Privacy policy

Welcome to the VoxiKids Privacy Policy!

We are very glad that you are here and we can't wait to discover what VOXivers can do for you.
The VoxiKids mobile app is mainly intended for children between 2-8 years old, to practice their language and pronunciation.
The VOXi speech therapy platform, developed together with speech therapy specialists, includes a series of management tools that streamline parent-patient collaboration and facilitate remote work, with the common goal of child recovery and good integration in the preschool and school environment.

With VoxiKids - Easy Speech! Speaking correctly has never been easier!

In order to accomplish these things, VOXivers needs to process certain personal data from you, to help you understand how the app works and get the maximum results. We are transparent and don't want you to think that we process data without informing you for what purposes.

With this Privacy Policy, we tell you how we process your personal data, what we do with it and what rights you have in relation to it.

Let's get started!

1.1. Where can you find us?

We'll refer to VoxkiKids by we, the company or organization, to make it easier to follow.

This Privacy Policy applies wherever you find us online. In particular, we are present through voxivers.com or voxikids.com and under its domains or affiliated sites (which we will collectively refer to collectively as the "Site"), as well as all media profiles/pages associated with this brand, including but not limited to Facebook, Instagram, Youtube, Twitter, LinkedIn, Google Play and Apple Store platforms where we are in app form, etc., and we will refer to all of them as the "Platform" or Mobile App).

The platform is especially dedicated to children, and that means we take extra care with this data and we will always check that there is parental or guardian consent.

It is important that you read this policy in conjunction with our Terms & Conditions and Cookies Policy and with all the Data Processing & Privacy Notices that we will provide to you on various occasions when we collect or process your personal data so that you are always fully informed about what and how we use that data. This Privacy Policy represents the main regulatory framework for the protection of personal data and is in addition to the other notices specific to certain activities in the app comes as an addition to the other notices and is not intended to supersede them.

1.2 We are VOXivers - includes VoxiKids mobile app and VOXi Platform

From a legal point of view, you can also find our identification details below:

Name	Speakquest SRL
Head office	Locality Victoria, str. Victoriei, nr. 22, jud Brașov,
Trade register number:	J8/458/2020
Unique identification code	42327556
E-mail	[email protected]

To the extent that you have any queries, comments or complaints about us or the personal data we process for you, you can always send us an e-mail at any time to the above address.

Under the law, in relation to you we are a personal data controller. In that capacity, we have a number of obligations, including to inform you about the data we process, how we do it, what rights you have and how you can exercise those rights.

1.3. Who are you?

Whether you are the User (the child using the services of our platform), the Parent or the legal guardian - the User or the Speech Therapist conducting speech therapy sessions (the Professional), you are the data subject in relation to the processing of personal data concerning you.

As a person, you have different characteristics that make you unique and help us to identify you: name, surname, address, image, voice, etc.

We process this data mainly to enable you to access the services we offer through our online platform and mobile applications. This means that we are responsible for keeping your data confidential and you benefit from a number of rights whereby you have control over this data processing.

That's why we need to tell you what personal data we process, why we need it, what we do with it and for how long.

Data we collect from you through the online platform

2.1. If you are the child's parent or guardian

In order to facilitate your child's access to VOXivers facilities, you will need to provide us with certain personal data.

Depending on the services or functionalities that you wish to access for your child and that we have developed, we may need to collect, process, store or transfer certain personal data:

Category	Dates included
Identification data	first name, last name, username or similar identifier, date of birth, language in which you wish to communicate.
Contact date	billing address, e-mail address
Financial data	payment or card/bank account information, purchase information
Trading dates	details of payments to and from you and other details of services you have purchased from us
Technical data	internet protocol (IP) address, login details, browser type and version, location and time zone settings, browser plug-ins and versions, operating system, operating platform and other technologies on the devices you use to access this website
Profile date	user name, password, the commands you have made, your interests and preferences, your language characteristics, the feedback you have given, your survey answers
Usage & interaction data	information about how you use our website, services, including video and audio recordings of speech therapy sessions
Marketing & communication data	your preferences for receiving marketing materials from us and our third parties and your preferred methods of communication

If you are the parent or guardian of a child under the age of 16 we will need your explicit consent to process your child's personal data, but in particular for special categories of data, such as data relating to your child's health. So, in addition to the information above, you will need to provide us with the following data for each child you register in your account:

first name, surname;
age;
hearing age;
any speech difficulties your child has, as indicated in the platform;
explicit consent to the processing of the child's personal data
a sworn declaration that you are a legal representative or guardian.

Please keep in mind that this data is necessary for us to be able to provide the best experience for your child and to customize their experience on our online platform. Our aim is to make speech therapy play and the level of play should be tailored to the requirements, needs and abilities of each individual child.

And Popeye the Sailor ate a lot of spinach before he got big and strong.

When choosing private sessions with a speech and language therapist, please note that the interaction that takes place online between the child and the speech and language therapist will not be audio-recorded. This is necessary in order for the speech therapist to be able to correct the child's speech and to help the child improve his or her hearing and pronunciation by checking the stimuli and the correctness of the exercises, while monitoring the child's progress over time.

It is preferable that the private therapy sessions take place in a location where the child and the parent are present to supervise the therapy session from a distance, without other people or stimuli that could distract the child.

2.2. If you are a User - the child receiving speech therapy services

If you are a child under the age of 16 who wishes to use our platform, you will not be able to access the services offered by the VOXi online platform without the consent of the parent or legal guardian.

Depending on the services or functionalities that you wish to access for your child and that we have developed, we may need to collect, process, store or transfer certain personal data:

Category	Dates included
Identification data	first name, surname, username or similar identifier, date of birth, language in which you wish to communicate, level of language development
Contact date	billing address, e-mail address
Financial data	payment or credit card/bank account information, purchase information - will be kept in the cloud with maximum security - no access to it
Trading dates	details of payments made and other details of the services you have purchased from us
Technical data	internet protocol (IP) address, login details, browser type and version, location and time zone settings, browser plug-ins and versions, operating system, operating platform and other technologies on the devices you use to access this website
Profile date	your username, profile picture, the orders you have made, your interests and preferences, your language characteristics, the feedback you have given, your survey answers
Usage & interaction data	information about how you use our website, services
Marketing & communication data	your preferences for receiving marketing materials from us and our third parties and your preferred methods of communication

2.3. If you are a professional (speech therapist)

We need information about your professional qualifications so that we can verify that you are indeed a professional before allowing you access to the platform. This information consists of:

proof of a degree in psychology
attestation of the right of free practice
proof of having completed a specialized course in speech therapy
documents proving the form of professional organization (SRL, PFA, etc.)

If you are unable to provide us with information about your qualifications, we will not be able to create an account and register you on the platform.

Category	Dates included
Identification data	first name, last name, username or similar identifier, language in which you wish to communicate, city, country
Professional information	the data included in diplomas, certificates, documents proving the form of professional organization (SRL, PFA, etc.)
Contact date	billing address, e-mail address, telephone number
Transaction (financial) data	details of payments to and from you and other details of the services you have accessed, your bank account
Technical data	internet protocol (IP) address, login details, browser type and version, location and time zone settings, browser plugins and versions, operating system, operating platform and other technologies on the devices you use to access this website
Profile date	your user name, the commands you have made, your interests and preferences, your language characteristics, the feedback you have given, your survey responses
Usage & interaction data	information about how you use our website, services,
Marketing & communication data	your preferences for receiving marketing materials from us and our third parties and your preferred methods of communication

2.4. Aggregated/anonymized data

We collect, use and share for any purpose Aggregated Data, such as statistical or demographic data. Aggregate Data may be derived from your personal data, but is not considered personal data for the purposes of the law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific functionality of the Site. However, in the event that we combine or correlate Aggregated Data with your Personal Data in such a way that we can directly or indirectly identify you, we will treat the resulting combined data as Personal Data that will be used as described herein.

We will also apply data anonymization procedures to analyze the child's progress in order to ways to improve the quality of our services.

What information in your child's profile is visible to others?

Your child's full profile is confidential. Other parents in the same kindergarten, school or speech therapist's office cannot see other children's data. The logopedist (specialist/psychologist) can only see the child's name, avatar (which can be the default avatar or the avatar modified by the parents) and the data set by the parent him/herself (name/surname, chronological age, language delays). Specialists (speech therapists/psychologists) can see the data provided by the parent on the basis of the parental consent that the parents give on the platform when creating the child profile.

How do we collect your personal data?

We may collect your personal data in several ways, such as:

Direct interaction
Indirect interaction
Automated technologies or interactions
Third parties or publicly available information
Information that we build internally, as you interact with VOXivers products, either through the online platform or through the connection you have with a speech therapist.

4.1. If you are a Father

Source

Dates

Direct interaction

You can directly provide us with data about yourself(such as Identifying Data, Contact Data and Financial Data) by filling in the existing fields on the website or by email, telephone or other method we make available to you. This includes Personal Data you provide to us when:

● you want to download one or more of the materials we put on the Platform;

● you want to buy/benefit from one of our goods or services;

● connect with a speech therapist through the VOXi platform;

● make an account with us on our website or mobile app;

● subscribe to our services or publications;

● request promotional & marketing materials;

● enter a competition or promotion, fill in a questionnaire, etc.;

● give feedback etc.

Automated technologies or interactions

As you use our website, we may automatically collect Technical Data about the equipment you use, how you browse and various patterns. We collect this information through the use of cookies, server logs and other similar technologies.

Please read our cookie policy for further details.

4.2. If you are a User (Child)

Source	Dates
Parent or guardian	name, surname, chronological age, language age
Interaction with a speech therapist	we do not collect/record video and audio of speech therapy sessions, the whole session is completely private
Automated technologies or interactions	As you use our website, we may automatically collect Technical Data about the equipment you use, how you browse and various patterns. We collect this information through the use of cookies, server logs and other similar technologies. Please read our cookie policy for further details.

4.3. If you are a professional (speech therapist)

Source

Dates

Direct interaction

You can directly provide us with data about yourself(such as Identifying Data, Contact Data, Financial Data and Professional Data) by filling in the existing fields on the website or by email, telephone or other method we provide you with, as well as by uploading/transmitting supporting documents. This includes the personal data you provide to us when:

● you register in our network of logloggers;

● connect with a child through the VOXi platform;

● subscribe to our services or publications;

● request promotional & marketing materials;

● complete a questionnaire, give us feedback etc.

Automated technologies or interactions

Please read our cookie policy for further details.

Why do we collect your personal data?

We will mainly collect your (or the minor's) personal data in order to directly provide the service you are accessing.

However, we do use your (or your minor's) personal data so that we can improve the Platform, send you suggestions about facilities that might help you, see what you would like and how we can make the service better.

In short, our grounds for processing your data will generally be as follows:

You have consented to the processing of your personal data

Please note that you can withdraw your consent at any time by following theunsubscribeinstructions in each e-mail or by sending a written request to the e-mail address [email protected]

The processing is necessary for the conclusion or performance of a contract between you and us
Processing is necessary for our legitimate interests or the legitimate interests of another party

We have set out below, in a tabular format, a description of the ways in which we plan to use your personal data and the legal basis on which we do so. We have also identified our legitimate interests where appropriate.

Please keep in mind that we may process your personal data on more than one legal basis, depending on the purpose for which we use the data. Please contact us at [email protected] if you would like more details about the legal grounds we rely on when processing your personal data where there has been more than one legal ground highlighted in the table below:

Aim	Personal data	Further information	Legal basis
Register as a User	Identification Data Contact Date	If you decide to register as a user on the Platform, we need to process your data in order to identify you as a user of the Platform and to provide you with access to its various features and services available to you as a registered user. In certain cases, the creation of an account will be automatic in order to be able to access the services you have purchased from us. You can cancel your registered user account at any time either from your account on the website, from your Customer Account or by emailing [email protected]. At the same time, depending on the development of the Platform, you will have the possibility to log in through a social network, such as Facebook/Google, either to register as a new user or to associate the login with your current account. In this case, your login details, as well as your email address (if you accept this), will be imported from your social network account. By using this login option, the social network may send us some additional information from your public profile, such as your name, gender, approximate age or profile picture, in accordance with the social network's terms of use, which we recommend you read carefully. If you do not consent to this transfer of data, we will not retain this additional information. Please note that if you choose to connect with an approved social network, this may involve providing certain information about your activity on that social network. In any case, we recommend that you check your privacy settings and read the privacy policy of those social networks to know how this data is processed by social networks.	The processing of your data is necessary in order to sign the terms governing your use of the site. In other words, in order to register you as a user of the site, we need to process your personal data, otherwise we would not be able to manage your registration (the basis being the conclusion or performance of a contract, including previous steps for the conclusion)
Access to materials	Identification Data Contact Date	We will use your personal data to give you access to the materials you want to download from the Platform, such as guides, lists, suggestions, ratings or other materials that we will make available to you, free of charge	Conclusion and performance of the contract (provision of services)
Conclusion and performance of your electronic contract with us	Identification Data Contact Date Financial Data Date of Use Trading dates Profi dates	For the operations described here, we will use your personal data to: ● we deliver the service you contracted ● contact you about updates or informational communications regarding contracted functionality or services, including sending you surveys regarding the quality of services provided. ● managing payments for purchased services is done through an external service, so VOXivers has access to a limited set of data. Your card details do not remain saved on any of the company's servers. ● We activate the necessary mechanisms to prevent potential fraud against you and us during the purchase process. If we assess that the transaction may be fraudulent, this processing may result in the transaction being blocked. ● for invoicing - to provide you with electronic/physical invoices and receipts for the transactions you have made. ● for providing other services to be implemented.	Conclusion and execution of the contract (provision of services). It is necessary for us to process your personal data in order to be able to execute the electronic contract for the provision of the services you want from us. We also have a legitimate interest in carrying out the necessary checks to detect and prevent fraud when you want to make a purchase.
Inquiries or requests made via Customer Service/Support	Identification Data Contact Date Financial Data Trade Dates Profile Date	We process only the personal data strictly necessary to handle or resolve your request or application. We have a legitimate interest in responding to your requests or questions through the various means of contact. This includes private messages that you send us in which you ask us questions about the Platform, campaigns or want more information. We understand that the processing of this data is also to your benefit, as it allows us to be able to assist you properly and to find a solution to your questions. When you contact us, in particular to handle incidents or ask us for clarifications on the service purchased, the processing is necessary for the proper performance of the sales contract. When you contact us to deal with order-related incidents or to make a complaint, the processing of your personal data is for the fulfillment of our legal obligations in this regard.	Conclusion and performance of the contract (provision of services) Legitimate interest
To manage the relationship we have with you	Identification Data Contact Date Profile Date	This processing involves: (a) notify you about changes to our terms & conditions and data processing policies (b) ask you to leave us a review or participate in a survey We will process your data in order to keep your data up to date and to understand how users use our services or how we could improve them.	Conclusion and performance of the contract (provision of services) The legitimate interest to improve the services we offer.
Marketing	Identification Data Contact Date Trade Dates Profile Date Marketing and Communication Data	We will process your personal data for this purpose mainly in the following cases: ● if you subscribe to our newsletter, we will process your personal data to manage your communication preferences, including sending you personalized information about our services by various means (such as email or SMS). We may also send you this information via push notifications if you have enabled them on your mobile device or in your browser. Please be aware that this data processing involves analyzing your user or customer profile for the purpose of creating profiles by which we determine what your preferences are at a given point in time based on your browsing history and choices and thus which services best suit you at the time you submit your information to us. For example, on the basis of your shopping and browsing history, we will make suggestions to you about facilities that we think may be of interest and use to you. You will be able to unsubscribe from the newsletter at any time and totally free of charge by following the unsubscribe instructions in each e-mail or by sending a written request to [email protected] ● To carry out promotional actions (e.g. to run competitions). By taking part in any promotional action, you authorize us to process the data you provide in relation to each action, which we may communicate through various means, such as social media or even on the website. At each promotional action in which you participate, you will be able to access the terms and conditions section, where we will provide more detailed information about the processing of your data in that context.	We process your data for marketing purposes based on the consent you give us, for example when you agree to receive personalized information by various means, when you authorize push notifications to be sent to your mobile device or browser. We also have a legitimate interest in presenting you with personalized information (such as offers for services similar to those already purchased by you, or new added facilities that may be of great interest to you) because we understand that processing this data is also to your benefit as it allows us to improve your user experience and thus to access information according to your preferences.
Improve- the services	Identification Data Contact Date Trade Dates Profile Date Marketing and Communication Data Technical Dates	If you access our website, we inform you that we will process your browsing data for analytical and statistical purposes, i.e. to understand how users interact with our website and so that we can improve it. We also sometimes carry out quality actions and surveys to find out how satisfied our customers and users are with our services and to detect areas where we can improve our services.	We consider that we have a legitimate interest when we analyze how our website is used and the level of user satisfaction. The processing of this data is also for your benefit as the aim is to improve the user experience and provide a better service.
To deliver relevant content and personalized ads, and to measure and understand the effectiveness of the ads we offer you	Identification Data Contact Date Usage Data Profile Date Marketing and Communication Data Technical Dates	We need this data to understand how our customers and users use our services, to develop new services, to grow our business and to adapt our marketing strategy	Consent
Use analytics data to improve the Platform, services, departments- customer tul and experience	Technical Dates Usage Data	This data is necessary for us to understand the categories of customers for our services, to keep our platforms up to date and relevant, to develop new services, to grow our business and to adapt our marketing strategy	Legitimate interest
Tips and recommendations on services that might be of interest to you	Identification Data Contact Date Usage Data Profile Date Marketing and Communication Data Technical Dates	We need this data to grow our business and adapt our marketing strategy	Legitimate interest
When you react to social media content	Name, image, any information publicly accessible in your social media profile, or voluntarily communicated by you.	We are present on Facebook and LinkedIn, Instagram, Youtube and Twitter. Whenever you interact with us through our open accounts on these platforms (e.g. comment, like, share, review, etc.) we will have access to the publicly available data on your profile. The interaction of a user with one of the social plugins available on the platform www.voxivers.com and voxiclinic.com, provided by the social networks, involves an exchange of data between the application and the respective social media network for which the platform owner is responsible together with the respective social media platform.	We process your data in our legitimate interest in order to respond to any questions, complaints or recommendations you send us, to improve our services and the experience we offer to our customers and to keep you informed about news we publish that may be of interest to you.

In short, we will retain your personal data for as long as necessary to fulfill the purposes for which we have collected it, including for the purposes of satisfying any legal, accounting or reporting requirements.

In determining the appropriate retention period for personal data, we have taken into account the value, nature and sensitivity of your personal data, the potential risk of harm caused by unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes by other means and applicable legal requirements.

Purpose of processing	Storage term
Register as a User	● We will keep the data recorded in your account until you decide to close your account, but we will delete them (including your account) if it has been more than 5 years since you last logged into your account. ● The data recorded in the financial-accounting documents (e.g. invoices, card payments, reimbursement payments, etc.) will be kept in the archive for 5 years, starting from the end of the financial year during which they were drawn up, in accordance with the periods of the Accounting Law no. 82/1991 and Order 2634/2015
Access to materials	You will have access to materials for as long as your account is active
Conclusion and performance of your electronic contract with us	● The data recorded in the financial-accounting documents (e.g. invoices, card payments, reimbursement payments, etc.) will be kept in the archive for 5 years, starting from the end of the financial year during which they were drawn up, in accordance with the periods of the Accounting Law no. 82/1991 and Order 2634/2015 ● Video and audio recordings of speech therapy sessions will be stored for 12 months
Inquiries or requests made via Customer Service/Support	We will not keep in our database communications older than 1 year from the date of the last interaction.
To manage the relationship we have with you	We will process your data that you provide to us for 12 months from the time we receive it
Marketing	● In case of newsletter subscription, data processing will continue until you unsubscribe ● In the case of processing carried out for legitimate interest, when you are already our customer, we will process your data for the duration of the contract and will continue to do so for 3 years after the termination of the contract.
Improving services	We will process the data for 12 months from the time of collection
To deliver relevant content and personalized ads, and to measure and understand the effectiveness of the ads we offer you	We will process the data for 12 months from the moment you have given your consent to this processing
Use analytics data to improve the Platform, services, customer service, customer department and experience	We will process your data during the performance of the contract and will continue to do so for 3 years after the termination of the contract.
Tips and recommendations on services that might be of interest to you	We will process your data that you provide to us for 12 months from the time we receive it
When you react to social media content	Data transmitted through social media networks will be stored by them according to their own policies.

Under certain circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for scientific, historical or statistical research purposes, in which case we may use this information for an unlimited period of time without prior notice to you.

Data we collect from you via the mobile app

The mobile VoxiKids App, through which users have access to over 300 interactive educational exercises specially designed for children aged 3 to 8, is available in both Android and iOS.

The personal data that we process are those provided by the parent or guardian by registering in the application and those deriving from the use of the mobile application.

Depending on the services or functionalities that you wish to access for your child and that we have developed, we may need to collect, process, store or transfer certain personal data:

Category	Dates included
Identification data	Username, e-mail, language in which you wish to communicate
Contact date	e-mail address
Financial data	payment or credit card/bank account information is held and managed by Google Play or the App Store, we are responsible for information about purchases made

Technical data	IP (internet protocol) address, login details, browser type and version, location and time zone settings, operating system
Profile date	user name, password, the commands you have made, your interests and preferences, your language characteristics, the feedback you have given, your survey responses
Usage & interaction data	information about how you use the app, your child's progress
Marketing & communication data	your preferences for receiving marketing materials from us and our third parties and your preferred methods of communication

If you are the parent or guardian of a child under the age of 16 we will need your explicit consent to process your child's personal data. So, in addition to the information above, you will need to provide us with the following data for your child:

first name, surname;
age;
explicit consent to the processing of the child's personal data;
a sworn declaration that you are a legal representative or guardian.

Please keep in mind that this data is necessary for us to be able to provide the best experience for your child and to customize their experience in the app. Our aim is to make speech therapy play and the level of play should be tailored to each individual child's requirements, needs and abilities.

We may collect your personal data in several ways, such as:

Direct interaction
Indirect interaction
Automated technologies or interactions
Third parties or publicly available information
Information that we build internally as you interact with VOXivers products via the mobile app

Source

Dates

Direct interaction

You can directly provide us with data about yourself(such as Identifying Data, Contact Data) by filling in the existing fields on the website or by email, telephone or other method we provide you. This includes personal data you provide to us when:

● you want to download one or more of the materials we put on the Platform;

● you want to buy/benefit from one of our goods or services;

● make an account in the mobile app

● subscribe to our services or publications;

● Your activity in the mobile app

● request promotional & marketing materials;

● enter a competition or promotion, fill in a questionnaire, etc.;

● give feedback etc.

Automated technologies or interactions

As you use our app, we may automatically collect Technical Data about the equipment you use, how you browse and various patterns. We collect this information through the use of cookies, server logs and other similar technologies.

Please read our cookie policy for further details.

Why do we collect your personal data?

Mainly we will collect your (or the minor's) personal data in order to be able to directly provide access to the mobile application features.

However, we use your (or your minor's) personal data so that we can improve the App, send you suggestions about facilities that might help you, see what you would like and how we can make the service better.

In short, our grounds for processing your data will generally be as follows:

You have consented to the processing of your personal data

Please note that you can withdraw your consent at any time by following theunsubscribeinstructions in each e-mail or by sending a written request to the e-mail address [email protected]

The processing is necessary for the conclusion or performance of a contract between you and us
Processing is necessary for our legitimate interests or the legitimate interests of another party

When using the mobile app, and subject to your consent, VoxiKids can send push notifications to communicate useful information to parents or tell them about a new event or survey that requires a quick response.

Aim	Personal data	Further information	Legal basis
Register as a User	Identification Data Contact Date	If you decide to register as a user in the mobile application, we need to process your data in order to identify you as a user of the mobile application and to provide you with access to its various features and services available to you as a registered user. In some cases, the creation of an account will be automatic in order to access the services you have purchased from us. You can cancel your registered user account at any time either from your account on the website, from your Customer Account or by emailing [email protected].	The processing of your data is necessary for signing the terms governing the use of the application. In other words, in order to register you as a user of the website, we need to process your personal data, otherwise we would not be able to manage your registration (the basis being the conclusion or performance of a contract, including previous steps for the conclusion)
Access to materials	Identification Data Contact Date	We will use your personal data to provide you with access to the materials you wish to download from the App, such as the child progress report recorded while going through the exercises available in the App.	Conclusion and performance of the contract (provision of services)
Conclusion and performance of your electronic contract with us	Identification Data Contact Date Financial Data Date of Use Trading dates Profi dates	For the operations described here, we will use your personal data to: ● we deliver the service you contracted ● contact you about updates or informational communications regarding contracted features and services, including sending you surveys on the quality of services provided. ● managing payments for purchased services is done through an external service, so VOXivers has access to a limited set of data. Your card details are not saved on any of the company's servers. ● We activate the necessary mechanisms to prevent potential fraud against you and us during the purchase process. If we assess that the transaction may be fraudulent, this processing may result in the transaction being blocked. ● for invoicing - to provide you with electronic/physical invoices and receipts for the transactions you have made. ● for providing other services to be implemented.	Conclusion and execution of the contract (provision of services). It is necessary for us to process your personal data in order to be able to execute the electronic contract for the provision of the services you want from us. We also have a legitimate interest in carrying out the necessary checks to detect and prevent fraud when you want to make a purchase.
Inquiries or requests made via Customer Service/Support	Identification Data Contact Date Financial Data Trade Dates Profile Date	We process only the personal data strictly necessary to handle or resolve your request or application. We have a legitimate interest in responding to your requests or questions through the various means of contact. This includes private messages that you send us in which you ask us questions about the App, campaigns or would like more information. We understand that the processing of this data is also to your benefit, as it allows us to be able to assist you properly and to find a solution to your questions. When you contact us, in particular to handle incidents or ask us for clarifications on the service purchased, the processing is necessary for the proper performance of the sales contract. When you contact us to deal with order-related incidents or to make a complaint, the processing of your personal data is for the fulfillment of our legal obligations in this regard.	Conclusion and performance of the contract (provision of services) Legitimate interest
To manage the relationship we have with you	Identification Data Contact Date Profile Date	This processing involves: (a) notify you about changes to our terms & conditions and data processing policies (b) ask you to leave us a review or participate in a survey We will process your data in order to keep your data up to date and to understand how users use our services or how we could improve them.	Conclusion and performance of the contract (provision of services) The legitimate interest to improve the services we offer.
Marketing	Identification Data Contact Date Trade Dates Profile Date Marketing and Communication Data	We will process your personal data for this purpose mainly in the following cases: ● if you subscribe to our newsletter, we will process your personal data to manage your communication preferences, including sending you personalized information about our services by various means (such as email or SMS). We may also send you this information via push notifications if you have enabled them on your mobile device or in your browser. Please be aware that this data processing involves analyzing your user or customer profile for the purpose of creating profiles by which we determine what your preferences are at a given point in time based on your browsing history and choices and thus which services best suit you at the time you submit your information to us. For example, on the basis of your shopping and browsing history, we will make suggestions to you about facilities that we think may be of interest and use to you. You will be able to unsubscribe from the newsletter at any time and totally free of charge by following the unsubscribe instructions in each e-mail or by sending a written request to [email protected] ● to carry out promotional actions (e.g. to run competitions). By participating in any promotional action, you authorize us to process the data you provide in relation to each action, which we may communicate through various means, such as social media or even on the website. In each promotional action in which you participate, you will be able to access the terms and conditions section, where we will provide more detailed information about the processing of your data in that context.	We process your data for marketing purposes based on the consent you give us, for example when you agree to receive personalized information by various means, when you authorize push notifications to be sent to your mobile device or browser. We also have a legitimate interest in presenting you with personalized information (such as offers for services similar to those already purchased by you, or new added facilities that may be of great interest to you) because we understand that processing this data is also to your benefit as it allows us to improve your user experience and thus to access information according to your preferences.
Improve- the services	Identification Data Contact Date Trade Dates Profile Date Technical Dates	If you use the mobile app, we inform you that we will process your browsing data for analytical and statistical purposes, i.e. to understand how users interact with our app and so that we can improve it. We also sometimes carry out quality actions and surveys to find out how satisfied our customers and users are with our services and to detect areas where we can improve our services.	We consider that we have a legitimate interest when we analyze how our application is used and the level of user satisfaction. The processing of this data is also for your benefit as the aim is to improve the user experience and provide a better service.
To deliver relevant content and personalized ads, and to measure and understand the effectiveness of the ads we offer you	Identification Data Contact Date Usage Data Profile Date Marketing and Communication Data Technical Dates	We need this data to understand how our customers and users use our services, to develop new services, to grow our business and to adapt our marketing strategy.	Consent
Use analytics data to improve the Platform, services, departments- customer tul and experience	Technical Dates Usage Data	This data is necessary for us to understand the categories of customers for our services, to keep the content of the app up to date and of interest, to develop new services, to grow our business and to adapt our marketing strategy.	Legitimate interest
Tips and recommendations on services that might be of interest to you	Identification Data Contact Date Usage Data Profile Date Marketing and Communication Data Technical Dates	We need this data to grow our business and adapt our marketing strategy.	Legitimate interest
When you react to social media content	Name, image, any information publicly accessible in your social media profile, or voluntarily communicated by you.	We are present on Facebook and LinkedIn, Instagram, Youtube and Twitter. Whenever you interact with us through our open accounts on these platforms (e.g. comment, like, share, review, etc.) we will have access to the publicly available data on your profile. The interaction of a user with one of the social plugins available in the VoxiKids App mobile application, provided by social networks, involves an exchange of data between the application and the respective social media network for which the owner of the application is responsible together with the respective social media platform.	We process your data in our legitimate interest in order to respond to any questions, complaints or recommendations you send us, to improve our services and the experience we offer to our customers and to keep you informed about news we publish that may be of interest to you.

Purpose of processing	Stored term
Register as a User	● We will keep the data recorded in your account until you decide to close your account, but we will delete them (including your account) if it has been more than 5 years since you last logged into your account. ● The data recorded in the financial-accounting documents (e.g. invoices, card payments, etc.) will be kept in the archive for 5 years, starting from the end of the financial year during which they were drawn up, in accordance with the periods of the Accounting Law no. 82/1991 and Order 2634/2015
Access to materials	You will have access to materials for as long as your account is active
Conclusion and performance of your electronic contract with us	● The data recorded in the financial-accounting documents (e.g. invoices, card payments, reimbursement payments, etc.) will be kept in the archive for 5 years, starting from the end of the financial year during which they were drawn up, in accordance with the periods of the Accounting Law no. 82/1991 and Order 2634/2015
Inquiries or requests made via Customer Service/Support	We will not keep in our database communications older than 1 year from the date of the last interaction.
To manage the relationship we have with you	We will process your data that you provide to us for 12 months from the time we receive it
Marketing	● In case of newsletter subscription, data processing will continue until you unsubscribe ● In the case of processing carried out for legitimate interest, when you are already our customer, we will process your data for the duration of the contract and will continue to do so for 3 years after the termination of the contract.
Improving services	We will process the data for 12 months from the time of collection
To deliver relevant content and personalized ads, and to measure and understand the effectiveness of the ads we offer you	We will process the data for 12 months from the moment you have given your consent to this processing
Use analytics data to improve Platform, services, customer service and experience	We will process your data during the performance of the contract and will continue to do so for 3 years after the termination of the contract.
Tips and recommendations on services that might be of interest to you	We will process your data that you provide to us for 12 months from the time we receive it
When you react to social media content	Data transmitted through social media networks will be stored by them according to their own policies.

Disclosure of your personal data

We will only disclose your personal data to the extent that this is strictly necessary to achieve the intended purpose. We have taken all necessary steps to ensure that external service providers who have access to your data have also implemented physical, electronic and managerial security measures to protect your data.

For example, we may provide your data to other companies, such as IT service providers, media agencies, advertisers, accounting and human resources services, integrated solution providers, legal services and other third parties with whom we have a contractual relationship. These third parties are selected with great care so that your data is processed only for the purposes we indicate.

Another example is sending personal data to the e-mail provider we use to send messages to you.

We may also share your data with other business partners as part of a joint effort to provide a product or service.

We may also pass the data on to other parties with your consent or in accordance with your instructions.

We may also provide your personal information to public prosecutors, police, courts of law and other authorized state bodies, on the basis and within the limits of the law and following specific requests.

We will, within reasonable limits, ensure that your data does not leave the European Economic Area, but to the extent that we transfer data to countries outside the EEA, we will, in all cases, ensure that the transfers are legitimate, based on your explicit consent or other lawful basis.

11.1. Who we share your data with

In some cases, other third parties will also have access to personal data, such as:

Suppliers of IT services for our company (hosting and data storage - Amazon) or suppliers to whom we outsource certain technical support services for our website or suppliers of customer relationship management systems
BlueSnap and ChargeBee payment processors
Third parties that place cookies: google.com, hubspot.com, facebook.com
Online platforms: Facebook, Twitter, LinkedIn, Instagram, Youtube
Regulatory and other state authorities, if required by legal or statutory requirements

11.2. Disclosure of your personal data

The transfer of personal data to a third State may only take place if the State to which the transfer is intended ensures an adequate level of protection.

The transfer of data to a State whose legislation does not provide for a level of protection at least equal to that afforded by the General Data Protection Regulation is possible only if there are sufficient safeguards with regard to the protection of the fundamental rights of the data subjects. These safeguards will be established by us in contracts concluded with the providers/service providers to whom your personal data will be transferred.

Some of our service providers may be located outside the European Economic Area(EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data outside of the EEA, we will ensure that a similar level of protection is in place through one of the following safeguards:

we will transfer your personal data to countries where the European Commission has demonstrated that they provide an adequate level of security for personal data. For more details, click here.
when we use certain service providers, we will be able to use certain model contracts provided and approved by the European Commission which offer the same protection for personal data as they do in Europe. For more details, click here.
When we use US providers, we will be able to transfer the data if they offer similar conditions of protection for data shared between the EU and the US. For more details, click here.

Please contact us at [email protected] if you would like more information about the specific mechanism we use when transferring your personal data outside the EEA.

11.3. Data security

We understand how important the security of personal data is, and we take the necessary measures to protect our customers and others whose data we process from unauthorized access to personal data, as well as from unauthorized alteration, disclosure or destruction of the data we process in the course of our business.

We have implemented the following technical and organizational personal data security measures:

Dedicated policies. We adopt and constantly review internal personal data processing practices and policies (including physical and electronic security measures) to protect our systems from unauthorized access or other possible security threats. These policies are under constant review to ensure that we comply with legal requirements and that our systems are functioning properly.

Data minimization. We ensure that your personal data that we process is limited to only that which is necessary, appropriate and relevant for the purposes stated in this Policy.

Restricting access to data. We try to restrict access to the personal data we process as much as possible to the minimum necessary: employees, collaborators and others who need to access this data in order to process it and carry out a service. Our partners and collaborators are subject to strict confidentiality obligations (either by contract or by law).

Specific technical measures. We use technologies to ensure the security of our customers, always trying to implement the most optimal solutions for data protection. We also periodically back-up data to be able to recover them in the event of an incident and have regular audit procedures in place regarding the security of the equipment used. However, no website, no application and no internet connection is completely secure and untouchable (see NASA).

Ensuring the accuracy of your data. Sometimes we may ask you to confirm the accuracy or timeliness of your data to make sure that it reflects reality.

Staff training. We constantly train and test our employees and collaborators on legislation and best practices in the field of personal data processing.

Data anonymization. Where we can, we try as far as possible to anonymize/pseudonymize the personal data we process so that we can no longer identify the individuals to whom it relates.

However, while we are constantly striving to ensure the security of the data you entrust to us, it is possible that we may also experience less fortunate events and security incidents/breaches. In these cases, we will strictly follow the procedure for reporting and notifying security incidents and will take all necessary steps to restore the situation to normal as soon as possible.

12.1. User Content

User Content is the "in-session" information that you provide directly to us through your use of the Platform/Mobile App Services, such as video and audio recordings of speech therapy sessions, files, chat logs and transcripts, progress and any other information uploaded while using the Services. VOXivers uses Customer Content solely in connection with providing the Services on the Platform/Mobile App - we do not monitor, sell or use Customer Content for any other purpose.

Please be aware that no security measure is perfect or impenetrable and that we are not responsible for circumvention of any security measures contained in the Platform/Mobile App. You should be cautious about the access you provide to others when using the Platform/Mobile App and the information you choose to share when using the Platform.

VOXivers DOES NOT sell or rent your (or your child's) personal information to any third party for any purpose - including advertising or marketing purposes.

12.2. What we can't do without your data

When we ask you to fill in your personal data in order to provide you with access to certain functionalities or services of the Mobile Platform/App, we will mark some fields as mandatory, as this is information we need in order to provide you with the service or to provide you with access to the functionality.

Please note that if you choose not to provide us with this information, you may not be able to complete your user registration or take advantage of these services or features. In such a case, we may have to limit your access to a service that you want from us, but we will notify you at that time if this happens.

Also, if at the time you send us a request via the contact address or the form on the Platform/Mobile App or otherwise and we are unable to verify your identity, we reserve the right not to respond to that request.

12.3. Reviews

We post testimonials on our Service, which may contain personal information, such as the name, photograph, and/or a video of the person providing such a review. We obtain the individual's consent in advance to ensure that we have permission to post this content publicly. To request removal of your personal information from our testimonials, please contact us at [email protected]

12.4. Information collected automatically

VOXivers products automatically receive and record information from our server logs in your browser, including your IP address, cookie information, and the page you requested. We also log your activity on the Platform/Mobile Services, as well as the number and frequency of visitors to our website and its components. VOXivers Products uses cookies to ensure that all users enjoy the best experience on the Site, customized to their browsing needs.

In certain circumstances, you have certain rights in relation to your personal data under the law. To exercise them, please contact us at [email protected]

In short, under the law, you have the following rights:

Right to withdraw consent - when the processing was based on your consent and there is no other basis for processing. . Please note that withdrawal of consent does not affect processing that has taken place up to that point.
The right to be informed about the processing of your data - which is realized through this Privacy Policy.
Right of data access - you have the right to receive a copy of the data we process about you. Additional copies may be provided for a fee.
The right to rectify inaccurate or incomplete data - you have the right to ask us to amend/complete the data we process about you where you consider that we should do so.
Right of erasure ("right to be forgotten") - this right allows you to request that in certain circumstances, where we have no other basis for processing your data, we delete your data and not process it in the future.
The right to restriction of processing - when we process your data to fulfill our public interest tasks or our legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to the processing. You also have the right to ask us to restrict processing when we process your data for direct marketing purposes.
The right to transfer the data we hold about you to another controller - where your data is in a format that allows us to transfer it to another controller in an automated, machine-readable and easily accessible format.
The right to object to data processing - when we process your data to fulfill a public interest or pursue our legitimate interests or those of a third party.
Right not to be subject to a decision based solely on automated processing, including profiling
Right to go to court
The right to complain to a Supervisory Authority, whose contact details can be found below:

Name	National Supervisory Authority for Personal Data Processing
Address	B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, Bucharest, Romania
Phone	+40.318.059.211 or +40.318.059.212
E-mail	[email protected]

Please note:

You can withdraw your consent to direct marketing at any time by following the unsubscribe instructions in each email/sms or other electronic message.
If you wish to exercise your rights, you can do so by sending a written, signed and dated request to [email protected]
The rights listed above are not absolute. There are exceptions, which is why every request we receive will be analyzed to decide whether or not it is justified. If your request is justified, we will make it easier for you to exercise your rights. If the request is unfounded, we will reject it, but we will inform you of the reasons for the refusal and of your rights to lodge a complaint with the Supervisory Authority and to go to court.
Response deadline: We will endeavor to respond to your request within 30 days. However, the deadline may be extended depending on various issues, such as the complexity of the request, the large number of requests received, or the inability to reach you in a timely manner.
What we may need from you In order to be able to respond to your requests to exercise your rights, we may need additional information from you to be able to confirm your identity. If, despite our best efforts, we are unable to identify you, and you do not provide us with additional information to enable us to identify you, we are under no obligation to comply with your request.
Fee. You will not have to pay any fee for exercising your right of access to data (or any other right). However, you may have to pay a reasonable fee if your request is unfounded, excessive or repetitive. Alternatively, we may refuse to grant your request in these circumstances.

We will update this Privacy Policy whenever there are changes in the way we process data and notify you via the Platform or by email of the latest version. All updates and changes to this Notice are effective immediately upon notice, which we will provide by posting on the Website and/or notifying you by email. Even if you do not receive a notification, we encourage you to periodically access and read this Policy to stay up to date with the latest versions.

Privacy policy

Welcome to the VoxiKids Privacy Policy!

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