This privacy policy (the Privacy Policy) governs the manner LetzMath S.à r.l., a private limited liability company (société à responsabilité limitée) existing under the laws of Grand Duchy of Luxembourg, with its registered office at 6a, Avenue des Hauts-Fourneaux, L-4362 Esch-sur-Alzette, Grand Duchy of Luxembourg and registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés, Luxembourg) under the number R.C.S. Luxembourg B 247246 (LetzMath, We or Us) collects, uses, maintains, stores and discloses, as applicable, information concerning its clients and/or users and/or other natural persons that have requested information (the Users or a User, as applicable) of and concerning its website, mobiles applications or any other services provided by LetzMath (the Services).

Personal information is collected and stored with your consent and will be processed in accordance with the law of 1 August 2018 on the protection of individuals with regard to the processing of personal data in criminal matters and in matters of national security, and the European Regulation no. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data.

Personal information will be collected on the basis of:

• The Users’ consent, which they can withdraw at any time;

• legal obligations applicable to Us including to cooperate with a law enforcement body or regulatory authorities, to exercise or defend our legal rights or to disclose it when necessary, as evidence in litigation in which We are involved;

• our obligations under contracts concluded with the Users and for the performance of our Services;

• the need for protection of vital interests of Users and/or third parties.

LetzMath commits to adopt appropriate data collection, storage and processing practices and security measures to ensure protection against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information.

LetzMath further commits not to sell, trade, or otherwise transfer to third parties collected Users’ personal identification information. The Users however accepts that their personal identification information collected by LetzMath be transferred to website hosting and editing partners and other sub-contractors who assist LetzMath in providing its Services subject that these sub-contractors undertake to process the information only according to the applicable law regarding the protection of personal identification information. LetzMath may also release User’s personal identification information when considered necessary to, notably, comply with law, enforce its websites’ general terms of use or protect its or third parties’ rights, property, or safety.

LetzMath acts a data controller and appointed a data protection officer who can be contacted by using the following information:

LetzMath S.à r.l.

6a, Avenue des Hauts-Fourneaux

L-4362 Esch-sur-Alzette

Grand Duchy of Luxembourg

Email: [email protected]

Personal information Users voluntary disclose

LetzMath collects personal information that Users voluntarily provide to LetzMath when they register on the Services, express an interest in obtaining information about Us or our products and/or Services, when they participate in activities on the Services, or otherwise when they contact Us.

The personal information that We collect depends on the context of the Users’ interactions with Us and the Services, the choices they make, and the products and features they use. The personal information We collect may include Users’ names, email addresses, usernames, passwords, contact or authentication data billing addresses, debit/credit card numbers, age and location.

When necessary, with the Users’ consent or as otherwise permitted by applicable law, LetzMath will process sensitive information including health, financial, biometric and student data.

LetzMath may collect data necessary to process Users’ payment they make purchases, such as payment instrument number and the security code associated with the payment instrument. All payment data is stored by Stripe, Google, and Apple. Each of them provides specific privacy notice available at the following links: https://stripe.com/en-gb-lu/privacy, https://policies.google.com/privacy?hl=en-US, https://developer.apple.com/app-store/app-privacy-details/.

LetzMath may provide the Users with the option to register using their existing social media account details, like their Facebook, Twitter, or other social media account. If Users choose to register in this way, We will collect the information described in the section called “Social Logins”.

If Users use our application, We also may collect the following information if they choose to provide Us with access or permission, such information being primarily needed to maintain the security and operation of our application, for troubleshooting, and for our internal analytics and reporting purposes:

• Track location-based information from Users’ mobile device, either continuously or while Users are using our mobile application, to provide certain location-based Services. If Users wish to change our access or permissions, they may do so in their device’s settings.
• We may request access or permission to certain features from Users’ mobile device, including their mobile device’s camera, and other features. If they wish to change our access or permissions, they may do so in their device’s settings.
• We automatically collect device information (such as mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If Users are using our application, We may also collect information about the phone network associated with their mobile device, mobile device’s operating system or platform, the type of mobile device, mobile device’s unique device ID, and information about the features of our application Users accessed.
• We may request to send push notifications regarding Users’ account or certain features of the application. If they wish to opt out from receiving these types of communications, they may turn them off in their device’s settings.

All personal information provided by Users must be true, complete, and accurate. Users must notify Us of any changes to such personal information.

Information automatically collected

We automatically collect certain information primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes when a User visits, uses, or navigates our Services. This information does not reveal the User’s specific identity (e.g., name or contact information) but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when a User uses our Services, and other technical information.

We also collect information through cookies and similar technologies.

The information We collect includes:

• log and usage data, being service-related, diagnostic, usage, and performance information our servers automatically collect when Users access or use our Services and which We record in log files. Depending on how Users interact with Us, this log data may include IP address, device information, browser type, and settings and information about the activity of the Users in the Services (such as the date/time stamps associated with the Users’ usage, pages and files viewed, searches, and other actions the Users take such as which features the Users use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• device data such as information about the Users’ computer, phone, tablet, or other device used to access the Services. Depending on the device used, this device data may include information such as the Users’ IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• location data such as information about the Users device’s location, which can be either precise or imprecise. How much information We collect depends on the type and settings of the device used to access the Services. Users can opt out of allowing Us to collect this information either by refusing access to the information or by disabling location setting on the device. However, if Users choose to opt out, they may not be able to use certain aspects of the Services.

The Users acknowledge that the provision of its Services by LetzMath may be subject to prior collection and processing of personal and/or non-personal identification information.

LetzMath will take all reasonable measures to ensure that personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy.

LetzMath will retain the Users’ personal data:

• For the duration of the relationship with the User;
• For the time the personal data are necessary regarding the purposes detailed in this Privacy Policy;
• Until the expiry of a one-month period following the end of any applicable limitation period under applicable law; and
• With the User’s consent, until the expiry of any additional retention period.

Identification information is used by LetzMath to provide the Users with its Services and LetzMath may hence collect and use the Users’ personal and non-personal identification information for the following purposes:

• To facilitate account creation and authentication and otherwise manage and keep in working order the Users accounts;
• Improvement of the Services, our website and communication tools;
• Delivery of the Services to Users;
• Personalization of experience;
• Communication with Users including for the purpose of addressing Users’ inquiries or order and to provide support to Users;
• Provide Users with information related to the Services;
• To save or protect an individual’s vital interest, to prevent harm.

LetzMath commits to implement appropriate measures, including technical and organisational security measures, in order to protect the personal data of Users against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised use.

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

The Users remain responsible for ensuring that any personal data sent to LetzMath are sent securely.

LetzMath further commits not to transfer any personal data to any third country or to any international organization, subject to exceptions including without limitation valid transfer mechanisms under European Regulation no. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data.

LetzMath may share personal information with third-party vendors, service providers, contractors, or agents who perform services for Us or on our behalf and require access to such information to do that work. The categories of third parties We may share personal information with are data analytics services, finance and accounting tools, performance monitoring tools and financing, investment and due diligence.

We also may need to share Users’ personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company or with our business partners to offer Users certain products, services, or promotions.

LetzMath may take the opportunity to improve the User’s experience in regard of its Services through the use of cookies and similar tracking technologies.

The User’s Internet navigator will in such a case places cookies on his hard drive to gather information used to customize the navigation in the framework of the Services provided by LetzMath.

Most Web browsers are set to accept cookies by default. If Users prefer, they can choose to set their browser to remove cookies and to reject cookies. If Users choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Most Web browsers and some mobile operating systems include a Do-Not-Track (DNT) feature or setting that can be activated to signal the privacy preference not to have data about online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates the Users’ choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform Users about that practice in a revised version of this Privacy Policy.

LetzMath may amend and update the Privacy Policy at any time and the updated version will be effective as soon as it is accessible.

LetzMath therefore invites the Users to frequently check the last version of the Privacy Policy provided on its website.

If material changes are made to this privacy notice, We may notify Users either by prominently posting a notice of such changes or by directly sending a notification.

Users agree that their review and awareness of the last updated version of the Privacy Policy is their responsibility.

Acceptance of these terms

Users confirm their agreement to the Privacy Policy by using the Services provided by LetzMath.

In case of disagreement to the Privacy Policy, it is recommended that the relevant User does not use the Services provided by LetzMath. Continued use of the Services provided by LetzMath following the amendment and update to the Privacy Policy will be considered as an acceptance of the related changes.

Users have the right to request access to the personal information collected from them, change that information, or delete it. Users also have the right to request restriction of processing concerning their personal information, to object to processing and to data portability.

Users can unsubscribe from marketing and promotional communications at any time by sending a request via an email. However, We may still communicate with Users including to send service-related communications necessary for the administration and use of Users’ account, to respond to service requests, or for other non-marketing purposes.

In case of termination of Users’ account, We will deactivate or delete Users’ account and information from our active databases. However, We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

For these purposes, please contact Us at [email protected].

Should Users consider the processing of their personal information infringes their privacy rights, Users have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of their residence, place of work or in the place of the alleged breach of their privacy rights. The competent supervisory authority in Grand Duchy of Luxembourg is the National Commission for Data Protection (Commission Nationale pour la Protection des Données).