Privacy Policy

Last updated: 2023-03-08

Introduction

This is a policy regulating how Hypocampus AB, corp. id. no 559072-5155 (hereinafter ”Hypocampus”) processes personal data.

When you use our services, which currently include inter alia hypocampus.se, hypocampus.fr, cortexio.se, cortexio.com, any subdomain to cortexio.se or cortexio.com, Hypocampus-based services and other Hypocampus-related sites and apps that state that, these services are powered by Cortexio (hereinafter ”the service” or ”our service” ), which is owned by Hypocampus. Therefore, in connection with the use of our services, we may collect and process certain personal data. This policy regulates our processing of personal data. By signing up for and using our services, you agree to our processing of personal data in accordance with this policy. We are the data controller for these personal data. We comply with the general data protection regulation (EU) 2016/679

1. Personal Data collected by the service

We collect personal data about you in order for our service to be able to give you an optimal learning experience

1.1 Mandatory personal data

We collect the following personal data, and the collection of this data is a requirement for the service to function.

• Email
  You must provide a valid Email for login purposes
• Name
  If and when you make a purchase your full Name is mandatory
• Question statistics and study time
  Your answers to questions
  Time spent on reading and answering questions
  If the browser tab where the service is open is Active or not
• Payments
  Information that you have purchased a subscription, book or study plan (not card number)
  (The payment service that handles card payments on the service is Stripe)

1.2 Voluntary personal data

You may provide this personal data to the service, but it is not mandatory for your use of our services. However, if you provide some of these, we may be able to improve the services and your experiences since we may be able to suggest modifications of your study plan and provide recommendations based on the data you provide to us, which may in turn lead to improved study results.

• Profile information: Name, profile picture
  You can use the service without providing this information, unless you make a purchase, in which case Name is required
• Current school, term etc
  You will get a better learning experience if you supply this information, but it is optional
• Content
  Notes, markings, pictures, documents that you add yourself

2. Data handled by third party services

In addition to data collected described under 1.1 and 1.2, Data generated by your activity on the service is handled by third party services.

The handled Data is used to improve both user experience and personal learning efficiency. This data is not sold or by other means used to profit Hypocampus in any other way than aforementioned reasons.

Data that we collect:

• Activity on the screen: mouse clicks, keyboard events
• If the browser tab is active
• How you navigate through the system

3. How we store your Personal Data

3.1 How we store your Personal Data

We store the personal data we collect at Amazon Web Services. The servers are located in the EU, in Frankfurt, Germany.

Access to raw personal data is restricted to a few employees at Hypocampus AB and spreading this data without each user's permission is illegal in the EU with large fines and a potential personal legal prosecution as a result.

3.2 How third party services handle your Personal Data

Data collected and stored under 2. is described on each third party service policy pages:

• Google Analytics
• Mixpanel
• HubSpot
• Mailchimp

Access to these services is restricted to a few employees at Hypocampus AB and spreading this data without each user's permission is illegal in the EU with large fines and a potential personal legal prosecution as a result.

4. Why do we collect and store Personal Data?

We process your personal data for the following purposes:

4.1 Establish and administer customer relationships

• Provide access to our services (log-in and reset your password)
• Create a customer account
• Provide our services
• Provide support
• Manage invoicing and accounting
• Facilitate our customer relationship in other ways

4.2 General marketing purposes

• Sending offers and marketing material related to the service to existing and potential customers. We will transfer your personal data to a third party (ie email address to the email service) for marketing purposes (but only accessible to our collaboration partners which provide access to services through Cortexio), and you have the option to opt-out from receiving marketing communication from us at any time
• Sending newsletters and/or other marketing communications, such as e.g. “the case of the week”, to customers and persons who have signed up to receive such communication from us

4.3 Statistical purposes & further development

• Statistical analysis
• Business intelligence, for ourselves and third parties, to further develop our products, services and offerings. This concerns personal data in aggregated and in an anonymous format
  Points of interest:
  Content popularity
  Are the study questions too easy, optimal or too hard?
  Average study time
  Behaviour patterns
  Study patterns
  

4. Personal adaption of the content

• Study analysis, resulting in tailored recommendations as regards rehearsal of certain study questions, modification of study plan etc
• We may also use nudging by sending you e-mails and/or notifications if you have not been logged on for a long time or if your study time is not optimal
• Estimate the drop-out risk

5. To improve our support services

6. Research purposes

We make personal data available for research purposes, but only in aggregated and anonymous format. If Personal and non-anonymous Data is shared this is always done with the consent of each user.

5. Legal grounds for Processing

We process personal data based on our legitimate interests, based on fulfilling our agreement with the registered person (i.e. you), and based on consent.

Specifically, our processing of personal data for the purposes of establishing and administering customer relationships (point 1 above) is based on our legitimate interests, if our agreement is with a school, or on fulfilling our agreement with the registered person, if our agreement is with you as a student. Our processing of personal data for general marketing purposes (point 2A above) is based on our legitimate interests, but, in the case of newsletters etc. (point 2B above), our processing is based on consent. Our processing of personal data for statistical purposes & further development (point 3 above) is based on our legitimate interests. Our processing of personal data for personal adaption of the content (point 4 above) is based on consent. Our processing of personal data to improve our support services (point 5 above) and for research purposes (point 6 above) are based on our legitimate interests.

Furthermore, we process personal data as required by law (e.g. for accounting purposes).

6. For how long do we store the Personal Data we Collect?

For students, we store the personal data during the time which you are a student and three years thereafter, unless you have requested deletion of the personal data before that point in time.

We store e-mail for subscribers to our newsletters and other marketing communication for the time period during which the subscription is active. If you have opted out of receiving newsletters and marketing communication, we store information about such opt-out for the sole purpose of ensuring that we do not send you such communication which you do not wish to receive.

Additionally, we may store the personal data for a longer time period as required by mandatory applicable law.

7. Transfer of Personal Data

In connection with the services we provide, we need to transfer personal data to third parties, and in such cases, we always enter into a data processing agreement with the data processor. Our current service providers are listed at .3. In case we transfer personal data outside the EU, such transfers are made under the EU's standard contractual clauses.

8. Cookies

Our platform uses cookies to provide certain functionality, to gather data to improve our platform and to help us with marketing.

When you use our website we place some cookies on your device. We use cookies and similar technologies to: measure activity on our website, offer certain functionality provided by third-party tools, and to help with marketing.

By continuing to use our website with your browser settings set to accept cookies, you are giving us your consent to place non-essential cookies on your computer or device.

More details of which cookies are stored can be found in our Cookie policy

9. Your Rights

You have the right to request information about which personal data we have collected about you and any personal data you have put in yourself, and the right to request that these shall be corrected or destroyed, or that the processing shall be restricted. You also have a right to data portability.

To the extent that the processing is based on consent, you can withdraw your consent at any time, as a whole or in part.

Please contact privacy@cortexio.se for all such matters.

You also have the right to lodge a complaint with the applicable data protection authority, https://www.datainspektionen.se.