In this privacy policy we explain how we use your personal data when, for example, you visit, register and learn on our website www.evulpo.com or enable others to learn and pay for it.
To make reading easier for you, we say «evulpo» when we talk about the website www.evulpo.com and the learning platform available there.
We may amend this privacy statement from time to time, for example, because we expand the services offered on evulpo. The current version of this statement can be found on our website at https://evulpo.com/en/uk/privacy.
Personal data is information about a specific person. For example, your date of birth, email address, telephone number, contract details, communications with you and certain details about your behaviour on evulpo are personal data. When we say "data" here, we mean such personal data.
The "processing" of data refers to the handling of data. This includes, for example, collecting, storing, changing or deleting data.
"We" or "us" means the company evulpo AG. We are responsible for the processing of your personal data when you visit evulpo and learn there, contact us or otherwise deal with us. In individual cases, it may be that another company is responsible for handling your personal data. However, we will point this out to you.
This is how you can contact us if you have any questions about data or would like to exercise your rights (see section 9 below):
evulpo AG
Schifflände 26
8001 Zurich, Switzerland
[email protected]
[email protected]
DP Dock DPO Services GmbH
Attn: evulpo AG
Grüffkamp 10
24159 Kiel, Germany
Much of the data we process is obtained because you give it to us. For example, if you are a student visiting evulpo and you are trying out how to learn through evulpo, we will ask you for your school level and the region where you go to school in order to present you with the right content.
For parental responsibility holders:In some cases, your account information may be used. If a minor fills in this information on your behalf, please make sure the information is correct.
We process various data about you. We have summarised the most important ones for you:
Technical data: To ensure that evulpo works when you visit evulpo and is also secure, we need to collect various technical data (IP address, browser, date and time of visit). Technical data helps, for example, your computer to work with evulpo. This technical data does not in itself tell us anything about you. However, this can change if, for example, you are registered with us.
Data when contacting us or subscribing to our newsletter: If you contact us, for example by e-mail or via the contact form, we collect the content of the exchanged messages and other data related to them. For example, it is possible to tell from an e-mail when it was sent. We process this data because we cannot deal with your request in any other way. We also keep this data - for example, in case you have questions and to train our staff. We also collect your contact details in order to send you advertising about our offers. If you sign up to our newsletter on evulpo, we can keep you informed about what’s new on evulpo. If you are under 16, please ask your parents for permission before subscribing to a newsletter. You can always say "no" to newsletters - so you don’t have to sign up if we suggest it. Once you have said "yes" to newsletters, you can change your mind at any time and let us know or unsubscribe.
Data for trial use/registration and use (contract data): If you are using evulpo on a trial basis as a pupil, we ask you for information such as your class, your school level, your name and your school canton or district. To be able to study with evulpo permanently, you need a user account. When you create your account, you will have to provide us with certain information, such as your name. To enable you to use evulpo as a student, we need to process certain information about you. For example, we keep track of your progress so that we can show you the right lessons or correct your completed exercise sheets. This also includes evaluating how you can improve. We also process data about you when we help you with technical problems with evulpo. Moreover, continuous learning with evulpo is not free of charge. Therefore, we learn about the person who pays for evulpo - whether student, pupil or parent - for example, address as well as account or credit card number and other payment data.
Behavioural data: We also collect data about how you use evulpo. For example, we can track which website you came to evulpo from or which learning offers you click on most often. We analyse this data to constantly improve evulpo and make it even more interesting for you. We also keep track of what you were interested in. We anonymise or delete this data if the time at which we collected it was too long ago. Anonymising means that we change the data so that we no longer know who is behind it. We also use this data to show you advertising that speaks directly to you - also on other sites on the internet, for example on platforms for exchange, which are summarised under the term "social media". If we have to do this, we will ask for your consent beforehand via the cookie banner and through the use of cookies (please see point 9). You can also say "no" at any time to such advertising that addresses you directly. We collect your behavioural data by "tracking" via technologies such as "cookies". We explain what this is in more detail in section 9, where we also explain how you can prevent the collection of your behavioural data.
Other data and purposes: We may also process data about you in other situations. We also use data to comply with laws or recommendations from public authorities. For example, we may disclose your name or other information to a government agency or court because there is a law that requires us to do so. We also use your data to better organise and protect our company. This concerns, for example, data during registration or about your behaviour on evulpo (e.g. through the use of cookies). If we do not have certain data, you cannot use evulpo with all its possibilities. For example, we cannot activate the learning content for you if we do not know which school level you are in.
If we ask you for your consent to the processing of your data (your "consent", for example for sending newsletters or for the processing of behavioural data, as the case may be), this is the basis for the corresponding handling of your data. You can "withdraw" consent that you have given us at any time, i.e. revoke it. Simply contact us - you will find our contact details under point 2. From this point on, we may no longer rely on your consent. However, we may be allowed to continue processing your data for other reasons.
In all other cases (where we do not ask for your consent), we process your data either because it is necessary to enable you to learn about evulpo ("conclusion and performance of a contract") or because it is in our "legitimate interest" (for example, to continually improve evulpo and fix bugs).
We have described from point 3 what data we use from you and for what purpose. We send data to various other persons. They are called recipients and can be divided into the following groups:
Service providers: We work with other people (including companies) who help us process your data in connection with evulpo. Often these companies work on our behalf, which means that we give them instructions on how to handle your data.
Advertising partners: We also work with people who advertise for us. We call them "advertising partners". This is how we want as many people as possible to hear about evulpo and decide to visit and learn there. For this purpose, we send our advertising partners data about you. The advertising partners study this data to decide where, how and to whom evulpo should best be advertised. We explain this in more detail in section 9.
Authorities: We may disclose your data to authorities or courts if we are legally obliged to do so or because it is in our legitimate interest to do so.
Other people: Your data may also be shared with other people, for example your bank or a payment service provider, when you pay for learning at evulpo.
If you want to send us a message via the contact form or by e-mail, your details from the enquiry form and your e-mail address will be stored by us for the purpose of processing the enquiry (for example, giving feedback or changing the account type) and in the event of follow-up questions. Under no circumstances will we pass on this data without your consent. The legal basis for processing the data is our legitimate interest in answering your enquiry. Your data will be deleted once we have completed processing your enquiry, unless there are laws that prohibit such deletion. You can revoke the processing of this data at any time.
On our website, we may include links to social media providers (Facebook, Instagram, TikTok, LinkedIn), i.e. platforms on the internet that enable people to get in touch with each other. For example, if you click on the symbol of such a platform, the provider knows that you are currently at evulpo. If you have your own account with this provider, he can track where you are on the internet. The provider decides for itself and independently of evulpo which data it collects about you and how it uses it. You can use technical settings in your browser (the programme you use to access the internet) to ensure that no cookies are placed or otherwise circumvented and that existing cookies are deleted.
As described above, we also share your data with other organisations. This is not only in the country where you live. Your data is also processed in other countries in Europe, the USA and, in exceptional cases, in any country in the world.
If a recipient is located in a country where your data is not adequately protected according to the data protection law applicable to you, we ensure this protection in another way - a bit like a safety net. For example, we contractually oblige the recipient to ensure that your data is adequately protected. How the recipient is supposed to do this is described in the so-called standard contractual clauses of the European Union. You can have a look at these clauses here.
We process your data for as long as it is necessary to achieve the purpose of the data processing. If necessary, we keep data longer because a law requires it. While we keep your data, we take care to protect your data so that it is not lost or inadvertently disclosed, for example.
In certain circumstances, you have the right to object to the processing of your data - that is, to tell us not to process your data in this way. For example, you can tell us that you no longer want us to use your data for direct marketing. Direct marketing refers to any type of advertising that specifically addresses you, for example by sending you an email.
To better control what happens to your data, you have various rights. Depending on which law applies, you have the following options: You can ask us whether we process your data and, if so, what data we process, and you can ask us for a copy of your data. You can also request that we correct incorrect data (for example, an error in your address). You can also request that we give you certain data so that you can process it further. If you want, we can also pass it directly to another data controller so that they can process it. You also have the right to revoke any consent you have given us. You can also ask for your data to be deleted. Please note, however, that these rights sometimes only apply under certain conditions. It may also be that we may or must continue to process data despite an objection.
evulpo uses "online tracking". This means tracking on the internet. Imagine eating biscuits at home without using a plate and walking from room to room. This creates a trail of crumbs and your parents know exactly which way you went and also when you went back to the first room. There are technologies on the internet that work in a similar way. Websites put crumbs in your pocket, which you gradually lose. The websites recognise you when you come back. In reality, these are not crumbs, but files (small texts or pictures) that we or others place on your computer. We call these files "cookies":
Some cookies are used to enable evulpo to function at all and to allow you to switch from one page to another, for example. These cookies are only stored on your computer for a short time.
There are also cookies that monitor how you use evulpo. They remain on your computer even when you are no longer on the internet (i.e. when you close the windows of your browser). Various service providers help us to take a closer look at these cookies and to conclude how we can make evulpo more interesting for you.
Other cookies make it possible for us and our advertising partners to decide to whom advertisements about evulpo are shown on the internet. The cookies help us and our advertising partners to show you and others advertisements that are likely to interest you. If you say "no" to such cookies, you will not see less advertising, but just any other advertising.
We also use techniques similar to cookies to advertise evulpo. For example, we may share your email address with our advertising partners who operate a platform themselves, such as Facebook. If you have an account there under the same email address, our advertising partners will show you our advertising. If you do not have an account there, our advertising partner will not know your email address, but that there is a connection between you and evulpo. . If you want to prevent cookies, it is best to ask your parents to help you. Please note, however, that evulpo may no longer function properly depending on which cookies you prevent.
Among other things, "Google Analytics" helps us study data to improve evulpo and make it more interesting. Google Analytics is operated by the companies Google LLC and Google Inc ("Google"). Google helps you to say "no" to cookies via this link: https://tools.google.com/dlpage/gaoptout?hl=de.
Mixpanel" also helps us with this examination of data. Mixpanel is operated by the company Mixpanel Inc ("Mixpanel"), also in the United States.
Hotjar is a web analytics service provided by Hotjar Ltd. ("Hotjar") (http://www.hotjar.com, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe), which enables evulpo to use the platform analyze. Hotjar stores this data on servers in Europe (Ireland). Information on the opt-out plug-in can be found here: Hotjar - Do Not Track
This Privacy Policy is dated 8 December 2022 and is available to you at any time on our website.