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Privacy Policy

Welcome to the VoxiKids & VoxiClini privacy policy!
We are very glad you are here and can’t wait for you to discover what VoxiKids and VoxiClinic can do for you.
The VoxiKids mobile app is primarily meant for children, but it can also be used by adults to practice their language and pronunciation.
The VoxiClinic platform is created in collaboration with speech therapy specialists and includes a series of management tools that make the parent-therapist relationship much more efficient, aiming to aid in the child’s recovery and their integration into the pre-school and school environment.

VoxiKids - Easy Speech! It has never been easier to speak correctly!
To achieve these things, VoxiKids and VoxiClinic need to process some of your personal data, in order to help you understand how the app works so that you achieve the best results. We are transparent and do not want you to think that we process any data without informing you on the purpose of this action.
Through this Privacy Policy, we are informing you about how we process personal data, what we do with them and what your rights are with regards to your personal data.
Let’s begin!

1.1. Where to find us?

We will refer to VoxiKids and VoxiClinic as us, the company or organisation, so it’s easier to follow.

This Privacy Policy is applicable anywhere you encounter us in the online environment. Especially, we are present online via the voxikids.com website and its subdomains and all affiliated websites (which we will refer to collectively asSites”), as well as all social 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 featured as an app, and we will refer to them all asPlatform”).

The platform is dedicated especially to children, and this means that we take extra care with this data and will always ensure that there exists parental or legal guardian agreement in this respect.

It is important that you read this policy together without Terms and Conditions and our Cookies Policy and all the notifications regarding data processing & privacy that we will provide on various occasions when we collect or process your personal data, so that you may always be fully informed with regards to why and how we use this data. This Privacy Policy represents the main regulatory framework regarding personal data protection and is completed by other notifications specific to certain activities within the app, it functions as an addition to the other notifications, and it is not intended to eliminate them.

1.2. We are known as VoxiKids & VoxiClinic

From a legal standpoint, you can find out identification data below:

Name Speakquest SRL
Registered office Localitate Victoria, str. Victoriei, nr. 14 bl. 22, ap. 16, jud Brașov,
Trade register number J8/458/2020
VAT number 42327556
E-mail sales@voxikids.com

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

According to the law, in our relationship with you we are an operator of personal data. In this capacity, we have a series of obligations, among which is to inform you with regards to the data that we process, the methods we use, the rights you how and how you can exercise them.

1.3. Who you are?

Whether you are the User (a child that uses the services provided on our platform), the parent or guardian of the User, or the Speech Therapist that carries out therapy sessions (Professional), you are the person concerned regarding the processing of your personal data.

As a person, you have different defining traits, which make you unique and thus help us to identify you: first name, last name, address, image, voice etc.

We process this data particularly to grant you access to our services that we provide via the online platform and mobile app. This means that we are responsible for keeping your data private and that you benefit from a series of rights through which you can exert control over the processing of your data.

That is why we must disclose what kind of personal data we process, why we need this data, what we do with it and for how long.

The data we collect via the online platform VoxiClinic

2.1. If you are the Parent of guardian of the child

In order to facilitate the child’s access to the services provided by VoxiClinic, you will need to provide us with certain personal data.

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

Category Data included
Identification data last name, first name, username or similar identifier, birthdate, your language preference
Contact data billing address, email
Financial data Information regarding payments or bank account/card Information about purchase orders
Trading data Details regarding payments from and toward you, and other details regarding the services you have purchased from us
Technical data IP address, login data, the type and version of the browser used, settings regarding location and time zone, browser plugins and their versions, operating system, operating platform, and other technologies on the devices that you use to access our site.
Profile data Username, password, orders made by you, your interests, and preferences, your characteristics regarding language, feedback offered, your answers to surveys
Usage and interaction data Information about how you use our website, services, including video footage and audio recordings of the speech therapy sessions
Marketing and communication data Your preferences on receiving marketing materials from us and other third parties, as well as your preferred communication methods

If you are a parent or legal guardian of a child under the age of 16 we will need your explicit consent to process the personal data of the child, but especially for special categories of data, such as data about the child’s health status. As such, alongside the above information, you will have to provide, for each child that you register into your account, the following data

  1. first name, last name;
  2. age;
  3. language age
  4. any speech difficulties that the child/adult has, as specified on the platform;
  5. your explicit consent regarding the processing of the child’s personal data;
  6. an affidavit regarding your status as legal representative or guardian.

Please bear in mind that this data is necessary so that we may offer the best possible experience to your child, and so that we may customize their experience in our online platform. Our aim is to turn speech therapy into play, and the play level needs to be adapted to the requirements, needs and abilities of each child.

Even Popeye the Sailor Man had to eat a lot of spinach before he became big and strong!

When you choose to have private sessions with a speech therapist, please keep in mind that the interaction that occurs between the child and the therapist will be recorded (audio & video) and that the speech therapist will have access to this information for 12 months. This is necessary so that the speech therapist may correct the speech patterns of the child and help them enhance their hearing and pronunciation, by verifying the stimuli and accuracy of the exercises used and, at the same time, by following the child’s progress over time.

It is preferable that these private therapy sessions occur at a location where the child and parent are both present, so that the parent can ensure a smooth running of the online therapy session, without other people or stimuli that may distract the child.

2.2. If you are a User – the child that 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 VoxiClinicplatform without the consent of a Parent or legal guardian.

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

Category Data included
Identification data Last name, first name, username or similar identifier, birthdate, your language
Contact data billing address, email
Financial data Information regarding payments or bank account/card Information about purchase orders
Trading data detalii privind plățile efectuate și alte detalii privind serviciile pe care le-ai achiziționat de la noi
Technical data IP address, login data, the type and version of the browser used, settings regarding location and time zone, browser plugins and their versions, operating system, operating platform, and other technologies on the devices that you use to access our site.
Profile data Username, password, orders made by you, your interests, and preferences, your characteristics regarding language, feedback offered, your answers to surveys
Usage and interaction data Information about how you use our website, services, including video footage and audio recordings of the speech therapy sessions
Marketing and communication data Your preferences on receiving marketing materials from us and other third parties, as well as your preferred communication methods

2.3.  If you are a professional (speech therapist)

We require information regarding your professional qualifications in order to verify that you really are a professional, before allowing you access on our platform. This information consists in

  1. proof that you are a psychology graduate
  2. practice license number
  3. proof that you have graduated a specialised course in speech therapy
  4. supporting documents attesting to the type of business organisation (LLC, sole proprietorship etc.)

To the extent that we you will not be able to send us information regarding your qualifications, we will be unable to create a professional account for you and register you on our platform.

Category Data included
Identification data Last name, first name (username) or similar identifier, your preferred communication language, city, country
Professional data data included on your diplomas, certifications, supporting documents attesting to the type of business organization (LLC, sole proprietorship etc.)
Contact data billing address, email, telephone number
Date de tranzacționare (financiare) detalii privind plățile de la și către tine și alte detalii privind serviciile pe care le-ai accesat, contul bancar
Technical data IP address, login data, the type and version of the browser used, settings regarding location and time zone, browser plugins and their versions, operating system, operating platform, and other technologies on the devices that you use to access our site.
Profile data Username, password, orders made by you, your interests, and preferences, your characteristics regarding language, feedback offered, your answers to surveys
Usage and interaction data Information about how you use our website, services, including video footage and audio recordings of the speech therapy sessions
Marketing and communication data Your preferences on receiving marketing materials from us and other third parties, as well as your preferred communication methods

2.4. Aggregate / anonymised data

We collect, use and share for any purpose aggregate data, such as statistical or demographical data. Aggregate data can arise from your personal data, but they are not considered personal data as per existing laws because this information does not reveal your identity, directly or indirectly. For example, we might aggregate your usage data in order to calculate the percentage of users who access a certain functionality of our website. However, in the event that we merge or correlate aggregate data with your personal data so that we may identify you directly or indirectly, we will treat the resulting combined data as personal data which will be used as described in this document.

We will also apply data anonymizing procedures (such as to audio recordings of speech therapy sessions) to analyze the child’s progress in order to find ways to improve the quality of our services.

3.   What information from a child’s profile is visible to others?

The child’s complete profile is confidential. Other parents attending the same kindergarten, school of therapy office, cannot view the children’s data. The speech therapist (specialist/psychologist) may only view the children’s names, the avatars used (which can be an implicit avatar or one that was modified by the parents) and any data set by the parents themselves (first name/last name, biological age, language age, speech difficulties). Specialists (speech therapists/psychologists) can view the data supplied by the parents pertaining to the children they have interacted with based on parental consent.

4. How we collect your personal data

We can collect your personal data in different ways, such as:

  1. Direct interaction
  2. Indirect interaction
  3. Automated technologies or interactions
  4. Third parties or information that is publicly available
  5. Information that we build internally, as you interact VoxiClinic and/or VoxiKids, either through the online platform, or through the collection that you have with a speech therapist.

4.1. If you are a Parent

Source Data
Direct interaction You can provide us directly with data about you (such as Identification Data, contact information and Financial Data) by filling in the existing fields on our site or via email, telephone, or any other method that we provide. This includes personal data you supply to us when:

●      you wish to download one or several materials that we feature on the Platform

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

●     you engage a speech therapist via the VoxiClinic Voxi Clinic;

●      you create an account on our site

●      you subscribe to our services or our publications

●      your request for promotional & marketing materials

●     you enter a competition or promotion, you complete a survey etc.

●      you send us feedback

Automated technologies or interactions As you use our site, we will be able to collect data automatically. Technical data about the equipment you use, the manner in which you navigate our site and other behavioral patterns. We will collect this information via the use of cookies, server logs and other similar technologies.

Please read our cookies policy for more details.

4.2. If you are a User (Child)

Source Data
Parent or Legal Guardian First name, last name, chronological age, language age
Interaction with a speech therapist We have access to audio-video recordings of speech therapy sessions
Automated technologies or interactions As you use our site, we will be able to collect data automatically. Technical data about the equipment you use, the manner in which you navigate our site and other behavioral patterns. We will collect this information via the use of cookies, server logs and other similar technologies.

Please read our cookies policy for more details.

4.3. If you are a professional (speech therapist)

Source Data
Direct interaction You can provide us directly with data about you (such as Identification Data, contact information, Financial Data, Professional Data) by filling in the existing fields on our site or via email, telephone, or any other method that we provide, as well as by loading/sending supporting documents. This includes personal data you supply to us when

●      you register on our speech therapists’ network

● you get in touch with a child via the Voxi Clinic;

●      you subscribe to our services or our publications

●      your request for promotional & marketing materials

you complete a survey, you provide a feedback etc.

Automated technologies or interactions As you use our site, we will be able to collect data automatically. Technical data about the equipment you use, the manner in which you navigate our site and other behavioral patterns. We will collect this information via the use of cookies, server logs and other similar technologies.

Please read our cookies policy for more details.

5.   Why we collect your personal data

We mainly collect your personal data (or the personal data of a minor) so that we can directly offer the service that you wish to access.

We mainly collect your personal data (or the personal data of a minor) so that we can directly offer the service that you wish to access. However, we also use your personal data (or the personal data of the minor) in order to improve the Platform, to send you suggestions about features and services that may help you, to see what you’d like and how we can offer you the best service.

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

  • You have given us your consent regarding the processing of personal data

Keep in mind that you may withdraw consent at any time, by following the instructions unsubscribeunsubscribe”) din fiecare e-mail sau prin transmiterea unei cereri scrise la adresa de e-mail contact@voxikids.com

  • The processing of personal data is necessary to enter into a contract or for the performance of a contract between you and us
  • The processing of personal data is necessary for the purpose of our - or a third party’s, legitimate interests

We have included below, in a table format, a description of the ways in which we plan to use your personal data, as well as the legal grounds on which we act. Moreover, we have identified our legitimate interests wherever they applied.

Please bear in mind that it is possible to process your personal data based on several legal grounds, dependent on the purposes for which we use this data. Please contact us at the email address dpo@voxikids.com if you wish to learn more details about the legal grounds we invoke when we process your personal data, wherever there existed more than a single legal ground as shown in the table below

Purpose Personal Data Additional Information Legal ground
Registering as a User Identification Data

Contact Data

In case you decide to register as a user on our Platform, we must process your data in order to identify you as a user and offer your access to different functionalities and services available for you as a registered user. In certain situations, creating an account will be an automatic process, in order to grant you access to the services that you have purchased from us.

At any time, you can cancel your user account registered either from your account on our site, from your Client Account, or at the email address suport@voxikids.com

Depending on the Platform’s degree of development, you will have the possibility to connect via a social network, such as Facebook/Google, either to register as a new user, or to associate your social media profile with your current account. In this case, your login data, as well as your email address (provided you agree to this (will be imported from your social media account. By using this login option, the social network in question may send us some additional information from your public profile, such as: name, sex, approximate age or profile image, 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 keep in mind that if you opt to connect via a social network, this may involve providing certain information about your activity on that social network. In any case, we recommend that you verify your privacy settings and read the privacy policies of your social networks, so that you may understand how this data is processed by social networks.

The processing of your personal data is necessary to sign the terms that regulate the use of the site. In other words, for your registration as a site user, we must process your personal data, otherwise we would be unable to manage your registration (the legal basis being entering into or performing a contract, including previous steps to enter into an agreement).
Access to materials Identification Data

Contact Data

 

We will use your personal data to grant you access to the materials you wish to download on the Platform, such as guides, lists, suggestions, evaluations, or other materials that we freely offer. Entering and performing the contract (offering the services)
Entering into an electronic contract with us and contract performance Identification Data

Contact Data

Financial Data

Usage data

Trading data

Profile data

 

For the operations described here, we will use your personal data to:

● we deliver the service you have contracted

●  we will contact you about updates or information regarding functionalities or contracted services, including sending you surveys about the quality of the services delivered.

●  manage payments for purchased services, which occurs via an external service, such that VoxiKids/VoxiClinic has access to a limited data set. Your credit card information is not saved on any of the company’s servers.

● activate the necessary mechanisms to prevent any potential fraud against you and against us during the purchase process. If we believe that the transaction might be fraudulent, this data processing could lead to blocking the transaction in question.

● billing – we offer you, in electronic format the bills and receipts corresponding to the transactions made.

● offer you various other services that are to be implemented.

Entering and performing the contract (offering the services). It is necessary to process your personal data in order to perform the electronic contract for the services you have purchased from us.

We also have a legitimate interest to carry out the necessary check-ups in order to detect and prevent potential fraud attempts when you wish to make a purchase.

Inquiries or requests made through Client Service / Support Identification Data

Contact Data

Financial Data

Trading data

Profile Data

 

We only process the personal data that is strictly needed to manage or solve your inquiries.

We have a legitimate interest to answer to any inquiries or questions that you send us via any of the existing means of contact. Here, we include any private messages that you send us asking about the Platform, our campaigns or when you simply wish to obtain more information.

We understand that processing this data is also in your best interest, as it allows us to adequately help you and to find a solution to your inquiries. When you contact us especially for incident management or to request clarification about a purchased service, the processing is necessary to perform the contract under good conditions.

When you contact us about resolving incidents regarding an order or to log in a complaint, the processing of your personal data occurs so that we can fulfill our legal obligations in this regard.

Entering and performing the contract (offering the services)

Legitimate interest.

 

To manage the relationship, we have with you Identification Data

Contact Data

Profile Data

 

This data processing involves:

(a) that we notify you about any changes to our terms & conditions and our data processing policy

(b) to ask you to leave us a review or to participate in a survey

 

We will process your data to have up-to-date information and to understand how our users use our services or how we could improve them.

Entering and performing the contract (offering the services)

Legitimate interest to improve the services offered.

Marketing Identification Data

Contact Data

Trading data

Profile Data

Marketing & Communication Data

 

We will process your personal data for this purpose in the following situations:

● if you sign up to our newsletter, we will process your personal data to manage your communication preferences, including sending you customized information about our services via different means (such as email or SMS). We will be able to send you this information via push notifications if you have them enabled on your mobile device or browser.

Please keep in mind that this data processing involves analyzing your user or client profile to then create profiles that help us determine what your preferences are at any given moment, based on your navigation history and the choices you’ve made, and, as such, which services are best suited for you at this time. For example, based on your shopping and navigation history, we can make suggestions regarding the features that we think would be useful or interesting.

You can unsubscribe from our newsletter freely at any time, by following the unsubscribe instructions found in every e-mail, or by sending us a written request at the e-mail address suport@voxikids.com

● For promotional actions (such as holding various contests). By participating in any promotional action, you authorize us to process the data provided for every such action, and which we can communicate through various means, such as social media or even our site. With every promotional action you participate in, you will be able to access the terms & conditions section, in which you can find more detailed information about data processing in that specific context.

 

We process your personal data for marketing purposes based on your given consent, for example when you agree to receive personalized information via different means, when you authorize push notifications on your mobile device or on your browser.

We also have a legitimate interest to show you personalized information (such as offers for services similar to the ones you have already purchased, or new added features, which could be of interest to you) because we understand that processing this data is also to your advantage, as it enables us to improve your experience as a user and therefore to access the information you need based on your preferences.

Impro-

ving

Identification Data

Contact Data

Trading data

Profile Data

Marketing & Communication Data

Technical data

 

If you access our site, we hereby inform you that we shall process your navigation data for analytical and statistical purposes, meaning to better understand how our users interact with our site, so that we can then improve it.

Sometimes we also carry our actions and quality surveys which concern learning what the level of customer and user satisfaction is, as well as what the areas of improvement are for the services provided.

 

We believe that we have a legitimate interest when we analyze the manner in which our site is used, as well as the degree of customer satisfaction.

The processing of this data is also to your advantage, as its purpose is to improve user experience and to offer a superior quality service.

 

To deliver relevant content and personalized advertising and to measure and understand the efficiency of the advertisements we show you Identification Data

Contact Data

Usage data

Profile Data

Marketing & Communication Data

Technical data

 

This data is needed to understand how our users and clients use our services, to develop new services, to grow our business and to adapt our marketing strategy.    Consent
Using data analysis to improve the Platform, services, client depart-

ment and user experience.

Technical data

Usage data

This data is necessary to understand the categories of customers we have for our services, to maintain our platforms with up to date 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 could be of interest to you Identification Data

Contact Data

Usage data

Profile Data

Marketing & Communication Data

Technical data

 

This data is necessary to grow our business and to adapt our marketing strategy.   Legitimate interest
When you react to the content presented to you via social networks Name, image, any publicly accessible information on your social media profile, or explicitly communicated by you We are present on Facebook, LinkedIn, Instagram, YouTube, and Twitter. Any time you interact with us via our profiles 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 vokids.com and voxikids-clinic.com platforms, supplied by social networks, implies a data exchange between the app and the respective social network, for which the platform owner is responsible alongside the respective social network.

We process your personal data in our legitimate interest to be able to answer any inquiry, complaint, or recommendation that you send us, to improve the services and experience of our clients and to keep you up to date with any news we publish, and which could be of interest to you

In short, we will store your personal data for as long as it necessary to fulfill the goals they were collected for, including for the purposes of fulfilling any legal, accounting or reporting obligations.

To determine the adequate storage period for personal data, we looked at the value, nature and sensitivity of the personal data in question, the potential risk of damages caused by unauthorized use or by disclosing your personal data, the purposes for which we process your personal data and whether we can fulfill these purposes through different means, as well as any applicable legal obligations.

Purposes of processing your personal data Data storage period
Registering as a User ● We will store the data registered to your account until you decide to close your account. We will, however, delete this data (including your account) if more than 5 years have passed since your last log-in.

● The data are recorded in financial and accounting documents (such as bills, payments made by card, payments on delivery etc.) will be archived for 5 years, starting from the end of the financial year during which they were recorded, in accordance with the standards of accounting law no. 82/1991 and of Order 2634/2015.

Access to materials You will have access to VoxiKids/VoxiClinic materials for the full period of time that your account is active
Entering into an electronic contract with us and contract performance ● The data are recorded in financial and accounting documents (such as bills, payments made by card, payments on delivery etc.) will be archived for 5 years, starting from the end of the financial year during which they were recorded, in accordance with the standards of accounting law no. 82/1991 and of Order 2634/2015.

● The audio and video recordings of the therapy sessions will be stored for a period of 12 months.

Inquiries or requests made through Client Service / Support We will not keep in our database any communications older than 1 year from the date of the last interaction.
To manage the relationship, we have with you We will process the data that you have transmitted to us for a period of 12 months from the moment of reception.
Marketing ● In the event that you are subscribed to our newsletter, data processing will continue until you request to be unsubscribed.

● In the event that data processing is carried out in our legitimate interest when you have already become our client, we will process your data throughout the contract performance period and we will continue to do so for 3 years from the termination of the contract.

Improving the services offered We will process your data for 12 months from the moment of collection.
To deliver relevant content and personalized advertising and to measure and understand the efficiency of the advertisements we show you We will process your data for 12 months from the moment you consented to this processing of personal data.
Using data analysis to improve the Platform, services, client department, and user experience. We will process your data throughout the contract performance period and we will continue to do so for 3 years from the termination of the contract.
Suggestions and recommendations about services that could be of interest to you We will process the data that you have transmitted to us for a period of 12 months from the moment of reception.
When you react to the content presented to you via social networks Data transmitted through social media networks will be stored according to these networks’ own policies.

In certain circumstances, we can anonymize your personal data (such that they can no longer be associated with you) for scientific, historical, or statistical research purposes, in which case we can use this information for an unlimited period of time without notifying you in advance.

7.   7. The data we collect from you via our mobile application

Mobile app VoxiKids, through which users have access to over 200 interactive speech therapy exercises, especially designed for children with language deficiencies or speech impairments and problems communicating, is available for both Android and iOS.

The personal data we process are ones provided the parent or legal guardian via registration in the app, and data derived from using the mobile app.

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

Category

Data included

Identification data  Username, e-mail, the language you wish to use
Contact data E-mail address
Financial data Information regarding payments or about cards / bank accounts is kept and managed by Google Play or the App Store. VoxiKids is privy to information about purchases made.
Technical data IP address, login data, the type of browser used and its version, settings regarding location and time zone, operating system
Profile data Username, password, orders made by you, your interests, and preferences, your characteristics regarding language, feedback offered, your answers to surveys
Usage and interaction data Information about how you use the app, the child’s evolution.
Marketing and communication data Your preferences on receiving marketing materials from us and other third parties, as well as your preferred communication methods

If you are a parent or legal guardian of a child under the age of 16 we will require your explicit consent to process the child’s personal data. As such, alongside the information mentioned above, you will have to provide us the following data about your child:

  1. first name, last name;
  2. age;
  3. your explicit consent regarding the processing of personal data belonging to the child;
  4. an affidavit regarding your status as legal representative or guardian.

Please bear in mind that this data is necessary so that we may offer the best possible experience to your child, and so that we may customize their experience in our mobile app. Our aim is to turn speech therapy into play, and the play level needs to be adapted to the requirements, needs and abilities of each child.

8.  How we collect your personal data

We can collect your personal data in different ways, such as:

  1. Direct interaction
  2. Indirect interaction
  3. Automated technologies or interactions
  4. Third parties or information that is publicly available
  5. Information that we build internally, as you interact VoxiKids, through the mobile application.
Source Data
Direct interaction You can provide us directly with data about you (such as Identification Data, contact information)) by filling in the existing fields on our site or via email, telephone, or any other method that we provide. This includes personal data you supply to us when:

●      you wish to download one or several materials that we feature on the Platform

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

● you create an account in the mobile app/ or/and in the platform

●      you subscribe to our services or our publications

●      Activitatea ta din aplicația mobilă

●      your request for promotional & marketing materials

●     you enter a competition or promotion, you complete a survey etc.

●      you send us feedback

Automated technologies or interactions As you use our app, we will be able to collect data automatically technical data about the equipment you use, the manner in which you navigate our app, and other behavioral patterns. We will collect this information via the use of cookies, server logs, and other similar technologies.

Please read our cookies policy for more details.

9.   Why we collect your personal data  

We mainly collect your personal data (or the personal data of the minor) so that we can offer you direct access to the functionalities of the mobile app.

However, we also use your personal data (or the personal data of the minor) in order to improve the App, to send you suggestions about features that may help you, to see what you’d like and how we can offer you the best service.

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

  • You have given us your consent regarding the processing of personal data

Keep in mind that you may withdraw consent at any time, by following the instructions unsubscribeunsubscribefound in every email, or by sending us a written request to the email address contact@voxikids.com

  • The processing of personal data is necessary to enter into a contract or for the performance of a contract between you and us
  • The processing of personal data is necessary for the purpose of our - or a third party’s, legitimate interests

We have included below, in a table format, a description of the ways in which we plan to use your personal data, as well as the legal grounds on which we act. Moreover, we have identified our legitimate interests wherever they applied.

Please bear in mind that it is possible to process your personal data based on several legal grounds, dependent on the purposes for which we use this data. Please contact us at the email address dpo@voxikids.com if you wish to learn more details about the legal grounds we invoke when we process your personal data, wherever there exists more than a single legal ground as shown in the table below:

When you use the mobile app - and subject to your prior consent, VoxiKids may send you 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 ground
Registering as a User Identification Data

Contact Data

In case you decide to register as a user in our App, we must process your data in order to identify you as a user and offer your access to different functionalities and services available for you as a registered user. In certain situations, creating an account will be an automatic process, in order to grant you access to the services that you have purchased from us.

At any time, you can cancel your user account registered either from your account on our site, from your Client Account, or at the email address contact@voxikids.com.

The processing of your personal data is necessary to sign the terms that regulate the use of the App. In other words, for your registration as an App user, we must process your personal data, otherwise we would be unable to manage your registration (the legal basis being entering into or performing a contract, including previous steps to enter into an agreement).
Access to materials Identification Data

Contact Data

 

We will use your personal data to grant you access to the materials you wish to download from the App, such as the child’s progress report, registered as the child completed the exercises offered in the app. Entering and performing the contract (offering the services)
Entering into an electronic contract with us and contract performance Identification Data

Contact Data

Financial Data

Usage data

Trading data

Profile data

 

For the operations described here, we will use your personal data to:

● deliver the service you have contracted

● contact you about updates or information regarding functionalities or contracted services, including sending you surveys about the quality of the services delivered.

● manage payments for purchased services, which occurs via an external service, such that VoxiKids has access to a limited data set. Your credit card information is not saved on any of the company’s servers.

● activate the necessary mechanisms to prevent any potential fraud against you and against us during the purchase process. If we believe that the transaction might be fraudulent, this data processing could lead to blocking the transaction in question.

● bill you – to offer you, in electronic/physical format, the bills and receipts corresponding to the transactions made.

● offer you various other services that are to be implemented.

Entering and performing the contract (offering the services). It is necessary to process your personal data in order to perform the electronic contract for the services you have purchased from us.

We also have a legitimate interest to carry out the necessary check-ups in order to detect and prevent potential fraud attempts when you wish to make a purchase.

Inquiries or requests made through Client Service / Support Identification Data

Contact Data

Financial Data

Trading data

Profile Data

 

We only process the personal data that is strictly needed to manage or solve your inquiries.

We have a legitimate interest to answer to any inquiries or questions that you send us via any of the existing means of contact. Here, we include any private messages that you send us asking about the App, our campaigns or when you simply wish to obtain more information.

We understand that processing this data is also in your best interest, as it allows us to adequately help you and to find a solution to your inquiries. When you contact us especially for incident management or to request clarification about a purchased service, the processing is necessary to perform the contract under good conditions.

When you contact us about resolving incidents regarding an order or to log in a complaint, the processing of your personal data occurs so that we can fulfill our legal obligations in this regard.

Entering and performing the contract (offering the services)

Legitimate interest.

 

To manage the relationship, we have with you Identification Data

Contact Data

Profile Data

 

This data processing involves:

(a) that we notify you about any changes to our terms & conditions and our data processing policy

(b) to ask you to leave us a review or to participate in a survey

 

We will process your data to have up-to-date information and to understand how our users use our services or how we could improve them.

Entering and performing the contract (offering the services)

Legitimate interest to improve the services offered.

Marketing Identification Data

Contact Data

Trading data

Profile Data

Marketing & Communication Data

 

We will process your personal data for this purpose in the following situations:

● if you sign up to our newsletter, we will process your personal data to manage your communication preferences, including sending you customized information about our services via different means (such as email or SMS). We will be able to send you this information via push notifications if you have them enabled on your mobile device or browser.

Please keep in mind that this data processing involves analyzing your user or client profile to then create profiles that help us determine what your preferences are at any given moment, based on your navigation history and the choices you’ve made, and, as such, which services are best suited for you at this time. For example, based on your shopping and navigation history, we can make suggestions regarding the features that we think would be useful or interesting.

You can unsubscribe from our newsletter freely at any time, by following the unsubscribe instructions found in every e-mail, or by sending us a written request at the e-mail address contact@voxikids.com.

● for promotional actions (such as holding various contests). By participating in any promotional action, you authorize us to process the data provided for every such action, and which we can communicate through various means, such as social media or even our site. With every promotional action you participate in, you will be able to access the terms & conditions section, in which you can find more detailed information about data processing in that specific context.

We process your personal data for marketing purposes based on your given consent, for example when you agree to receive personalized information via different means, when you authorize push notifications on your mobile device or on your browser.

We also have a legitimate interest to show you personalized information (such as offers for services similar to the ones you have already purchased, or new added features, which could be of interest to you) because we understand that processing this data is also to your advantage, as it enables us to improve your experience as a user and therefore to access the information you need based on your preferences.

Impro-

ving

Identification Data

Contact Data

Trading data

Profile Data

Technical data

 

If you use our mobile app, we hereby inform you that we shall process your navigation data for analytical and statistical purposes, meaning to better understand how our users interact with our app, so that we can then improve it.

Sometimes we also carry our actions and quality surveys which concern learning what the level of customer and user satisfaction is, as well as what the areas of improvement are for the services provided.

 

We believe that we have a legitimate interest when we analyze the manner in which our app is used, as well as the degree of customer satisfaction.

The processing of this data is also to your advantage, as its purpose is to improve user experience and to offer a superior quality service.

To deliver relevant content and personalized advertising and to measure and understand the efficiency of the advertisements we show you Identification Data

Contact Data

Usage data

Profile Data

Marketing & Communication Data

Technical data

 

This data is needed to understand how our users and clients use our services, to develop new services, to grow our business and to adapt our marketing strategy. Consent
Using data analysis to improve the Platform, services, client depart-

ment and user experience.

Technical data

Usage data

This data is necessary to understand the categories of customers we have for our services, to keep the app 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 could be of interest to you Identification Data

Contact Data

Usage data

Profile Data

Marketing & Communication Data

Technical data

 

This data is necessary to grow our business and to adapt our marketing strategy. Legitimate interest
When you react to the content presented to you via social networks Name, image, any publicly accessible information on your social media profile, or explicitly communicated by you We are present on Facebook, LinkedIn, Instagram, YouTube, and Twitter. Any time you interact with us via our profiles 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 in the VoxiKids App, supplied by social networks, implies a data exchange between the app and the respective social network, for which the platform owner is responsible alongside the respective social network.

We process your personal data in our legitimate interest to be able to answer any inquiry, complaint, or recommendation that you send us, to improve the services and experience of our clients and to keep you up to date with any news we publish, and which could be of interest to you

In short, we will store your personal data for as long as it necessary to fulfill the goals they were collected for, including for the purposes of fulfilling any legal, accounting or reporting obligations.

To determine the adequate storage period for personal data, we looked at the value, nature and sensitivity of the personal data in question, the potential risk of damages caused by unauthorized use or by disclosing your personal data, the purposes for which we process your personal data and whether we can fulfill these purposes through different means, as well as any applicable legal obligations.

Purposes of processing your personal data Data storage period
Registering as a User ● We will store the data registered to your account until you decide to close your account. We will, however, delete this data (including your account) if more than 5 years have passed since your last log-in.

● The data recorded in financial and accounting documents (such as bills, payments made by card, payments on delivery etc.) will be archived for 5 years, starting from the end of the financial year during which they were recorded, in accordance with the standards of accounting law no. 82/1991 and of Order 2634/2015.

Access to materials You will have access to VoxiKids/VoxiClinic materials for the full period of time that your account is active
Entering into an electronic contract with us and contract performance ● The data recorded in financial and accounting documents (such as bills, payments made by card, payments on delivery etc.) will be archived for 5 years, starting from the end of the financial year during which they were recorded, in accordance with the standards of accounting law no. 82/1991 and of Order 2634/2015.
Inquiries or requests made through Client Service / Support We will not keep in our database any communications older than 1 year from the date of the last interaction.
To manage the relationship, we have with you We will process the data that you have transmitted to us for a period of 12 months from the moment of reception.
Marketing ● In the event that you are subscribed to our newsletter, data processing will continue until you request to be unsubscribed.

● In the event that data processing is carried out in our legitimate interest when you have already become our client, we will process your data throughout the contract performance period and we will continue to do so for 3 years from the termination of the contract.

Improving the services offered We will process your data for 12 months from the moment of collection.
To deliver relevant content and personalized advertising and to measure and understand the efficiency of the advertisements we show you We will process your data for 12 months from the moment you consented to this processing of personal data.
Using data analysis to improve the Platform, services, client department and user experience. We will process your data throughout the contract performance period and we will continue to do so for 3 years from the termination of the contract.
Suggestions and recommendations about services that could be of interest to you We will process the data that you have transmitted to us for a period of 12 months from the moment of reception.
When you react to the content presented to you via social networks Data transmitted through social media networks will be stored according to these networks’ own policies.

In certain circumstances, we can anonymize your personal data (such that they can no longer be associated with you) for scientific, historical, or statistical research purposes, in which case we can use this information for an unlimited period of time without notifying you in advance.

11. Disclosing your personal data

We will disclose your personal data only to the extent that this is strictly necessary to achieve the aim pursued. We have taken all necessary precautions to ensure that out external service providers that have access to your data, have implemented physical, electronic and management security measures to protect your data.

For example, we could deliver your data to other companies, such as IT service suppliers, media agencies, advertising agencies, accounting services and human resources, integrated solutions suppliers, legal services and other third parties to whom we are contractually tied. These third parties are very carefully selected so that your data are processed only for the purposes we have indicated.

Another example is sending personal data to the e-mail provider that we use to send you messages.

We could also share your data to other business partners as part of a common effort to provide a product or service.

We can send your data to other parties whilst having your consent or per your instructions.

We will also be able to supply your personal data to the prosecutor’s office, the police, courts of law and other state authorities, subject to and in accordance with legal provisions, and as a consequence of clearly 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 your data to states outside of EEA, we will ensure, in all cases, that the transfers are legitimate and are based on your explicit consent or another legal ground.

11.1.  Who we share your data with

In some cases, other third parties will have access to your personal data, such as:

  1. IT service providers that our company works with (offering hosting and data storage – Amazon) or suppliers to whom we outsource certain technical support services for our site, or suppliers for customer relationship management systems.
  2. Payment processors BlueSnap and ChargeBee
  3. Third parties that place cookies: google.com hubspot.com, facebook.com
  4. Online Platforms: Facebook, Twitter, LinkedIn, Instagram, YouTube
  5. Regulatory authorities and other state authorities, if requested in accordance with legal or statutory provisions

11.2. Disclosing your personal data

Personal data transfer towards a third-party state can only occur if the state in question can ensure an adequate protection level.

The transfer towards a state whose legislation does not include a level of protection that is at least equal to the General Data Protection Regulation, is possible only if there are enough guarantees regarding the protection of fundamental rights of the individuals concerned. These guarantees will be established by us via contracts signed with suppliers/service providers who will be the recipients of your personal data.

Some of our service providers may be located outside of the European Economic Area (EEA), such that their processing of your data involves a data transfer outside of the EEA.), astfel încât procesarea din partea lor a datelor tale personale va implica un transfer de date în afara SEE.

Every time we transfer your personal data outside of SSE, we will ensure that there exists a level of protection similar to GDPR via one of these safeguarding mechanisms:

  1. 1. We will transfer your personal data towards countries that have been proven by the European Commission to deliver an adequate safety level for personal data. For more details, click here.
  2. când apelăm la anumiți furnizori de servicii, vom putea folosi anumite modele de contracte furnizate și aprobate de Comisia Europeană care oferă datelor personale aceeași protecție pe care o au în Europa. Pentru mai multe detalii, dați click here.
  3. When we rely on suppliers from the USA, we will be able to transfer the data if they offer similar data protection conditions for data shared between the EU and USA. For more details, click here. here.

Please contact us at the email address dpo@voxikids.com if you want to learn more information about the specific mechanism we use when we transfer data to persons outside of the EEA.

11.3. Data securityr

We understand how important personal data security is and we take the necessary measures to protect our clients and other people, whose personal data we process, from any unauthorized access to personal data, as well as from any modification, disclosure or unauthorized destruction of the data we process in our day-to-day activity.

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

Dedicated policies. We adopt and revise constantly our practices and internal data security policies (including physical and electronic security measures), to protect our systems against unauthorized access or any possible threats to our security. These policies are subject to constant verifications, to ensure that we respect legal provisions and that our systems are functioning adequately.

Data Minimization. We ensure that the personal data that we process are limited to only the necessary, adequate and relevant ones for the purposes declared in this Policy.

Restricting access to data.. We try to restrict access to the personal data we process to the minimum necessary: employees, contributors, and other individuals who need to access these data in order to process and fulfill a service. Our partners and collaborators are subject to strict privacy obligations (either by contract, or legal provisions).

Specific technical measures.. We use technologies that ensure the security of our clients, while always trying to implement optimal data security solutions. We also make periodic backups of the data, so that we may recover them in case any incident arises, and we have implemented periodic audit procedures regarding the security of the equipment used. However, no website, no app and no internet connection are completely secure and untouchable (see NASA).

Ensuring the accuracy of your data. Sometimes it may be possible that we ask you to confirm how accurate and up to date your data is, so that we may ensure the data reflects reality.

Staff training We train and test our employees and contributors constantly, regarding current legislation and best practices with respect to the processing of personal data.

Data anonymization.. Wherever we can, we try as much as possible to anonymize / pseudomyze the personal data we process, such that we ca no longer identify the persons they refer to.

However, although we are constantly striving to ensure the security of the data you entrust us with, it is possible that we will encounter less fortunate events and thus have security breaches. In these situations, we will strictly follow the procedure for reporting and following up security incidents and we will take all necessary measures to restore the situation to normal in the shortest possible time.

12.1. User content.

ser content is represented by the “in session” information that you offer us directly by using the services offered on the Platform or mobile App, such as audio and video recordings of speech therapy sessions, files, chat logs and transcripts, the child’s evolution and any other information uploaded during the use of the Services. VoxiClinic and/or VoxiKids uses client content only as it pertains to delivering the services on the Platform/mobile App – we do not monitor, sell or use client content for any other purposes.

Please bear in mind that no security measure is perfect and impenetrable and that we are not responsible for circumventing any security measures contained in the Platform / mobile App. You should be cautious regarding the access you offer to others when you use the Platform / mobile App and the information you choose to share when you use the Platform.

VoxiClinic and/or VoxiKids does NOT sell or rent your personal information (or that of your child) toward any third party for any purpose – including for any advertising or marketing purposes.

12.2. What we cannot do without your personal data

When we ask you to complete your personal data to offer you access to certain functionalities or services within the Platform / mobile App, we will mark certain fields as mandatory, because this is information, we require to be able to deliver the service or to offer you access to that specific functionality.

Please bear in mind that, if you decide not to provide this information to us, it is possible that you will be unable to finalize your registration as a user or that you will be unable to benefit from these services or functionalities. In such a scenario, we could find ourselves having to limit your access to a certain service that you wish to use. We will, however, notify you at the time this occurs.

For exampleif you will wish to benefit from our services and to be put in touch with a speech therapist, we will have to take video footage of you so that the speech therapist may correct the speech pattern of the child and help them improve their hearing and pronunciation by checking stimuli and the accuracy of the exercises, while also following their progress over time. If you do not wish to do this, we will be unable to offer this service for which you have registered on the Platform.

Furthermore, if we are unable to verify your identity at the time that you send us an inquiry via the contact address, the contact form found in the Platform / mobile App, or any of the other available means of contact, we reserve the right to not respond to that specific inquiry.

12.3.  Reviews

We post testimonials on our Service, which may contain personal information, such as name, photo and / or video of the person that offers us such a review. We obtain each person’s prior consent to ensure that we have permission to post this content publicly. To request deletion of your personal information from our testimonials, please contact us at contact@voxikids.com.

12.4. Information collected automatically

VoxiKids/VoxiClinic receives and records automatically information from our server logs and your browser, including your IP address, information about company cookies and the page you have accessed. We also record the details of your activity on Services, as well as the number and frequency of visitors to our site and any of its components. The company uses cookies to ensure that all users are enjoying the best experience on the site, personalised according to their navigation needs.

In some circumstances, you benefit from certain rights regarding your personal data in accordance with legal provisions. In order to exercise these rights, please contact us at the email address dpo@voxikids.com.

In brief:, according to current legislation, you have the following rights:

  1. The right to withdraw consent– when the processing of your data was based on your consent and there is no other ground for processing. Please keep in mind that withdrawing consent does not affect the data processing that occurred until that point.
  2. The right to be informed about the processing of your data which is fulfilled via this Privacy Policy.
  3. The right to data accessyou have the right to receive a copy of the data that we process about you. Additional copies will be rendered against payment.
  4. The right to rectify inaccurate or incomplete datayou have the right to request that we modify / complete the data that we process about you when you consider that we must do so..
  5. The right to be forgotten (data deletion”)this right enables you to ask that, in certain circumstances when we no longer have any legal grounds to process your data, that we delete your data and no longer process them in the future.
  6. The right to restrict processingwhen we process your personal data to fulfill tasks of public interest or our legitimate interests (or those of a third party) and there exists some information about your particular situation which may make you want to object to the processing of this data. You also have the right to ask that we restrict processing when we process your data for the purposes of direct marketing.
  7. The right to transmit the data that we have about you toward another operatorwhen your data is in a format that enables us to transfer them towards a different operator in an easily accessible, automated format that can be read by a machine.
  8. The right to object to the processing of datawhen we process your data to fulfill a public interest, or when we are pursuing our legitimate interests or those of a third party.
  9. The right to not be subject to a decision based exclusively on automatic processing, including profile creation
  10. The right to go to court
  11. The right to lodge a complaint with a Supervisory Authority, whose contact information you can find below:
Name Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal
Address B-dul G-ral. Gheorghe Magheru nr. 28-30, Sector 1, cod poștal 010336, București, România
Phone +40.318.059.211 sau +40.318.059.212
E-mail anspdcp@dataprotection.ro

Please keep in mind that:

  1. You can withdraw consent for direct marketing at any moment by following the unsubscribing instructions found in every e-mail / message or any other electronic message.
  2. If you want to exercise your rights, you can do so by sending a signed and dated written request to the e-mail address: dpo@voxikids.com.
  3. The rights listed above are not absoluteThere are exceptions, which is why every request we receive will be analyzed to determine whether it is founded or not. To the extent that the request is founded, we will facilitate the exercise of your rights. If the request is unfounded, we will dismiss it, however we will inform you about the reasons for its dismissal and of your rights to lodge a complaint with the Supervisory Authority or to go to court.
  4. Response time: We will try to respond to your inquiry within 30 days. However, this time frame may be extended depending on different aspects, such as the complexity of your request, the volume of requests we have received or the impossibility of identifying you in good time.
  5. What we may need from you. To be able to respond to your requests through which you are exercising your rights, we may need additional information from you to confirm your identity. If, although we are making every effort, we are unable to identify you and you do not supply the additional information we require in order to identify you, we are not obligated to pursue the request.
  6. TaxYou will not be required to pay any tax to exercise your data access right (or any other right). However, you may be required to pay a certain reasonable tax if your request is unfounded, excessive, or repetitive. Alternatively, we will be able to decline pursuing your inquiry in these circumstances.

We will update this privacy policy any time there will be any changes to the way we process data, and we will notify you via the Platform or via an email about the latest version. All updates and changes to the present Note are applicable immediately following the notification, which we will display on the site and/or in an e-mail. Even if you do not receive a notification, we encourage you to periodically access and read this Policy, to stay up to date with the latest version.

This Privacy Policy was updated on December 22nd, 2020.