammakite does make features and services available to children, we recognize that collecting personal data from children requires further privacy protections. Accordingly, Gammakite will: (1) notify parents or guardians about Gammakite ’s privacy and information practices regarding children, including what personal data we collection and how we use, share, and protect that personal data; (2) limit our collection of personal data to ensure that we collect no more than is necessary to provide Gammakite’s services; (3) obtain parental consent before collecting personal data from children; and (4) allow parents to request that Gammakite change or delete personal data about their children. Children outside of the European Union If a child of under 13 years from outside the EU registers for the Gammakite service, upon registration the child will provide an adult’s e - mail address, to whom Gammakite sends a notification. These child users will receive the following service restrictions: Instead of any Personally Identifiable Information about the child, we will only store the e - mail address of their parent/guardian. Only family friendly advertisements are shown and these ads do not do behavioral tracking. Mature words such as "beer" and "wine" are disabled. Social features are disabled, e.g. profiles, forums, clubs, etc. They can not enter profile information such as a profile picture or a bio. At the point when the user is known to have reached the age of 13, the account will automatically be transitioned to be a normal non - restricted account. At all times Gammakite does not knowingly collect personal information from children in connection with the Service. If we discover that we have unknowingly collected personal information from these children, we will delete it. If you believe we have collected personal information from a child, please contact us at [email protected] 12. Links
The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by Gammakite via the Service. 13. Information security
Gammakite has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data, Testing ID, User Photo, access credentials, and Gammakite English Test results. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to th e data we seek to protect. 14. Do Not Track
The Service is not designed to respond to “do not track” signals sent by some browsers. 15. Contact Us
Address: Gammakite , Inc. 405 Concord Ave PO Box 468 Belmont , MA 02478 For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at [email protected] For all support inquiries, please contact [email protected]
Last revised on 20 th July, 2020​