WordDive Terms of Use

Terms of Use

1. General
2. Beginning of Contract
3. Identification
4. Production and Use of Service
5. Maintenance of Service and Repairing of Defects
6. Reclamations Concerning the Service and Liability for Damage
7. Payments and Billing
8. Duration of Contract and the Usability of Personal Parts of Service
9. Closing the Customer's Service
10. Termination of Contract
11. Consequences of Termination of Contract
12. Other Terms

Privacy Policy

1. General

1.1 The Object of the Terms of Use and Description of Service. WordDive Ltd, address: Verstaankatu 1, 2F, FI 33100 Tampere, Finland (hereinafter referred to as the "Company") offers services and products, such as the WordDive service (hereinafter referred to as the "Service"), to its users (hereinafter referred to as the "Customer") according to these Terms of Use. The exact content of the Service is determined in the descriptions and special terms of Service, presented on the Service website or otherwise at the time of ordering the Service.

1.2 Applicable Terms of Contract and Order of Application. These Terms of Use apply to the Service and the use and ordering of services and products produced by Company and offered through the Service. In addition, different parts of the Service may require separate contracts with the Company, with special terms and descriptions of service that differ from or add to these terms. In case these general terms and the specific terms concerning a certain part of the Service are in conflict, the more specific terms will apply primarily, and these general terms secondarily where the part of the Service in question is concerned.

Note especially the special terms for the following parts of the Service:
Finland, English for the Matriculation Exam course: www.worddive.com/fi/kielikurssit/englannin-abikurssi#CONDITIONS
Finland, Swedish for the Matriculation Exam course: www.worddive.com/fi/kielikurssit/ruotsin-abikurssi#CONDITIONS

1.3 Chargeable Services. The Customer can order the different products or services available through the Service by online payment, credit card payment or by using another specified method of payment. The Company will announce the price of each product or service according to method of payment and the Terms of Delivery complementing these terms separately.

1.4 Customer's Right of Withdrawal. The Customer has no right of withdrawal of the order after the delivery of the product or service has begun by electronic means with the Customer's agreement.

1.5. Customers under the age of majority. The use of the Service is allowed only for persons 16 and over.

2. Beginning of Contract

2.1 Beginning of Contract in Service. The contract begins when the Customer, during registration, has agreed to these Terms of Use and the Privacy Policy of the customer registry of the Company’s WordDive service and when the Company has acknowledged the Customer's payment for the purchase of the product or service.

2.2 Validity of the Information Provided by the Customer in the Service. The commissions of the Customer made in the Service are handled and delivered according to the information provided by the Customer. The Customer is responsible for the validity of the given information, and the Company has no obligation to check or add to the information.

3. Identification

3.1 Means of Identification. The use of certain parts of the Service requires a username and a personal password or another means of identification accepted by the Company. The email address provided by the Customer will function as the username.

3.2 Customer's Means of Identification. The Company gives the Customer usernames, passwords and other possible means of identification for the purpose of using the Service during the contract period and only for the agreed-upon purpose compliant with these Terms of Use. The Customer does not have the right of ownership to these means of identification, and has no right to continue using them after the end of the Contract, unless otherwise agreed or legally required.

3.3 Company's Right to Change the Means of Identification. At any time, the Company has the right to change the Customer's means of identification. If possible within reason, the Company will inform the Customer of any changes in means of identification beforehand.

3.4 Safekeeping of the Means of Identification. The Customer is responsible for the careful safekeeping of the Customer's means of identification. The Customer agrees to keep the password and any other possible, additional means of identification separate so that a third party cannot access them. The password used in connection with the means of identification is personal and is not to be given to a third party.

4. Production and Use of Service

4.1 Production of Service. The Company has the right to produce the Service in any way it deems fit. The Company has the right to make changes that affect the content, technology and use of the Service. If these changes require changes in the Customer's equipment and software, the Customer must, at his or her own expense, take care of them. The Company strives to issue information on those changes affecting the Customer beforehand within a reasonable time, for example, by notifications published through the Service.
The Company has the right to stop the production of the Service or its part. In this case, the Company strives to inform the Customer of this beforehand within a reasonable time, for example, on the Service website.

4.2. The information material produced by Customers using the Service. As described in more detail in the Company’s privacy policy and pursuant to the applicable laws regarding the handling of personal information, the Company has the right to collect, save and process all information material created by Customers using the Service. This means, for instance, answers to the exercises that are written or recorded by the Customer during the use of the Service. All information material produced by Customers using the Service will remain the property of the Company, and the Company has the right to use it in ways described in the privacy policy. Unless otherwise decreed in the privacy policy or applicable information processing legislation, the Customer has no right to the answer information material written or recorded by the Customer during the contract or after the end of the Contract.

4.3 Right to Use Concerning the Material Published in the Service. The Service includes and provides material protected by copyright, trademark rights and other immaterial rights. Without specific written consent from the creator, holder of rights or the Company or specific announcement of a wider right to use in the Service (for example, for press releases), the Customer has no right to distribute, publish, copy, distribute to the public or otherwise utilize material that is acquired from or through the Service except for the Customer's own private use. The holder of rights of the material presented in or available through the Service may make demands directly to the Customer in case of the inappropriate use of protected material as defined in this section.

4.4 Right to Use Concerning Software and Documents. The Company grants the Customer the right to use the machine code versions of the software and documents delivered by the Company according to the contract. According to the right to use, the Customer may use the software and documents only according to the possible licensing conditions accompanying the software, the instructions of the Company, and only directly pertaining to the use of the Service. The ownership and immaterial rights of software and documents, as well as their revised versions, are the property of the Company or a third party (such as the principal or subcontractor of the Company), and the Customer has no right, without a prior written agreement from the Company, to copy, translate or change documents or software or distribute them for the use of a third party, unless otherwise compelled by imperative law.

4.5 Customer's Equipment and Software. The terminals, software and connections (such as connections to a mobile communication network and the Internet) that are required to use the Service are not included in the Service. The Customer is responsible for acquiring, maintaining and updating these devices, connections and software. In addition, the Customer is responsible for these devices and software not interfering or disturbing the functioning of the Company or the Service. Devices and software that may be causing disturbances must immediately be disconnected from the Service.

5. Maintenance of Service and Repairing of Defects

5.1 Maintenance of Service and Repairing of Defects. The Company strives to take care, to the best of its ability, of the functionality of the Service and to repair any possible defects in the Service within a reasonable time.

5.2 Temporary Interruptions. The Company has the right to close the Service or a part of it temporarily if there is justifiable reason to do so. In this case, the Company strives to work so that the interruption will be as brief as possible and cause as little disadvantage to the Customer as possible. The Company will, within its capabilities and beforehand if necessary, inform the Customer of the interruption, for example, on the Service website.

6. Reclamations Concerning the Service and Liability for Damage

6.1 Customer Reclamations. If the Customer notices a defect in the service, the Customer must make a reclamation and request a correction within a reasonable time after the defect was or should have been noticed. The reclamation can be made electronically through https://www.worddive.com/en/contact or by emailing info@worddive.com.

6.2 Correction of the Defect. In case the Company offers, without delay, to correct the defect pointed out by the Customer, the Company has the right to correct the defect. In case the defect cannot be corrected or is not corrected within a reasonable time after the Customer pointed it out, the Customer has the right to receive a price reduction relative to the defect.

6.3 Liability for Damage. The Customer has the right to demand compensation for direct damage according to the Consumer Protection Act sections regarding compensation. The Company is not liable for damage caused by the defect in case the defect is caused by a reason unrelated to the Company or a hindrance outside the Company's sphere of influence. The Customer has the right to be compensated for indirect damage caused by the defect only when the defect is caused intentionally by the Company or is caused by negligence on the part of the Company. The Customer is always obligated to act so that the damage caused by the defect does not increase needlessly due to the Customer's actions or negligence. The Company is only liable to consumer Customers for damage caused by the defect.

6.4 Responsibilities in Sales to Companies and Educational Institutes. The products and services are always sold as is. The Company is not liable for direct or indirect damage or loss of profit caused by defects in the products or services and/or the use of the products or services. The liability of the Company is always limited according to the content of these Terms of Contract.

6.5 Defects in Customer Controlled Devices or Software. If the Customer, knowingly or despite being notified by the Company, uses defective or disruptive devices or software, the Customer is liable to compensate the Company for any possible damages and the expenses of searching for the defects.

7. Payments and Billing

7.1 Payments for Service. The Customer pays for the use of the chargeable parts of the Service according to the price list or contract. The prices of the Service are available on the Service website at www.worddive.com. The Company may use third party billing services to exact the payments for the use of the Service. In these cases, the payments for the use of the Service are exacted according to the billing periods and terms as defined in the contracts between the third parties in question (such as mobile communication operators) and the Customer, unless otherwise specified in the Service.

The payments are exacted in advance for each billing period. Payments must also be made in case of Service downtime caused by the Customer or a reason the Customer is responsible for. In case of end of contract, the Company will not refund the Customer for advance payments.

7.2 Price Changes. The Company reserves the right to change its prices and the payments for the use of the Service. The current prices are announced on the Service website.

7.3 Methods of Payment. The products are paid in conjunction with the order. The available payment services depend on the country in question. One or more of the following payment services are available in each country for the users of the webstore: www.worddive.com

Apple App Store
Apple
1 Infinite Loop
Cupertino, CA 95014
UNITED STATES
Apple App Store provides tightly integrated and easy payments for Apple devices.

Klarna AB
Sveavägen 46
SE-111 34 Stockholm
SWEDEN
Klarna Group is the leading European payment provider. Their idea is to simplify buying.

PayPal Europe
22-24 Boulevard Royal
L-2449 Luxembourg
LUXEMBOURG
PayPal is the leading online payment service in the world.

Paytrail Oyj
Business ID: 2122839-7
Innova 2, Lutakonaukio 7
40100 Jyväskylä
FINLAND
Phone: +358 20 718 1830
www.paytrail.com
Paytrail Oyj (2122839-7) provides netbank related payment transfer services in co-operation with Finnish banks and credit institutions. Paytrail Oyj will be shown as the recipient in the invoice and Paytrail Oyj will forward the payment to the merchant. Paytrail Oyj is an authorized Payment Institution. For reclamations, please contact the website you made your payment to.

8. Duration of Contract and the Usability of Personal Parts of Service

8.1 Running Time of Personal Services and Products. For the fixed-period parts of the Service, the Company will announce the running time of that part either during the ordering of the service or in some other way within the Service. The Customer must note that the Service and its inherent characteristics are not eternal by nature, and the Company does not guarantee that the Service or the products or services purchased through it will remain unchanged. The username and other personal data connected to the Service are stored for a minimum of twelve (12) months after the latest contract period of the Customer has ended. After this, the Company has the right to remove the Customer's username and other personal data connected to the Service. More information about the processing of personal information during the use of the Service is available in the Privacy Policy of the Company’s WordDive service.

9. Closing the Customer's Service

9.1 Company's Right to Close the Service. The Company has the right to close the Customer's Service completely or partially and leave the Customer's order unfulfilled if:
9.1.1 The Customer has neglected to make a due payment despite being sent a reminder,
9.1.2 Despite notification by the Company, the Customer uses disruptive devices or software,
9.1.3 By use of the Service, the Customer has caused disruption to the Company, other Service users, or third parties,
9.1.4 The Customer breaks the duties that are agreed to in the contract,
9.1.5 The Customer has given fundamentally erroneous information during the opening of the Service or later, or
9.1.6 There is cause to suspect that the Customer is using the Service for illegal actions.
In effect since 30.1.2020
9.1.7 The Company has a technical or business-related reason which requires closing of the Service. In this case, the Company compensates the Customer the sum equivalent to the remaining study time.

10. Termination of Contract

Sections 10.1 and 10.2 before 1.7.2019
10.1 Customer's Right to Terminate the Contract. The Customer has the right to terminate an open-ended contract after observing a two (2) week termination period.
10.2 Company's Right to Terminate the Contract. The Company has the right to terminate an open-ended contract after observing a one (1) month termination period.

Clarified sections 10.1 and 10.2 from 1.7.2019 onwards
10.1 Customer's Right to Terminate the Contract. The Customer has the right to terminate an open-ended contract (subscription) by canceling it at least 24 hours before the beginning of the next billing period. The customer has the right to continue using the Service until the end of the already paid period. Instructions for canceling a subscription can be found in the following article: How can I cancel my WordDive subscription?
10.2 Company's Right to Terminate the Contract. The Company has the right to terminate an open-ended contract (subscription) after observing a one (1) month termination period.

10.3 Company's Right to Dissolve the Contract. The Company has the right to dissolve the contract if:
10.3.1 The Customer has not used the Service for over twelve (12) months,
10.3.2 The Customer's Service has been completely closed for one (1) month for a reason mentioned in section 9.1,
10.3.3 The Customer has otherwise, essentially and despite being notified, neglected the duties that have been agreed to in the contract.

11. Consequences of Termination of Contract

11.1 End of Service use and removal of data. When the contract ends, the Company has the right to stop the use of the Service with the Customer's user information and remove any possible data that the Customer may have saved in the customer-specific parts of the Service.

12. Other Terms

12.1 Issuing Information. The Customer must, before opening the Service, provide the Company the information it requires for the Service (customer information) and make sure that the given information is valid. The Customer must immediately notify the Company of changes to customer information on the Service website under Settings.

12.2 Notices. The Customer must send any written notices concerning this contract (including notice of termination) to the Company address info@worddive.com or WordDive Ltd, Verstaankatu 1, 2F, FI 33100 Tampere, Finland. The Company may send any written notices concerning this contract to the latest email address that the Customer has provided to the Company. General notices concerning the Service can also be published on the Service website. A notice sent by the Customer will be considered received on the seventh (7th) day after sending by post and on the next work day after sending by email.

12.3 Transferring the Contract. The Company has the right to transfer the contract to a third party fully or in part. The Company will notify the Customer of the transfer well beforehand. In addition, the Company has the right to transfer the payments due under the contract to the third party. After the notification of the transfer of due payments to the third party, the payments are only valid when made to the receiving party of the transfer. The Customer has no right to transfer the contract to a third party without a prior written agreement from the Company.

12.4 Applicable Law and Venue. This contract and its service-specific special terms operate under Finnish law and disputes concerning the contract are handled in Pirkanmaa District Court. In addition, a Consumer has the right to bring the dispute to be handled by the Consumer Disputes Board or in the Consumer's domestic District Court in Finland. If the Consumer is not a Finnish resident, disputes are handled in Pirkanmaa District Court, Finland.

12.5 Force Majeure. The parties are released from their duties and their duty to pay compensation when the breaking of the contract duties or failing to fulfill them is due to force majeure. A sufficient basis for the release from duty (force majeure) is an unusual event hindering the fulfilling of the contract that affects the matter, occurs after the contract is made, is independent of either party, and that cannot reasonably be avoided or overcome. Such events include war, rebellion, requisition or confiscation for general needs, termination of energy distribution, labor dispute, fire, thunderstorm or other natural phenomenon, cable damage caused by a third party, or another similarly effective and unusual event independent of either party. If the fulfilling of contract duty is delayed because of one of the abovementioned reasons, the period of fulfillment shall be extended for as long as is deemed reasonable with all the affecting circumstances in mind.

12.12.6 Effective Date of Terms of Use. These terms of use are effective from 1.3.2015 and are effective until further notice. Terms of Use are available from the Company free of charge.

12.7 Changes in Terms of Use. The Company can change these Terms of Use. The Customer will be notified of any new Terms of Use with customer notices and/or within the Service (for example, on the Service website at www.WordDive.com). The changed Terms of Use will be applied to the contracts made before the effective date of the new terms.

7.2.2020

WordDive Privacy Policy

1. Name and Address of the Registry Keeper
2. Contact Information in Registry Matters
3. Name of Registry
4. What Kind of Information is Collected?
5. Why Is My Information Collected?
6. What Are the Legal Grounds for Information Processing?
7. Which Sources Does the Information Come from?
8. Will Personal Information Be Shared with Third Parties?
9. Will Information Be Transferred Outside the EU or the ETA?
10. Right to Inspect and Right to Request Correction
11. Other Rights Related to Processing of Personal Information
12. Storing of Information
13. Use of Cookies
14. Registry Protection

Privacy Policy

This WordDive Ltd (later referred to as ”Company”) customer registry privacy policy is written according to the General Data Protection Regulation (EU) 679/2016. The Data Protection Regulation is a directly applicable legal framework in all EU Member States from 25.5.2018. WordDive Ltd is committed to following the applicable data protection legal framework when processing your personal information. This Privacy Policy provides a comprehensive explanation of the processing of personal information to customers using the WordDive service (later referred to as ”User”).

If you have any questions about the way your personal information is handled, please contact us at the address below.

1. Name and Address of the Registry Keeper

WordDive Oy
Verstaankatu 1, 2F
33100 Tampere, Finland

2. Contact Information in Registry Matters

info@worddive.com
+358 10 205 4455
(Charge 8,35 ct/call + 16,69 ct/min. This price is in euros and may include additional fees if calling from outside of Finland.)

3. Name of Registry

Marketing and Customer Registry of the WordDive service.

4. What Kind of Information is Collected?

Information submitted by the user during registration:
In order to register for the WordDive service and to use the service, the User has to provide their name, email address, preferred password for the user ID (email address), and the country where the service is being accessed from.

If the User registers for the service through Facebook, the Company will know the User’s Facebook username. Apple mobile devices also use a Sign in with Apple functionality which automatically gives the information on your name and email address from your Apple ID. If you want to, you can edit your name and choose to keep your email address private. You can find more information at https://support.apple.com/en-us/HT211687.

In addition, the User can voluntarily give the following information during registration or use of the service: year of birth, gender, first language, and where they heard about the service. Information about age, gender, and first language is used to develop the service, optimize the exercises, and to set the default translation language. Information about where the User heard about the service is used for marketing development purposes.

Information collected automatically during registration:
Personal User identifier
Time of registration
Registration channel
Free sample activation data
User interface language
User type
Time zone

Information generated automatically during use of the service:
First login day
Purchase events
Start and end date of licence
Login data (”Remember me” cookies)
Offer campaign data
Analytics data (Google Analytics)
Learning results
User’s achievements in the mobile app
Hints and reminders shown to User
Time from last password change

Information submitted or selected by the User during use of the service:
Audio files generated by User doing speaking exercises
Wrong answers (not connected to individual users)
Feedback on study material (optional)
Friends added by User (optional)
Study group data (for organisation users)
User’s exams (prep course users)
Grade guarantee refund data (prep course users)
Newsletter subscription or unsubscription
General service usage settings
User’s course-specific settings
User’s language-specific settings

Other information collected and handled for purposes described in section 5:
Notes added manually by customer service or R&D
Information about which emails sent by WordDive the User has opened

5. Why Is My Information Collected?

The information specified in section 4 is collected and processed for the following purposes:

Use of the service

The User’s email address and password are required for registering and logging in to the service, except if the User uses the Sign in with Apple functionality. During purchase events, information related to the purchase, such as the chosen course package and the duration of the licence, is stored so that we can deliver the User the service the User has bought. Information about country is required to set the correct currency and tax.

The WordDive service is based on personal optimisation (profiling), which requires the Company to store information such as the User’s exercise data, including selected, written, and recorded answers. Optional information, such as age and gender, is also used to develop the service and optimise the exercises.

The profile formed as a result of this optimisation consists of information collected from the User during registration and use of the service. This information is necessary to use the service, i.e., to get the individual optimisation.

Much of the other information specified in section 4 is required to use the different features of the service. For example, certificates are sent based on stored results. The settings selected by the User are stored in order to adjust the functioning of the service according to the User’s wishes.

Research and development

The development of WordDive’s features and exercise algorithm is based on different tests and statistical analysis of User behaviour data stored in the database, as well as the Users’ learning results. The data used in research and development is not traceable to an individual User. According to the applicable data protection legal framework, the analysis is made statistically using a large mass of data (e.g. all Users learning English) where the information is stored anonymously and individual Users are no longer identifiable.

Customer service and informing Users

The User’s contact information, payment information, and exercise information is also required to answer customer support requests. These requests usually involve looking at the User’s information and exercise data in WordDive’s management panel and checking payment information in various payment service providers’ management panels. User email addresses are also required for informing purposes.

Marketing

Marketing platform pixels and other similar techniques collect information about Users’ movement and actions in the WordDive service. This information can be used to show them targeted advertising. The purpose of targeted advertising, e.g. in Facebook and Google, is to show each consumer advertisements for products and services the consumer is interested in rather than completely random advertisements.

The visiting User has the right to resist this kind of profiling-based advertising or withdraw consent by disabling “Targeting cookies” from the website’s cookie settings. The registered User can manage their ad settings directly in the social media services they use. Instructions for managing the ad settings can be found from the websites of those services.

https://www.facebook.com/help/247395082112892?helpref=related
https://support.snapchat.com/en-US/a/advertising-preferences

Accounting

The User’s personal information is also handled while fulfilling the Company’s legal duties, such as taxation and accounting of the Company. For accounting and taxation purposes, the Company must know, e.g., which products the Users have purchased, how much the products cost, which payment service provider was used, and which country the purchases were made from (country information affects, e.g., the amount of Value Added Tax). User contact information is required in case any problems or misuse issues related to payments arise.

Changes or additions to information usage purposes

In case there are essential changes to the usage purposes of personal information or new purposes are taken into use, the Company will inform the User well in advance before carrying out the changes. In these cases, the Company must also ask the User’s consent for such essential changes or new usage.

6. What Are the Legal Grounds for Information Processing?

There are six legal grounds for processing personal information defined in the EU Data Protection Regulation. These are:

• Consent
• Performance of a contract
• Legal obligation
• Protection of vital interests
• Grounds related to public interest or official authority
• Legitimate interests

WordDive collects and processes personal information mainly on the grounds of consent, performance of a contract, grounds related to the Company’s compliance with legal obligations, and legitimate interests.

Before the User registers to the WordDive service and submits personal information to the Company, the User is requested to read the contents of the Privacy Policy related to the use of this service carefully before consenting to the processing of the User’s personal information. The request for consent is presented clearly and separately from other matters, in an easily understandable and accessible form, in clear and simple language. At the same time, the User is informed that the User has the right to withdraw consent at any time. More information about withdrawing consent is given elsewhere in this Privacy Policy. According to the free consent principle, the User may choose which consent-based personal data usage purposes the User consents to.

Grounds related to performance of a contract means that certain information has to be collected from the User to make it technically possible to use and purchase the service.

Compliance with a legal obligation means processing personal information, e.g., for the purposes of performing the Company’s duties related to accounting and taxation.

The Company may have legitimate interests related to the following functions amongst others: customer service, handling of misuse cases, product and service development.

The collecting and processing of all information listed in section 4 is based on some of these legal grounds. If you would like to get a more detailed explanation of these legal grounds, you may request it by email at info@worddive.com.

If the User does not want to submit personal information which is required on the grounds of performance of contract, grounds related to the Company’s compliance with legal obligations or the Company’s other legitimate interests, the service cannot be used.

7. Which Sources Does the Information Come from?

Personal information is collected mainly from the Users themselves, either directly or through cookies (see section 14). Information is also generated automatically during registration, purchase, and use of the service (see section 4).

Personal information can also be collected from publicly available information and other external sources: registries upheld by authorities (e.g., civil registry) and credit registers.

8. Will Personal Information Be Shared with Third Parties?

Personal information will be shared with payment service providers that charge for products and services ordered from or used via WordDive. The payment service providers used by WordDive are:

• Apple App Store
• Google Play Store
• Klarna
• PayPal Europe
• Paytrail

The processing of information by the abovementioned payment service providers occurs according to the requirements of the EU Data Protection Regulation, and an agreement on the processing and confidentiality of personal information has been made with them. WordDive is responsible for the processing of personal information done by these third parties the same way as it itself is in regard to the User.

Personal and puchase information are also shared with the following third parties:

• Joviaali Oy, responsible for the accounting and payroll of the Company
• Freshdesk, a software used by the customer service of the Company
• Mailchimp, a software used by the Company in sending newsletters
• Google, a service used by the Company in advertising and analytics
• Facebook, a service used by the Company in advertising
• Instagram, a service used by the Company in advertising
• Snapchat, a service used by the Company in advertising
• Smartly, a service used by the Company in advertising
• Appsflyer, an analytics service used by the Company
• App Annie, an analytics service used by the Company
• Unity, a service used by the Company in product development

The processing of information by the abovementioned companies occurs according to the requirements of the EU Data Protection Regulation, and an agreement on the processing and confidentiality of personal information has been made with the companies. WordDive is responsible for the processing of personal information done by these third parties the same way as it itself is in regard to the User.

A User visiting the Company’s website has the right to resist this kind of profiling-based advertising or withdraw consent by disabling “Targeting cookies” from the website’s cookie settings.

A registered User can manage their advertising settings directly in the social media services they use. Instructions on advertising settings used by the marketing partners of the Company can be found directly from the partners’ websites.

The WordDive.com website as well as the WordDive mobile application are located on the servers of the Finnish cloud service provider Nebula in Helsinki. Part of the service is located on the servers of the trustworthy international service provider AWS (Amazon Web Services) in Ireland. Both Nebula and Amazon are ISO 27001–certified.

WordDive can share the User’s information also with other third parties if the User has given their consent to it. WordDive can also use other subcontractors, unnamed here, in the processing of the User’s information as long as the processing happens according to the requirements of the EU Data Protection Regulation.

WordDive is responsible for its subcontractors’ processing of personal information the same way as it itself is in regard to the User. With contractual arrangements, WordDive ensures that subcontractors are bound by non-disclosure and confidentiality, and that they carry out the appropriate technical and organisational measures when processing personal information.

WordDive may also transfer information to a company belonging to the same business group as well as during company reorganisation.

9. Will Information Be Transferred Outside the EU or the ETA?

Some of the third parties mentioned in section 8, with whom personal information of the Users is shared, are companies outside the EU (American). However, all the companies are large, reliable operators that have many clients in the EU area and that follow the principles of the EU Data Protection Regulation.

If personal information is transferred outside the EU or the ETA, the transfers always comply with the EU’s standard contract clauses or other appropriate protective measures to ensure that the transfer complies with the EU Data Protection Regulation’s requirements.

More information about data protection in these companies as well as the international data protection certificates granted to them can be found from the companies’ websites.

10. Right to Inspect and Right to Request Correction

WordDive does not check the correctness of the information submitted by the User. Users logged in to the service can check and change their settings related to the use of the service, as well as the personal information submitted during registration.

The User also has the right to request a copy of all other information concerning themselves from the WordDive customer service, as well as the right to request the correction of any possible incorrect information in the system from the customer service. The copy can be requested by email at info@worddive.com. Requesting a copy is free in principle. However, WordDive may charge a reasonable fee for repeated information requests on the grounds of administrative expenses or refuse to perform the action requested by the User if the request is clearly baseless and unreasonable.

11. Other Rights Related to Processing of Personal Information

Deleting information

The User can delete their own user account through the service settings. The User also has the right to request the Company to delete all the User’s personal information from the WordDive database. Information deletion can be requested by email at info@worddive.com.

All other information, apart from that which is required by official authorities (e.g., payment transaction data for accounting) the data used in research and development which is generated by the use of the service (e.g. written or recorded answers), can be deleted from the database manually. After other information has been deleted, such exercise data cannot be connected to the User. In other words, it becomes anonymous information as recommended by the applicable data protection legal framework.

Refusing direct marketing

The User can forbid the use of their information for direct marketing purposes, marketing research, and opinion polls. WordDive uses the MailChimp software for practically all marketing letters and research invitations. The User can unsubscribe from these by disabling emails in their settings or by clicking the newsletter unsubscribing link that can be found in the footer of each newsletter.

Limiting information processing

TThe User can forbid the use of their information on the so-called Top List, which displays the Users’ first names, the initial of their last names, and the sum of their progress in the service during a certain period of time, e.g., one week. There are two Top Lists: one for the friends added by the User and one for all Users. The purpose of the lists is to motivate the Users and their friends to learn languages.

The Company has the right to save the User’s photo if the User has given the Company the right to use it. The User always retains the right to decide where the picture can be shown or if it can be shown at all.

Transferring information

The User has the right to transfer the information concerning them from one registry keeper to another. In matters concerning transferring information, please contact info@worddive.com.

Right to withdraw consent

If the User has consented to personal data processing that is not based on performance of contract, the Company’s compliance with legal obligations, or the Company’s legitimate interests, the User also has the right to withdraw this consent. Targeting cookies can be disabled from the cookie settings. The User can withdraw consent to direct marketing by disabling emails in their settings.

Right to file notice of appeal to authorities

If the User is of the opinion that WordDive does not comply with the Finnish Personal Data Act or the requirements of the EU Data Protection Regulation, the User has the right to file notice of appeal to an authority. In Finland, this authority is the Data Protection Ombudsman.

12. Storing of Information

WordDive will store User and usage information for a minimum of one year after the end of the User’s last subscription period, unless the User specifically requests to have the information deleted. After this, the information may be deleted from the registry during database clean-ups carried out at certain intervals according to the current practice.

Notwithstanding the above, and for the sake of clarity, it should be noted that information related to purchase events may be stored even after this time, to the extent and for the time the service provider believes it necessary to store this information, in order to carry out accounting and other legal obligations.

13. Use of Cookies

In order to monitor the use of the service and to make it possible, cookies may be introduced to the User’s computer at times. Cookies make it possible for the Company to provide the User with a service that takes the User’s wishes and preferences into account better.

Cookies can also be used to give the User better offers and more personal product recommendations, either directly or through an external service, such as Google or Facebook.

In addition, cookies are used to monitor the number of visitors in the service. Parts of the website require accepting cookies in order to function. Targeting cookies can be disabled from the cookie settings.

You can also manage advertisement settings in your Facebook or Google or other social media account. You can manage cookies on your computer by using a service designed for that purpose, such as Disconnect.

https://disconnect.me/disconnect

For more information concerning browser-based online marketing and online privacy:

https://www.youronlinechoices.com/

14. Registry Protection

All persons handling the registry possess a personal user permission (username, password, and level of rights) granted by the registry keeper. These persons operate under a non-disclosure agreement or are otherwise legally obligated to confidentiality. The personal information of Users is accessible only by persons who need this information to do their work. These include the customer service personnel and technical staff.

WordDive will, to the best of its ability, strive to offer the service in such a way that external parties will not get unlawful access to the User's information or communications. Other parties connected to providing the service (e.g., payment service providers and network or mobile operators) are responsible for their own data security.

WordDive strives to offer the service according to the principle of Privacy by Default. Personal information is processed in pseudonymous or anonymous form whenever possible. The information content of the registry is technically secured and backups are made regularly.

WordDive carries out the appropriate technical and organisational actions in connection to processing personal information, especially in order to protect personal information from data security breaches. If, despite this, a data security breach (i.e., accidental or illegal destruction, loss, altering, unlawful transfer or access) that causes a high risk to the Users’ rights and freedoms should occur, we will inform without delay the Users of the violation, including its likely effects and the recommended actions for counteracting its harmful effects.

17.5.2021