Privacy Policy

Version: 1.0.0, effective date: 5 July 2018

Introduction

NovoLearning BV (from hereon referred to as "NovoLearning", "us", "we", or "our") operates the website www.novo-learning.com, the Novo Player and the Novo Studio (from hereon the "Services").

This page informs our customers and users of our policies regarding the collection, use, storage and disclosure of personal data when using our Services and of data regarding the use of our Services.

We use your data to provide and improve the Services. The statement below defines what we do with this data and what rights you have. This Privacy Policy applies if you use our Services.

Additionally to this Privacy Policy, you must agree to the Terms of Service before using any of our Services. The Terms of Service are accessible from www.novo-learning.com/terms.

As a courtesy to you, we have translated this Privacy Policy to other languages. However, we consider the original English version to be binding.

Definitions

Personal Data

Personal Data is data about a living individual who can be identified from those data (or from combining with other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either through use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller is a person who (either alone or with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) is any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual that the Personal Data is about.

Content

Content is data that is needed so that our Services are useful to the Users of our Services. Content consists of textual, image, audio and video material, and the coherent organization of this.

User

The User is the individual using our Services. The User therefore is the Data Subject, the subject of Personal Data.

Organization

An Organization is a logical collection of Users. Every User is associated with at least one Organization.

Manager

A Manager is a User with additional privileges regarding access to Personal and Usage Data. Typically a Manager governs the learning activities of a User.

Content Partner

A Content Partner is an Organization with additional privileges regarding the creation of new Content or the adaptation of existing Content.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Services.

Use of the website www.novo-learning.com

Our website provides general information about NovoLearning and its services.

Personal Data

If you apply for a trial account, we collect your contact information. We collect no other personal data when you use our website.

Usage data

Usage data we collect

We use cookies and similar tracking technologies.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

We use Google Analytics as 3rd party Service Provider to obtain usage statistics of our website.

Our website may be hosted by a 3rd party Service Provider. This Service Provider may also collect logging information on how the website is accessed and used. This Usage Data may include information such as your computer's Internet Protocol address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

How we use your Usage Data

We use Cookies on the website to track the activity on our website and hold certain information. Examples of Cookies we use:

Session Cookies
We use Session Cookies to operate our Service
Preference Cookies
We use Preference Cookies to remember your preferences and various settings
Security Cookies
We use Security Cookies for security purposes

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

NovoLearning does not use the logging information of the website www.novo-learning.com.

How we store your data

Cookies are stored on your device.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

Google may store your Usage Data of our website on their own servers. We can only view aggregate statistics of your Usage Data mixed with that of other visitors of the website. We cannot trace your personal Usage Data of our website.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about your activity.

For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page: http://www.google.com/intl/en/policies/privacy/

Use of the Novo Player

The purpose of the Novo Player is that you, as a User, learn new skills. Therefore we need to know it is you that is working with the Novo Player. To this end, you log in to the Player using a NovoLearning personal account name. For almost all operations, the Novo Player uses an anonymized version of the account name, called a NovoLearning personal ID. This ID is used in keeping track of a learning plan, tracking and reporting progress, registering test results and for tracking issues with the Novo Player itself that you may have reported.

Personal Data

You obtain a personal account name by registering to NovoLearning. This process may be prepared for you by a Manager in your Organization, but you finalize the registration yourself by agreeing to the Terms of Service, and acknowledging this Privacy Policy.

Personal Data we collect

In the registration process we register the following Primary Personal Data, and link it to your NovoLearning personal account name:

  • Your e-mail address
  • Your NovoLearning personal account name
  • Your phone number (optional)
  • A unique ID of the devices on which you have used the Novo Player

In using the Novo Player, you can optionally provide the following Secondary Personal Data:

  • Given name and Family name
  • A profile picture
How we use your Personal Data

Your NovoLearning personal account name is used to authenticate you during the login process. By logging in to the Novo Player, we know what activities we can present to you, and make sure the progress you make is attributed to you and not to someone else.

Your NovoLearning personal ID is used in the Novo Player to record Usage Data (see below), and can be seen as an anonymizing identity. By using your personal ID and not your personal account name, we can separate your identity from your activities.

We may use your Personal Data to contact you:

  • To provide customer support, in case you have experienced technical problems with the Novo Player
  • To notify you about changes to the Novo Player
  • To send you notifications on behalf of other Users of your Organization

When we issue a digital or printed certificate of a certain accomplishment, e.g., the proof that you completed a course or passed a test, we will use your Personal Data in order to put your name on the certificate.

During use of the Novo Player, the Secondary Personal Data (name, profile picture) may be visible on screen so that you can easily see that you are logged in.

If you carry out your learning activities with the Novo Player within an Organization, other Users of this Organization may have access to your Secondary Personal Data in order to help associating you with your learning progress or make collaboration more easy.

If you opt-in to share accomplishments with other Users in your Organization, we may use your Secondary Personal Data to show your name and profile picture to them.

If you have supplied a telephone number, we may use this for password reset requests and authentication.

How we store your Personal Data

Your Personal Data is stored in a separate database from where we store your Usage Data (see below). The database is located on servers in Europe and Singapore, and is secured by up-to-date security measures following the NovoLearning Information Security Policy.

When your account is terminated, your Personal Data will be disassociated from the NovoLearning personal ID. Within 6 months of the termination date, the Personal Data will be deleted permanently from our databases.

Usage Data

When you use the Novo Player, you read text, watch images and videos, and listen to audio clips, and carry out exercises in order to learn certain skills. An exercise may involve mouse, touch or spoken actions from you. In most cases you get direct feedback about your actions.

Usage Data we collect

We may collect the following data related to the usage of the Novo Player:

  • The response that you give in an exercise, which can be entered through mouse or touch actions, or through speaking. For some exercise types, we store the location where you touch or click an image. For spoken exercises, we also collect the spoken utterance.
  • Other learning-related events in using the Novo Player, such as playing a video or joining a class.

Additionally, our servers register information that is related to the internet connection necessary to operate the Novo Player. This logging information includes the IP-address from which the connection to the server is made, and the time at which various network related events occur.

How we use the Usage Data

The Novo Player events are used to track your progress in an activity. The responses are used to determine how you are doing in the activity, so that your progress can be shown to you. In case a Manager in your Organization governs your learning activities with the Novo Player, this person can see these statistics as well.

The responses you give are used for determining the level at which you are performing in the activity, or for recording choices in learning paths that you make. If the activity is not a test activity, the responses can also be used to give you immediate feedback about the correctness of an exercise, so that you can learn from it. If you review an activity, the stored responses are used to show you what your responses were. You can review on a different device than the one you originally used for the activity.

The spoken responses are sent to an Automatic Speech Processing service to determine what you have said. In the case of a pronunciation exercise, the spoken response is also used to determine how you pronounced the words. This can be used for direct feedback on your choice or the pronunciation quality. When you review an activity, you can listen to the recording that was made. This can also happen at a later instance, from a different device.

In case a Manager in your Organization governs your learning activities with the Novo Player, the Manager can have access to individual responses, including the spoken exercises. This Manager will be able to associate these responses with your name and profile picture (Secondary Personal Data).

If you opt-in to share responses with other Users in your Organization, we may present these responses to these Users.

We may use your Usage Data to build aggregate statistics and share these with Content Partners for the purpose of assessing the effectivenses of existing courses and for improving them. These statistics cannot be traced back to individual responses and/or to you, and will not include original spoken responses.

NovoLearning can use the audio that has been recorded for resolving technical issues, quality control and for improving the Automatic Speech Processing system. Only relevant personnel at NovoLearning will be authorized to have access to the data, and only for the purpose mentioned above and for research and development of new speech technologies.

NovoLearning can further use the responses you have given for resolving technical issues. Only relevant personnel at NovoLearning will be authorized to have access to the data.

Internet connection data (IP-addresses, times of network events) are used solely for detecting, preventing and addressing technical issues.

How we store the Usage Data

The Usage Data of the activities you carry out using the Novo Player are stored in a Learning Record Store. This is a database that logs the events and responses, and associates these with your NovoLearning personal ID. Because the events and responses represent essential information regarding your learning progress, test results and certificates, we take great care to secure this information, both against loss due to technical disasters and against unauthorized access. The database is located in data centres in The Netherlands and Singapore, and are secured by up-to-date security measures following the NovoLearning Information Security Policy.

The Learning Record Store does not store any Primary or Secondary Personal Data. Any association with you is by anonimized NovoLearning personal ID.

The spoken utterances are stored on data storage servers in data centres located in The Netherlands. These services have been certified according to internationally recognized standards for information security and safety.

Internet connection data (IP-addresses, times of network events) are stored in computer log files on the servers that provide the Service required by the Novo Player. They are accessible only by authorized personnel from NovoLearning, and have a limited life time as a result of a standard log rotation protocol.

Use of the Novo Studio

The Novo Studio is an application that allows you to manage learning content and the learning progress of members of your Organization. Because we provide powerful and detailed information about activities and courses, it is important that we know that it is you that is working with the Novo Studio and that you are authorized to do so. To this end, you must log in to the Novo Studio using a NovoLearning personal account name. The way you log in and the way we store information about you is the same as in the case of the Novo Player, described above. In fact, your NovoLearning account name may be shared between the Novo Player and the Novo Studio if your are authorized to use both Services.

Personal Data

You obtain a NovoLearning personal account name by registering with NovoLearning. If you take on the role of Manager for your Organization, we will set up the account as a result of the Service contract. As for the Novo Player, you finalize the registration yourself by agreeing to the Terms of Service, acknowledging this Privacy Policy.

Personal Data we collect

In the registration process we register the following Primary Personal Data, and associate it to your NovoLearning personal account name:

  • A NovoLearning personal account name
  • Your e-mail address
  • Your phone number (optional)

In using the Novo Player, you can provide the following Secondary Personal Data, which is optional:

  • Given name and Family name
  • A profile picture
How we use your Personal Data

Your NovoLearning personal account name is used to authenticate you during the login process. By logging in to the Novo Studio, we can make sure you have the right privileges in working with the Studio.

Your NovoLearning personal ID may be used in the Novo Studio to record Usage Data (see below), and can be seen as an anonymizing identity. By using your personal ID and not your personal account name, we can separate your identity from your activities.

We may use your Personal Data to contact you:

  • To provide customer support, in case you have experienced technical problems with the Novo Studio
  • To notify you about changes to the Novo Studio

During use of the Novo Studio, the Secondary Personal Data (name, profile picture) may be visible on screen so that you can easily see that you are logged in.

How we store your Personal Data

Your Personal Data is stored in a separate data table from where we store your Usage Data (see below). The database is located on servers in Europe and Singapore and secured by up-to-date security measures following the NovoLearning Information Security Policy.

When you stop using our Services, your Personal Data will be disassociated from the NovoLearning personal account name and ID. Within 6 months of the date that you stop using our Services, the Personal Data will be deleted permanently from our databases.

Usage Data

With the Novo Studio, you can create Content, add Users, and view progress. Most of these actions will add or change data in our databases that maintain the content available in the Novo Player or the database of users. During content creation, you can try out an exercise live as if you were a User using the Novo Player, and this can in some cases generate some Usage Data. Typically, we do not store Usage Data like we do in the Novo Player.

Usage Data we collect

We do not store your Usage Data except for the cases mentioned below. We only store the result of your actions in the content database.

When you review content in the Novo Studio, you can provide responses to the activities you are reviewing. The Usage Data of this reviewing is not collected, except in the case of spoken exercises, when the speech utterances are collected.

Additionally, our servers register information that is related to the internet connection necessary to operate the Novo Studio. This logging information includes the IP-address from which the connection to the server is made, and the time at which various network related events occur. Further, our servers log changes that occur in the database.

How we use your Usage Data

When you are creating Content, your actions are used to make a consistent representation of the content you create, that can be manipulated using the Novo Studio, and can be used in the Novo Player.

When you are adding Users to your Organization, we prepare NovoLearning personal IDs and send out notifications to these users, so that their registration can be completed.

When you assign activities to Users, we may prepare notifications to users and send these out.

Internet connection data (IP-addresses, times of network events) and server logs are used solely for detecting, preventing and addressing technical issues.

How we store Usage Data

The results of your actions (content creation, user management, activity assigments) are stored in our databases. The database is located in datacentres in The Netherlands and Singapore, and are secured by up-to-date security measures following the NovoLearning Information Security Policy.

The spoken utterances are stored on data storage servers in data centres located in The Netherlands. These services have been certified towards data security and safety by internationally recognized standards.

Internet connection data (IP-addresses, times of network events) are stored in server log files on the servers that provide the Service required by the Novo Studio. They are accessibly only by authorized personnel from NovoLearning, and have a limited life time as a result of a standard log rotation protocol.

Other

Retention of Data

NovoLearning will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

NovoLearning will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside The Netherlands and choose to provide information to us, please note that we transfer the data, including Personal Data, to The Netherlands and process it there.

NovoLearning will take all steps necessary, within reason, to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Business Transaction

If NovoLearning is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, NovoLearning may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

NovoLearning may disclose your Personal Data if we believe, in good faith, that such action is necessary to:

  • comply with a legal obligation
  • protect and defend the rights or property of NovoLearning BV
  • prevent or investigate possible wrongdoing in connection with any of the Services
  • protect the personal safety of users of the Service or the public
  • protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights

NovoLearning aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the right:

  • To access and receive a copy of the Personal Data we hold about you
  • To rectify any Personal Data held about you that is inaccurate
  • To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to NovoLearning. You can request to obtain a copy of your Personal and Usage Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 16 ("Children").

We do not knowingly collect information from anyone under the age of 16 that may identify the person. If you are a parent or guardian and you are aware that one of your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our databases.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

E-mail: dpo@novo-learning.com
Telephone: +31 24 365 2400

Data Protection Officer
NovoLearning BV
Toernooiveld 300
6525 EC Nijmegen
The Netherlands