Last updated: 28th October 2022
Flowchase’s mission is to help English as a foreign language teachers make their classes more engaging and personalise the way they teach pronunciation and spoken skills through the power of voice technology. Earning your trust by ensuring your privacy and safety is therefore extremely important to us.
— What information Flowchase collects from you (and why we collect it).
— How we use and share that information.
— The choices you have, including how to access, update and delete your information.
— This Policy applies to all products and services offered by Flowchase SRL (hereinafter referred to as “Flowchase,” “we,” “us, » “our,” also including our subsidiaries or affiliates).
If you have suggestions that can help us improve it or any questions about this Agreement, please email us and let us know. This Agreement explains our obligations to you, and your obligations to us.
SECTIONS WRITTEN IN CAPITAL LETTERS ARE ESPECIALLY IMPORTANT FOR LEGAL COMPLIANCE, SO PLEASE MAKE SURE TO REVIEW THEM CAREFULLY
We have done our best to write this Policy in simple, clear terms. We encourage you to read it carefully, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
- Purpose of processing: provide access to and use of Flowchase services (website, textbook and mobile apps).
- Legal grounds: processing based on user consent, contract performance and the legitimate interest of the company or third parties.
Whether you are new here (welcome!), or have been using Flowchase for a long time (welcome back!), please do take the time to get to know our privacy practices. We believe them to be fairly clear and friendly, but if you have any questions or feedback, we are here to help. To learn more about how we protect your privacy, reach out to our Data Protection Officer (DPO) via the contacts listed in this document.
What is Flowchase?
Flowchase Privacy Principles
- What are Flowchase's principles when processing personal information?
- Why does Flowchase collect personal information from its users?
- What are my rights when using Flowchase?
- Which are my responsibilities when Using Flowchase?
- What are Flowchase’s commitments to providing transparency and choice?
- Change of Purpose
- Contract Performance
- Legitimate Interests
- How will Flowchase notify me of changes to this policy?
Protecting Our Students
- What information does Flowchase collect from students, and how is it used?
- What students’ information is visible to others?
- How long does Flowchase keep students’ information?
- Parental Choices
- What information does Flowchase collect?
- Information You Provide to Us
- Information Collected Automatically
- How does Flowchase use the information it collects?
- How long does Flowchase keep information about me?
- Will Flowchase share any information it collects?
- Which are Flowchase's Third-Party Service Providers?
- Accountability for Onward Transfer
- How does Flowchase protect and secure my information?
- How would Flowchase deal with a security breach?
Managing My Information
- How can I access and manage my personal information?
- How can I delete my account?
- Student Data Control by the School or Educational Institution
- How can I lodge any complaints?
- EEA Residents
- Appointed EU Representative
- Transfers of Personal Information to Europe
- Processing in Other Regions
Flowchase is an easy-to-use mobile app and its companion textbook that help English as a foreign language teachers engage their students and personalise the way pronunciation and spoken skills are taught. Flowchase can be used by students entirely autonomously as prescribed by their teacher, school, educational institution, or organisation, or it can be integrated into their curriculum.
Outside the classroom, students use Flowchase to learn about pronunciation concepts, train their ear to listen for specific sounds or sound patterns through listening activities, and practice speaking English by repeating selected words and sentences. One account can be used to sign in on multiple devices, in which case the students’ progress will be synced.
In the classroom, teachers use Flowchase to put what students have learned into practice through the use of group activities from the Flowchase Textbook. Flowchase collects students' scores on listening and speaking activities and their quiz responses, which teachers can view in progress reports that we upload on our website, accessible from the Teacher Admin area.
In collecting and processing your personal information, we will comply with the data protection laws and regulations in force at the time. This requires that the personal information we hold about you must be:
Flowchase collects personal information from users in order to provide the Service. Concretely, the personal information of students and teachers is collected and used for the following purposes:
Your rights relating to your personal information include:
We require that your personal information is accurate. Please let us know if the personal information you provided us for creating your account has changed. If we do not have the correct information, we cannot take responsibility for information-related errors.
Additionally, if we determine that you are in violation of this Policy, you will be subject to disciplinary action that could eventually lead to the banning of your account.
We try to be transparent about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:
When providing you with information on the processing of your personal information, such as its collection, transfer to other countries, types or identity of third parties to which we disclose that information and the purposes for which we do so, we will make sure that such information is provided in clear and understandable language. Also, initial notice on our practices and policies will be provided when you are first asked to provide personal information to us, or as soon as practicable thereafter, and in any event before we use the information for a purpose other than that for which it was originally collected.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
When, as a teacher or school/educational institution/organisation representative, or when acting on behalf of a company or other organisation, you create a Flowchase account, you provide your first and last name and one or more contact methods such as an email address or phone number (“Contact Information”). We require those data elements for you to enter into the Terms of Service agreement with us, and we process those elements on the basis of performing that contract.
European Educational Institutions and GDPR: According to article 8 of the GDPR, minors shall be entitled to give valid consent only if they are 16 years old (unless Member States have set a lower age limit which, nonetheless, cannot be under 13 years old). Under that age limit, processing of personal information related to minors shall be subject to parental consent. Schools/educational institutions are in control of their students’ personal information and are obliged to take all necessary measures for protecting said information. This means that schools/educational institutions will have to be especially cautious when contracting any service that may require disclosure of student personal information. In other words, schools/educational institutions are data controllers in terms of GDPR and thus determine the purposes and means of the processing of student personal data. As a consequence, schools/educational institutions will also be responsible for informing students and their parents accordingly about what data is collected, which are the purposes of collection, how data is used and to which third parties it is disclosed, including Flowchase.
Generally, the remainder of the processing of personal information we perform is necessary for the purposes of our legitimate interests or those of third parties. For example, for legal compliance purposes or to maintain ongoing confidentiality, integrity, availability and resilience of Flowchase's systems, website, and overall services, we must keep logs of Technical Information; and, in order to respond to legal process, we are required to keep records of users who have sent and received DMCA takedown notices.
The breach of certain rules in the use of the Service may lead to the suspension or indefinite ban of your account, depending on the severity of the offence. In the event of an indefinite account ban, Flowchase may keep part of your personal information, such as, but not limited to, IP address and Contact Information, to prevent you from accessing or using the Service.
Flowchase collects the minimal amount of information from students necessary to create accounts on our Service: we ask students to provide their name, a form of Contact Information, and a unique code they have been given by their teacher or institution to join a class or group. Beyond this information, students can submit responses or audios depending on the activities they are assigned or choose to complete. All this information will only be used for the purposes of the school/educational institution/organisation/teacher. In addition to the information entered by the student, we automatically collect some information from any use of our Service as set forth in the "Information Collected Automatically" section.
We use this information to provide the Service to the student, for security and safety purposes, or as required by law or to enforce our Terms. We will not require students to provide more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a student in a manner inconsistent with GDPR or any other applicable laws or regulations, we will take appropriate steps to delete the information. We do not disclose any personal information about students to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other users. Information collected from students (including personal information and information collected automatically) is never used or disclosed for third-party advertising, including any kind of first- or third-party behaviorally targeted advertising, and students’ personal information is never sold or rented to anyone, including marketers or advertisers.
No student’s profile is made available or visible to the public, or to any other students, through Flowchase. Our applications have no social networking features and don’t allow students to chat with each other. Teachers may share their classes, including grades or scores, with other teachers they co-teach with in their school/educational institution, to help them collaborate. If the teacher chooses to display Flowchase in their classroom, by projecting via a beamer, a smartboard or interactive whiteboard, students physically present in that classroom may see other students’ names, responses or total scores.
EDUCATIONAL INSTITUTIONS, ORGANISATIONS AND TEACHERS SHALL MAKE A RESPONSIBLE USE OF THE SERVICE AND AVOID COMPROMISING STUDENTS' PERSONAL INFORMATION AT ALL TIMES WHEN DISPLAYING FLOWCHASE IN THE CLASSROOM. FLOWCHASE SHALL NOT BE HELD LIABLE FOR THE INAPPROPRIATE USE OF THE SERVICE BY THE EDUCATIONAL INSTITUTION, THE ORGANISATION OR THE TEACHER.
We only keep a student’s personal information for as long as his or her student account is active, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms:
After deletion of the account, Flowchase may retain backups of the mentioned information for a variable period of time, depending on the specific requirements of our infrastructure, but never for longer than six (6) months. Nevertheless, Flowchase shall not be responsible for the accidental loss or destruction of data on behalf of users. Flowchase will not be obliged to recover erased data stored in backups when erasure is attributable to users.
EDUCATIONAL INSTITUTIONS UTILISING THE SERVICE ARE RESPONSIBLE FOR COMPLYING WITH THE RETENTION OF STUDENT EDUCATION RECORDS FOR AS LONG AS LEGALLY APPLICABLE. STUDENT PROGRESS MAY BE SAVED FOR EITHER SHORTER OR LONGER PERIODS THAN THE ONES STATED ABOVE IF SO DECIDED BY THE EDUCATIONAL INSTITUTION.
FLOWCHASE SHALL NOT BE RESPONSIBLE FOR ERASURE OF STUDENT PROGRESS DUE TO ACCOUNT DELETION AFTER AN EXTENDED PERIOD OF INACTIVITY OR BECAUSE OF THE VOLUNTARY ELECTION TO DELETE TEACHER ACCOUNTS. SCHOOL/EDUCATIONAL INSTITUTION OFFICIALS MAY REQUEST DELETION OF STUDENT INFORMATION AND CONTENT AT ANY TIME BY CONTACTING OUR DATA PROTECTION OFFICER.
Any parents that want copies of their children’s personal information that we may have stored can contact their children’s school personnel to that end. At any time, the school can also refuse to permit us to collect further personal information from its students, and can request that we delete the personal information we have collected from them by contacting our Data Protection Officer. Please keep in mind that deleting records may require us to terminate the account in question. Also remember that before we can share the information with the school, or delete it per your request, we will, by reasonable means, proceed to verify the identity of the requester.
We collect two types of information about you: (1) information that you voluntarily provide us by using the Flowchase Service (described below under “Information you provide to us”) and (2) information collected automatically as result of your use of the Service (described below under “Information collected automatically”). The types and amounts of information collected will vary depending on whether the user is a teacher or student (e.g. we collect minimal information from students) and how they use Flowchase (e.g. if teachers join their school/educational institution, we may need to collect school/educational institutions address information).
There are currently two categories of users on our Service: teachers and students. We collect and store the following types of information from each type of user:
Our use of the information above is described below in the "How Does Flowchase Use the Information it Collects?” section. If you are using the Flowchase App, we may ask you for certain permissions.
The technologies and information we automatically collect include:
First and foremost, you should know that Flowchase does not sell, share, or rent any of your, or your students' personal information to any third party for any purpose including for advertising or marketing purposes. Flowchase does not cooperate with data brokers. We use the information we collect from you to provide you with the best Flowchase experience. More specifically, this information is used to:
We store your personal information for as long as it is necessary to provide products and Services to you and others, including those described above. As a general rule, if your account is inactive for twelve (12) months or more (meaning you have not logged into your account during that time), Flowchase will automatically delete your account. Deletion will affect any on-going paid subscriptions, which will be immediately cancelled. See the section “How long does Flowchase keep students’ information?” for more information on how we handle inactive and deleted accounts.
Note we may retain and use de-identified data (i.e. data which has been stripped off of all information that can be used to identify a person) for purposes of research, improvement of our products and services, and/or the development of new products and services. We may also have to retain some information after your account is deleted, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms. In case we keep copies or backups of personal information, such copies or backups may be kept for a maximum term of six (6) months after the deletion of your account. Remember that you can delete your account at any time by contacting us, especially by contacting our Data Protection Officer. In addition to the policy above that applies to all users, we only keep a student’s personal information while the student’s account is active, unless we are required by law to retain it or need it to ensure the security of our community or our Service, or to enforce our Terms.
It is important to us that we keep your information safe and secure. To best provide our services, and keep your information safe, we work with a few other companies (we can’t do it all ourselves!). These companies (“processors” under the GDPR, "third-party service providers", "collaborators" or "agents") will only have access to the information they need to provide the Flowchase service.
We will transfer your personal information to third-party service providers only for limited and specific purposes. We will obtain contractual assurances from our collaborators that they will safeguard personal information in a manner consistent with this Policy and that they will provide the same level of protection as per best industry standards. We recognize our responsibility and potential liability for onward transfers to agents. Where we have knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy and/or level of protection as required by applicable laws and regulations, we will take reasonable steps to prevent, remediate or stop such use or disclosure. If we transfer personal information to non-agent third parties, that is to say, any new collaborators that are not included in the previously mentioned list, we will (1) notify you with all necessary information on any key elements affecting the processing of your personal data, and (2) obtain contractual assurance from these parties that they will provide the same level of security as per best industry standards and in accordance with any applicable laws and regulations.
Your Flowchase account is protected by a one-time password you can renew every time you log in on a new or existing device. You obtain this password on the contact method you used to sign up, and must enter it in the Flowchase App or Teacher Admin within a limited window of time to validate your account or confirm your identity to log in. You can help us protect your account from unauthorised access by ensuring no one else than you has access to your contact method.
The security of your personal information is important to us. We work hard to protect our community, and we maintain administrative, technical and physical safeguards designed to protect against unauthorised use, disclosure of or access to personal information, such as:
Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems as per best industry standards, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorised use or other factors may compromise the security of user information at any time.
Both notifications will be written in plain language, will be titled “Notice of Data Breach” and will present the information described above under the following heading: “What Happened,” “What Information Was Involved,” “What We Are Doing,” “What You Can Do” and “For More Information”. Additional information may be provided as a supplement to the notice.
We hope you will love using Flowchase now and always. However, if for some reason you ever want to delete your account, any school, educational institution, or organisation official can do that at any time by contacting our Data Protection Officer, and we will proceed to delete the requested data within ten (10) business days. Parents, legal guardians, or eligible students may delete their accounts by contacting their educational institution.
If you are a student using our Mobile Application, you can delete your account from within the application; please note that this is a ‘soft’ delete of your account, and your data will be deleted by automated means within a reasonable period of time so that it may be recovered in case of user error.
When we delete your account, we delete any personal information that you provided in your profile (such as your name and contact information) and depending on the category of the user you are (i.e., teacher or student), also questions, responses and comments. Please note that information that you have shared with others, that others have shared about you, or content other users may have copied and stored, is not part of your account and may not be deleted when you delete your account.
Part of your personal information will remain in our possession as a copy or backup that is part of our disaster recovery storage system. However, such copies and backups will be kept for a maximum term of six (6) months and they will neither be accessible to the public, nor used by Flowchase in the normal course of business.
Access to the Service by the students is subject to the obtaining of a specific code provided by the teacher, school, educational institution, or organisation. The school, educational institution, or organisation is, at the same time, responsible for its students' personal information and in control of student academic records. As a consequence, modification or deletion of student personal information that is part of or affects student academic records is subject to the school/educational institution/organisation's discretion.
In a co-teaching setting, all teachers are considered equally responsible and accountable for the class. Responsibility for the modification or deletion of student information, or grading of assignments among any other related features shall be exclusively of the teachers.
FLOWCHASE SHALL NOT BE RESPONSIBLE FOR THE DELETION OF THE CLASS OR PART OF ITS CONTENT, OR FOR THE ERASURE OR DELETION OF STUDENT PROGRESS OR STUDENT ACCOUNTS, BY ANY OF THE TEACHERS PARTICIPATING IN THE CO-TEACHING CLASS.
You may file a complaint concerning Flowchase's processing of your personal data by contacting our Data Protection Officer via email@example.com, or by regular mail to the following address:
Attention: Data Protection Officer
Chemin du Cyclotron, 6
If your complaint cannot be resolved through our internal processes, we will direct you to the state or national data protection authority in the jurisdiction where you reside.
EEA residents and residents from the United Kingdom (UK) will have the right to lodge a complaint to the EU Data Protection Authorities or the Swiss Federal Data and Information Commissioner (FDPIC), Flowchase will comply with the advice of competent European Union authorities in such cases, and will provide appropriate recourse free of charge.
In the event that Flowchase or the aforementioned authorities determine that Flowchase failed to comply with this policy, Flowchase will take appropriate steps to address any adverse effects arising directly from such failure and to promote future compliance.
Our EU representative may be reached at the email firstname.lastname@example.org or at the following physical address:
Attention: Data Protection Officer
Chemin du Cyclotron, 6