Privacy Notice

 

This Privacy Notice explains our practices, your choices regarding the collection, use, and disclosure of certain information, your personal information, by the Calm Island (https://www.calmid.com, “Calm Island”).

 

 

Contacting Us

 

If you have general questions about your account or how to contact customer service for assistance, questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer, Ethan, HeeSeob Jeong, by email at calm_privacy@calmid.com

 

The data controller of your personal information is Calm Island. Please note that if you contact us to assist you, for your safety and our, we may need to authenticate your identity before fulfilling your request.

 

 

Collection of Information

 

We receive and store information about you such as:

 

  •  Information provided by the users: We collect information you provide to us which includes:
    • Name, email, gender, birth date, ID, telephone number, nationality, language, Connection Information (CI), Duplication Information (DI), payment method(s), etc. (For minors, information of their legal representative (name, date of birth, CI, DI, etc. of the legal representative)) for Internet membership service
    • Member name, address, age, registered organization, and email, detail of subscription and KidsLoop content use (content classification (books, applications and videos), content titles, time of using the content by hour, day and month, attendance (class classification, class titles, schedule, achievement and member evaluation) for analysis of how members use the content & service suggestion
    • Pictures, audio and videos for application service
    • Name, telephone number for Service of providing learners with development history and analytic results according to the Learning Lab use

 

  • Information collected while the users are using the services: Besides the information directly provided by the users, the Calm Island can collect information while the users are using the Calm Island’s KidsLoop service and application service.
    • Equipment information such as records on the use of and access to KidsLoop services, verification records, access IP information, unique number for equipment identification (example, equipment ID), OS information (country, language), application version, etc.
    • Log information such as IP address, log data, use time, search words input by users, internet protocol address, cookies and web beacons, etc.
    • Other information such as preference, visited pages, etc. regarding the users’ KidsLoop service use, time of playing videos and audios, time of using activities, Bada Pen data, quiz results, places where a photo is taken, date of creating files, etc.

 

  • Information provided by Partners: Calm Island receives information from the other companies with which its members have made a contract (hereinafter referred to as the “Partners”). The Partners include offline class companies furnishing the Learning Lab services, such as Learning Park, Kindergarten Solution, etc. The information that the Partners provide for the Calm Island can differ depending on the nature of the Partners’ services and include as follows:
    • Name and birth date of learners (children)
    • Name and phone number of their legal representative
    • Pictures of Learners(children) for Social Feed Service

 

  • Information from other sources: Calm Island also obtain information from other sources. The Calm Island protects this information according to the practices described in this Privacy Statement, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include:
    • payment service providers who provide us with payment information, or updates to that information, based on their relationship with you;

 

Method of collection

 

The Company collects the information of the users in the following manner (Under GDPR 6(1)(a)):

  • Collection through websites and mobile devices with the prior consent of the users

 

Use of Information

 

We use information to provide, analyze, administer, enhance and personalize our KidsLoop services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use information to:

 

  • To detect and deter unauthorized or fraudulent use of or abuse of the KidsLoop services such as member management, identification, etc.;
  • To perform contractual obligations and facilitate the payment and settlement of KidsLoop service fees in relation to the services demanded by the users;
  • To improve the existing services and develop new services
  • To notify a change, if any, in the Policy or functions of the Calm Island’s website or applications;
  • To use the users’ information with their prior consent (for example, utilization of marketing advertisement, etc.);
  • To allow a user to search, be notified of and automatically register, his or her friends whose contact information is saved on the user’s mobile phone, or to search and be notified of other users he or she might know;
  • To make statistics on the KidsLoop service use of members, to provide KidsLoop services and place advertisements based on the statistical properties;
  • To provide information on promotional events and opportunities to participate therein; or
  • To comply with applicable law or legal obligations

 

Disclosure of Information

 

We disclose your information for certain purposes and to third parties, as described below:

 

  • Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services.
  • Partners: Users may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing the service to members and providing information about the availability of the service. For example, depending on what Partner services you use, we may share information:
    • in order to facilitate Partner collection of payment for the Calm Island service for distribution to us;
    • with Partners who operate voice assistant platforms that allow you to interact with our service using voice commands;
    • so that content and features available in The Calm Island service can be suggested to you in the Partner’s user interface. For members, these suggestions are part of the Calm Island service and may include customized and personalized viewing recommendations.
    • such as pictures from Learner (Chlidren) that Partners provided to [Teacher] for the Social Feed service
  • Promotional offers: We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
  • Protection of The Calm Island and others: The Calm Island and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of The Calm Island, its users or the public, as required or permitted by law.
  • Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

 

Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Notice and as permitted by the applicable laws on data protection. Personal information transferred (such as name and contact information) may be saved electronically on servers operated by our Service Providers for record keeping purposes and other purposes as set out in this Privacy Notice.

 

Need to disclose personal information

 

The personal information provided by users is the requirement for the KidsLoop service use contract between a user and the Calm Island so that the Calm Island provides the users with great services. The users may be restricted to use the Calm Island’s KidsLoop services unless they give consent to the collection of required personal information while they can use the Calm Island’s services except the  services which require the consent to the collection of the optional information if they refuse to give consent to the collection of such optional information.

 

Overseas Transfer of Data

 

The Calm Island can disclose users’ personal information to the companies located in other countries or other companies for any purpose specified in this Policy. It will take reasonable measures to the companies where the information is transmitted, retained or processed in order to protect the information. The Calm Island discloses the users’ personal information in accordance with the documents including standard clauses of personal data protection approved or adopted by the recipient of personal data or European Committee (Under GDPR 46).

 

User’s right

 

The users or their legal representatives, as main agents of the information, can exercise the following rights regarding the collection, use and disclosure of personal information by the Calm Island:

  • the right to access by the data subject (Under GDPR 15);
  • the right to rectification and (Under GDPR 16)
  • the right to erasure (Under GDPR 17)
  • the right to restriction of processing (Under GDPR 18)
  • the right to data portability (Under GDPR 20)
  • the right to object (Under GDPR 21)
  • automated individual decision-making, including profiling (Under GDPR 22)
  • to request the withdrawal of prior consent (Under GDPR 7(3))

 

If, in order to exercise any of the foregoing rights, a user contacts the Calm Island (or person in charge of management of personal information or a deputy) by using the menu of ‘amendment to member information’ on the website, in writing, or by e-mail or phone, the Calm Island will immediately take an action accordingly: provided, however, that the Calm Island may reject such request if and to the extent there are reasonable grounds prescribed in law or equivalent thereto.

 

Also the users or their legal representatives have the right to lodge a complaint with a supervisory authority (Under GDPR 13(2), GDPR 14(2)(e)).

 

Security

 

The Calm Island takes the security of personal information seriously. It has the following security measures to prevent the unauthorized access to, or disclosure, use or change of the personal information (Under GDPR 32).

 

  • To encrypt personal information
  • To transmit users’ personal information by an encrypted communication zone
  • To keep encrypted essential information such as passwords
  • Authentication security strategy: Authentication Sessions
  • Hashing user password in the database
  • SSL certificate managed with AWS Certificate Manager
  • To formulate countermeasures against hacking
  • To install a system in the zone to which the external access is strictly restricted so as to prevent users’ personal information from leakage or damage by hacking or computer viruses
  • To establish and implement internal management plans
  • To conduct regular internal audit (once a quarter) to safely process personal information
  • To keep minimal the number of employees processing personal information and educate them
  • To install and operate access control systems
  • To take necessary actions to restrict the access to the personal information, such as the grant, change or termination of the right to access the data base system of personal information processing
  • To keep the documents, storage devices, etc. which include personal information in a safe place with a lock
  • To designate a physical place of storing personal information to restrict the access by unauthorized persons and to establish and operate such access control procedure
  • Rest API Security with AWS: API Gateways
  • DynamoDB user data security with AWS: Databases
  • Take measures to prevent forgery or alteration of access records

 

Children

 

In principle, the Calm Island does not collect any information of the children under 13 or those of minimum age under law. However, if the Calm Island collects any personal information of the children under 13 or those of minimum age under relevant law for the services provided by Calm Island, including without limitation Learning Lab, Kids Loop, application service and Social feeds service use, it will comply with the following procedure for the protection of children’s personal information: (Under GDPR 8)

 

  • To verify if a child is subject to the guardian’s consent and such guardian is authorized, within the scope of reasonable efforts;
  • To have the consent from a child’s parent or guardian to collect the child’s personal information or to provide the child with product information and the Calm Island’s services directly;
  • To notify parents or guardian of Calm Island ‘s privacy policy for children, including the items, purpose and disclosure of collected personal information;
  • To grant a child’s legal representative the right to access, correct or delete or temporally suspend the processing of, the child’s personal information or the right to withdraw the prior consent of the representative; and
  • To limit the collection of personal information to the extent solely required for the participation in online activities

 

Profiling

 

Calm Island may use the users’ personal information to create individual or collective profiles (hereinafter referred to as “profiling”) for the purpose of identifying how to provide the users with better KidsLoop services, for example, providing the users with customized content of KidsLoop services by analyzing what attracts the users most regarding the Calm Island and the KidsLoop services rendered by the Calm Island, and how the users use the services. In addition, the Calm Island uses the personal data for the following purposes: to create user clusters to identify the users’ interest in the Calm Island’s products and/or services; to analyze the market and statistics or; to enhance the Calm Island’s services (all websites, etc.). It may integrate the data provided by all its websites and applications with the users’ personal data provided by Learning Lab. The processing of personal data for profiling is carried out in line with the guarantees and measures specified in applicable law (Under GDPR 22).

 

The storage limitation

 

The Calm Island will keep personal information in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Once this time period has expired, the Calm Island will delete personal information in one year from the expiration of the period; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject((Under GDPR 5(1)(e)).

 

Modification of Privacy Notice

 

The Calm Island has the right to amend or modify this Policy Notice from time to time, in which case, the Calm Island will make a public notice of it through bulletin board of its website (or through individual notice in writing or by fax or e-mail) and have the consent of the users if required by relevant law.

 

Cookies and Internet Advertising

 

The Calm Island may collect collective and impersonal information through ‘cookies’ or ‘web beacons’.

 

Cookies are substantially small text files to be sent to the browser of the users by the server used for the operation of the Calm Island’s websites and are stored in hard-disks of the users’ computers.

 

Web beacons are a small quantity of code which exists on websites and e-mail. By using web beacons, we can identify whether a user has interacted with certain webs or the contents of email.

 

These functions are used for evaluating, improving services and customizing user experience so that the Calm Island provides way improved KidsLoop services for the users.

 

The items of cookies to be collected by the Calm Island and the purpose of such collection are as follows:

 

  • Required cookies: This kind of cookies is indispensably necessary for the users to use the functions of the Calm Island’s website. No services such as shopping cart or electronic bill payment can be provided for a user unless he or she accepts these cookies. These cookies do not collect any information which can be used for marketing or store the sites that the users have visited.
  • To retain the information entered in an order form while searching other webpages during the web browser session
  • To retain the purchased services for the webpage of products and checkout
  • To verify whether a user logs onto the website
  • To ensure that a user is connected to a correct service on the v’s website if the Calm Island makes any change in the operation of the Calm Island’s website.
  • To connect the users to a certain application or server of the services
  • Performance cookies: This kind of cookies collects information of how the users use the Calm Island ‘s website such as the webpages most frequently visited by the users. Such data helps the v optimize its website so that the users can search more conveniently on its website. Such cookies do not collect any information regarding users’ identification. All or any information collected by this kind of cookies is anonymous since the information is collectively processed.
  • Web analysis: to provide statistical data on how to use the website;
  • Advertisement response fee: to confirm the effect of the Calm Island’s advertisement;
  • Tracing affiliates; to provide Calm Island’s affiliates with the feedback of anonymous information that one of the visitors to the Calm Island’s website has visited an affiliate’s website;
  • Error management: to identify errors which have occurred in order to improve the Calm Island’s website; or
  • Design testing: to test other designs of the Calm Island’s website
  • Functionality cookies: This kind of cookies is used to store the set-ups so as to provide services and improve the user experience. No information collected by these cookies identifies individual users.
  • To store changed set-ups such as layout, text size, basic set-up and colors; or
  • To store the survey which has been conducted by the Calm Island and completed by the users
  • Target cookies: This kind of cookies is connected with the services provided by a 3rd party such as the buttons of ‘likes’ and ‘share’. The 3rd party recognizes the users’ visit to the Calm Island’s website to provide such services.
  • To allow social networks connected to such cookies to use the users’ visit information, thus putting the advertisement targeting the users; or
  • To provide the users’ visit information for advertisement agencies so that the agencies can suggest the tailored ad which can attract the interest of the users

 

The users have an option for cookie installation:  accepting all cookies, making each cookie confirmed whenever it is saved, or refusing the storage of all cookies. However, such refusal by a user may result in the limit to the part of the Calm Island’s services.

 

 

The latest update date: (2019-10-01)