Plotagon® Privacy Policy

Plotagon Production AB (“Plotagon®”, “we”, “our”, us) respect your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do and do not use the personal information you transmit (“personal data”) when using the Plotagon® website (the “Website”) and Plotagon®’s software for desktops, tablets and mobile handsets including both Plotagon® Story and the educational software Plotagon® Education (the “Software”) and other services provided by Plotagon® (the Website and the Software are collectively referred to as the “Services”).

Unless stated otherwise in this Privacy Policy, the same conditions shall apply for Plotagon® Story and Plotagon® Education.

Before registering a Plotagon® account, you need to expressly acknowledge that you consent to Plotagon®’s processing of your personal data in the manner set out in this Privacy Policy. The kind of personal data and the purposes for which we may process your personal data, and hence need your affirmative consent, is described in the Sections “Personal data that we collect about you” and “Sharing of your personal data” below. Please make sure that you have read and fully understood these sections (i.e. the information we may collect about you and how we can use and/or share such information) before consenting to Plotagon’s processing of your personal data. Note that you always have the choice to withdraw your consent at a later stage.

If you have questions regarding your personal data stored with us, including a request for access rectification or deletion, or you object to certain uses, please feel free to contact us e.g. by sending an email to privacy@plotagon.com or write to us at:

Plotagon Production AB
Grev Turegatan 9, 2tr
114 46 Stockholm
Sweden.

Fundamentals on personal data protection

Protecting the security and privacy of your personal data is essential to us. Therefore, we are always working on upholding compliance with applicable laws on data protection and data security, including but not limited to the European Data Protection Directive 95/46/EC and relevant US federal and State laws that may apply to the receipt, storing, maintenance or access to personal data. Since your personal data can be stored on many different locations, please note that it may be subject to privacy laws that are different from those in your country of residence.

This Privacy Policy is designed to give you full transparency regarding our data protection practices. If there’s anything that’s not clear from this Privacy Policy, please feel free to email us at the above stated address.

We will retain your personal data only for the period necessary to fulfil the purposes for which such data was collected. When it is no longer necessary for us to retain such data, it will be deleted or made anonymous in a safe and permanent manner or access to it will be blocked to the extent that statutory data retention requirements apply.

Personal data that we collect about you

Depending on how you use the Services and what plan you sign up for, you may be required to provide certain personal data from various sources:

 

Information that you provide voluntarily

Plotagon® only collects personal data that it deems necessary to fulfil your online requests and our legitimate business objectives. If you wish to use the Software you will need to register a Plotagon® account and, by doing so, you will provide us with certain personal data. The personal data required for registration may vary depending on the type of Service that you use.

  • Essential Information: When you register a Plotagon® account, you will need to provide your email address and choose a password. In addition, if you purchase a premium subscription, you will also need to provide your real name, billing address and payment verification information. If you are a teacher or school administrator purchasing subscription for Plotagon® Education you will also need to provide the name and address of the school that you are representing. The same applies for teachers and school administrators residing the United States who wish to add students to an existing Plotagon® Education account.
  • Students: If you are student using Plotagon Education we will only store the email address and password that your teacher/school administrator provides us with when setting up your account.
  • Profile Information: As long as you are not a student using Plotagon® Education you may choose, at your discretion, to provide additional information when setting up your user profile in Plotagon®. Such additional information may include:

o              your real name

o              a user name (which may be your real name or a pseudonym)

o              your city and country of residence

o              an avatar

None of this profile information is mandatory, and any information you do provide may be deleted, edited, changed or amended by you at any time by altering your profile information.

 

  • Any additional personal data that you provide when using the Services (e.g. in your animated stories that you share or otherwise post via the Software) and metadata associated with such personal data, which may include content creation date, formatting information; location information such as country, region and city (geotags).
  • Information provided when communicating with us: You will provide certain personal data if you contact us by email, use any of the web forms on the Website, or contact us by mail, fax or other offline means.
  • Survey Information: If you participate in any survey, you will provide certain personal data as part of your response, unless you respond anonymously.

 

Automatically collected information

There is certain information that we collect automatically as the result of your use of the Services. This information includes:

  • the Internet Protocol (IP) address of the device from which you access the Website (this can sometimes be used to derive the location from which the Website has been accessed).
  • the site that you visited immediately prior to visiting the Website.
  • any search terms that you may enter on the Website.
  • the time, frequency and duration of your visits to the Website.
  • your browser type and operating system.
  • the nature of the device from which you are accessing the Services, for example, whether you are accessing the Services from a personal computer or from a mobile device.
  • information collected through cookies and similar technology, as described in the section Cookies and Logs below.

 

How we may use your personal data

We use the information that we collect about you for the following purposes:

  • Your email address and password are used to identify you when you log into the Website and in order to give you access to the Software.
  • Applying to Plotagon® Story users only: Any additional personal data that you provide in your publicly shared animated stories will be publicly accessible and viewed by others. Please bear this in mind when sharing your animated stories online.
  • If you are a teacher or a school administrator having purchased a subscription for Plotagon® Education or if purchased content as a Plotagon Story user, your name, address and payment verification information will be used to process your account subscription and/orto collect your payment.
  • Your email address will be used to send you service updates and notifications regarding your account. For information about how to change your preferences, and to unsubscribe from newsletters, marketing messages and email notifications, please see the section “How you can control shared personal data”, below.
  • Content that you have freely chosen to upload when using the Services may be stored and used by Plotagon® as promotional material even after your account has been deleted.

Your personal data may also be used by us for the following general purposes:

  • To operate and maintain your Plotagon® account, and to provide you access to the Software and use and any Services that you may request from time to time.
  • To identify you as the creator of the animated stories that you share, the comments that you post and/or the other contributions that you make when using the Services.
  • To seek your participation in surveys, and to conduct and analyze the results of those surveys if you choose to participate.
  • To provide you with technical support.
  • To analyse the use of Website and in order to improve Plotagon®.
  • To enable you to communicate with other Plotagon® users.
  • To customize your use of the Services and/or the content of any email newsletter or other material that we may send to you from time to time.
  • To prevent or take action against activities that are, or may be, in breach of our Terms of Use or applicable law.
  • For other purposes, provided we disclose this to you at the relevant time, and provided that you agree to the proposed use of your personal data.

If you are a student using Plotagon® Education, please note that your name and email address will only be shared amongst teachers/administrators of the same class. If you, as an educational user, choose to share your animated stories with other students using Plotagon® Education, your user name will be shared with such users. For more information about our policy towards children and compliance with the Children’s Online Privacy Protection Act, please see below.

Sharing of your personal data

We will not share your personal data with any third party, except as described in this Privacy Policy. There are circumstances where we may need to share some of the personal data we collect about you or which you provide to us. These circumstances are as follows:

  • Other Users (applying to Plotagon® Story users only): Any personal data included in your publicly shared animated stories (other than your email address).
  • With your consent: We will disclose your personal data if you have explicitly agreed that we may do so. We will make this clear to you at the point at which we collect your information.
  • Service Providers: We may also transfer, disclose or share your personally identifiable information with our partners and affiliates and third parties whom may be engaged by us specifically to handle and deliver certain activities necessary to operate our business (e.g. processing of payments). These third parties will have access to certain information about you, but only where this is necessary in order for those third parties to provide their services to us. Where we transfer personal data to these third parties, we ask and require these third parties to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us.
  • As aggregated data: We may aggregate your personal data with similar data relating to other users of the Services in order to create statistical information regarding the Services and its use, which we may then share with third parties or make publicly available. However, none of this information would include any email address or other contact information, or anything that could be used to identify you individually.
  • If required by law: We will disclose your personal data if we believe in good faith that we are permitted or required to do so by law, including in response to a court order, subpoena or other legal demand or request.
  • In the context of a business transfer: In the event of a corporate reorganization (e.g. all or substantially all of the assets relating to Plotagon® are transferred or sold to another entity
  • To protect legitimate interests: We may disclose your personal data if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors or shareholders, and/or to ensure the safety and security of the Services.

Please note that this Privacy Policy does not apply to any third party sites or applications, and we cannot control the activities of those sites or applications. You are advised to read the privacy policies of those sites or applications before sharing your information with, or connecting your Plotagon® account to, any of these third party sites or applications.

Cookies and Logs

A cookie is information a website places on your computer’s hard drive so that the website is able to remember your preferences and/or which pages you visited on the website and make your visit more efficient and enjoyable. Plotagon® may use cookies to determine the number of unique visitors to the Service over a given period, or to remember user account details, etc. so that the need for multiple log-ins is eliminated. It may combine information collected through cookies to any personal data submitted online when using the Service to help personalize a user’s access to and use of the Service. Cookies may be disabled on your computer by indicating this in the preferences or options menus in your browser. Plotagon® may collect data in the form of logs. Log data collected on web servers supplies Plotagon® with aggregate information about the number of visits to different pages on the Service and other navigational data. Further information is available at http://aboutcookies.org.

How you can control shared personal data

We do our best to give you as much choice as possible regarding the amount of personal data you provide to us, and the control you have over that information.

It is not necessary for you to provide us with any information in order to visit the Website, although certain information will be collected automatically by virtue of your visit (as described above). However, if you do decide to register a Plotagon® account, you can control your personal data as described below.

Most of the personal data you provide to us can be accessed and updated by logging in to your Plotagon® account on the Website. If you wish to access, amend or delete any other personal data we hold about you, or if you have any objection to the processing of any information that we hold about you, please contact us at privacy@plotagon.com or the address below.

If you ask us to delete your account (either via the Settings page or by email), we will do so within a reasonable period of time, but we may need to retain some of your personal data in order to satisfy our legal obligations, or where we have a legitimate reason for doing so.

If you have questions regarding your personal data stored with us, including a request for access rectification or deletion, or you object to certain uses, please feel free to contact us e.g. by sending an email to privacy@plotagon.com.

Security and data breaches

We use appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. Your personal data is stored in a secure manner on protected equipment. Only a limited number of personnel have access to this equipment and only persons with a legitimate reason have access to your personal data. Unfortunately, the transmission of your personal data via the internet is not completely secure. While we will endeavour (through the use of appropriate security measures) to protect your personal data, we cannot guarantee the security of such data when it is transmitted to us via the internet: you accept that any such transmission of your personal data is at your own risk.

International data transfers

Plotagon® is based in Europe, and your personal data is collected, stored, used and shared in accordance with European laws. However, from time to time, it may be necessary for us to transfer your personal data to the US. You should be aware that privacy laws in the US may not be equivalent to the laws in your country, and by using the Services, you consent to the transfer, storage and processing of your personal data in the US in accordance with this Privacy Policy and applicable law.

Our policy toward children

You acknowledge that the Services are not intended for use if you are under thirteen (13) years of age unless you are using our educational software Plotagon® Education and have been given access thereto as part of your school’s educational plan. If you are under thirteen years (13) of age and are using Plotagon® Education in the United States, you shall further ensure that the consent of your parents or legal guardians has been obtained by your school as described below, in compliance the Children’s Online Privacy Protection Act (“COPPA”).

Plotagon is required under COPPA, with limited exceptions, to obtain verifiable parental consent in order to collect, use, or disclose personal data from you, if you are under 13 years of age (a “Child”). COPPA allows your school to obtain consent for the online collection of personal data from you and other children who are students at your school. If you are a Child who wants to use our Educational Plan, you must first obtain an account from your school.

Before an Educational Plan account is provided to a school, we require that the school (a) obtains verifiable parental consent with regard to every Child that will use the Services, (b) consents (on behalf of the parents/legal guardians) to the collection, use and disclosure of personal data of the Child, through the Services, in accordance with this Privacy Policy and the consent form made available by Plotagon® and (c) agrees (on behalf of the parents/legal guardians) that the Child’s online activities are subject to the Terms of Use. As required under COPPA, we allow parents/legal guardians certain choices regarding the personal data submitted by their children. Parents/legal guardians should make any permitted requests with the school and have the school, as the parent’s/legal guardian’s agent, pass on those requests to Plotagon®. We may rely on the instructions that we receive from the school that we reasonably believe are given by a Child’s parent to the school. For example, if a representative from the Child’s school contacts us and provides the account information we request, we may assume that the person calling is acting on behalf of the Child’s parent.

We provide parents/legal guardians the following choices with respect to the collection, use, retention and disclosure of personal data. A Child’s registration information is always accessible to him/her. A parent/legal guardian has the right to review his/her Child’s personal data, which the parent can obtain by contacting his/her Child’s school. After reviewing the Child’s personal data, the parent/legal guardian may ask us to update or delete the Child’s personal data by requesting such changes through the Child’s school.

If a parent/legal guardian chooses to prohibit any future collection, use or disclosure of the Child’s personal data, the parent/legal guardian may do so by terminating the Child’s account through the school, and requesting the deletion of the Child’s personal data through the school. Upon receiving such request from the Child’s school, we will delete the Child’s account information from our live databases and all the information and data stored for such account. Plotagon will not have any liability whatsoever for any termination of the account or related deletion of the Child’s personal data. When we delete personal data, it will be deleted from our active databases but may remain in our archives.

Our policy on student data

We acknowledge that the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g (“FERPA”) primarily applies to schools that receive funding from the U.S. Department of Education and that Plotagon® will be indirectly affected by the FERPA regulatory framework when providing services to educational institutions in the US.

As required of such schools under FERPA, as an administrator or teacher under an Educational Plan, You agree that You have obtained valid student and parental consent to disclose personally identifiable information to us.

Plotagon® makes the following commitments to schools regulated by FERPA: Plotagon® will protect the confidentiality of any student data and/or personally identifiable information provided to us or any of our representatives. We further acknowledge that we will review and comply with all information security programs, plans, guidelines, standards and policies that apply to our work as a result of the FERPA regulatory framework and will implement and maintain any other reasonable and appropriate security procedures and practices necessary to protect personal data and/or student information from unauthorized access, destruction, use, modification, disclosure or loss.

Plotagon® specifically agrees with schools regulated by FERPA to:

  • use personable identifiable student data for no purpose other than in connection with providing the Services for a legitimate and educational interest;
  • use reasonable methods, consistent with reasonable industry standards to protect student data from re-disclosure and not to share the student data received under this Agreement with any other entity without the prior written approval of the school responsible under FERPA;
  • not to copy reproduce or transmit student data except as necessary to provide the Services in furtherance of a legitimate and educational interest ;
  • notify the Chief Information Officer for the school responsible under FERPA without undue delay that it has experienced a data breach, breach of security or unauthorized acquisition or use of student data;
  • to maintain sufficient backup copies of data files in case of customer system failure or any other unseen event resulting in loss of student data;
  • to, upon request of the school responsible under FERPA, promptly provide the school responsible under FERPA with any specified portion of the student data; and
  • to, upon request of the school responsible under FERPA, promptly return and/or erase applicable portions of the student data.

Changes and Updates to this Privacy Policy

Occasionally we may, in our discretion, make changes to the Privacy Policy. If we make material changes to the Privacy Policy, we will provide you with prominent notice as appropriate under the circumstances, either by sending you an email prior to the implementation of the altered terms or by asking for your explicit approval to the updated terms and conditions within the Services. In case prominent notice if provided to you in the form of an email, your continued use of the Services after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the Privacy Policy, you may revoke your acceptance hereto by contacting us at legal@plotagon.com, or write to us at the address set out in the first section of this Privacy Policy.

 

Last amended: January 24, 2017

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