Privacy Policy for Gabi Education Limited
This is Gabi Education Limited Privacy Policy. It was last updated on 18 November 2019.
Policy Summary
Personal Data collected and the reasons for processing
- Gabi Education Limited: Generally, we do not automatically process any personal data from users from “our application(s)”.
- iOS Subscription Applications: The only exception to this is when you subscribe to an iOS application made by Gabi via the Apple App Store – where Apple creates a Subscriber ID to provide us with information about the subscription you purchased and your country of residence.
- gabi.hk Website: We do not process any personal data from users of “our website”.
Contact Information
Owner and Data Controller Gabi FUNG Email the data controller: info@gabi.hk
Further information about Personal Data
Gabi Applications and Websites are directed to children under the age of 13.
The “Application(s)” and “Website(s)” are directed to children under the age of 13. They do not collect, store or use any personal data about the child.
You or the parent/guardian may review the personal data collected – if any – outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Data Controller.
Full Privacy Policy
Personal Data collected and the reasons for processing
- Gabi Applications: Generally, we do not process any personal data from users of “our application(s)”.
- iOS Subscription Applications: The only exception to this is when you subscribe to an iOS application made by Gabi via the Apple App Store – where Apple creates a Subscriber ID to provide us with information about the subscription you purchased and your country of residence.
- gabi.hk Website: We do not process any personal data from users of “our website”.
Contact Information
Owner and Data Controller Gabi FUNG Email the data controller: info@gabi.hk
Further information about Personal Data
Gabi Applications and Websites are directed to children under the age of 13.
The “Application(s)” and “Website(s)” are directed to children under the age of 13. They do not collect, store or use any personal data about the child.
You or the parent/guardian may review the personal data collected – if any – outlined in the rest of this policy, ask for its deletion and request any further collection or use to be omitted by contacting the Data Controller.
How we use information we collect
We only process your personal data when necessary. When we do process your personal data, the lawful basis has been deemed to be ‘legitimate interests’.
Broadly speaking ‘legitimate interests’ means we can process your personal data if:
- We have a genuine and legitimate reason, and;
- We are not harming any of your rights and interests
Legal bases for processing (for EEA users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws.
Email Communications
The lawful basis for processing personal data is ‘Legitimate Interests’. This is based on the following ‘legitimate interests’:
Gabi
- Customer Support: Respond to user enquiries about “our applications” and “our website(s)”.
- Account Administration: Process instructions from users of “our applications” and “our website(s)”.
- Related Products: Other Gabi education products may be of use to parents/guardians and children.
Parents/Guardians/Children
- Customer Support: Ability to ask questions, and get answers, about Gabi products.
- Account Administration: Ability to send administration requests.
- Related Products: Get information about related products from Gabi
How we store and secure information
We only use data hosting service providers in the European Union or companies participating in the EU – U.S. Privacy Shield Framework to host the information we collect, and we take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the your personal data.
While we implement safeguards designed to protect your information, no security system can be guaranteed to be 100% secure, so we cannot guarantee the absolute security of your personal data due to the inherent nature of the Internet.
How long we keep information
How long we keep information we collect about you depends on the type of information, which is described in further detail below.
Email Communications If you contact us with a query about our products, or to inform us of a technical issue that you are experiencing, the personal data you provide will be processed in order to fulfill your request(s). Your personal data is only kept for the time necessary to provide the service requested by you.
Once that service has been provided, we will ensure the secure deletion of your personal data from our servers within 12 months.
At any time, you can request that the Data Controller suspend or remove the data.
Your Rights
If, at any time, we process your personal data, you have the following rights:
- The right to be informed: We will provide you with details of why and how we process your personal data at the point of data collection.
- The right of access: You can request access to the personal data that we process.
- The right to rectification: You can request that your personal data is rectified if it is inaccurate or incomplete.
- The right to erasure (the ‘right to be forgotten’): You can request the deletion or removal of your personal data.
- The right to restrict processing: You can request that we restrict the processing of your personal data.
- The right to object: You have the right to object to Gabi processing your personal data.
How to access and update your Personal Data
Email Communications Your personal data can be accessed and updated at any time. To do so, please contact the Data Controller:
By Email: info@gabi.hk
How to request we delete your Personal Data
Email Communications Your personal data can be deleted, at any time. To do so, please contact the Data Controller:
By Email: info@gabi.hk
How to withdraw your consent
If you have consented to Gabi processing your personal data, you have the right to withdraw your consent, at any time. To do so, please contact the Data Controller:
By Email: info@gabi.hk
How to make a complaint
You can make a complaint about how we use your personal data, at any time. To do so, please contact the Data Controller:
By Email: info@gabi.hk
Complaints will be dealt with by the Data Controller, and will be responded to within 30 days at the latest.
If you are not satisfied with the way your complaint was handled, you may be able to refer your complaint to your local data protection regulator. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Australia this is the Office of the Australian Information Commissioner.
Changes to the Privacy Policy
Should we change our privacy policy, we will post the changes here. Where the changes are significant, we may also choose to email users that we hold personal details for with details of the update. Where required by law, will we obtain your consent to make these changes.
Personal Data
Personal Data (also referred to as “personally identifiable information”) is any data that can be used to directly or indirectly identify a specific individual. Examples of personal data can include, but are not limited to:
- name
- postal address
- email address
- telephone number
- IP address: Internet Protocol address – a numerical label assigned to each device connected to the internet
- login IDs: information such as a username or email address
- geolocation: the geographical location of a person or device
- biometric data: fingerprint or facial recognition information
- behavioural data: information about how and what an individual user does within one of our products
Application(s)
The software created by Gabi for iOS & Android devices – the tools by which the Personal Data of the User may be collected
Website(s)
A set of related web pages created by Gabi Limited located under the following domain names, the tools by which the Personal Data of the User may be collected:
- http://gabi.hk
Data Controller (or Owner)
The natural person, legal person, or organisation responsible for protecting information – for the purposes of this privacy policy it is Gabi.
Data Processor
The natural person, legal person, public administration or any other body, association or organisation authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.
Data Subject
The legal or natural person to whom the Personal Data refers.
User
The individual using the “application” or “website”, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.