Privacy Policy

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Owner and Data Controller

http://www.speako-app.com
info@speako-app.com

Types of Data collected

Among the types of Personal Data that this Application collects, there are:

Microphone permission; Usage Data; User name; password; unique device identifiers (Android ID, Device platform etc.).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy.

Personal Data may be freely provided by the User, parental guardian or Speech therapist.
In case of Usage Data, it is collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. No Cookies or other tracking tools are collected by this app.

What we collect in our Game

For every device a Game is installed on, or the end device, we collect the following Information:

Device Information:

Device identifier (a unique number that lets us tell the devices apart).
Device Type
Device platform (IOS/Android)

User Information:

Full name, age, gender, city of residence.
Phone number (for users under the age of 13 years old the parental guardian phone number is used.)
Email address (in some cases, for Speech Therapists).

Session information:

Game version (specific Game(s) and the versions thereof);
Length of plat session.
Usage statistics (score, completion percent, etc)
Usage logs
User authentication details.

Children Privacy Policy

The service is designed for users aged 6 years old and above. We only collect information about children under the age of 13 with parental consent (in a process through the Speech Therapist). If we are notified about non-consensual data collection of a user under the age of 13, we will operate to either gain consent of prior and future data collection from a parental guardian, or proceed to delete the collected nonconsensual data.

We will act accordingly to the privacy policies noted in EU General Data Protection Regulation (GDPR) & Children's Online Privacy Protection Rule ("COPPA"). For more information visit their respective sites.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, Speech and Language Pathologies [Speech therapists] ).

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which the Owner is subject;
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users), as well as the following: Device permissions for Personal Data access, Analytics, Registration and authentication provided directly by this Application.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

How we use this information collected in our Games
We Collect this information in order to provide the speech therapists some basic tools to monitor patient’s activity. In addition, we use this data to validate the success of the service. We do not share or sell any of this information to other persons or companies.

Device permissions for Personal Data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.

The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If user grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Microphone permission

Allows access to the microphone's audio from the user's device.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics
The services contained in this section enable the Owner to monitor and analyze application traffic and can be used to keep track of User behavior.
Amazon Web Services (AWS) S3 & Athena
AWS Athena is a query service provided by Amazon Web Services (AWS). AWS thena enables the analysis of data stored in Amazon S3 using standard SQL queries. AWS Athena utilizes the data collected to track and examine the usage of this Application, allowing for the preparation of reports on its activities and sharing them with other AWS services. Personal Data processed: Usage Data. This data is utilized for fine-tuning and optimizing the speech and language practice using the device by the user. Additionally, this data is uploaded and statistically analyzed by the SLP (Speech and Language Practitioner) for progress monitoring and treatment advancement, leveraging the capabilities of AWS Athena.

Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the user's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Microphone permission.

Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
To find out more, please refer to the description of each service.

Registration and authentication provided directly by this Application
Registration is allowed only from within the Speech Therapist’s Dashboard in the application. By authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected for identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing. This Data can be provided by the SLP in charge of the treatment.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Data exposed for a Public Interest is an aggregated Data for statistical usage only. Although Personal Data is never exposed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs), use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the device and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Small sets of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: June 24, 2023