Kahoot! Privacy Notice
- The Basics
- Personal Information we process
- Use of Personal Information
- Third-Party Applications and Websites
- Your Data Protection Rights
- Sharing your Personal Information
- Our Security
- International Transfers
- Retention of Personal Information
- California, Colorado, Connecticut, Utah, and Virginia Consumers
- Do Not Track
- Changes to this Notice
- Our collection of Personal Information from Children
- Questions & Concerns
- Automated decision making or Profiling in respect of applicants for employment
- Controllers
- Direct marketing
- Annex A – Definitions
1. The Basics
About this Privacy Notice
Kahoot! is committed to protecting the privacy and security of the users of our Services and App, Visitors of our Websites, personnel of corporate customers and vendors, applicants for employment, and Visitors to our premises (together, “you”), and to being transparent about how we process information about you. This Privacy Notice describes how we process your Personal Information and how you can exercise your privacy rights. This Privacy Notice is issued by each of the Controller entities listed in Section 16 below (together, “Kahoot!”, “we”, “us” and “our”).
Capitalized terms have the meaning given to them in Annex A “Definitions”. Kahoot!’s Services allow our users to create and upload content, play and host games and invite others to join a game. Kahoot! acts as a processor for Personal Information in user content, and for Personal Information that we may otherwise collect and process on behalf of our users on our platform. Such processing is not covered by this Privacy Notice.
About Us
Kahoot! is a global educational technology and software-as-a-service group providing a learning platform for the global educational technology market. We focus on developing a comprehensive offering of engaging learning tools for enterprises, the educational sector as well as for personal users. The Kahoot! platform enables users to unlock their full potential through learning. More information about our Services and how you can use them can be found in our T&Cs and on this website.
The Services, App and Website do not include any third party advertising, including any targeted advertising.
Our handling of student information
We are dedicated to making learning awesome and we take the privacy of our users seriously. Keeping students’ Personal Information safe is a priority at Kahoot!. In this Privacy Notice, we also explain how we use the Personal Information we collect from and about students when they engage with Kahoot! in the classroom through the School Services. We use such Personal Information solely as a service provider or “processor” to our school and school district customers.
As a trusted provider of tools that help teachers and schools make learning awesome for students, Kahoot! is particularly concerned about the collection and use of students’ Personal Information. We only request the Personal Information of students that we need to provide the School Services to our customer, and we comply with applicable privacy laws, such as the EU’s General Data Protection Regulation (“GDPR”), the UK GDPR, the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), the California Student Online Personal Information Protection Act (“SOPIPA”) and other US state education privacy laws.
Kahoot! does not collect, retain, use or share students’ Personal Information, except as necessary for authorized school purposes, at the direction of our school and school district customers and pursuant to our agreements with them. Without limitation, this means that:
- We do not sell students’ Personal Information.
- We do not serve third party ads (including targeted ads) on our platforms and do not use information we collect from students or others to serve targeted ads on other services. Kahoot! does not use or disclose information collected through the School Services for any targeted advertising purposes.
- We do not build a profile of a student other than in support of authorized school purposes, such as for purposes of attendance or assessment.
- We retain students’ Personal Information only for as long as permitted by our agreements with our school or school district customers.
We support our school customers in providing parents and eligible students with access to their Personal Information and in fulfilling other requests that parents and eligible students may make, such as to request deletion of students’ Personal Information or to refuse its further collection or use. If you are, or your Child is, a student and you have questions or wish to exercise any rights that may be available to you or your Child under applicable law, please contact your school.
Our handling of candidate information
We use a recruitment vendor to assist with our recruitment process. The recruitment vendor processes Personal Information as a processor on our behalf, they are only entitled to process your Personal Information in accordance with our instructions.
When you apply for a job opening via a Partner’s website or application, you should note that the relevant Partner may retain your Personal Information and may also collect data from us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the relevant Partner’s own privacy notice.
2. Personal Information we process
The Personal Information we process depends on the context of your interactions with Kahoot!, your Kahoot! account settings, the products and features you use, your location and applicable law. However, the Personal Information we collect broadly falls into the following categories:
2.1 Information you provide to us: You may provide certain Personal Information to us when you sign up for a Kahoot! account and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your Google account with Kahoot!), apply for a job opening with us or communicate with us in any other way. This information may include:
- Personal details. Such as your given name(s); and preferred name;
- Contact details. E-mail address, mailing address, telephone number and job title of the contact person of users (for example businesses or educational institutions);
- Correspondence. Records and copies of your correspondence if you contact us;
- Data relating to our Websites and App, and your account. Such as:
- 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 (city and country only), interests, picture, organization, title/position, age, what Kahoot! groups you are part of and who you interact with by using the Services;
- Troubleshooting and support data, which is data you provide, or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry; and
- Information about your download and/or use of our App and Services.
- Payment details. Billing address and the last four digits and expiration of a stored credit card, or other payment information and financial information that we/our payment processors need in order to provide the Services;
Security information. Your encrypted password(s); login attempt details; security settings; and other security-related information; - Views and opinions. Any views and opinions that you choose to send to us, or publicly post about us on social media platforms;
- Communication data. Several of our Services let you share information with other people, and you have the control over what you share and with whom you share. For example, when signed in and interacting with certain Kahoot! Services, such as leaving comments on the Websites, you may disclose Personal Information to us and the general public. We strongly advise that you limit the disclosure of Personal Information through, for example, comments. Remember, when you share Personal Information publicly, for example through the comment section on our Website, the information you disclose may become publicly available and accessible through search engines. If you disclose Personal Information through comments within a Kahoot! group participation, i.e. not the general public, please note that the information you disclose will be available to other group participants;
- Information you make public. We collect or obtain Personal Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us);
- Content information. If you interact with any third-party content on a Website or in the App (including third-party plugins and Cookies) we receive Personal Information from the relevant third-party provider of that content;
- Consent records. Records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent);
- Employer details. Where you interact with us in your capacity as an employee of a third-party; and the name, address, telephone number and email address of your employer, to the extent relevant; and
- Demographic information. Gender (job applicants only); date of birth / age; nationality (job applicants only); salutation; title; and language preferences.
2.2 Additional Personal Information we collect from or about students:
- Children players. Kahoot! collects only a nickname, which is not linked to any other Personal Information, including any persistent identifier, from a Child who merely plays a Kahoot! game. We use the nickname to permit the Child to play;
- Student Data collected at a teacher’s direction. Certain features of the School Services permit a teacher to collect information about the class, as well as about individual students, such as games played, results, answers submitted when playing Kahoot! games and performance on Kahoot! games. We use such information only to provide the Services to the teacher, such as to permit the teacher to interact with students and track their progress over time. A school or teacher may permit students to share information with others, such as with other students in the same class, school or school district. Kahoot! acts as a processor when processing Student Data; and
- Player ID feature. A school or school district may enable the Player ID feature, which collects the following Student Data: (i) a student’s name (for grades K-12) and (ii) (for non Child users only) email address for purposes of attendance or assessment. Kahoot! acts as a processor when processing Personal Information as part of the Player ID feature.
2.3 Additional Personal Information we collect from or about candidates:
- Information you provide. This includes information provided through an online job site, via email, in person at interviews and/or by any other method. In particular, we process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to us, as well as your video in case you conduct your interview using the Video Interview feature; and
- Recruitment record. A record of your progress through any hiring process that We may conduct.
2.4 Information we collect automatically as Service Usage Data:
- In some (but not all) countries, including the UK and countries within the EEA, the following information may be considered Personal Information under applicable data protection laws and may include:
- Technical data:
- Browser or device information which is collected through your device, such as Media Access Control (MAC) address, screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version of the Services (such as the App) you are using;
- Usage data which is collected whenever you interact with our Service. This may include the dates and times you access the Services and your browsing activities (such as what portions of the Service you used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Service. If you are using our App, we may collect information about how often you use the App and other performance data. This information allows us to improve the content and operation of the Services and facilitate research and analysis of the Services;
- 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 (such as the date/time stamps associated with your usage, participation in Kahoot! games, results, pages and files viewed, searches and other actions you take (for example, which features you used)). We may also access metadata and other information associated with files that you upload into our Services; and
- Cookie data: Cookies which allow us to collect information such as browser type and other anonymous traffic data. Please see our Cookie Notice for more information on our use of Cookies.
2.5 Information we collect from other sources:
- From time to time, we may collect Personal Information about you from other sources, such as our Partners, integrations or other third-parties, for example where you have given permission to the third-party to share your information with us;
- We collect or obtain Personal Information from third-parties who provide it to us (e.g., law enforcement authorities.);
With regards to candidates for employment:- We may link the data you provide to us, with other publicly available information about you that you have published on the Internet. This may include sources such as LinkedIn and other social media profiles;
- We may search various databases – some publicly available and others not, which may include your Personal Information (including your CV or resumé), to find possible applicants to fill our job openings; and
- We may receive your Personal Information from a third-party who recommends you as an applicant for a specific job opening or for our business more generally.
2.6 Information we create: We also create Personal Information about you in certain circumstances, such as records of your interactions with us or Visitor logs. We may also combine Personal Information from any of our Websites, the App or services, including where those data are collected from different devices or sources.
2.7 Anonymized information: Where appropriate, Kahoot! anonymizes information collected automatically before using it. Subject to applicable law and our agreements with our customers, we may use and disclose such anonymized information for any purpose, including for analytics purposes, to help us understand how our products are used and improve upon them. We will not seek to re-identify any information that we have anonymized.
3. Use of Personal Information
3.1 Purposes and legal bases: We may use your Personal Information which we collect for the purposes and on the legal bases identified below:
| Purpose of processing | Legal basis for processing | Categories of Personal Information (as listed in Section 2 above) |
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Each category of Personal Information identified in Section 2 above, to the extent necessary in the context of the relevant legal claim or proceeding. |
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We do not sell Personal Information and we do not share Personal Information with third-parties for marketing purposes. For purposes of the CCPA, “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
3.2 Sensitive Personal Information
We do not seek to collect or otherwise process Sensitive Personal Information in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Information for any reason, we rely on one of the following legal bases:
- Compliance with applicable law: We may process your Sensitive Personal Information where the processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- Detection and prevention of crime: We may process your Sensitive Personal Information where the processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
- Establishment, exercise or defense of legal claims: We may process your Sensitive Personal Information where the processing is necessary for the establishment, exercise or defense of legal claims; or
- Consent: We may process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your express consent prior to processing your Sensitive Personal Information (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
If you provide Sensitive Personal Information to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the processing of the Sensitive Personal Information.
4. Third-Party Applications and websites
We may use the Personal Information we collect or receive through the Service, as a processor and as otherwise stated in this Privacy Notice, to enable your use of the integrations and plugins you choose to connect to your Kahoot! account. For instance, if you choose to connect a Google integration to your Kahoot! account, we’ll ask you to grant us permission to view and/or download, as applicable, your Google Sheets, Google Contacts and Google Drive. This allows us to configure your Google integration(s) in accordance with your preferences.
We also integrate with third-parties that make available content, products, and/or services to you, such as the YouTube API for videos. Use of these Third-Party Applications is optional. The Third-Party Applications may have their own privacy policies that apply to you when you choose to use these Third-Party Applications, including but not limited to YouTube whose privacy notice is located at http://www.google.com/policies/privacy.
The Third-Party Applications may collect Personal Information about you but we do not share Personal Information with them.
The Services and Websites include social media features, such as social media plug-ins with Twitter, LinkedIn, Instagram, TikTok and Facebook. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
The Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
5. Your Data Protection Rights
Know your rights
Depending on the jurisdiction in which you reside, you may have the following data protection rights:
- the right not to provide your Personal Information to us (however, please note that we will be unable to provide you with the full benefit of our Websites, the App or the Service, if you do not provide us with your Personal Information – e.g., we might not be able to process your requests without the necessary details);
- the right to request access to, or copies of, your Personal Information, together with information regarding the nature, processing and disclosure of those Personal Information;
- the right to request rectification of any inaccuracies in your Personal Information;
- the right to request, on legitimate grounds:
- erasure of your Personal Information; or
- restriction of processing of your Personal Information;
- the right to have certain Personal Information transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
- the right to lodge a complaint with your applicable data protection authority regarding our collection and use of your Personal Information. Please contact your local data protection authority for more information. Contact details for data protection authorities within the EEA are available here, the UK are available here, Norway are available here, and Switzerland are available here;
- if Personal Information is collected or processed on the basis of consent, or if you have, for example, consented to receiving marketing emails from Kahoot!, you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
- if you are an applicant for employment, you also have:
- the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and
- the right to claim compensation for damages caused by our breach of any data protection laws.
- Kahoot! supports our school customers in providing parents and eligible students with access to their Personal Information and in fulfilling other requests that parents and eligible students may make to access their data. Please also see the section about our processing of Personal Information about Children below.
Subject to applicable law, you may also have the following additional rights regarding the processing of your Personal Information:
- the right to object, on grounds relating to your particular situation, to the processing of your Personal Information by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR / UK GDPR (as applicable); and
- the right to object to the processing of your Personal Information by us or on our behalf for direct marketing purposes.
Please note that the above rights may be subject to exceptions and limitations. We cannot, for example, provide Personal Information if it would violate our intellectual property rights, or delete your Personal Information if we have a legal obligation to retain such data. Kahoot! will respond to your request to exercise your data protection rights consistent with applicable law.
In some cases, it will be necessary to provide evidence of your identity before we can give effect to these rights; and where your request requires the establishment of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law), we will investigate your request reasonably promptly, before deciding what action to take.
Exercise your rights
To exercise your rights pursuant to applicable data protection law, you may contact us on privacy@kahoot.com. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
Note that you can manage your individual account, including requesting account deletion, through your Kahoot! user settings. Here you may update contact information, payment details and preferences. You can also contact us directly via our Support Contact Form.
6. Sharing your Personal Information
We do not share Personal Information with third-parties except in the limited circumstances outlined below.
- you and, where appropriate, your appointed representatives.
- Affiliates. We may share and disclose your Personal Information with the companies in the Kahoot! Group, for our legitimate business purposes or to provide services that may include one or more of our Group Companies.
- Service providers. We may share Personal Information with our trusted service providers who perform services on our behalf (e.g. web hosting, technical support, processing of payment, analytics services and content provision), but strictly for the purpose of carrying out work on our behalf as described in this Privacy Notice. For example, companies we’ve hired to help us provide and support our Services or assist in protecting and securing our systems and services and other business-related functions.
- Recruitment partners. We may share your Personal Information with:
- Third-party service providers such as our recruitment vendor, who use it only in accordance with our instructions and as required by law.
- Where you have applied for a job opening through our recruitment vendor, and where you have consented to this disclosure, we will disclose to them certain Personal Information that we hold, including but not limited to a unique identifier used by our recruitment vendor to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). Our recruitment vendor’s Privacy Notice in respect of their use of the Disposition Data is available on their website.
- Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.
- Social media partners. Kahoot! may cooperate with social media channels to promote our Services, both on our Websites and third-party websites. Notwithstanding the above, we never share information about Children for the purposes or with the parties described in this section.
- Public institution(s). 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, or by order of a competent court, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
- A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Notice, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.
- Professional advisors. Accountants, auditors, consultants, lawyers and other outside professional advisors to Kahoot!, subject to binding contractual obligations of confidentiality.
- Any other person with your consent, or where required by applicable law or court order, or for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, or for the establishment, exercise or defense of legal claims.
- Any relevant third-party provider, where our Websites use third-party plugins or content. If you choose to interact with any such plugins or content, your Personal Information may be shared with the relevant third-party provider. We recommend that you review that third-party’s privacy policy before interacting with its plugins or content.
Regardless of the above, Kahoot! does not sell Personal Information and we will never share or sell Student Data for marketing purposes.
We may also share anonymized, aggregated information with selected third-parties for statistical purposes (for example, see section 2 above).
We are responsible for the data privacy of the service providers we may share Personal Information with. Kahoot! only uses service providers that have data protection and security standards consistent with our own. Our service providers are not permitted to use Personal Information they process on our behalf for any other purposes than as needed to carry out their work for us. We enter into written agreements with all of our service providers restricting the use of Personal Information and imposing the same level of privacy, confidentiality and information security that apply to Kahoot!.
7. Our Security
Kahoot! maintains a comprehensive security program designed to protect the security, privacy, confidentiality and integrity of Personal Information within our organization. We have in place appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. We limit access to your Personal Information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. Our security measures include data encryption, firewalls, data use, and access limitations for our personnel and service providers, and physical access controls to our facilities. Our service providers that process payment data, maintain the applicable Payment Card Industry (PCI) compliance levels.
We also have procedures in place to address suspected data security breaches. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
Details about our security program can be found in our Trust Center. If you have any questions about the security of your Personal Information, you may contact us at privacy@kahoot.com.
8. International Transfers
We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purposes identified in Section 3.1 above. This may involve countries where the data protection, privacy rights and other laws may not be as comprehensive as in your country. Whenever we transfer your information, we take steps, including preventive measures, designed to protect your Personal Information.
For all 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 to a Third Country are made based on an appropriate legal basis, including to a country who has received a finding of adequacy by the European Commission or the UK for the purposes of Article 45 of the GDPR / UK GDPR (as applicable), including the EU-US Data Privacy Framework, including the UK and Swiss extensions, or on the basis of executed standard contractual clauses approved by the European Commission or the Information Commissioner’s Office (“SCCs”).
Kahoot! maintains strict organizational and technical measures to protect Personal Information stored on our, and our trusted third-parties’, servers. For example, access to any Personal Information we process in order to provide the Services is limited through login credentials, multi-factor authentication, access on a need-to-know basis and restricted access to administrative accounts for the employees who require access in order to perform their duties towards you, such as providing support services.
Please note that when you transfer any Personal Information directly to any Kahoot! entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Information. We will nevertheless process your Personal Information, from the point at which we receive those data, in accordance with the provisions of this Privacy Notice.
You are entitled to request a copy of our SCCs using the contact details provided below.
If you want to know more about Kahoot!´s international transfers and the measures we take to keep your Personal Information safe, please reach out to us on privacy@kahoot.com.
9. Retention of Personal Information
We do not retain Personal Information longer than necessary for the purposes for which Personal Information was collected. We retain Personal Information where we have an ongoing legitimate business or legal obligation to do so. Our retention periods will vary depending on the type of data involved, but, generally, we refer to these criteria in order to determine retention period:
1. we will retain Personal Information in a form that permits identification only for as long as:
a. we maintain an ongoing relationship with you (e.g., where you are a user, or you are lawfully included in our mailing list and have not unsubscribed); or
b. your Personal Information are necessary in connection with the lawful purposes set out in this Privacy Notice, for which we have a valid legal basis (e.g., where your Personal Information are included in a contract between us and your school, and we have a legitimate interest in processing those Personal Information for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Information),
plus:
2. the duration of any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Information, or to which your Personal Information are relevant); and
and:
3. in addition, if any relevant legal claims are brought, we continue to process Personal Information for such additional periods as are necessary in connection with that claim.
During the periods noted above, we will restrict our processing of your Personal Information to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods noted above in this section 9, each to the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Information; or
- anonymize the relevant Personal Information.
We generally retain candidate Personal Information for 24 months.
When we have no ongoing legitimate business need to process your Personal Information, it will be deleted or anonymized as soon as possible and in accordance with applicable law.
10. California, Colorado, Connecticut, Utah, and Virginia Consumers
This section supplements our Privacy Policy and provides additional details regarding our collection, use,
and disclosure of Personal Information relating to consumers in California, Colorado, Connecticut, Utah,
and Virginia
Collection, Processing, and Disclosure of Personal Information
The following chart details the categories of Personal Information we collect and process, as well as the
categories we disclose to third parties for our operational business purposes, including within the 12
months preceding the date this Privacy Policy was last modified.
| Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes | Processing Purposes
(See Section 3, “Use of Personal Information,” above, for a detailed description of each Processing Purpose) |
Identifiers, such as:
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Affiliates; service providers; social media providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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Personal information as defined in the California customer records law, such as
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Affiliates; service providers; social media providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Protected class information under California or federal law, such as age | Affiliates; service providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Commercial information, such as transaction information and purchase history for account holders | Affiliates; service providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Internet or network activity information, such as browsing history, search history, and interactions with our online properties | Affiliates; service providers; social media providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Geolocation data at a city-level only, derived from your IP address | Affiliates; service providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Audio, electronic, visual, and similar information that you choose to upload, such as photographs | Affiliates; service providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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| Employment information, such as your current employer, business contact information, and job title | Affiliates; service providers; social media providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent |
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Sensitive Personal Information
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Affiliates; service providers; public institutions, including law enforcement, government authorities and other regulatory bodies; potential buyers; other third parties with your express consent | Please see the section below, entitled “Collection, Processing, and Disclosure of Sensitive Personal Information.” |
Collection, Processing, and Disclosure of Sensitive Personal Information
Subject to your consent where required by applicable law, we collect, process, and disclose Sensitive Personal Information for purposes of providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, and providing storage; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use Sensitive Personal Information beyond these purposes.
Rights and Requests
You may, subject to applicable law, make the following requests:
- To know whether we process your Personal Information and to access such Personal Information. If you are a California resident, you may also request the following:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we disclosed and the categories of third-parties to whom we disclosed such Personal Information.
- To correct inaccuracies in your Personal Information.
- To have your Personal Information deleted.
- To receive the specific pieces of your Personal Information, including a copy of your Personal Information in a portable format.
You have the right not to be unlawfully discriminated against for exercising your privacy rights.
To make a request, please contact us at privacy@kahoot.com. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may decline to honor your request where an exception applies. We may need to request your registered email address, user nickname, and/or recent login activity, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.
When offering Services to its users, Kahoot! may act as a “service provider” or “processor,” and we collect consumer Personal Information on behalf of our users in order to provide the Service. If applicable, please direct any requests for access, correction, or deletion of your Personal Information to the user with whom you have a direct relationship.
We do not sell Personal Information (including Sensitive Personal Information), and we do not “share” or otherwise process Personal Information (including Sensitive Personal Information) for purposes of cross-context behavioral or targeted advertising, as defined under applicable law. We have not engaged in such activities in the 12 months preceding the date this Privacy Notice was last modified. Without limiting the foregoing, we do not sell or “share” Personal Information (including Sensitive Personal Information) of minors under 16 years of age.
Appeal Process
If you are a Colorado, Connecticut, or Virginia consumer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at privacy@kahoot.com.
Authorized Agents
If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Rights and Requests.” We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Rights and Requests” or confirm that you provided the agent permission to submit the request.
De-Identified Information
Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information. Compliance with FERPA, COPPA, SOPIPA and similar education privacy laws
We comply with FERPA, COPPA, SOPIPA and similar laws when applicable to our relationship with our school or school district customer. When FERPA applies, we act as a “school official” to our customer, which means that we are under the direct control of the school or district and use Student Data to provide our Services to the school or district, as set forth in our agreement with it. To the extent COPPA applies, our school or district customer provides us with any necessary consent on behalf of students’ parents or guardians to permit use of Kahoot! in the classroom.
11. Do Not Track
Certain US state laws require us to indicate whether we honor “Do Not Track” settings in your browser. Kahoot! adheres to the standards set out in this Privacy Notice and does not monitor or follow any Do Not Track browser requests.
12. Changes to this Notice
We may change this Privacy Notice at any time and from time to time. If we make material changes in the Privacy Notice, for example if we seek to use Personal Information in a materially different way than we had previously, we will provide prior notice to you for example by email or a pop-up. You can always delete your account and stop using our Services if you do not accept the change.
13. Our collection of Personal Information from Children
When a Child creates an account, we collect his or her email address only for the purpose of providing password reminders to him or her, but we do not collect any other Personal Information. We immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the Child. We may collect certain Personal Information from Children through our products for teachers/schools, but we do so only at their direction in our capacity as a processor. When a parent creates a profile for a Child within the parent’s account, we process the Child’s first name only.
We also collect a username and password from Child account holders, which are used for login purposes only, to permit the Child account holder to use the Services.
We and our service providers also collect the information described above, under “information we collect automatically,” from Children.
If you are a parent or guardian, you may review the information we have collected from your Child or ask us to make no further use of, or delete, such information. In your request, please include your name and your Child’s Kahoot! username, and specify the action you would like us to take. For your Child’s protection, we may need to verify your identity before implementing your request. If your Child uses our Services through his or her school, please contact the school or school district with any such request.
14. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, you may contact us on privacy@kahoot.com.
15. Automated decision making or Profiling in respect of applicants for employment
Our recruitment partners in their capacity as controllers may use technology to select appropriate applicants for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable applicants is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.
16. Controllers
For the purposes of this Notice, the relevant Controllers are:
| Controller entity | Contact details |
|---|---|
| Kahoot! AS | [privacy@kahoot.com] |
| Kahoot! EDU Limited | |
| Kahoot Poland z.o.o | |
| Kahoot DragonBox AS | |
| DragonBox Finland Oy | |
| We Want To Know S.a.r.l. | |
| Motimate AS | |
| Digital Teaching Tools Finland Oy | |
| Kahoot! Denmark Aps | |
| Kahoot! Spain SL | |
| PlanB Labs OÜ | |
| Poio AS |
Note that for our School Services, or where Services are made available to you through an organization that you are affiliated with, offered in the UK and EEA, Kahoot! processes Personal Information as described in this Privacy Notice as a processor under the GDPR / UK GDPR, whilst the school, school district or business entity located in the UK and the EEA is a controller under the GDPR / UK GDPR. Our legal basis under the GDPR / UK GDPR for our processing of Personal Information stems from the agreement for the School Services or Services (as applicable). For all other processing purposes described above in section 2, Kahoot! is a controller.
17. Direct marketing
Where we have gained your consent, we process Personal Information to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our Websites, App, or Services that may be of interest to you. We also process Personal Information for the purposes of displaying content tailored to your use of our Websites, App, or Services. If we provide Websites, App, or Services to you, we may send or display information to you regarding our Websites, App, or Services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send or by unsubscribing in your profile settings (if applicable). After we have processed your unsubscribe request, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Websites, App, or Services you have requested. You can also unsubscribe to marketing communications in your user settings.
Annex A – Definitions
The following definitions applies to this Privacy Notice:
“Affiliate” means an entity that directly or indirectly Controls, is Controlled by or is under common Control with an entity.
“App” means Kahoot!’s software/mobile applications or any other application made available by us (including where we make such application available via third-party stores or marketplaces or by any other means).
“CCPA” means the California Consumer Privacy Act of 2018.
“Child” or “Children” means children under age 13 in the US and children under age 16 outside the US.
“Control” means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests then outstanding of the entity in question. The term “Controlled” shall be construed accordingly.
“Cookie” means a small file that is placed on your device when you visit a website (including our Websites). In this Privacy Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“EEA” means the European Economic Area.
“EU” means the European Union.
“Kahoot!” means Kahoot! AS, organization number 997 770 234, located at Kronprinsesse Märthas plass 1, 0160 Oslo, Norway, and its affiliates.
“Partner” means any job site or similar online service provider that Kahoot!’s applicants for employment apply for job openings through.
“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
“Privacy Notice” means this Kahoot! privacy notice.
“Profiling” means any form of automated processing of Personal Information consisting of the use of Personal Information to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“School Services” means the products that are offered to schools and teachers in Kahoot! EDU and Kahoot! for teachers.
“Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that is deemed to be sensitive under applicable law.
“Services” means the Kahoot! services, including any software, that are available on our platform.
“Service Usage Data” means information we gather automatically through your use of the Services and as further detailed in the “Personal Information we process” section below.
“Student Data” means Personal Information that Kahoot! processes about students on a school or teacher´s behalf as authorized by the school for the provision of the School Services.
“T&C” means the Kahoot! terms and conditions available here.
“Third Country” means any country outside the EU/EEA (for the purposes of the GDPR) and any country outside the UK (for the purposes of the UK GDPR).
“Third-Party Applications” means websites and services delivered by third-parties that are integrated in the Services and resources in order to make certain features, content, products and/or services available to you.
“UK” means the United Kingdom.
“Visitor” means, depending on the context, any person who visits any of our Kahoot! Websites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.
“Websites” means any website operated, or maintained, by us or on our behalf.