TutoTOONS Privacy Policy

Last Revised: 25 September 2017

TutoTOONS LIMITED and its subsidiaries and affiliates (the “Company” or “we”) respect the privacy of its users (the “User” or “you”) and are committed to protecting our Users’ information, be it yours or your Child’s. We believe that you have a right to know about our practices regarding the information we may collect and use when you decide to use our mobile applications such as our interactive e-books, games and educational experiences (the “Products”) and our website (the Products and the website together, or the “Service”).

Content

1. TYPES OF DATA THAT WE COLLECT

1.1.We collect two types of Data – Personal Data and Usage Data.

1.2.We may collect the following categories of Data:

1.2.1. The User’s device identifier, IP address or a number held in a cookie, identifiers for advertisers (IDFA) or any other persistent identifier;

1.2.2. Transaction information that the User provides when he or she purchase the Products or the Service from us, including the User’s name, surname, address, telephone number and payment information;

1.2.3. Location information when the User uses our Services, including the location information that is either provided by a mobile device interacting with one of our Products or that is associated with User’s IP address, where we are permitted by law to process this information;

1.2.4. Usage, viewing and technical data, such as the mobile operating system, type of mobile Internet browser, screen resolution, device vendor, language and statistical information about the way the User is using the Products and Services;

1.2.5. Online contact information, such as an email address.

1.3.We may collect the following Data from Children:

1.3.1. A device identifier, IP address, a number held in a cookie, identifiers for advertisers (IDFA) or any other persistent identifier;

1.3.2. Location information, such us the country or city. We do not collect geolocation information or the physical address of the Child;

1.3.3. Usage, viewing and technical data;

1.3.4. The Child’s online contact information, in order to respond a question or request from a Child.

2. HOW WE COLLECT YOUR DATA

2.1.We collect the Data that the User provides to us when the User requests the Products or the Services from us, or otherwise interacts with us by using one or more devices.

2.2.We automatically collect the Data through technology such as cookies, Flash cookies or other similar technologies, including when the User uses our Products on a third-party site or platform.

2.3.We will ask you for your verifiable consent before collecting any Personal Data if such consent is required by the local law. You have the right to withdraw your consent at any time.

2.4.In cases where it will be necessary to obtain the User's consent before collecting Personal Data, the Service will not be available to that User until such consent is obtained.

2.5. You have the right, at any time, to know whether your Personal Data has been stored and can consult with us to learn about the contents and origin of this storage, to verify their accuracy or to ask for the Data to be supplemented, cancelled, updated or corrected.

2.6.We will ask for a parent’s or guardian’s email address before we collect any Personal Data from the Child. We will provide the Child’s parents or guardians with a notice and obtain verifiable parental consent prior to the collection, use and/or disclosure of any Personal Data from the Child, if such consent is required by the local law. If we do not receive the parental consent within a reasonable time, we will delete the parent contact information and any other information that has been collected from the Child.

2.7.Our Products and Services do not enable a Child to make Personal Data publicly available.

2.8.If a parent or guardian becomes aware that his or her Child has provided us with Personal Data without their consent, he or she should contact us at [email protected] We will delete such Data irretrievably within a reasonable period of time.

2.9.We allow the use of some features of our Service and some Products offline (without an internet connection). Offline use of the Service and Products will preclude the collection of any Data pertaining to you and/or your use of the Service or Products (including, as applicable, the information pertaining to your Child and their use of the Service or Products) by any third parties and/or us.

3. RETENTION TIME

3.1.We will keep the User’s Personal Data for the time necessary to provide the Service requested by the User. The User can always request that we suspend or delete the Data irretrievably by sending a request to us at: [email protected]

3.2. The parent or guardian can review or have the Child's Personal Data deleted, and can refuse to permit the further collection or use of the Child's Data at any time by sending a request to us at:

4. THE USE OF THE COLLECTED DATA

4.1.We collect Personal Data, such as the transaction information, User’s device identifier, IP address, a number held in a cookie or any other persistent identifier; and Usage Data, such as statistical information, only for internal purposes in order to

4.1.1. serve the User with contextual advertisements;

4.1.2. analyse our Products and Service;

4.1.3. provide the User with the Service functionalities and performance;

4.1.4. improve our Products and Service;

4.1.5. authenticate the Users or personalise the content;

4.1.6. protect the security or integrity of the User or our Service;

4.1.7. ensure the legal or regulatory compliances.

4.2.We collect Personal Data, such as the transaction information, in order to provide the User with access to our Products and Service.

4.3. We collect Personal Data, such as online personal information, in order to:

4.3.1. provide parents with a notice and obtain the parent’s consent prior to the collection, use, and/or disclosure of any Personal Data from the Child; We collect this Data only when it is necessary to provide the Child’s parent or guardian with a notice and to obtain the parent’s consent prior to collecting, using, or disclosing any Personal Data of the Child; If we do not receive the parental consent within a reasonable time, we will delete this information; or

4.3.2. respond to a question or request from a Child; we will delete this information immediately after responding to the question or request.

4.4.We do not make any decisions based solely on automated processes.

5. THIRD PARTY OPERATORS

5.1.Here is the list of the third-party operators who may collect persistent identifiers through our Products and Service:

5.1.1. Chartboost (Chartboost, Inc.)
Chartboost is an advertising service provided by Chartboost, Inc. Personal Data collected: Cookies and Usage Data.

  • Place of processing: US – Privacy Policy
  • Address: 85 2nd Street, Suite 100, San Francisco, CA 94105, USA
  • Email: [email protected]

5.1.2. SuperAwesome (SuperAwesome Ltd)
SuperAwesome is an advertising service provided by SuperAwesome Ltd.

Personal Data collected: None.
SuperAwesome is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, SuperAwesome has voluntarily undertaken this privacy initiative, and its services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, SuperAwesome’s services are subject to frequent audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

  • Place of processing: UK – Privacy Policy
  • Address: Trading Ltd, 40 Long Acre, London WC2E 9LG, United Kingdom
  • Phone: + 44 203 668 6677
  • Email: [email protected]

5.1.3. Fyber (SponsorPay GmbH)
Fyber is an advertising service provided by Fyber GmbH. Personal Data collected: Cookies and Usage Data.

  • Place of processing: Germany – Privacy Policy
  • Address: Fyber GmbH, Johannisstrasse 20, 10117 Berlin, Germany
  • Email:[email protected]

5.1.4. Flurry Analytics (Flurry, Inc.)
Flurry Analytics is an analytics service provided by Yahoo! Inc. This service is designed for analytics involving mobile apps and can collect various types of information about your phone, which is highlighted in the Flurry Analytics privacy policy. If the User chooses to opt out of this service, Flurry will stop tracking the data for the device identified by the MAC address that has been provided and/or the device identifier going forward. The analytics service tracking will stop across all applications within the Flurry network. Personal Data collected: Cookies, Usage Data and various other types of Data as specified in the privacy policy of the service.

  • Place of processing: US – Privacy Policy
  • Address: 701 First Avenue, Sunnyvale, CA 94089, USA
  • Phone: (408) 349-5070

5.1.5. Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected through the service to track and examine the use of this application, to prepare reports on its activities and to share the Data with other Google services. Google may use the Data that has been collected to contextualise and personalise the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: US – Privacy Policy – Opt Out Address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

5.1.6. Kidoz (KIDOZ Ltd.)
Kidoz is an advertising service provided by KIDOZ Ltd. Personal Data collected: Cookies, Usage Data and various other types of Data as specified in the privacy policy of the service.

  • Place of processing: Israel – Privacy Policy
  • Address: KIDOZ, PO BOX 8517, Poleg Industrial park, Netanya, Israel
  • Phone: +972-9-7716444
  • Email: [email protected]

6. SECURITY

6.1.We process the Data of our Users in a proper manner and take the appropriate security measures to prevent any unauthorised access, disclosure, modification or unauthorised destruction of the Data.

6.2.We take great care to maintain the security of the Service and of your information, and to prevent unauthorised access to it through industry standard technologies and internal procedures, including through the use of encryption mechanisms. However, we cannot guarantee that unauthorised access will never occur.

7. COOKIES AND LOCAL STORAGE

7.1.When you access or use the Service, we may use industry-wide technologies such as cookies and Flash cookies (or similar technologies), which will store certain information on your device (“Local Storage“) and which will allow us to enable the automatic activation of certain features, and to make your Service experience much more convenient and effortless.

7.2. The cookies used by the Service are created for each session, they do not include or gather any information about you other than your session key, and they are removed as soon as the session ends. It is easy to prohibit the activation of Local Storage. Most browsers and platforms will allow you to erase cookies from your device, block the acceptance of cookies, or to receive a warning before a cookie is stored. In order to erase or disable the Local Storage option in Flash, you should use the settings option of Flash according to the specific instructions provided by the technology provider. However, if you block or erase cookies, or change the settings in Flash, your online experience may be limited.

7.3.We may also use certain third-party cookies (e.g. Google Authentication). These are a different kind of cookie that is stored on your computer by third parties, rather than by the Company. This kind of cookie is only read (and is not altered by the Service) each time you visit the Service. Third party cookies store only Usage Data, such as the different pages you have visited strictly within the Service (such the “About” page, the “Contact Us” page, the duration of your browsing session, etc.).

7.4. You can set your browser or mobile device to not accept cookies. However, in a few cases some features of our Products may not function as a result.

8. THE RIGHTS OF THE USERS (APPLICABLE ONLY IN THE EUROPEAN UNION)

8.1. You have the right to lodge a complaint with a single supervisory authority, in particular in the European Union Member State of your habitual residence, and the right to an effective judicial remedy if you consider that your rights have been infringed.

8.2.Where the Personal Data collection and processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processes based on your consent before its withdrawal.

8.3. You have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transmit this Data to another controller.

9. SHARING INFORMATION WITH THIRD PARTIES

9.1.We may share information only in the following cases:

9.1.1. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

9.1.2. to enforce this Privacy Policy or the Terms and Conditions of Use of the Company, including for the investigation of potential violations thereof;

9.1.3. to detect, prevent, or otherwise address any fraud, security or technical issues;

9.1.4. to respond to claims that any content published on the Service violates any right of a third party;

9.1.5. to protect the rights, property, or personal safety of the Company, its Users or the general public;

9.1.6. when the Company is undergoing any change in its controlling members, including by means of a merger, acquisition or purchase of all or substantially all of the assets of the Company;

9.1.7. pursuant to your approval, in order to supply certain Services that you have requested from the Company;

9.1.8. to perform a business, professional, or technology support function for us;

9.1.9. to allow our partners and affiliates to serve you with contextual advertisements only.

10. CHANGES TO THE PRIVACY POLICY

10.1. The terms of this Privacy Policy will govern the usage of the Service and any Data collected therein. Company reserves the right to change this policy at any time, so please re-visit this page frequently. In the case of any material change, we will make reasonable efforts to post a clear notice about this on the Service page.

10.2. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Service on the Last Revised date will constitute the acceptance of, and an agreement to be bound by, those changes.

11. COMMENTS AND QUESTIONS

11.1. If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us at:

11.2. We will make an effort to reply to you within a reasonable time frame.

12. DEFINITIONS

12.1. Children (or Child) In the United Kingdom and United States, the term “Children” refers to individuals under 13 years of age. In European Union, the term “Children” refers to individuals under 16 years of age (unless a lower national age threshold between 13 and 16 applies).

12.2. Cookies Small pieces of data that are stored in the User's device.

12.3. Data Personal Data or/and Usage Data

12.4. Personal Data Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name and last name, an identification number, location data (physical address including the street name and name of the city), online contact information, phone number, photograph, video or audio file, which contains the person’s image or voice, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

12.5. Usage Data

12.6. Information collected automatically which can include: the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the city, the features of the browser and the operating system utilised by the User, the various time details per visit, the mobile operating system, the type of mobile internet browser, the screen resolution, the device vendor, the language and statistical information about the way that the User is using the Products and Services, and other parameters about the device’s operating system and/or the User's IT environment.