Last updated: November 3, 2024
The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.
This policy is split into sections as follows:
This policy applies to all products built and maintained by Benjamin Paddags (for the sake of simplicity referred to as "we") including LanGam.
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with us). We refer collectively to these categories of individuals as "you" throughout this policy.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for a Benjamin Paddags product, we ask for identifying information such as your name and email address. This allows you to recover your account using your email address if you forget your password, personalize your new account, and receive essential product updates (Legal basis: Contractual Necessity). We may also send you optional surveys to understand how you use our products and to make improvements (Legal basis: Legitimate Interest). With your consent, we will send you our newsletter and other updates (Legal basis: Consent). We sometimes also give you the option to add a profile picture that displays in our products (Legal basis: Consent).
We’ll never sell your personal information to third parties, and we won’t use your name in marketing statements without your permission either.
If you sign up for a paid Benjamin Paddags product, you will be asked to provide payment information and a billing address. Credit card information is submitted directly to our payment processor and does not reach Benjamin Paddags servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, to maintain account history, invoicing, and billing support (Legal basis: Contractual Necessity and Legal Obligation). We store your billing address for invoicing, sales tax calculation, and fraud detection (Legal basis: Legal Obligation). We occasionally use aggregate billing information to guide marketing efforts (Legal basis: Legitimate Interest).
We store data necessary for you to use our products, such as the languages you learn in LanGam and your vocabulary study history, games started, and in-game progress. This data is kept as long as your account is active (Legal basis: Contractual Necessity). If you delete your account, we’ll delete this content within 60 days.
For most of our products, we log the IP address used to sign up for an account to mitigate spam signups (Legal basis: Legitimate Interest). We also log all account access by IP address for security and fraud prevention purposes, retaining this login data as long as your account is active (Legal basis: Legitimate Interest).
We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active (Legal basis: Legitimate Interest).
We use CAPTCHA across our applications to mitigate brute force logins and prevent spam. CAPTCHA assesses various information, like IP address and mouse movements, to detect non-human activity (Legal basis: Legitimate Interest).
Benjamin Paddags runs contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to the LanGam marketing site. Where permissible under law, we may load an ad-company script on their browsers that sets a third-party cookie and sends information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form (Legal basis: Legitimate Interest).
We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics (Legal basis: Consent for non-essential cookies).
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off. Where we use third party cookies and tracking, we show you a cookie consent banner at your first visit, where you can adjust your preferences.
When you email Benjamin Paddags with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future (Legal basis: Legitimate Interest).
We also store information you may volunteer, for example, written feedback or responses to surveys (Legal basis: Consent).
To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you. We establish GDPR-compliant data processing agreements with each subprocessor, extending GDPR safeguards everywhere personal data is processed. We use the following third-party subprocessors for LanGam:
LanGam also integrates chatbot solutions by OpenAI, but we do not expose any personal data we have saved about you. Only what you type into the chat is shared with OpenAI. The chat function is a part of the fictional game and there is thus no reason for you to type any personal data into the chat. To the extent permissible by law, it is you who is responsible for your use of the chat functionality.
To exclude you from seeing our ads. Where permissible by law and if you have a LanGam account, we may disclose a one-way hash of your email address with ad companies to exclude you from seeing our ads.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding abuse of our services. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. Benjamin Paddags is a Danish company and all data infrastructure is located in the Germany.
Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if German or Danish law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to disclose data, we must comply. Likewise, we will only respond to requests from government authorities outside these countries if compelled through procedures outlined in a mutual legal assistance treaty or agreement. It is our policy to notify affected users before we disclose data unless we are legally prohibited from doing so, and except in some emergency cases.
If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.
Finally, if Benjamin Paddags is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.
At Benjamin Paddags, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
Some of these rights can be exercised by signing in and updating your account information. Otherwise, please contact privacy@langam.app and we will assist you. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at privacy@langam.app. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. Most data are not encrypted while they live in our database (since they need to be ready to send to you when you need them). To secure your data at rest, we use role-based access controls to limit who can access different types of data. We use secure authentication measures, such as unique logins and strong passwords for accessing databases and administrative dashboards. We periodically review and update our security practices.
We keep your information for the time necessary for the purposes for which it is processed (for most data, this is until you delete your account). The length of time for which we retain information depends on the purposes for which we collected and use it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our products and other web properties are operated in the EU and no personal data is transferred to third party servers outside of the EU.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.
Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at privacy@langam.app and we’ll be happy to try to answer them!
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Adapted from the Basecamp open-source policies / CC BY 4.0