Privacy Policy

There is a child-friendly version of this policy at https://www.upsc-memorylab.in/privacy-policy-tafeltrainer-child

 0. Summary

We process your learning behaviour to help you learn better. MemoryLab adapts based on your learning behaviour, like the speed and accuracy of your answers. We may process this information to improve the system, or – without anyone being able to recognize you – to make statements about the learning behaviour of larger groups of people.

To comply with privacy legislation pertaining to children, we do not store your personal information. In the case of future updates to Times Tables by MemoryLab, this Privacy Policy will be updated to reflect any changes as soon as they are available.

1. Introduction: Who is MemoryLab?

SlimStampen BV (‘Company’, ‘we’, ‘us’, ‘our’, ‘MemoryLab’ or ‘SlimStampen’) is a company established in the Netherlands that uses the trade name MemoryLab. MemoryLab operates under Dutch law. Our office is located at Stationsstraat 10 in Groningen (9711 AS), the Netherlands. We are registered with the Dutch Chamber of Commerce (KVK) with KVK-number 81374755. If you have any questions or concerns, please contact us at info@memorylab.nl.

MemoryLab is an adaptive learning tool. We respect the privacy of our users, including children, parents, and teachers (together, “Users”) and protect it as best we can. In order to provide our Services (“Services”) to you, we may collect, store, use and/or share (“process”) learning data. In this privacy policy we inform you how and why we process your data.

2. Personal information

To use our Services, you must have an AppleID. This is required to ensure that (only) you can log in. We will never provide this information to other parties. We do not handle any payment or billing data. 

Times Tables by MemoryLab does not provide pupils with any means to communicate, directly or indirectly, with each other.

No sensitive information processing.

In accordance with privacy laws, we do not process sensitive or unnecessary information such as someone’s race, religion or health.

We may collect details of other interactions that you have with us, together with any other information that you choose to provide us with, outside of Times Tables by MemoryLab. For example, through correspondence and interactions with our support team.

3. How and why do we process your data?

We process your learning information for a variety of reasons, depending on how you interact with our Services, including:

To make adaptive learning possible

MemoryLab adapts based on your previous learning behavior. That is why we store that learning behavior as:

• what you answered;
• how long it took you to do so;
• practice time per exercise;
• which fact lists were practiced;
• when you practised;
• the levels you have played;
• the rewards you obtained.

We only use this data to improve the system, or – without anyone being able to recognize you in it – to make statements about the learning behaviour of larger groups of people. To further the understanding of memory and learning, this anonymised data may be used in scientific research. 

To deliver and facilitate delivery of services to you

When you practise with MemoryLab lessons, we keep track of how you practise. This information is also stored in our systems and used to analyse, optimise and improve MemoryLab. In addition, some of your usage information is necessary to be able to offer you the Service. For example, you can view your progress across levels, and earn trophies.

We temporarily collect anonymous error information to help us ‘debug’ (solve) problems, so we can see how problems have arisen. This information contains your IP address (the number of your computer that makes it possible to recognize your computer), and the type of browser (the computer program to view internet pages). It is automatically removed after 14 days. The processing of this information is necessary to securely and correctly offer our Service and will not be used for any purpose other than debugging problems.

To enable the use of third-party software

We do not share learning data with third-party software providers. However, there are some third parties who perform Services for us or on our behalf and require access to certain information to do that work. There is no advertising of any kind, third-party or otherwise, in our app. The third parties we use for Times Tables by MemoryLab are the following:

• Cloud computing services – Microsoft Azure
  • To ensure an industry standard application and provide you with our Service, our software’s storage and hosting is handled through the Microsoft Azure Cloud service. Microsoft does not share your data with advertiser-supported services, nor do they mine it for any purposes like marketing research or advertising.

• Collection of performance data – Grafana Faro

• • We integrated Grafana Faro, which collects performance data on the webviews in the app. Performance data like page load times and web console errors to alert us of issues in the webviews.
  • This is anonymous data collected for monitoring the technical performance of the screens. We do not collect information that is linked to a person.

Your learning data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. We have taken appropriate safeguards to require that your learning data will remain protected in accordance with this Privacy Policy. 

4. What legal bases do we rely on to process your information?

For Times Tables by MemoryLab, we do not process any personal information. The references to processing of personal data in this section refer only to that which you choose to provide us with, outside of Times Tables by MemoryLab. For example, through correspondence and interactions with our support team.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. 
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Understand how our users use our products and Services so we can improve user experience
  • Improve the system, or – without anyone being able to recognize you in it – to make statements about the learning behaviour of larger groups of people.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

5. What are your rights?

For Times Tables by MemoryLab, we do not process any personal information. The references to processing of personal data in this section refer only to that which you choose to provide us with, outside of Times Tables by MemoryLab. For example, through correspondence and interactions with our support team.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These rights are outlined below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

5.1. Right of access

You can ask us whether we store your personal data. If we process the data, the request is not excessive and sharing the data does not violate the privacy of others, we may send you a copy of that data.

5.2. Right to rectification

You can make changes to correct incorrect personal data yourself directly in your Profile.

5.3. Right to erasure

You can ask us to delete (certain) personal data about you. If we comply with your request, we will delete that personal data. However, we may need to retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

5.4. Right to restriction of processing

You can ask us not to use your personal data for a while. This means that if we comply with your request, we will not use your personal data for a certain period of time unless this is permitted by law.

5.5. Right to data portability

You can ask us to send you your data so that you can easily give it to another party (data portability). If we comply with your request, we will provide the data to you so that you can give it to a third party.

5.6. Right to object

You can object to the use of your personal data in certain cases, for example, if we use your personal data for our interest.

5.7. Right to a human eye when making decisions

Privacy related decisions regarding your data will not be automated. Your request will always be reviewed by a person.

5.8 Right to withdraw your consent

You have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us or removing your account on the ‘Profile’ page. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

6. How long do we keep your information?

We will only keep your learning data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your learning data for longer than the period of time in which you have an account with us.

7. How do we keep your information safe?

For Times Tables by MemoryLab, we do not process any personal information. The references to processing of personal data in this section refer only to that which you choose to provide us with, outside of Times Tables by MemoryLab. For example, through correspondence and interactions with our support team.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect our Users’ personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do we make updates to this policy?

Yes, we may update this privacy policy from time to time. The updated version will be indicated by an updated ‘Last Update’ date and the updated version will become effective as soon as it becomes available.
 If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

9. Questions

If you have any questions about your privacy or this policy, please let us know by sending an email to info@memorylab.nl.

Last updated: January 10, 2024