Privacy Policy

Last updated: October 2021

  1. Introduction

The “Service” is a platform that enables people to connect via video and audio calls while interacting in a 2D space. Its users are able to access and upload content, and have access to certain features and content provided by Fresco. The Service a part of the family of apps of Kahoot! ASA (company reg. no. 997 770 234) (“Kahoot”) and its subsidiaries (the “Kahoot! Group”). For the purpose of this privacy policy, Kahoot is referred to as “Fresco”

Fresco is committed to protecting the privacy and security of your information and being transparent about how we process such information (“Personal Information“). This Privacy Policy describes the manner in which Fresco (“we“, “us“, or “our“) collects, uses and discloses your Personal Information and how you can exercise your data protection rights.  

We will not collect, use or share your information with anyone except as described in this Privacy Policy. The Personal Information we collect is used to provide and improve the Service. 

  1. What personal information we collect

The Personal Information we process depends on the context of your interactions with Fresco and the Service, and falls into the following categories: 

  1. We may process Personal Information you provide to us, including:
  • Account log-in credentials such as your email address or username and password when you sign up for an account with us.
  • Account holder information such as your location, profile picture, and who you interact with by using the Service, as well as Kahoot! account information if you have a Kahoot! account.
  • Content you provide through our Service, such as video and audio streams, text, pictures, or other files.
  • Information you through our support channels.
  1. We may process some Personal Information automatically, including:
  • Browser or device information which is collected through your device, such as Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and version of the Services you are using.
  • Usage data which is collected whenever you interact with our Service, such as the dates and times you access the Services and your browsing activities (such as what portions of the Service you used). 
  • Log data whereby our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP-addresses and your activity in the Services.
  • Cookies. Please refer to our Cookie Notice for further information.
  1. Personal data collected by Third Parties

Personal Data about you might be given to us from other sources such as chat support, email, telephone, or from companies that distribute the Services by way of a co-branded or private-labelled website, companies that offer their products and/or services via the Services, or companies that provide services (such as payment processing services) in connection with the Services (collectively, “Partner Companies”). Our Partner Companies may supply us with Personal Data that was not already available to us. We may add this information-to-information we have already collected via our Services in order to perform and improve the Services. This Privacy Policy applies only to the use and disclosure of Personal Data that we collect while you use the Services. When you click on a third party link, you will leave our site and go to another site. Your connection to and use of such third party website and/or services are subject to such third party‚Äôs terms and conditions and privacy policy.

  1. How we use personal information

Fresco collects and uses your personal information for the following purposes and legal basis:

  • Providing the Service: Providing access and functionality to the Service and personalize your experience in order to manage our contractual relationship with you, or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Services. We may use information in the aggregate to understand how our users as a group use the services and resources provided on our Service.
  • Enable you with certain features: We may automatically process your Personal Information, in reliance of our legitimate interest, in order to enable you to use certain features of our Services, such as to make a comment or join a video call.
  • Communicate with you: To communicate with you about your account and our Service in order to perform our contract with you for the use of the Service, or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Services.  
  • Marketing: We may use your Personal Information in order to market, promote, and drive engagement with our Services in accordance with your marketing preferences and this Privacy Policy. We will not send you unsolicited or third party marketing. 
  • Support and improve the Service: We may use your Personal Information to support and improve our Service in order to comply with our contract with you for the use of the Service. Where we have not entered unto a contract with you, we may use such information in reliance on our legitimate interest in administering and improving the Service.
  • Optimalization of the Service: We may use third party services to optimize the Fresco platform in reliance on our legitimate interest in administering the Service and providing certain features. 
  • Comply with legal obligations: We may use your Personal Information in order to comply with any legal obligations, such as by court order or at the request by public authorities.
  1. Your data protection rights

You may have certain rights pertaining to your Personal Information. If you are in the EEA, Switzerland or the UK, your rights relating to the processing of your personal data by us as a controller includes:

  • Access, correct and update your Personal Information. You may submit an enquiry to access your Personal Information, or to correct and update any of the Personal Information we may hold on you. 
  • Delete, restrict or object to the processing of your Personal Information. You may ask us to erase the Personal Information we have collected, object to further processing of your Personal Information or restrict our processing of your Personal Information.
  • If the Personal Information we have collected is based on your consent, such as by signing up to our newsletter, you may withdraw your consent at any time.

If you wish to exercise any of your data protection rights, please contact us at [email protected] 

In addition, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction regarding our collection and use of your Personal Information. Contact details for all EU data protection authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

  1. How we share collected information

We do not sell, trade, or rent your personal identification information to others. 

  • Affiliates: We may disclose your Personal Information with companies affiliated with the Kahoot Group in reliance with our legitimate business purposes. 
  • Service Providers: We work with trusted third-party service providers, such as Amazon Web Services, to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
  • Public Institutions: We may disclose your Personal Information if ordered by any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
  1. International Transfers

We do not transfer or process your Personal Information to countries outside the EEA. However, to ensure that audit and video streams are provided to you without delay, we use a content delivery network. Therefore, if you are located outside the EEA when using our Service, video and audit streams will be processed by a server close to your location outside the EEA and transferred to/accessed from the EEA, as the case may be.

For any international transfers, both within the Kahoot Group or to our sub-processors, we ensure that the recipient of your Personal Information offers an adequate level of protection by entering into appropriate agreements. All international transfers are made on the basis of the EU commission approved standard contractual clauses (“SCC’s”). 

  1. Our security 

We use data hosting service providers in Europe to host the information we collect. We strive to protect the Personal Information we collect, and we have therefore implemented appropriate and reasonable technical and organisational measures designed to protect and secure your Personal Information. 

  1. How long is the data retained

We do not retain Personal Information that is no longer necessary for achieving the purpose for which it was collected. We may retain your information for the following purposes:

  • When the Personal Information is necessary to provide our Service. The Personal Information related to your account is deleted when the account is deleted. 
  • We may retain some of the information you share in the Service to allow other team members to continue using our Services after you have deleted your account, such as content uploaded to the Service. Such content is deleted once the space to which the content was uploaded is deleted. 
  • When we have a legal obligation, contractual need or legitimate interest to store your Personal Information. 

At your request, we may delete your account and the Personal Information we have collected.

  1. collection of Personal information from Children

Our Services are not directed at children, and you may not use our Services if you are under the age of 18. You must also be old enough to consent to the processing of your Personal Data in your country (in some countries we may allow your parent or guardian to do so on your behalf).

  1. Changes to this privacy policy

We may update this Privacy Policy from time to time at our discretion. We may notify you if there are material changes to how we handle your Personal Information. When we make changes to this Privacy Policy, we will revise the updated date at the top of this page.

  1. Contact us

If you have any questions about this Privacy Policy, inquiries or complaints concerning our processing of your Personal Information, or if you wish to exercise your data protection rights, please contact us at [email protected].