Privacy Policy

1. Introduction

We are committed to safeguarding the privacy of our users.

This policy applies where we are acting as a data controller with respect to the personal data of our users; in other words, where we determine the purposes and means of the processing of that personal data.

We use cookies on our website. In this document, we describe why they are necessary for the provision of our services.

In this policy, "we", "us" and "our" refer to Joubel AS. For more information about us, see Section 12.

2. Credit

This document was created using a template from Docular (https://docular.net).

3. How we use your personal data

In this Section 3 we have set out:

  • the general categories of personal data that we may process;
  • the purposes for which we may process personal data; and
  • the legal bases of the processing.

We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data is Google Analytics using settings to anonymize your identity, and HotJar. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, e.g. learning which path a user takes to find the information he or she is looking for, or learning about the browser to know which one should be supported, or offering you the opportunity to use third party services that we cannot supply ourselves.

We may process your account data ("account data"). The account data may include your login name and your email address. The account data may be processed for the purposes of operating our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and to offer you our services.

We may process your information included in your personal profile on our website ("profile data"). The profile data may include your real name (if provided), email address, profile picture (if provided), location (if provided), and duration of your membership. The profile data may be processed for supporting communication among community members by providing information to get to know each other better and to provide you with information that you requested, e.g our newsletter. The legal basis for this processing is our legitimate interests, namely building a community around our services that can provide support among each other, and to inform you about news.

We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include the content that you provided us with as an author, e.g. your voice for speech recognition, and your interaction results as a user: start time, finish time and score. The service data may be processed for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, and providing our services to you.

We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication, e.g. providing content or forum posts. The legal basis for this processing is our legitimate interests, namely offering you our services, and building a community around our services that can provide support among each other.

We may process information contained in any enquiry you submit to us regarding our services ("enquiry data"). The enquiry data may be processed for the purposes of answering our users’ enquiries and offering relevant services to them. The legal basis for this processing is our legitimate interests, namely to answer your enquiries and to inform you about our services that may be relevant you.

We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with you, communicating with you, keeping records of those communications and promoting our products and services to you. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is our legitimate interests, namely informing you about new answers to you forum posts, account problems, or informing you about our services, news and progress made.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and efficient communications with you.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose all personal data categories to our suppliers or subcontractors insofar as reasonably necessary for operating our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you, administration of our website and business, and providing our services to you.

  • Amazon
    For hosting our website h5p.com, we are using the infrastructure and services of Amazon, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA. While hosting our website, Amazon may process usage data, account data, profile data, service data, publication data, enquiry data, and notification data for the purposes mentioned in Section 3. Amazon is Privacy-Shield certified and offers a guarantee to comply with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4). For further information about how Amazon processes data and how you can object, please consult their privacy policy (https://aws.amazon.com/privacy/).
  • DigitalOcean
    For hosting our website h5p.org, we are using the infrastructure and services of DigitalOcean, 101 Avenue of the Americas, 10th Floor New York, NY 10013, USA. While hosting our website, DigitalOcean may process usage data, account data, profile data, service data, publication data, enquiry data, and notification data for the purposes mentioned in Section 3. For further information about how DigitalOcean processes data and how you can object, please consult their privacy policy (https://www.digitalocean.com/legal/terms/).
  • Google/YouTube
    We may provide Google Analytics with usage data in general, and we may provide usage data to YouTube, because we are embedding videos hosted on YouTube for the purpose of demonstrating our services. Also, we’re using Gmail to process enquiry data, customer relationship data, and correspondence data if you use our contact form of forum for the purposes mentioned in Section 3. Furthermore, we may provide Google Cloud with your service data if you are using Speak the Words for the purposes mentioned in Section 3. Google Analytics, Google Cloud, Gmail and YouTube are services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google uses cookies, and with it we are providing usage data for the purposes mentioned in Section 3. The usage data that’s created by using our website will generally be transferred to and stored on a server hosted by Google in the USA. Google is Privacy-Shield certified and offers a guarantee to comply with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI).  For further information about how Google processes data and how you can object, please consult their privacy policy (https://policies.google.com/privacy and https://policies.google.com/technologies/ads).
  • Groove
    If you reach out to us via email, our forum or the contact form on our website, we may provide publication data, enquiry data, customer relationship data, and correspondence data to Groove Networks, LLC, 100 Cummings Center, Suite 535Q, Beverly, MA 01803, United States for the purposes mentioned in Section 3. For further information about how Groove processes data and how you can object, please consult their privacy policy (https://www.groovehq.com/our/privacy).
  • HotJar
    We may provide HotJar with usage data to learn about how you interact with our website for the purpose of learning how it can be improved. HotJar is a service of Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street St Julians STJ 1000, Malta. HotJar will set a cookie when you use our website, and with it we are providing usage data for the purposes mentioned in Section 3. For further information about how HotJar processes data and how you can object, please consult their privacy policy (https://www.hotjar.com/legal/policies/privacy).
  • MailChimp
    If you subscribe to our newsletter, we may provide profile data to The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA for the purposes mentioned in section 3. The Rocket Science Group/MailChimp is Privacy-Shield certified and offers a guarantee to comply with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG). For further information about how MailChimp processes data and how you can object, please consult their privacy policy (https://mailchimp.com/legal/privacy/).
  • ProsperWorks
    If you reach out to us, we may provide enquiry data, customer relationship data, and correspondence data to ProsperWorks Inc., 301 Howard St. #600, San Francisco, CA 94105, USA for the purposes mentioned in Section 3. ProsperWorks is Privacy-Shield certified and offers a guarantee to comply with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000CbBKAA0). For further information about how ProsperWorks processes data and how you can object, please consult their privacy policy (https://www.prosperworks.com/privacy).
  • Twitter
    We may embed a feed hosted on Twitter for the purpose of demonstrating our services. Twitter is a service of Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Twitter will set a cookie if you click on the Twitter share button or watch the Twitter content type demonstration, and with it we are providing usage data for the purposes mentioned in Section 3. The usage data that’s created by using our website will generally be transferred to and stored on a server hosted by Twitter in the USA. Twitter is Privacy-Shield certified and offers a guarantee to comply with European data privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO). For further information about how Twitter processes data and how you can object, please consult their privacy policy (https://twitter.com/en/privacy).

Financial transactions relating to our website and services may be handled by our payment services providers in the future. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at their website.

In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting personal data

This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data until you request deletion.

Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Non-personal data

If you are using H5P, we may collect anonymized statistics. We do so in order to learn how people create content, so we can improve our service. The statistics do not contain personal data. Nevertheless, we want to make their use transparent. You can find more details at https://h5p.org/tracking-the-usage-of-h5p. 

7. Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of significant changes to this policy by email.

8. Your rights

In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is:

  • consent; or
  • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

9. About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

We use cookies for the following purposes:

  • authentication - we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are set by h5p.org);
  • status - we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are set by h5p.org);
  • personalisation - we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: a cookie set by Drupal for preferences, a cookie set by our Interactive Video Player to remember the preferred caption language, a cookie for the WYSIWYG editor for preferences);
  • security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: a PHP session cookie and a cookie by CloudFront that provide a secure login and protection against Cross-Site Request Forgery);
  • analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: a 3rd party cookie set by Google Analytics and a 3rd party cookie set by HotJar); and
  • cookie consent - we may use cookies to store your preferences in relation to the use of cookies more generally in the future.

11. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

We use Twitter to offer you an optional Twitter feed timeline in our services. This service uses cookies for displaying advertisements that will be relevant to you. You can view the privacy policy of this service provider at https://twitter.com/en/privacy.

It is in our legitimate interest to add interesting and affordable options to our services, in particular to provide you with an opportunity to embed and follow Twitter feeds in your content. We would not be able to provide this service to you for free without using Twitter’s services. The Twitter cookies are only set when viewing H5P content that includes a Twitter feed. Blocking the Twitter cookie is not possible for us without blocking the entire Twitter feed, but you may block the Twitter cookies in your browser settings without blocking the entire Twitter feed.

We use YouTube to offer you an optional video service in our services. This service uses cookies for displaying advertisements that will be relevant to you. You can view the privacy policy of this service provider at https://policies.google.com/privacy.

It is in our legitimate interest to add interesting and affordable options to our services, in particular to provide you with an opportunity to embed videos in your content and to watch them. We would not be able to provide this service to you for free without using YouTube’s services. The YouTube cookies are only set when viewing H5P content that includes a YouTube video. Blocking the YouTube cookies is not possible for us without blocking the entire YouTube video. Blocking the video would destroy the entire content. You may block the YouTube cookies in your browser settings without blocking the entire YouTube video.

12. Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

13. Our details

This website is owned and operated by Joubel AS.

We are registered in Norway under registration number 912 282 910, and our registered office is at c/o Flow Coworking AS Strandgata 9, 9008 Tromsø.

Our principal place of business is at c/o Flow Coworking AS Strandgata 9, 9008 Tromsø.

You can contact us:

  • by post, to the postal address given above;
  • using our website contact form; or
  • by email, using the email address published on our website.

14. Data protection officer

Our Data Protection Officer can be contacted at [email protected].