Privacy Policy

Welcome to the VoxiKids privacy policy!

We are very happy you're here and can't wait for you to discover what VoxiKids can do for you.
The VoxiKids App is primarily designed for children, but it can also be used by adults to practice their language and pronunciation.
The VoxiKids Clinic speech therapy platform is also prepared together with speech therapy specialists and includes a series of management tools that streamline parent-speech therapist collaboration with the common goal of the child's recovery and good integration into preschool and school.

VoxiKids – Easy Speech! It has never been easier to speak correctly!

To achieve these things, VoxiKids needs to process some of your personal data to help you understand how the application works and get the most out of it. We are transparent and don't want you to think that we process data without informing you of the purposes.

Through 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 will refer to VoxkiKids as we, the company or organization, to make it easier to follow.

This Privacy Policy applies everywhere you find us online. In particular, we are present through the website wp.voxikids.com and its subdomains or affiliated sites (which we will collectively refer to as "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 the form of an application, etc., and we will refer to all of them as "Platform".

The platform is specifically designed for children, which means we take extra care with this data and will always verify that we have the consent of a parent or guardian.

It is important to read this policy together with the Terms and Conditions and Cookie Policy, and with all the data processing & confidentiality notices that we will provide on different occasions when we collect or process your personal data so that you are always fully informed of why and how we use this data. This Privacy Policy is the main regulatory framework regarding the protection of personal data and is supplemented by the other notifications specific to certain activities in the application, and it comes as an addition to the other notifications and is not intended to eliminate them.

1.2. We are VoxiKids

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

Name	Speakquest SRL
Registered office	Victoria, str. Victoriei, nr. 14 bl. 22, ap. 16, jud Brașov,
Trade Registry number:	J8/458/2020
Unique identification code	42327556
E-mail	[email protected]

If you have any questions, comments or complaints regarding us or the personal data we process for you, you can send us an email at the address above at any time.

According to the law, in relation to you, we are a personal data operator. In this capacity, we also have a number of obligations, including informing you about the data we process, how we do it, what rights you have and how you can exercise these rights.

1.3. Who are you?

Whether you are the User (child using our platform's services), the User's Parent or guardian, or the Speech therapist who conducts 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 identify you: name, surname, address, image, voice, etc.

We process this data especially to allow you access to the services we offer through the online platform and mobile applications. This means that we are responsible for keeping your data confidential and you benefit from a series of rights through which you have control over these data processing activities.

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

The data we collect from you through the online platform

2.1. If you are the parent or guardian of the child

To facilitate the child's access to the facilities offered by VoxiKids – Easy Speech, you will need to provide us with certain personal data.

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

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

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

name, surname;
age;
auditory age;
any difficulties the child has in speaking, as will be indicated to you in the platform;
explicit consent regarding the processing of the child's personal data
declaration on own responsibility regarding the capacity as legal representative or guardian.

Please keep in mind that we need this data to provide the best possible experience for your child and to customize their experience on our online platform. Our goal is to make speech therapy a game, and the level of the game must be adapted to the requirements, needs, and skills of each child individually.

Even Popeye the Sailor ate a lot of spinach to become big and strong.

When you choose private sessions with a speech therapist, please note that the interaction between the child and the speech therapist will be recorded audio-video, and the speech therapist will have access to this information for 12 months. This is necessary for the speech therapist to correct the child's way of expressing themselves and to help them improve their hearing and pronunciation, by checking the stimuli and the correctness of the exercises, while also monitoring progress over time.

It is preferable for private therapy sessions to take place in a location where the child and a parent are present to supervise the smooth running of 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 who benefits from 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 VoxiKids Online platform without the consent of your Parent or guardian.

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

Category	Included data
Identification data	name, surname, username or similar identifier, date of birth, the language in which you wish to communicate, language development level
Contact details	billing address, e-mail address
Financial data	payment or bank card/account information and purchase details will be kept in the cloud with maximum security – without access to them
Transaction data	details of payments made and other details regarding the services you have purchased from us
Technical data	IP (internet protocol) address, login data, browser type and version, location and time zone settings, browser plug-ins and their versions, operating system, operating platform and other technologies on the devices you use to access this site
Profile data	username, profile picture, your orders, your interests and preferences, your language characteristics, feedback provided, answers to surveys
Usage & interaction data	information about how you use our site, services
Marketing & communication data	your preferences for receiving marketing materials from us and from our third parties and preferred methods of communication

2.3. If you are a professional (speech therapist)

We need information regarding your professional qualifications in order to verify that you are indeed a professional before allowing you access to the platform. This information consists of:

proof of graduation from the Faculty of Psychology
certificate of free practice right
proof of completion of a specialist course in speech therapy
documents proving the form of professional organization (LLC, PFA, etc.)

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

Category	Included data
Identification data	name, surname, username or similar identifier, the language in which you wish to communicate, city, country
Professional information	the data entered in diplomas, certificates, documents proving the form of professional organization (LLC, PFA, etc.)
Contact details	billing address, e-mail address, telephone number
Transaction (financial) data	details of payments from and to you and other details regarding the services you have accessed, bank account
Technical data	IP (internet protocol) address, login data, browser type and version, location and time zone settings, browser plug-ins and their versions, operating system, operating platform and other technologies on the devices you use to access this site
Profile data	username, your orders, your interests and preferences, your language characteristics, feedback provided, answers to surveys
Usage & interaction data	information about how you use our site, services,
Marketing & communication data	your preferences for receiving marketing materials from us and from our third parties and preferred methods of communication

2.4. Aggregated / anonymized data

We collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may derive from your personal data but is not considered personal data in 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 website feature. However, if we combine or correlate Aggregated Data with your personal data so that we can directly or indirectly identify you, we will treat the resulting combined data as personal data that will be used as described in this document.

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

What information from the child's profile is visible to others?

The child's complete profile is confidential. Other parents from the same kindergarten, school or speech therapy office cannot see the children's data. The speech therapist (specialist/psychologist) can only see the children's names, the avatar (which can be the default avatar or the avatar modified by the parents) and the data set by the parent (name/surname, chronological age, language age, language deficiencies). Specialists (speech therapists/psychologists) can see the data provided by the parent of the children they interacted with based on the parents' agreement.

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 VoxiKids, either through the online platform or through your connection with a speech therapist

4.1. If you are a Parent

Source

Data

Direct interaction

You can directly provide us with data about yourself (such as Identification Data, Contact Data, and Financial Data) by filling in the fields on the site or by email, phone, or other method we provide. This includes personal data you provide when:

● you wish to download one or more materials that we put on the Platform;

● you wish to purchase/benefit from one of our goods or services;

● you connect with a speech therapist through VoxiClinic;

● you create an account with us on the site;

● you subscribe to our services or publications;

● you request promotional & marketing materials;

● you enter a contest or promotion, complete a questionnaire, etc.;

● you give us feedback, etc.

Automated technologies or interactions

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

Please read our cookie policy for more details.

4.2. If you are a User (Child)

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

4.3. If you are a professional (speech therapist)

Source

Data

Direct interaction

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

● you register in our network of speech therapists;

● you connect with a child through VoxiClinic;

● you subscribe to our services or publications;

● you request promotional & marketing materials;

● you complete a questionnaire, give us feedback, etc.

Automated technologies or interactions

Please read our cookie policy for more details.

For what purpose do we collect your personal data?

Primarily, we will collect your personal data (or that of the minor) to directly provide the service you are accessing.

However, we use your personal data (or that of the minor) to improve the Platform, send you suggestions about features that might help you, see what you would like, and how we can make this service as good as possible.

In short, our grounds for processing your data will generally be the following:

You have given your consent for the processing of personal data

Remember that you can withdraw your consent at any time by following the unsubscribe instructions from each email or by sending a written request to [email protected]

Processing is necessary for the conclusion or execution of a contract between you and us
Processing is necessary for the purpose of our legitimate interests or those of another party

Below, in a table format, is a description of how we plan to use your personal data, as well as the legal basis on which we do so. We have also identified our legitimate interests where applicable.

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

Purpose	Personal data	Additional information	Legal basis
Registration as a User	Identification Data Contact Data	If you decide to register as a user on the Platform, we need to process your data to identify you as a user and to give you access to its various functionalities and services available to you as a registered user. In some cases, creating an account will be automatic in order to have access to the services you have purchased from us. You can cancel your registered user account at any time either from your account on the site, from the Client Account, or by emailing [email protected]. Also, depending on the development of the Platform, you will have the possibility to connect through a social network, such as Facebook/Google, either to register as a new user or to associate the connection with your current account. In this case, your login data, as well as your e-mail 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: name, gender, approximate age or profile picture, in accordance with the terms of use of the social network, which we recommend you read carefully. If you do not approve this data transfer, we will not keep 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 the privacy settings and read the privacy policy of those social networks to know how this data is processed by the social networks.	The processing of your data is necessary for signing the terms that govern the use of the site. In other words, for your registration as a user of the site, we must process your personal data, otherwise we could not manage the registration (the basis being the conclusion or execution of a contract, including prior steps for conclusion)
Access to materials	Identification Data Contact Data	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, evaluations, or other materials that we will make available to you for free.	Conclusion and execution of the contract (offering services)
Conclusion and execution of the electronic contract you enter into with us	Identification Data Contact Data Financial Data Usage Data Transaction data Profile Data	For the operations described here, we will use your personal data to: ● deliver the service you have contracted ● contact you regarding updates or informative communications about the functionalities or services contracted, including sending surveys regarding the quality of services provided. ● payment management for purchased services is done through an external service, so VoxiKids has access to a limited set of data. Your card details are not saved on any of the company's servers. ● activate the necessary mechanisms to prevent potential fraud against you and us during the purchase process. If we believe that the transaction may be fraudulent, this processing may lead to the blocking of the transaction. ● for billing purposes – to provide you with invoices and receipts for transactions made in electronic/physical format. ● to offer other services that will be implemented.	Conclusion and execution of the contract (offering services). It is necessary to process your personal data in order to execute the electronic contract for the provision of services that you want from us. We also have a legitimate interest in carrying out the necessary checks to detect and prevent any fraud when you want to make a purchase.
Requests or inquiries made through Customer Service/Support	Identification Data Contact Data Financial Data Transaction Data Profile Data	We only process the personal data strictly necessary to manage or resolve your request or inquiry. We have a legitimate interest in responding to requests or questions you ask us through the various means of contact available. This includes private messages you send us in which you ask questions about the Platform, campaigns, or want to obtain more information. We understand that the processing of this data is also to your advantage, as it allows us to help you appropriately and find a solution to your questions. When you contact us, especially for managing incidents or requesting clarifications regarding the purchased service, the processing is necessary for the proper execution of the sales contract. When you contact us to manage order-related incidents or to make a complaint, the processing of your personal data is done to fulfill our legal obligations in this regard.	Conclusion and execution of the contract (offering services) Legitimate interest
To manage the relationship we have with you	Identification Data Contact Data Profile Data	This processing involves: (a) notifying you about changes to the terms & conditions and data processing policies (b) asking you to leave us a review or participate in a survey We will process your data to keep it up-to-date and to understand how users use our services or how we could improve them.	Conclusion and execution of the contract (offering services) The legitimate interest in improving the services we offer.
Marketing	Identification Data Contact Data Transaction Data Profile Data Marketing and Communication Data	We will process your personal data for this purpose mainly in the following cases: ● If you subscribe to the newsletter, we will process your personal data to manage your communication preferences, including sending personalized information about our services through 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 keep in mind that this data processing involves analyzing your user or customer profile in order to create profiles that determine your preferences at a given time based on your browsing history and choices, and thus, which services best suit you at the time the information is sent to us. For example, based on your shopping and browsing history, we will make suggestions regarding the facilities that we believe may be of interest and use to you. You can unsubscribe from the newsletter at any time, completely free of charge, by following the unsubscribe instructions in each email or by sending a written request to the email address [email protected]. ● For carrying out promotional activities (for example, for running contests). By participating in any promotional activity, you authorize us to process the data provided for each activity, which we may communicate through various means, such as social networks or even on the site. For each promotional activity you participate in, you will be able to access the terms and conditions section, where we will provide more detailed information regarding 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 through various means, when you authorize the sending of push notifications on your mobile device or in your 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 features that may be of great interest to you) because we understand that the processing of this data is also to your advantage as it allows us to improve your experience as a user and thus access the information according to your preferences.
Improv- ing services	Identification Data Contact Data Transaction Data Profile Data Marketing and Communication Data Technical Data	If you access our site, we inform you that we will process your browsing data for analytical and statistical purposes, that is, to understand how users interact with our site and thus be able to make improvements to it. We also sometimes carry out quality actions and surveys aimed at knowing the degree of satisfaction of our customers and users and detecting areas in which we can improve the services offered.	We believe we have a legitimate interest when we analyze how our site is used, as well as user satisfaction. The processing of this data is also to your advantage as the purpose is to improve the user experience and provide a higher quality service.
To deliver relevant content and personalized ads and to measure and understand the effectiveness of the ads we serve you	Identification Data Contact Data Usage Data Profile Data Marketing and Communication Data Technical Data	This data is necessary for us to understand how customers and users use our services, to develop new services, to grow our business and to adapt our marketing strategy.	Consent
Using analytics data to improve the Platform, services, customer service and experience	Technical Data Usage Data	This data is necessary for us to understand the customer categories for our services, to maintain platforms with updated and interesting content, to develop new services, to grow our business and to adapt our marketing strategy.	Legitimate interest
Suggestions and recommendations about services that may be of interest to you	Identification Data Contact Data Usage Data Profile Data Marketing and Communication Data Technical Data	We need this data to grow our business and adapt our marketing strategy	Legitimate interest
When you react to content on social media	Name, image, any information publicly accessible in your social media profile, or voluntarily communicated by you	We are present on Facebook, LinkedIn, Instagram, YouTube, and Twitter. Whenever you interact with us through our accounts on these platforms (e.g., comments, likes, shares, reviews, etc.), we will have access to the data publicly available on your profile. A user's interaction with one of the social plugins available on the wp.voxikids.com and voxiclinic.com platforms, provided by 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 to respond to any questions, complaints, or recommendations you send us, to improve our services and the experience we offer our customers, and to keep you updated with the news we publish that may be of interest to you.

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

To determine the appropriate retention period for personal data, we have considered the value, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Purpose of processing	Storage period
Registration as a User	● We will keep the data registered in your account until you decide to close your account, but we will delete it (including your account) if more than 5 years have passed since your last login. ● The data entered in the financial-accounting documents (e.g., invoices, payments made by card, refund payments, etc.) will be kept in the archive for 5 years, starting from the date of the end of the financial year in 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 throughout the period your account is active
Conclusion and execution of the electronic contract you enter into with us	● The data entered in the financial-accounting documents (e.g., invoices, payments made by card, refund payments, etc.) will be kept in the archive for 5 years, starting from the date of the end of the financial year in 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 a period of 12 months.
Requests or inquiries made through Customer Service/Support	We will not keep communications older than 1 year in our database, from the date of the last interaction.
To manage the relationship we have with you	We will process the data you provide us for 12 months from the moment we receive it.
Marketing	● If you subscribe to the newsletter, the data processing will continue until you request unsubscription. ● In the case of processing carried out in 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.
Service improvement	We will process the data for 12 months from the moment of collection
To deliver relevant content and personalized ads and to measure and understand the effectiveness of the ads we serve you	We will process the data for 12 months from the moment you gave your consent for this processing.
Using analysis data to improve the Platform, services, customer department and experience	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.
Suggestions and recommendations about services that may be of interest to you	We will process the data you provide us for 12 months from the moment we receive it.
When you react to content on social media	The data transmitted through social media networks will be stored by them according to their own policies.

In 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 without notifying you in advance.

The data we collect from you through the mobile application

The mobile app VoxiKids App, through which users have access to over 200 interactive speech therapy exercises specially designed for children with speech impairments or language and communication problems, is available for both Android and IOS.

The personal data we process is that provided by the parent or guardian through registration in the app and that which derives from the use of the mobile app.

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

Category	Included data
Identification data	Username, email, language in which you wish to communicate
Contact details	email address
Financial data	Information regarding payments or your card/bank account is held and managed by Google Play or the App Store; we do not receive information about your purchases.

Technical data	IP (internet protocol) address, login data, browser type and version, location and time zone settings, operating system
Profile data	username, password, your orders, your interests and preferences, your language characteristics, feedback provided, answers to surveys
Usage & interaction data	information about how you use the app, the child's progress
Marketing & communication data	your preferences for receiving marketing materials from us and from our third parties and preferred methods of communication

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

name, surname;
age;
explicit consent regarding the processing of the child's personal data;
declaration on own responsibility regarding the capacity as legal representative or guardian.

Please keep in mind that this data is necessary for us to provide the best possible experience for your child and to personalize their experience in the app. Our goal is to make speech therapy a game, and the level of the game must be adapted to the requirements, needs, and skills of each child.

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 the VoxiKids App through the mobile application.

Source

Data

Direct interaction

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

● you wish to download one or more materials that we put on the Platform;

● you wish to purchase/benefit from one of our goods or services;

● you create an account in the mobile app

● you subscribe to our services or publications;

● Your activity in the mobile app

● you request promotional & marketing materials;

● you enter a contest or promotion, complete a questionnaire, etc.;

● you give us feedback, etc.

Automated technologies or interactions

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

Please read our cookie policy for more details.

For what purpose do we collect your personal data?

We will primarily collect your personal data (or that of your minor) in order to directly provide access to the features of the mobile application.

However, we use your personal data (or that of the minor) to improve the App, to send you suggestions about features that might help you, to see what you would like, and how we can make this service as good as possible.

In short, our grounds for processing your data will generally be the following:

You have given your consent for the processing of personal data

Remember that you can withdraw your consent at any time by following the unsubscribe instructions in each email or by sending a written request to the email address [email protected].

Processing is necessary for the conclusion or execution of a contract between you and us
Processing is necessary for the purpose of our legitimate interests or those of another party

Below, in a table format, is a description of how we plan to use your personal data, as well as the legal basis on which we do so. We have also identified our legitimate interests where applicable.

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

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

Purpose	Personal data	Additional information	Legal basis
Registration as a User	Identification Data Contact Data	If you decide to register as a user in the mobile app, we need to process your data to identify you as a user and to provide you with access to its various features and services available to you as a registered user. In some cases, creating 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 site, from the Client Account, or at the email address [email protected].	Processing your data is necessary for signing the terms that govern the use of the app. In other words, to register you as a user of the site, we must process your personal data; otherwise, we would not be able to manage the registration (the basis being the conclusion or performance of a contract, including prior steps for conclusion).
Access to materials	Identification Data Contact Data	We will use your personal data to provide you with access to the materials you wish to download from the App, such as the progress report of the child recorded while completing the exercises available in the app.	Conclusion and execution of the contract (offering services)
Conclusion and execution of the electronic contract you enter into with us	Identification Data Contact Data Financial Data Usage Data Transaction data Profile Data	For the operations described here, we will use your personal data to: ● we deliver the service you have contracted ● we contact you regarding updates or informative communications about the functionalities and services contracted, including sending surveys regarding the quality of services provided. ● Payment management for purchased services is done through an external service, so VoxiKids 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 against us during the purchase process. If we believe that the transaction could be fraudulent, this processing may lead to the blocking of the transaction. ● for billing – to provide you with invoices and receipts for transactions made in electronic/physical format. ● for offering other services that will be implemented.	Conclusion and execution of the contract (offering services). It is necessary to process your personal data in order to execute the electronic contract for the provision of services that you want from us. We also have a legitimate interest in carrying out the necessary checks to detect and prevent any fraud when you want to make a purchase.
Requests or inquiries made through Customer Service/Support	Identification Data Contact Data Financial Data Transaction Data Profile Data	We only process the personal data strictly necessary to manage or resolve your request or inquiry. We have a legitimate interest in responding to requests or questions you ask us through the various means of contact available. This includes private messages you send us in which you ask questions about the App, campaigns, or want to obtain more information. We understand that the processing of this data is also to your advantage, as it allows us to help you appropriately and find a solution to your questions. When you contact us, especially for managing incidents or requesting clarifications regarding the purchased service, the processing is necessary for the proper execution of the sales contract. When you contact us to manage order-related incidents or to make a complaint, the processing of your personal data is done to fulfill our legal obligations in this regard.	Conclusion and execution of the contract (offering services) Legitimate interest
To manage the relationship we have with you	Identification Data Contact Data Profile Data	This processing involves: (a) notifying you about changes to the terms & conditions and data processing policies (b) asking you to leave us a review or participate in a survey We will process your data to keep it up-to-date and to understand how users use our services or how we could improve them.	Conclusion and execution of the contract (offering services) The legitimate interest in improving the services we offer.
Marketing	Identification Data Contact Data Transaction Data Profile Data Marketing and Communication Data	We will process your personal data for this purpose mainly in the following cases: ● if you subscribe to the newsletter, we will process your personal data to manage your communication preferences, including sending personalized information about our services through various means (such as email or SMS). We may also send you this information through push notifications if you have enabled them on your mobile device or in your browser. Please keep in mind that this data processing involves analyzing your user or customer profile in order to create profiles that determine your preferences at a given time based on your browsing history and choices, and thus, which services best suit you at the time the information is sent to us. For example, based on your shopping and browsing history, we will make suggestions regarding the facilities that we believe may be of interest and use to you. You can unsubscribe from the newsletter at any time, completely free of charge, by following the unsubscribe instructions in each email or by sending a written request to the email address [email protected]. ● for carrying out promotional actions (for example, for conducting contests). By participating in any promotional action, you authorize us to process the data provided for each action, which we may communicate through various means, such as social networks or even on the site. For 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 regarding 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 through various means, when you authorize the sending of push notifications on your mobile device or in your 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 features that may be of great interest to you) because we understand that the processing of this data is also to your advantage as it allows us to improve your experience as a user and thus access the information according to your preferences.
Improv- ing services	Identification Data Contact Data Transaction Data Profile Data Technical Data	If you are using the mobile app, please be aware that we will process your browsing data for analytical and statistical purposes. This means we analyze how users interact with our app so we can improve it. We also occasionally conduct quality actions and surveys to understand customer and user satisfaction and to identify areas where we can improve our services.	We believe we have a legitimate interest when analyzing how our app is used, as well as user satisfaction. The processing of this data is also to your advantage as the purpose is to improve the user experience and provide a higher quality service.
To deliver relevant content and personalized ads and to measure and understand the effectiveness of the ads we serve you	Identification Data Contact Data Usage Data Profile Data Marketing and Communication Data Technical Data	This data is necessary for us to understand how customers and users use our services, to develop new services, to grow our business, and to adapt our marketing strategy.	Consent
Using analytics data to improve the Platform, services, customer service and experience	Technical Data Usage Data	This data is necessary for us to understand the customer categories for our services, to keep the app's content up-to-date and interesting, to develop new services, to grow our business, and to adapt our marketing strategy.	Legitimate interest
Suggestions and recommendations about services that may be of interest to you	Identification Data Contact Data Usage Data Profile Data Marketing and Communication Data Technical Data	We need this data to grow our business and adapt our marketing strategy.	Legitimate interest
When you react to content on social media	Name, image, any information publicly accessible in your social media profile, or voluntarily communicated by you	We are present on Facebook, LinkedIn, Instagram, YouTube, and Twitter. Whenever you interact with us through our accounts on these platforms (e.g., comments, likes, shares, reviews, etc.), we will have access to the data publicly available on your profile. When a user interacts with social plugins available in the VoxiKids App, provided by social networks, data is exchanged between the app and the respective social media network. The app owner and the social media platform are jointly responsible for this exchange.	We process your data in our legitimate interest to respond to any questions, complaints, or recommendations you send us, to improve our services and the experience we offer our customers, and to keep you updated with the news we publish that may be of interest to you.

Purpose of processing	Storage period
Registration as a User	● We will keep the data registered in your account until you decide to close your account, but we will delete it (including your account) if more than 5 years have passed since your last login. ● Data recorded in financial-accounting documents (e.g., invoices, payments made by card, etc.) will be kept in the archive for 5 years, starting from the end of the financial year in 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 throughout the period your account is active
Conclusion and execution of the electronic contract you enter into with us	● Data recorded in financial-accounting documents (e.g., invoices, payments made by card, refund payments, etc.) will be kept in the archive for 5 years, starting from the end of the financial year in which they were drawn up, in accordance with the periods of the Accounting Law no. 82/1991 and Order 2634/2015.
Requests or inquiries made through Customer Service/Support	We will not keep communications older than 1 year in our database, from the date of the last interaction.
To manage the relationship we have with you	We will process the data you provide us for 12 months from the moment we receive it.
Marketing	● If you subscribe to the newsletter, the data processing will continue until you request unsubscription. ● In the case of processing carried out in 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.
Service improvement	We will process the data for 12 months from the moment of collection
To deliver relevant content and personalized ads and to measure and understand the effectiveness of the ads we serve you	We will process the data for 12 months from the moment you gave your consent for this processing.
Using analytics data to improve the Platform, services, customer support, and overall experience.	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.
Suggestions and recommendations about services that may be of interest to you	We will process the data you provide us for 12 months from the moment we receive it.
When you react to content on social media	The 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 strictly necessary to achieve the intended purpose. We have taken all necessary measures to ensure that external service providers who have access to your data have also implemented physical, electronic, and managerial security measures to protect the data.

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

Another example is sending personal data to the email provider we use to send you messages.

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

We may also transmit the data to other parties with your consent or according to your instructions.

We may also provide your personal information to the prosecutor's office, police, courts, and other authorized state bodies, based on and within the limits of legal provisions and as a result of expressly formulated requests.

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

11.1.Who we share your data with

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

IT service providers for our company (hosting and data storage – Amazon) or providers to whom we outsource certain technical support services for our site or providers of customer relationship management systems.
Payment processors BlueSnap and ChargeBee
Third parties that place cookies: google.com, hubspot.com, facebook.com
Online platforms: Facebook, Twitter, LinkedIn, Instagram, Youtube
Regulatory authorities 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 country can only take place if the country to which the transfer is intended ensures an adequate level of protection.

Data transfer to a country whose legislation does not provide a level of protection at least equivalent to that offered by the General Data Protection Regulation is only possible if there are sufficient guarantees regarding the protection of the fundamental rights of the data subjects. These guarantees will be established by us through contracts concluded with the suppliers/service providers to whom your personal data will be transferred.

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

Whenever we transfer your personal data outside the SEE, we will ensure that there is a similar level of protection through one of the following safeguard mechanisms:

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

Please contact us at the email address [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 other individuals whose data we process from unauthorized access to personal data, as well as from unauthorized modification, disclosure, or destruction of the data we process in our current activity.

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

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

Data Minimization. We ensure that your personal data that we process is limited only to what is necessary, adequate, 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 other people who need to access this data to process it and complete a service. Our partners and collaborators are subject to strict confidentiality obligations (either by contract or legal).

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 make periodic data backups to be able to recover them in the event of a possible incident, and we have implemented periodic audit procedures regarding the security of the equipment used. However, no website, application, or internet connection is completely secure and unreachable (see NASA).

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

Staff Training. We constantly train and test employees and collaborators regarding the legislation and best practices in the field of personal data processing.

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

However, although we make constant efforts to ensure the security of the data you entrust to us, we may also experience less fortunate events and have security incidents/breaches. In these cases, we will strictly follow the security incident reporting and notification procedure and will take all necessary measures to restore the situation to normal as soon as possible.

12.1. User Content

User Content represents the 'in session' information you provide directly to us through the use of the services in the Platform/Mobile Application, 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. VoxiKids uses customer content only in connection with providing services from the Platform/Mobile Application – we do not monitor, sell, or use customer content for other purposes.

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

VoxiKids 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 cannot do without your data

When we ask you to fill in your personal data to give you access to certain features or services of the Platform/Mobile Application, we will mark some fields as mandatory, because this is information we need to be able to provide you with the service or to give you access to that functionality.

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

For example, if you want to benefit from our services and connect with a speech therapist, we will need to video record you so that the speech therapist can correct the child's way of expressing themselves and help them improve their hearing and pronunciation by checking the stimuli and the correctness of the exercises, while also monitoring progress over time. If you do not want to do this, we will not be able to offer you this service for which you are registering on the Platform.

Also, if when you send us a request to the contact address or through the form on the Platform/Mobile Application or through another indicated method and we cannot 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 video of the person providing us with such a review. We obtain the individual's consent beforehand to ensure we have permission to post this content publicly. To request the removal of your personal information from our testimonials, please contact us at [email protected]

12.4. Automatically collected information

VoxiKids automatically receives and records information from our server logs from your browser, including your IP address, VoxiKids cookie information, and the page you requested. We also record details of your activity on the Services, such as the number and frequency of visitors to our site and its components. VoxiKids uses cookies to ensure that all users enjoy the best possible experience on the site, customized to their browsing needs.

In certain circumstances, you have rights regarding your personal data in accordance with legal provisions. To exercise these rights, please contact us at the email address [email protected].

In short, according to the legislation in force, 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 the withdrawal of consent does not affect the processing that took place up to that point.
Right to be informed about the processing of your data – which is done through this Privacy Policy.
Right of access to data – you have the right to receive a copy of the data we process about you. Additional copies may be provided for a fee.
Right to rectify inaccurate or incomplete data – you have the right to ask us to modify/complete the data we process about you when you believe we need to do so.
Right to erasure (the “right to be forgotten”) – this right allows you to ask us to delete your data and not process it in the future in certain circumstances, when we no longer have any other basis for processing your data.
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 processing. You also have the right to ask us to restrict processing when we process your data for direct marketing purposes.
Right to transmit the data we have about you to another operator – when your data is in a format that allows us to transfer it to another operator in an automated, easily accessible and machine-readable format.
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 exclusively on automated processing, including profiling
Right to appeal to justice
Right to lodge a complaint with 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 remember that:

You can withdraw your consent for direct marketing at any time by following the unsubscribe instructions in each email/SMS or other electronic message.
If you want to exercise your rights, you can do so by sending a written, signed, and dated request to the email address: [email protected].
The rights listed above are not absolute. There are exceptions, so each request received will be analyzed to decide whether it is well-founded or not. To the extent that the request is well-founded, we will facilitate the exercise of 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 appeal to justice.
Response time: We will try to respond to your request within 30 days. However, the deadline may be extended depending on various aspects, such as the complexity of the request, the large number of requests received, or the impossibility of identifying you within a useful timeframe.
What we might need from you: In order to respond to your requests to exercise your rights, we may need additional information from you to confirm your identity. If, despite all our efforts, we are unable to identify you, and you do not provide us with additional information to help us identify you, we are not obliged to comply with the request.
Fee. You will not have to pay any fee to exercise your right to access 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 comply with your request in these circumstances.

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

Privacy Policy

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