Privacy Policy

Effective as of November 10, 2026

VISIARC AB ("VISIARC", "we", "us", or "our") is committed to protecting your personal information and your right to privacy. This policy explains what information we collect and how we use it.

If you have questions or concerns about this policy or our practices, contact us at legal@visiarc.com.

We may update this policy as we add new or different features, or as the law changes. Unless another date is given, changes are effective when posted.


Which section applies to you?

This policy has two sections, because we process personal data in two different ways:


  • SECTION 1: Our LTI apps (EdTech). If you use our LTI apps in your institution's LMS, this section applies. In this context, your institution is the data controller and we act as its processor.
  • SECTION 2: Our consumer apps, website, and consulting. If you use our consumer apps (including our coloring books and games), our website, or our consulting services, this section applies. In this context, we are the data controller.


SECTION 1

Our LTI apps (EdTech)

Our EdTech LTI apps integrate with your institution's LMS through the LTI standard. They are built on data minimization: they record only what is necessary to function, and they deliberately do not collect location, device, network, biometric, or usage-analytics data.

What our LTI apps do not collect or process:


  • No GPS, IP-based, or Wi-Fi location
  • No device telemetry, device identifiers, or user-agent profiling
  • No network data or IP addresses
  • No biometric or physical data
  • No usage analytics, behavioral tracking, or marketing identifiers
  • Where an app uses the device camera (for example, to scan a QR code), it is used only on the user's own device; no image or video is retained or transmitted.


Who is the controller. When you use our LTI apps, your institution (the LMS operator) is the data controller, and we are the processor. We process personal data only on your institution's documented instructions, under a data processing agreement.


Where your data is stored. Data for our LTI apps is stored in the region appropriate to your jurisdiction. For EU and UK institutions, EU residency is the starting point, as we are an EU company. Where your jurisdiction requires it, other regions are available. Data does not cross borders beyond the region defined at setup. The region is set when the app is installed, so your institution controls where its data resides.


Retention and your control. Uninstalling the app deletes our stored tokens immediately and irreversibly. The old token identifiers are not revivable: reinstalling the app mints entirely new tokens through a fresh authorization. We hold no tokens that survive uninstall. The only remaining record is your institution's own LMS integration entry, which is an anonymous string inside the LMS, under your institution's control, and not data held by us. Records are stored in your LMS, not on our servers; removing the app from your LMS removes our ability to read or write them.


Documents available on request. For each of our EdTech LTI apps, the following documents are available on request:


  • Data Processing & Storage Addendum
  • Data Flow
  • Enforcing Scopes (for the LMS developer key)
  • Data Protection Impact Assessment (DPIA), where applicable


Your rights. As a data subject, you have the right to access, rectify, erase, restrict, port, and object to the processing of your personal data. Where we act as processor, your institution is the primary point of contact for these requests, and we assist your institution in responding. Where we act as controller (for example, for our own staff), we respond directly.


SECTION 2

Our apps, website, and consulting

This section applies to our consumer apps (including our coloring books and games), our website, and our consulting services. In this context, we are the data controller.


What information we collect. We collect several types of information to provide and improve our services. When you use our services, we may ask you to provide personally identifiable information that can be used to contact or identify you, such as in our contact forms. This may include:


  • First name and last name
  • Email address
  • Mobile phone number
  • Company name
  • Usage data and cookies (see our Cookie Policy)


If you use our apps, we may also collect:


  • Geo-location. We may request access to, or permission to track, location-based information from your device, either continuously or while you are using the app, to provide location-based services. You can change this access in your device settings.
  • Mobile device access. We may request access to certain device features, including storage, camera, and other features. You can change this access in your device settings.
  • Mobile device data. We may automatically collect device information such as device ID, model, and manufacturer, operating system, version, and IP address.
  • Push notifications. We may send push notifications about your account or the app. You can turn these off in your device settings.
  • Usage data. We automatically collect certain information when you visit, use, or navigate our sites or apps. This information does not reveal your specific identity, such as your name or contact details. It may include your IP address, browser type and version, the pages you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.


How we use your information. We use the information we collect to:


  • Fulfill and manage your orders
  • Provide and maintain our services, including data analysis, identifying usage trends, and improving our products, services, marketing, and your experience
  • Notify you about changes to our services
  • Allow you to take part in interactive features when you choose to
  • Provide customer care and support
  • Monitor usage and detect, prevent, and address technical issues
  • Request feedback
  • Enforce our terms, conditions, and policies
  • Respond to legal requests and prevent harm


Will your information be shared? We share information only with your consent, to comply with the law, to protect your rights, or to fulfill business obligations. Your information may be transferred to, and maintained on, computers located outside your state, province, country, or other jurisdiction where data protection laws may differ. If you are located outside Sweden and choose to provide information to us, please note that we transfer the data, including personal information, to Sweden and process it there. Your consent to this policy, followed by your submission of such information, represents your agreement to that transfer. We take all steps reasonably necessary to ensure your data is treated securely and in accordance with this policy, and no transfer of your personal information will take place to an organization or a country unless adequate controls are in place, including the security of your data.


Legal basis. We may process or share data based on the following legal bases:


  • Consent. We may process your data if you have given specific consent to use your personal information for a specific purpose.
  • Legitimate interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a contract. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of that contract.
  • Legal obligations. We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
  • Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, or situations involving potential threats to the safety of any person.


More specifically, we may process or share your data in the following situations:


  • Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing. We may allow selected third parties to use tracking technology on our sites or apps to collect data about how you interact with them over time. Unless described in this policy, we do not share, sell, rent, or trade your information with third parties for their promotional purposes.
  • Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
  • In-app purchases. Some of our apps offer in-app purchases, such as an upgrade to a premium version. When you make an in-app purchase, we may process the transaction details necessary to complete the purchase. Payment is handled by the applicable app store or payment provider, and we do not store your full payment card details.


A few words about the information we might disclose. We share and disclose your information only with the third parties described in this policy. If we have processed your data based on your consent and you wish to revoke that consent, please contact us.


  • Analytics and testing. We may use third-party service providers to monitor and analyze the use of our services.
  • Web and mobile analytics: Google Analytics
  • App testing and analytics: Google Play Console and Apple TestFlight


Legal requirements. We may disclose your personal information in the good faith belief that such action is necessary to:


  • Comply with a legal obligation
  • Protect and defend the rights or property of VISIARC
  • Prevent or investigate possible wrongdoing in connection with our services
  • Protect the personal safety of users or the public
  • Protect against legal liability


How we keep your information safe. We aim to protect your personal information through a system of organizational and technical security measures. The security of your data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.


Your rights under the GDPR. If you are a resident of the European Economic Area, you have certain data protection rights under the GDPR. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information. In certain circumstances, you have the following rights:


  • The right to access, update, or delete the information we hold about you. Where possible, you can do this directly in your account settings. If you are unable to do so, contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if it is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your personal information.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we hold about you in a structured, machine-readable, and commonly used format.
  • The right to withdraw consent. You have the right to withdraw your consent at any time where we relied on your consent to process your personal information.


We may ask you to verify your identity before responding to such requests. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority in the EEA.


Service providers. We may employ third-party companies and individuals to facilitate our services, to provide the services on our behalf, to perform service-related services, or to assist us in analyzing how our services are used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


Links to other sites. Our services may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of third-party sites or services.


Children's privacy. Our consumer apps, including our coloring books and games, are designed for children and their parents. Some of these apps may still be in use on devices. We do not knowingly collect personal information from children under 13 except where a parent or guardian consents. If we learn that personal information from a child under 13 has been collected without consent, we will deactivate the account and take reasonable measures to promptly delete that data from our records. If you become aware of data we have collected from a child under 13, please contact us at legal@visiarc.com.


How to update or remove your information. We keep your content for as long as necessary to provide our services. If you want to opt out of services, or to review or delete your information, please contact us at legal@visiarc.com.