Privacy Policy
1. General Information
1.1. This Ylands EDU Privacy Policy (“Policy”) outlines how we process your personal data, how we handle such data, and how you can exercise your rights regarding your personal data when you use the Ylands EDU application, service, official website, or any other related services (“Services”).
1.2. This Policy also provides you with all the necessary information in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”).
1.3. The following definitions apply to this Policy: • a) “Company,” “we” refers to BOHEMIA INTERACTIVE a.s., with its registered office at Stříbrná Lhota 747, 252 10 Mníšek pod Brdy, Czech Republic, registered with the Commercial Register maintained by the Municipal Court in Prague, Section B, File 9791 (Company ID: 272 18 864, VAT No: CZ27218864).
b) “User,” “you” refers to any person, organization, or institution using the Services or entering into a contract for the provision of any of the Services.
c) “License Terms” refer to the End-User License Agreement for the Ylands EDU application, available at https://edu.ylands.com/en/eula.
d) “Terms of Service” refer to the terms and conditions for providing the Ylands EDU service, available at https://edu.ylands.com/en/terms-and-conditions.
e) “Responsible Person” refers to the individual responsible for ordering the Subscription, whether as an independent customer, a contact person for a corporate customer, or a person acting on behalf of the corporate entity.
f) “Subscription” means time-limited access to the full version of the Ylands EDU educational service provided by the Company under a service agreement.
g) “Services” are defined in Article 1.1 of this Policy. 1.4. This Policy forms an integral part of the Terms of Service or License Terms, and by agreeing to either of these documents, you acknowledge that you have reviewed this Policy.
1.5. The information contained in this Policy applies to all Users of our Services. If you represent a legal entity (e.g., a school), this Policy primarily concerns the personal data of the individual who acts or communicates on behalf of your organization regarding the Subscription.
1.6. We are the controller of your personal data, unless otherwise stated in this Policy.
2. From Where Do We Collect Your Data?
2.1. We collect your personal data directly from you, to the extent that you provide it, such as when submitting a contact form, entering into a contract, or directly communicating with us or our representatives. We may also obtain some additional data by monitoring the use of the Services. Unless explicitly stated otherwise in this Policy, such data is anonymized, making it impossible to identify the data subject.
3. For What Purpose and on What Legal Basis Do We Process Your Data?
Processing personal data to comply with legal obligations
3.1. We process your personal data based on Czech legal regulations applicable to our business activities. As this processing is based on legal obligations, your consent is not required.
a) If you purchase a Subscription, we process your personal data under Act No. 563/1991 Coll., on Accounting, Act No. 235/2004 Coll., on Value Added Tax, and Act No. 586/1992 Coll., on Income Tax, to fulfill our legal obligations under these laws, particularly keeping records of all payments and transactions related to the Subscription.
b) If you purchase a Subscription as a consumer, we also process your personal data to meet any obligations under Act No. 634/1992 Coll., on Consumer Protection.
Processing personal data to fulfill contractual obligations or take steps before contract conclusion
3.2. We process your personal data to fulfill our obligations under any contract with you. If you request it (e.g., by submitting a form), we may process your personal data before entering into the contract to take necessary steps to finalize it. Without processing certain essential personal data, we cannot enter into or fulfill the contract.
a) If you contact us by filling out and submitting a form on our website, we process the personal data you provide to us through this form. This data is used to contact you via our representatives to arrange the Subscription and possibly discuss individual terms. Based on this data, we may also identify you and take other necessary steps to conclude the contract.
b) Once you enter into a Subscription agreement, we are obligated to provide the Subscription under the agreed terms. We are also required to process payments, issue invoices, and inform you of important notifications related to the Subscription. For these purposes, we are authorized to process the necessary personal data.
Processing personal data for legitimate interests
3.3. We also process your personal data to pursue our legitimate interests:
a) If you use any of the Services and have provided us with your email address, we process it to send notifications regarding the Services and related offers or events.
b) We may process your personal data to detect and prevent fraudulent activities, including violations of the license terms or Subscription terms. We may also process limited personal data collected through monitoring the use of our Services to optimize and improve them.
3.4. A list of the categories of data we process under this Article 3 is provided in Annex 1 of this Policy.
4. How Is Your Personal Data Processed?
4.1. Privacy and security are key aspects of developing and providing the Services. We have assigned specific responsibilities for addressing privacy and security matters. Our internal policies and guidelines are enforced through appropriate actions, including proactive and reactive risk management, privacy and security engineering, training, and evaluation. We implement measures to address online safety, physical security, data loss risks, and other related risks, considering the nature of the data and the risks associated with processing it. Access to our databases containing personal data is restricted to authorized personnel with a legitimate need to access the information.
4.2. The personal data of end users of the Services is not processed or disclosed to third parties by us unless otherwise specified in this Policy. All data collected on student computer activities is anonymized, and we do not process their personal data.
5. Recipients of Your Data
5.1. All personal data shared under this Article is obtained directly from you or, where applicable, your organization.
5.2. The personal data we collect is primarily made available to selected employees responsible for the Services, but only to the extent necessary for fulfilling their job duties. Our employees are bound by confidentiality agreements covering all information they come into contact with during their work and must adhere to our internal policies governing the use of systems that handle your personal data.
5.3. Besides our employees, we share your personal data to the necessary extent with selected external collaborators responsible for customer communications, negotiating individual terms, or providing support for the implementation of Services in education. These individuals are also bound by confidentiality agreements covering all information they come into contact with during their work.
5.4. Personal data collected in connection with your license to use any of the Services may be disclosed to third parties under legal obligations we may have. Certain personal data may be shared with tax authorities, law enforcement agencies, and judicial bodies to the extent required.
5.5. Some of your personal data related to your Subscription may be shared with our partners who provide accounting or similar services for us. We may also share a necessary subset of the personal data collected during your use of the Services with our affiliated companies for the purpose of operating and improving the Services. All such partners and affiliated companies have signed confidentiality agreements with us and must comply with our policies on handling your personal data.
5.6. The email address we use for sending communications may be shared with electronic marketing service providers, provided that the email address is not used for any purposes other than those specified in this Policy.
5.7. If you access any of the Services through a platform provided by a third party, some data related to this access may be collected and processed by the third party. We are not responsible for the practices of these third parties, and we recommend that you carefully review their privacy policies and any permissions you grant to them.
5.8. A list of our partners and third parties with whom we may share your personal data is provided in Annex 2 of this Policy.
6. How Long Do We Retain Your Data?
6.1. We process your personal data only for as long as necessary for the purposes of its processing. We regularly assess whether the need to process specific personal data for a given purpose persists. If it is determined that the data is no longer necessary for any of the specified purposes, it will be deleted. The retention periods for your personal data are listed in Annex 1 of this Policy.
7. Your Rights
7.1. Right of access and rectification of personal data.
You have the right to access and correct or modify any inaccurate or incomplete personal data we collect about you.
7.2. Right to erasure of personal data.
You have the right to request the deletion of all personal data that is no longer needed or that has been processed unlawfully. If you would like your personal data to be deleted, you can contact us at [email protected]. Once we receive your request, we will delete any personal data that we are required to delete under the GDPR.
7.3. Right to restriction of processing of personal data.
You have the right to request that we restrict the processing of your personal data in certain cases, such as while your objection or request for erasure or correction of your personal data is being resolved.
7.4. Right to data portability. You have the right to request that we provide you with the personal data you have given to us, if it is being processed based on your consent or a contract with us and is being processed automatically. Upon request, we will provide your personal data in a structured, machine-readable format. You also have the right to request that we transfer this data to another controller, if technically feasible.
7.5. Right to object to the processing of personal data.
If you believe that processing your personal data based on our legitimate interest is not compatible with your rights, you may object to such processing and request a remedy.
7.6. Right to lodge a complaint.
If you believe that we have violated applicable laws in processing your personal data, you have the right to file a complaint with the data protection authority in your country, your place of work, or where the alleged violation occurred. In the Czech Republic, the relevant authority is:
Office for Personal Data Protection
Pplk. Sochora 27
170 00 Prague 7
Czech Republic
8. Final Provisions
8.1. This Policy becomes valid and effective as of July 30, 2024.
8.2. We may change this Policy from time to time to reflect changes in the content of the Services. We recommend that you periodically review this Policy to stay informed of any updates.
8.3. If you have any questions regarding the processing of your personal data or wish to exercise any of your rights under the GDPR, you can contact us at [email protected].
Annex 1 to the Ylands EDU Privacy Policy:
| Policy Provision | Categories of Personal Data We Process | Retention Period |
|---|---|---|
| Sec. 3.1 a) | - Records of purchased products or services - Records of payments made - Records of refunds |
10 years |
| Sec. 3.1 b) | - Name and surname of the Responsible person - Address of residence of the Responsible Person - Date of birth of the Responsible Person - Email address of the Responsible Person - Phone number of the Responsible Person - Records of complaints |
10 years |
| Sec. 3.2 a) | - Name and surname of the person filling out the form - Email address of the person filling out the form - Phone number of the person filling out the form - Name of the organization filling out the form - Position of the person filling out the form in the organization (if provided) |
5 years |
| Sec. 3.2 b) | - Name and surname of the Responsible Person - Name of the Responsible Person's organization - Payment details - Email addresses associated with sub-accounts |
For the duration of the contract |
| Sec. 3.3 a) | - Email address of the Responsible Person - Phone number of the Responsible Person |
For the duration of the contract and 1 year after its termination |
| Sec. 3.3 b) | - IP address | For the duration of service use |
| Sec. 3.3 c) | - Email address of the user in the role of the teacher and/or administrator - Device ID of the user in role of the teacher and/or administrator - Name of the assigned class (as entered by the teacher or the administrator) - Name of the organization - Number of devices logged into the class session |
For the duration of the contract and 1 year after its termination |
Annex 2 to the Ylands EDU Privacy Policy:
| Partner Identificaiton | Categories of Data Shared with the Partner | Purpose of Sharing |
|---|---|---|
| Martin Bukáček IČO: 015 87 897 Monika Macháňová IČO: 072 27 027 Daniel Koreň IČO: 065 15 193 Jiří Benda IČO: 656 64 205 Štěpán Bady IČO: 213 14 331 |
- Name and surname of the Contact Person - Email address of the Contact Person - Phone number of the Contact Person - Address of the Contact Person - Identification details of the organization - Position of the Contact Person in the organization - Names, surnames, and the email addresses of the organization's members (if requested by the organization) |
For customer communication, negotiating individual terms and providing support for the implementation of Services in education. |
| BOHEMIA INTERACTIVE SUTDIO s.r.o. IČO: 257 64 730 Nad Pomníkem 467/9, 152 00 Prague 5, Czech Republic |
- Records of purchased Subscriptions - Records of payments made - Name of the Contact Person - Address of the Contact Person - Email address - Records of complaints |
For the provision of accounting and similar services. |
| BOHEMIA INTERACTIVE SUTDIO s.r.o. IČO: 257 64 730 Nad Pomníkem 467/9, 152 00 Prague 5, Czech Republic BOHEMIA INTERACTIVE B.V. RSIN: 85614799 Dnazigerade 223, 1013AP Amsterdam, Netherlands BOHEMIA INTERACTIVE Co., Ltd. 378/80-81, Moo 12, Nongprue, Banglamung, Chonburi, 20150, Thailand |
- Necessary subset of your personal data | For the operation and improvement of our Services. |
| Treasure Data, Inc. 800 W. El Camino Real, Suite 180, CA 94043, United States |
- Device ID of the user in the role of teacher and/or administrator - Number of devices logged into the class session | Collection of analytical data for the optimization and improvement of our Services. |