1. Introduction

The DQ Assessment Sites (“Sites”) provide a platform to test your digital intelligence or DQ. You have trusted us to make safe and quality content that users of all ages can enjoy. Online, this trust is even more important to you, and to DQ LAB Pte. Ltd. (“DQ LAB”, “we”, “our”, or “us”). To make sure that the Sites stay safe and fun, and because your privacy is important to us, we will abide by this Privacy Policy.

This Privacy Policy describes the types of information which we may collect about you on the Sites where this Privacy Policy is posted and on applications we make available on third-party sites or platforms (if disclosed to you in connection with use of the application), how this information may be used and/or disclosed, the purposes for which your information is collected, used and/or disclosed, the retention of such information, and your right to access and correct such information. Personal information is information or a combination of pieces of information that could reasonably allow you to be identified (“Personal Information”). This Privacy Policy relates to the DQ LAB Services on the Sites (the “Services”), which comprise a questionnaire on digital intelligence for children, that are provided by DQ LAB.

2. Information we collect

DQ LAB will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us). Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data. To access the Services, DQ LAB may collect information about you and your child such as:

Personal details (e.g. name and date of birth)
Contact details (e.g. email address, phone number, postal address or mobile number)
Other information such as the name of your school, your child's school or organization;
Device properties, including but not limited to IP address, unique device identifier or other persistent or non-persistent device identifier;
Device software platform and firmware;
Geographical data such as zip code, area code and approximate location;
Activity progress, time used playing, score and achievements; and
Your responses to various surveys and quizzes

Please note, that parents, teachers or legal guardians may be asked to provide their child's name and email address in addition to information about themselves. In that event, such information will also be subject to this Privacy Policy.

3. How we use your personal information and the legal basis on which we use it

DQ LAB may use your Personal Information to:

send you messages about DQ LAB;
send you messages about research;
send you messages about new features or services;
send you messages about promotional material from some of our partners;
send you messages about marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications to contact you when necessary;

DQ LAB also may use your Personal Information, both individually or combined together:

for publishing research articles and/or reports;
for editorial and feedback purposes;
for marketing and promotional purposes;
for statistical analysis of users' behaviour;
for content improvement;
for technical support;
obtain your views or comments on the Services;
to verify your identity;
to manage and provide the Services; and
to customize content and layout of the Services.

DQ LAB does not sell or rent your Personal Information to third-parties for commercial purposes. DQ LAB may share your Personal Information you provide with our partners only for research purposes as described in the Information Sharing section below.We must have a legal basis to process your Personal Information. In most cases, the legal basis will be one of the following:

To fulfil our contractual obligations to you, for example, to provide the services. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations;
To comply with our legal obligations; or
To meet our legitimate interests, for example, to understand how you use our services and to enable us to derive knowledge from that to enable us to develop new services. When we process Personal to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information on the balancing test that we carry out to process your personal information to meet our legitimate interests, please contact us at the details below.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, or our use of cookies and tracking technologies). If we ask for your consent to process your personal information in relation to these activities, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.We do not directly market to children. Direct marketing communications are only sent to parents and schools to encourage the use of the DQ LAB platform.

4. Automated Processing

We use automated processing to produce DQ Reports to parents and teachers to keep them up to date about their child's progress on the programme. These reports are generated by our system based on the child's responses throughout the programme and are used to identify their strengths as well as any potential risks to the child.

5. Information Sharing

We may share your Personal Information with third parties under the following circumstances:

S ervice providers and business partners. We may share your Personal Information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to optimize our services, send newsletters and marketing emails, support email and messaging services and analyze information.
Law enforcement agency, court, regulator, government authority or other third party. We may share your Personal Information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Asset purchasers. We may share your Personal Information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “International Data Transfer” for more information.

6. Children's Privacy

We recognize the need to provide further privacy protections with respect to Personal Information we may collect from children under the age of eighteen (18) who are users of our Sites and applications (“Children” or “Child”). When we intend to collect Personal Information from Children, we take additional steps to protect Children's privacy, including:

Limiting our collection of Personal Information from Children to no more than is reasonably necessary to participate in an online activity;
Mandating strong passwords be used when Children sign up for the Service;
Utilizing a secure login form for the login pages of the Sites;
Ensuring that DQ LAB's information technology vendors and/or staff are reputable, experienced and properly accredited;
Implementing robust policies and procedures regarding confidentiality obligations;
Anonymizing Personal Information of Children before disclosure, where feasible;
Requesting for an updated copy of the Personal Information before making a decision that will significantly affect the Child;
Requesting updates of the Personal Information from the Children on a regular basis;
Giving parents/guardians the ability to request access to Personal Information we have collected from their Children and the ability to request that the Personal Information be changed or deleted;
Requiring parents/guardians to acknowledge our Terms of Use and Privacy Policy for Children, and give permission for Children to provide us with certain Personal Information required to set up an account on the Sites, to enter a contest and/or to participate in any other activity offered through the Sites (“Parental Consent”). In the event that a Child’s account (“Sub-Account”) is set up on his/her behalf by a teacher or educator in charge of him/her (“School Account Holder”), we mandate that such School Account Holder inform that Child's parent or guardian in writing with instructions for how to opt-out if needed. Children whom DQ LAB has knowledge are under the age of 13 and have registered individual accounts on the Sites are required to provide a parent's/guardian's e-mail address, and must have a parent/guardian provide Parental Consent. This e-mail address will be sent a notification message with an embedded link to our Terms of Use, Privacy Policy and Parental Consent page. The Child's registration or request will be considered incomplete until the Child's parent/guardian uses this link to provide Parental Consent; and
DQ LAB recommends that parents/guardians monitor and supervise the online activities of their Children.

7. Public Information Including User Generated Content (“UGC”)

Some of the Services may allow you to enter text and information in fields that are accessible by the general public, such as comment sections, and message boards. If you choose to participate in these public areas of the Services, please be aware that any information submitted through these areas will be in the public domain. Please use caution in disclosing Personal Information in these areas. You are responsible for any content, including Personal Information, that you contribute to be published or displayed (hereinafter, “posted”) on the Services or transmit to other users of the Services. Your UGC is posted on and transmitted to other users of the Services at your own risk. By posting UGC you are allowing all users of the Services to access and use that UGC, and to associate it with you. If we provide a feature that allows tagging of photos and profiles to UGC, then you or other users may tag your profile to UGC. Please be aware that no security measures are perfect or impenetrable.

Although we moderate public forums to keep their content appropriate for the forum's intended audience, we are not responsible for the information you or your Child submits in these open forums and in the public domain, nor for other users’ actions with respect to that information. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your UGC. Therefore, we cannot and do not guarantee that your UGC will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. You understand and acknowledge that, even after removal, copies of your UGC may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Services.

You acknowledge that you are responsible for any UGC you submit or contribute, and all UGC shall comply with the Terms of Use and all applicable laws and regulations.

8. Changes to this Privacy Policy

DQ LAB reserves the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of these Sites by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to these Sites. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. object to the processing).

You may request a copy of this Privacy Policy from us using the contact details set out below.

9. Data Security and Integrity

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to reasonably protect Personal Information from unauthorized access, collection, disclosure, use, copying, modification, disposal or similar risks. From time to time, we review our security procedures to consider appropriate new technology and methods. However, please be aware that despite our best efforts, no security measures can be perfect or impenetrable.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out Personal Information in public areas of the Sites like message boards. The information you share in public areas may be viewed by any user of the Sites.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to DQ LAB. Any transmission of Personal Information is at your own risk.

10. Retention of Personal Information

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the Personal Information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

Maintain business records for analysis and/or audit purposes
Comply with record retention requirements under the law
Defend or bring any existing or potential legal claims
Deal with any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

11. Your rights over your personal information

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

access your personal information
rectify the information we hold about you
erase your personal information
restrict our use of your personal information
object to our use of your personal information
receive your personal information in a useable electronic format and transmit it to a third party (right to data portability)
lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us at the details below.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

We will contact you if we need additional information from you in order to honor your requests.

12. International data transfer

Your personal information may be transferred to, stored and processed in a country that is not regarded as ensuring an adequate level of protection for personal information by the European Commission.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information about the appropriate safeguards in place, please contact us at the details below.

13. Contact us

DQ LAB is the relevant data controller responsible for the Personal Information we collect and process.

Our representative in Europe is below.
activeMind.legal
Rechtsanwaltsgesellschaft m. b. H
Potsdamer Straße 3
80802 München, Germany
Phone: +49 (0)89 / 418 560 170
Email: eu-dataprotection@dqforall.com

If you have a comment or question about this Privacy Policy, please contact Guest Services: dpo@dqforall.com. We will contact you within fourteen (14) days to confirm receipt of your email. Following receipt of your email, we will investigate your concern or complaint and endeavour to provide you with our response within a reasonable timeframe.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the country in which you are a resident.