Effective Date: June 10th, 2022
Minicoders is founded on the principle of improving the world’s access to quality education and we are committed to providing an educational, entertaining, and safe service for kids and parents. We know that you care about how your family’s personal information is used and shared, and we take your privacy and safety very seriously.
We inform you that we may include pop-up ads or other advertisements directed at children, but only and exclusively related to Minicoders products and/or services. Without prejudice of the foregoing, Child Users are blocked from accessing external links, which will only be available if an Adult User enters a password or answers a security question.
This Privacy Policy describes the ways in which MINICODERS 21, SL (“Company,” “we,” “us” or “our”) collect, use, and disclose information about you and the children who use your account through minicoders.com, and any other websites, applications and online services that link to this Policy (collectively, the “Services”).
By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use, and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the MINICODERS 21, SL Terms and is subject to the provisions of the Terms. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy you should not use our Services.
THIS IS A BINDING AGREEMENT BETWEEN YOU AND COMPANY. BY USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS IN THIS PRIVACY POLICY AND THE TERMS. THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION ABOUT COLLECTION OF PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN. PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING THE SERVICES.
This Privacy Policy explains how the Company may collect, use, and disclose the information we obtain through our website or the Services provided pursuant to the Terms. As used in this Privacy Policy, “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as your name, address, email address, or phone number. We do not consider Personal Information to include information that has been aggregated and/or de-identified so that it does not allow a third party to easily identify a specific individual.
We collect information, including Personal Information, when you:
We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.
A. Payment Information. If you make any purchases through our website, we may collect certain information regarding your purchase (such as your name and zip code) as necessary to process your order. You will be required to provide certain payment and billing information directly to our payment processing partners, including your name, credit card information, billing address, and zip code.
B. Using the Services. We collect information that you submit to us through our website. For example, when you post comments, make a purchase, we will collect the information you include in these submissions, including any Personal Information. In addition to the foregoing, if you use certain Services, we may collect and process other Personal Information, such as your Child User’s voice (specifically, and by way of example, through the following specific functionalities of our products and/or services: Virtual Assistant).
C. Customer Support. We collect all information that you provide to us, including any Personal Information when you contact us for customer support purposes.
D. Location Data. Once you register to the Minicoders app we may collect and process information about your location. This location information is being collected based on your IP address and is restricted to the name of your city. Minicoders is not using other technologies to determine your location (we do not use GPS, or other sensors). We do not collect location information about your exact whereabouts (i.e. name of the street or accurate address). When we have location information, we may use it to optimize our Services for you and others, allowing us to customize our website, understand and improve the services and develop new products, services, or features.
E. Cookies, Automatic Data Collection, and Related Technologies. As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
The information we collect automatically helps us to improve our website and to deliver a better and more personalized service, including by enabling us to:
Speed up your searches.
The technologies we use for this automatic data collection may include:
You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. However, if you refuse to accept browser cookies by activating the appropriate setting on your browser, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
We use information collected from you to:
Provide, administer, and facilitate your use of our Services, including to display customized content; process or fulfill your request(s) and/or order(s) for products, services, information or features, including the use of specific functionalities of our products and/or services (by way of example, and not as a limitation, Virtual Assistant); display surveys, communicate with you concerning your account by:
Responding to your questions or concerns;
Sending you administrative messages and information, those about changes to the Services, and updates to our Terms, and Privacy Policy;
Emailing you information or providing messages about your rewards programs, new services, new features, promotions, newsletters, which you can opt-out of at any time; Sending push notifications to your wireless device to provide updates and other relevant messages. You can manage push notifications from the “options” or “settings” page for the mobile application.
Understand and improve the services and develop new products, services or features;
Enable user-to-user communication and interaction;
Manage your account preferences, establish your profile and registration information;
Facilitate the technical functioning of our Services, including without limitation to troubleshoot and resolve issues, secure the Services, and prevent fraud and abuse;
Respond to customer support questions and issues and resolve disputes;
Create, review, analyze and share technical information;
Analyze trends and user traffic, track purchases and usage information;
Advertise our Services on third-party websites or mobile applications;
Market, process or fulfill promotions administered or sponsored by us;
Solicit feedback from users; As required or permitted by law; As we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services; Identify unique users across devices; or Tailor advertisements across devices.
Aggregate Data. We may de-identify and aggregate information collected through the Service and use it for any lawful purpose.
Child User Information. Information collected from Child Users may be used:
To measure a Child User’s performance in activities including their use of specific functionalities of our products and/or services (by way of example, and not as a limitation, Virtual Assitant), and to adapt a Child User’s learning experience to the Child User’s learning needs.
To analyze, provide progress reports on, or provide an assessment of a Child User’s performance.
Information collected from Child Users is never used to market to Child Users. Specifically, Personal Information collected from Child Users will never be used to serve targeted advertising, to build behavioral marketing profiles, or be shared with independent third parties for marketing purposes.
Both Adult and Child User Information. Information collected from both Adult and Child Users may be used:
We will share your information which may include registration information, profile information, shared content, and location information with the following third parties or under the following circumstances or as otherwise described in this Privacy Policy:
Third-Party Business Partners, Service Providers, Contractors or Agents. We may share your information with third-party companies that perform services on our behalf, including for payment processing, order fulfillment, video conferencing, scheduling, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), email and hosting services, services that process and administer consumer surveys, and customer services and support. We may also share your information with third-party companies that we partner with to provide certain services to you in connection with the Services. Those partners’ collection and use of information are subject to their privacy policies and other terms. You should review such privacy policies, terms, and other agreements.
Analytics and Data Enrichment Services. We use third-party analytics to help understand your usage of our Services and to improve our Services. We may provide your contact information, registration information, technical information, usage data, or de-identified data or to data enrichment services, which match such information with publicly available database information, including contact and social information from other sources, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with you in a more effective and customized manner.
Marketing. We do not rent, sell, or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes unless we have your permission. The Services may allow you to opt-in to receive communications from third parties. If you give us your permission to share your Personal Information with such third parties, then you may receive communications from such third parties and you are solely responsible for your engagement with such third parties.
As Required By Law and Similar Disclosure. We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of the Company’s assets, or transition of the Services to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable Personal Information was collected.
Consent. We may also disclose your Personal Information with your permission.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Please be aware, however, that no information system can be guaranteed to be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us through: info@minicoders.com
With relation to tThe Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) we do not collect any information from children and therefore no verifiable parental consent is needed. The only information we collect is from parents.
Children can access some parts of our website and its content and use some of its features without providing us with Personal Information. However, most content and features of the Services are available only to adult registered accounts and require us to collect certain information, including Personal Information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users when they visit or use the website.
We only collect as much information about a child as is reasonably necessary for the child to participate in the educational activity in our Services, and we do not condition his or her participation in the disclosure of more Personal Information than is reasonably necessary.
Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the website and use certain features. The information we collect through these technologies may include:
We may combine non-personal information we collect through these technologies with Personal Information about you or your child that we collect online.
For information about our automatic information collection practices, including how you can opt-out of certain information collection, see the Cookies, Automatic Data Collection, and Related Technologies section in this Privacy Policy.
How We Use Your Child’s Information.
We use the information we collect automatically through technology and other non-personal information we collect to improve our website and to deliver a better and more personalized experience by enabling us to:
Our Practices for Disclosing Children’s Information. We do not share, sell, rent, or transfer children’s Personal Information other than as described in this section:
Accessing and Correcting Your Child’s Personal Information. At any time, you may review the child’s Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child’s Personal Information.
You can review, change, or delete your child’s Personal Information by sending us a request here: info@minicoders.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
An Adult User can review or change the information they provided when registering for the Services, including by adding or removing Child Users to the Account, by updating information through the Parent Section of the Services by emailing Company support. In addition, at any time, Users may contact us to request that we provide for their review, or delete from our records, any Personal Information they have provided about Child Users associated with their Account, or to cease collecting Personal Information from those Child Users, as applicable. Please keep in mind that a request to delete Personal Information may lead to the cancellation of your Account.
When we change or delete any Personal Information at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.
We store information about users on servers primarily located in the United States and we may also store such information on servers and equipment in other countries. If you are accessing our Services from outside of the United States, please know the data and personal information you submit may be transferred to and stored on servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our Services, you consent to the transfer, storing and processing of your data in and to the United States and other countries where we may choose to store data.
California residents have the right to receive, once a year from us: a) information identifying any third-party company(ies) to whom we may have disclosed (within the previous calendar year) your Personal Information for that company’s direct marketing purposes, and b) a description of the categories of Personal Information disclosed. If you are a California resident and wish to obtain such information, submit a request to us at info@minicoders.com with “Request for California Privacy Information” as the subject line and in the body of your message. Only information required to be disclosed by law will be included in our response.
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide information and choices discussed throughout this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. It is enforceable since 25 May 2018. The GDPR replaces the 1995 Data Protection Directive.
We inform you that the provided data, will be processed by MINICODERS 21, SL with registered office in Plaça Pau Vila, 1, Esc. A Planta 2. Barcelona 08039, Spain.
To know more about what categories of data we collect and how we use the information we collect, please go to section 1 and 2 of Privacy Policy.
The legal basis for data processing is the user’s consent to it. This consent is requested through Controller’s forms during the registration – web or app.
We store information about users on servers primarily located in the United States and we may also store such information on servers and equipment in other countries. If you are accessing our Services from outside of the United States, please know the data and personal information you submit may be transferred to and stored on servers in the United States or other countries.
MINICODERS 21, SL uses a variety of third-party service providers to help us provide services related to our services. Service providers may be located inside or outside of the European Economic Area (“EEA”). We hold Data Processing Agreements (DPA) in place with all the third-party services, that guarantee that adequate safeguards are put in place with respect to the protection of such Personal Data as required by EU’s GDPR Data Protection policies. We do not sell personal information to third parties.
The people who provide us with any personal data have the following rights:
At MINICODERS 21, SL we are committed to taking data protection very seriously Check the Spanish Data Protection Agency website for more details about your rights. Additionally, we inform you about the possibility to make a claim before the competent control authority if you believe that your exercise of your rights was not satisfactory enough: the Agencia Española de Protección de Datos (C/ Jorge Juan, 6. 28001 – Madrid. Contact +34 901 100 099). More info at http://www.agpd.es/.
Posting of Revised Privacy Policy. Because we are always looking for new and innovative ways to help your family’s educational needs in connection with the use of our Services, this Privacy Policy may change over time. The effective date at the top indicates the last time this Privacy Policy was modified. If we modify the terms of this Privacy Policy we will post a notification on our Services. Your continued use of our Services after such changes are made shall constitute your acceptance of such changes and will be subject to the then-current Privacy Policy. If you cease to use our Services after such changes, your discontinued use shall not constitute acceptance of such changes and such changes shall not apply to you. Any revised Privacy Policy will supersede all previous privacy policies.
New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law. Also, we will solicit and obtain verifiable parental consent if our privacy practices change in a way that such consent becomes needed.
MINICODERS 21, SL, located in Spain, is the operator of the Services. Questions regarding this Privacy Policy and issues related to you or a Child User’s information for which you are responsible should be directed to us via any of the following methods:
Mailing address: Mexico, 3, Floor 4 Door 5. Barcelona 08004, Spain.
Attention: Legal Department
E-mail: info@minicoders.com
Telephone: +34 636 953 344