Europe and the rest of the World
Address: 3DBear Oy, c/o Startup Maria,
00180 Helsinki, Finland
Business ID: 2778736-8
Contact Person: Kristo Lehtonen (firstname.lastname@example.org)
Name of the register
Customer and marketing register of 3DBear Oy (the “Register”).
3DBear Oy (“3DBear” or “we”), collects personal data of its customers, users and visitors of its websites and applications whilst providing its services. The 3DBear application is the mobile application developed by 3DBear in order to provide its services to customers using mobile and other handheld devices. To use the service, you are required to register to 3DBear by providing your real name or alias and your email address. Some functions and sub-services of the site and application may require more information to be provided, but this will be clearly stated and you will be requested to provide the extra information before you can use these certain services and functions.
Purpose for processing personal data
There are several purposes for the processing of your personal data by 3DBear:
To provide our services
3DBear processes your personal data in the first place to be able to deliver our services to you and to run, maintain and develop our businesses. We would like to know who you are, so we can tailor our service to meet your needs and desires as precisely as possible. Some of the functions and services on this site and our application are simply unable to work properly if we do not know who is using them. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. In order to ensure that our services and products are in line with your needs, these data can be used for things like customer satisfaction surveys. We might also request another party to do this for us.
For customer communication (including marketing)
3DBear processes your personal data to contact you regarding our services and to inform you of changes to our services. Your data is also used for research and analysis to improve our services, websites and applications. We may also use your data entered on our websites and applications in certain cases to send information and marketing communication by e-mail, provided that you have given us consent to that or other legitimate grounds for such marketing communication exists.
Legitimate grounds for processing and storage limitation
3DBear processes your personal data to perform our contractual obligations towards you and to comply with legal obligations. Furthermore, we process your personal data to pursue our legitimate interest to maintain and develop our businesses.
Processed Data and Sources of Data
3DBear collects two types of information from our customers: (i) Customer Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify you as an individual, you can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.
We may collect the following basic Customer Data and store it in the Register: (i) first and last name; (ii) e-mail address, telephone number, address; (iii) payment information and transactional data. In addition, we may collect the following data arising from the customer relationship (i) information relating to maintaining the customer relationship; (ii) information on marketing permissions; and (iii) customer service data.
We may collect Customer Data from our customers and visitors in a variety of ways, including, when they register to our service, when they submit customer feedback, claims or other communication or when they subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments you carry out through our service. We will collect Customer Data from customers and visitors only if they voluntarily submit such information to us or carry out transactions or payments through our services, sites or applications. We may also update and supplement personal data with information provided by third parties in accordance with applicable data protection laws.
We and/or our authorized third party service providers, may automatically collect Technical Data when you visit or interact with our service, site or application. Technical Data may include the browser name, the type of computer or device, time spent on website, interaction with the services, URL of the website you visited before and after visiting the Services, the time and date of user visits, surfing habits, IP address, operating system and the Internet service providers utilized and other similar technical information.
The Service may also contain advertisements served by third parties that deliver cookies or other tracking technologies to your device so your online activities across third-party sites or online services can be tracked for advertising purposes. These third-party services are governed by separate privacy policies. The Network Advertising Initiative provides opt-out mechanisms from some behavioral online advertising: www.networkadvertising.org/choices/. Users located in the European Union can learn of their rights relating to online advertising at www.youronlinechoices.eu.
Transfer to countries outside Europe
3DBear may transfer your personal data to countries outside the European Union and the European Economic Area. When we transfer any data to a country for which no adequacy decision of the European Commission exits, such transfer will be subject to the provisions of the (standard or other) clauses adopted by the European Commission. If you wish to know more about international transfers of your personal data, you may contact us via the contact details above.
We do not share your personal data with third parties outside unless one of the following circumstances applies:
For legal reasons
We may share your personal data with third parties if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of 3DBear, our users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
For other legitimate reasons
With your explicit consent
We may share your personal data with third parties outside 3DBear for other reasons than the one mentions before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.
Right to access
3DBear offers you access to the personal data we process. This means you can contact us asking us to inform you about your personal data that we have collected and processed and the purposes such data are used for. We may charge a processing fee in case less than 12 months have passed since your last data request.
Right to correct
You have the right to have incorrect/unprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed by contacting us.
Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data have been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems.
Right to object
You may object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of our services or for compliance with a legal obligation. You may also object any further processing of your personal data after prior given consent. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our websites, applications and other services.
You have the right to opt out of receiving electronic direct marketing communications from us by clicking on the opt-out link provided in all marketing communications we send you, and choosing not to receive marketing communications from us in the future. You also have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling by contacting us on the addresses indicated above.
Right to restriction of processing
You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our websites, applications and other services.
Right to data portability
You have the right to receive your personal data from us in a structured, commonly used format in order to transmit the data to another controller.
How to use your rights
You may use these rights by sending a letter or e-mail, including your name, address, phone number and a copy of a valid ID to us on the addresses set out above. If your request regards personal data in a cookie, you have to enclose a copy of the said cookie. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection.
We will take all reasonable, appropriate security measures to protect 3DBear and our customers from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible.
1. What is 3DBear?
Note about Children: As required by applicable law and our Terms of Service, children under the age of 13 (or a higher age if required by applicable law) (“Child(ren)”) may only use our Services with the express prior consent of a parent or legal guardian. Children are prohibited from using the Services without the necessary parental consent. Teachers or administrators providing access to the Services for Children are responsible for obtaining any necessary parental consent prior to doing so. If you are a parent and believe that 3DBear has received or collected personal information regarding your Child without prior consent, please contact us immediately at email@example.com.
2. What is this policy?
Information Sharing: Remember that if you create a Profile (as defined below) or share personal information with other users on the Services, your information may be public. Note that we do not share your Personal Information with third parties for their marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled "Will 3DBear share any of the information it collects?"
Third party analytics providers: We work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.
3DBear never conducts advertising or marketing activities using student Personal Information. Please review "Third Party Analytics Providers” for additional information.
3. What information does 3DBear collect?
Information Shared With Us
1. Registration and Other Information You Provide
The Services may collect "Personal Information" (which is information that can reasonably be used, alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to, student data, metadata, and user content. This may include a name, email address, username, password, or assessment results. We may also use third parties to collect payment information (typically, credit card account information) if you choose to purchase a paid account. Any information combined with Personal Information will be treated as Personal Information.
2. Your Account, Community Forums and User Content
Your Account: You will have the opportunity to create an account, which consists of information about you, which may include Personal Information.
Community Communications: The Services may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality ("Community Communications").
Note that anything you post to a Community Communication may be public.
3. Third Party Services, Social Media Platforms, and Information Third Parties Provide About You
Third parties may provide us with information about you. For example, if you are on a third party web site, and you opt-in to receive information from us, that third party will forward information about you to us so that we may contact you as requested.
Information We Collect Automatically
Like other web sites and online services, we and our analytics providers, vendors and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the Services.
Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit, and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.
In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data.. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Usage Information is collected via tracking technologies, including:
1. Cookies: Our Services utilize Cookies to improve your current and future experience by allowing us to understand your usage of our Services. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. Cookies are small text files stored on your computer that allow us to personalize the content of our Services. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of our Services may not function properly.
2. Web Beacons: We may employ a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our Services by informing us of what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users for our affiliate program. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. This information is used to help improve the overall quality and experience of our Services. We tie the information gathered by clear gifs to our customers' Personal Information.
3. An Embedded Script: is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third party service provider and is deactivated or deleted when you disconnect from the Services.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
4. Flash & HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information.
Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here:
How We Respond To Do Not Track Signals:
Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.
4. How does 3DBear use the information it collects?
We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information to:
(1) Allow you to participate in features we offer or to provide related customer service, including, without limitation, to respond to your questions, complaints or comments;
(2) Tailor content, recommendations and offers we display to you, both on the Services and elsewhere online;
(3) Provide you with information;
(4) Process your registration with our Services, including verifying your e-mail address is active and valid;
(5) Improve the Services and for internal business purposes, including the measurement of ad effectiveness;
(6) Contact you with regard to your use of the Services and, in our discretion, changes to our policies; and
(7) Permit other 3DBear users to contact you, and vice versa; and
Please note that information submitted on the Services via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.
5. Will 3DBear share any of the information it collects?
3DBear does not share student Personal Information with third parties for their marketing purposes in compliance with all applicable laws (including California Business & Professions Code section 22584 ("SOPIPA"), and California Education Code section 49073.1). 3DBear may share non-student Personal Information for marketing purposes to the extent permissible by applicable laws. 3DBear may also share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties.
1. Service Providers
We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, such as shipping your order, sending our emails, or offering customer service. If you purchase any products or services, our billing partner will receive billing and financial information (e.g., credit card numbers) necessary to process your charges, including your postal and e-mail addresses, depending on your payment method.
2. Administrative, Legal Reasons & Academic Integrity Investigations
We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you.
3. Business Transitions
4. Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
We display personal testimonials of satisfied users on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.
6. How does 3DBear work with third parties?
No Targeted Advertising to Students or Parents
3DBear will never use any student Personal Information to advertise or market to students or their parents. We will not mine student Personal Information any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to students or their parents is prohibited.
Third Party Analytics Providers
We work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services and to provide us with information regarding the use of the Services.
Third Party Content, Links to Other Sites, and 3DBear Content Found Outside of the Services
Certain content provided through the Services may be hosted and served by third parties In addition, the Services may link to third party web sites or content over which 3DBear has no control and which are governed by the privacy policies and business practices of those third parties. In addition, third-parties may have different privacy policies which apply to such third party use of your information.
Please also note that 3DBear content may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data. 3DBear is not responsible or liable for the privacy practices or business practices of any third party.
7. What happens if I access 3DBear’s services through a mobile device?
If you use the Services through a mobile device or one of our mobile applications, you agree that 3DBear may store and use that information for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately). You may be able to opt-in to receiving text messages from 3DBear. You may always opt-out by replying "STOP" to one of the text messages received. You also acknowledge and agree that use of the Services through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access provider.
Push Notification: We will send you push notifications if you agree to receive them. You may opt-out of receiving these at any time by going to the phone settings and turning them off.
8. How does 3DBear protect children’s information?
Protecting the privacy of young children is especially important to 3DBear. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 16 years of age (“Child Users”). 3DBear does not knowingly permit Child Users to use our Services without prior, express consent from a parent or legal guardian. If we learn that Personal Information of a Child User has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian (“Parent”) and discover that your child under the age of 13 has a registered account with our Services without your consent, please alert 3DBear at firstname.lastname@example.org and request that we delete that child’s personal information from our systems.
How does a child register and use the services?
Schools and/or teachers are required to obtain any necessary parental consent before providing Child Users with access to the Services. Any consumer user must register and pay the subscription with a valid credit card prior to accessing the Services. By accepting those charges, the parent is consenting to a Child User accessing the Services and providing Personal Information to 3DBear.
What children’s information is visible to others?
No student’s profile is made available or visible to the public through 3DBear. If a teacher utilizes certain features through 3DBear’s App on a device in the classroom, other students can view User Content created by other students this shared device, but students can’t view each other’s information directly.
Parents can request to view their own child’s User Content by contacting their child’s teacher or school.
9. How does 3DBear protect and store my information?
3DBear takes data security very seriously. 3DBear takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. Measures taken to protect your data include:
We continually test 3DBear’s security practices for vulnerabilities
We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
We continually develop and implement features to keep your personal information safe - for example, when you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL/TLS) by default
We ensure passwords are stored and transferred securely using encryption and salted hashing
We also operate a ‘bug bounty’ security program to encourage an active community of third party security researchers to report any security bugs to us. More information on this is available by contacting us at email@example.com
Every 3DBear employee participates in training on the importance of and methods for protecting Personal Information. Training consists of how to remain compliant with federal and state regulations (e.g . COPPA), 3DBear policies, and general security posturing to protect student data (including techniques such as Two Factor Authentication, Drive Encryption, creating and managing strong passwords, etc).
All 3DBear employees are trained in security practices and procedures designed to keep Your Data under strict internal controls.
Developers peer-review code to make sure changes adhere to best practices for security.
Administrators are knowledgeable of security practices and harden the infrastructure with necessary patches, monitor security resources for advisories and vulnerabilities, and scan the environment and application to ensure that student information remains secure.
Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
How will 3DBear handle a data breach or security incident?
In the event that 3DBear becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage (www.3dbear.io) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
3DBear has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, document and take proactive steps to ensure the incident cannot be repeated. 3DBear will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, 3DBear will follow its internal procedures, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and students may have been impacted, the data that may have been accessed, 3DBear’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.
In the unlikely event of an unauthorized disclosure of Data, 3DBear has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.
If you have any questions about security on our Services, you can email us by clicking here.
10. How can I opt-out of sharing, providing, or receiving certain information?
Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it’s important to remember that many of 3DBear’s features may not be accessible, or may not function properly - for example, we may not be able to remember your language preferences for you.
Mobile Use: You may always opt-out of receiving text messages by replying "STOP" to one of the text messages received. You may opt-out of receiving push notifications at any time by going to the phone settings and turning them off.
Email Communication: You can opt-out of receiving further communications by clicking the unsubscribe button at the bottom of the email.
11. How can I access and manage my personal information?
You may be able to review the information you provided to us on a Service and make any desired changes to the information by contacting 3DBear at firstname.lastname@example.org. Requests regarding users participating through school or teacher accounts must be made through the applicable school or teacher.
12. What communications will I receive from 3DBear and how do I limit them?
All changes to your email settings and preferences must be made by using the unsubscribe button at the bottom of the 3DBear email. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account.
13. How do I close my account?
If you wish to close your account with one of our Services, please send your request via email to email@example.com and we will remove your Personal Information and Account, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and send your request using an email account that you have registered with 3DBear under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it. Requests to change your email preferences or unsubscribe from all emails may not be made through this email address, but rather must be submitted through one of the channels set out in the previous section.
14. How long does 3DBear keep my information?
Upon termination of your Account, 3DBear will take commercially reasonable steps to delete any Sensitive Information from its live databases in a reasonable amount of time not to exceed ninety (90) days. You understand and agree that 3DBear may continue to have Sensitive Information in archive files or similar databases. You further agree that 3DBear has no obligation to delete aggregated or de-identified information. 3DBear may retain and use aggregated and de-identified information for any purpose that is consistent with laws and regulations.
15. How will 3DBear notify me of changes to this policy?
16. What if I don’t live in the U.S.?
Consent to Transfer
18. How can I contact 3DBear with questions?
WeWork Irving Place
33 Irving Pl, New York