Privacy Policy - iOS

This Privacy Policy describes what information Reason Cybersecurity Ltd. (“we,” “us,” or “our”) may collect and how we may use, store and disclose such information which relates to identifiable individuals (“personal information” and “data subject” or “you”, respectively) when you visit or use our FamilyKeeper application (the “Application”), our website at https://familykeeper.reasonlabs.com/ (the “Website”) and/or any child’s mobile device the Application has been installed on. The Application and the Website shall be collectively referred to herein as the “Services”.

You are not legally required to provide us with any personal information, and may do so at your own free will. If you do not wish to provide us with your and/or your child’s personal information, or to have it processed by us or any of our service providers (as detailed below), please avoid any interaction with us, including visiting our Website and using our Application.

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal information (in general, or specifically with respect to the types of personal information you expect or elect to process of have processed via the Services, e.g., “special categories” under the GDPR), your acceptance of this Privacy Policy and our End User License Agreement available at https://familykeeper.reasonlabs.com/terms-of-use/, which is incorporated herein by reference, will be deemed as your consent to the processing of your personal information for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us at support@familykeeper.co.

If you are visiting or using our Services, please read this Privacy Policy carefully and make sure that you fully understand it. If you are a parent or legal guardian and wish to install the Application on a mobile device of a child under your care, we encourage you to discuss our privacy practices detailed below with your child prior to such installation, and to do so in such language and details as befits your child’s age and evolving capacities, at your discretion.

1. THE FAMILYKEEPER APPLICATION

THE APPLICATION WAS DESIGNED AS A SERVICE FOR PARENTS AND OTHER LEGAL CUSTODIANS TO SUPERVISE THE ACTIVITIES, INCLUDING INTERNET USE AND ONLINE COMMUNICATIONS, OF THE CHILDREN IN THEIR CARE, THROUGH THE USE OF THE FAMILYKEEPER CHILD APPLICATION INSTALLED ON THE MINOR’S DEVICE. YOU, AS THE USER OF THE APPLICATION, SHALL BE RESPONSIBLE TO ENSURE THAT THE CHILDREN IN YOUR CONTROL HAVE BEEN DULY NOTIFIED OF THE PURPOSES OF THIS APPLICATION AND THE PERSONAL INFORMATION THAT MAY BE COLLECTED BY THE APPLICATION. THIS APPLICATION IS NOT INTENDED TO REPLACE PARENTAL SUPERVISION AND VIGILANCE, BUT RATHER IS INTENDED TO ASSIST PARENTS IN GUIDING THE CHILDREN IN THEIR CARE IN THE PROPER AND RESPONSIBLE USE OF MOBILE DEVICES AND OTHER ONLINE ACTIVITIES. BY USING THE APPLICATION YOU ALSO REPRESENT AND AGREE THAT YOU WILL COMPLY WITH ALL APPLICABLE LAWS, RULES AND REGULATIONS IN CONNECTION WITH YOUR USE OF THE APPLICATION, INCLUDING (AS APPLICABLE) NOTIFYING THE CHILDREN OF THE USE OF THEIR PERSONAL INFORMATION COLLECTED BY YOU THROUGH THE APPLICATION, AS WELL AS ANY OTHER INDIVIDUAL THEIR INTERACTIONS WITH WHOM MAY BE MONITORED BY YOU THROUGH THE APPLICATION, OBTAINING THEIR CONSENT, AND USING SUCH PERSONAL INFORMATION FOR LAWFUL AND LEGITIMATE PURPOSES ONLY.

If you, as a parent or legal custodian, become aware that a child under your supervision has provided us information without your consent, or has otherwise provided us with any information that you would like to have removed, please contact us at: support@familykeeper.co

2. WHAT INFORMATION WE COLLECT

• Personal Information – Personal Information, including Children’s Personal Information (as detailed below), is information which can identify a specific individual. As the parent or legal custodian, you will voluntarily provide us certain information upon registration such as your email address, etc.
• Children’s Personal Information – with your consent, we may collect Personal Information from your child’s device, such as device identifiers, geolocation, Internet or electronic network activity information (such as search domains, URLs visited and browsing activity), and information regarding which apps are installed on your child’s device. Please note that the Application will announce its presence to the child, and that the child should be aware of the information accessible to the parent or legal custodian per the explanations you provided to the child.
• Non-Personal Information – We collect Non-Personal Information when you interact with our Services - for example, to know how many non-identifiable users visited our Website, as well as additional general technical information, including regarding you and your child’s device (such as your child’s device status, e.g., whether the device is on or off and battery level). We may also collect information voluntarily provided to us during the setup of the account, such as your child’s nickname and year of birth.

3. HOW WE COLLECT INFORMATION

We collect your information either directly from your interaction with our Services or indirectly in the following ways:

• Information we get from your use of the Services, such as information you may provide us relating to your desired preferences of the Services, certain schedules you may set, information collected from your child’s device including device status (on/off, battery status, etc.), permissions status as well as information relating to which applications are installed on your child’s device. Note that while the Application may send you alerts when the paired child device sends or receives unsafe content, we cannot access or retain such content, and that such alerts are always encrypted in transit.
• Cookies – When you access or use the Website, we may use industry technologies such as “cookies”, which store certain information on your computer and which may allow us to enable automatic activation of specific features, to make your experience more convenient. You may prohibit certain cookies by editing your preferences through the Website’s cookie settings. Further, most browsers allow you to either erase cookies, block acceptance of cookies, or receive a warning before a cookie is stored. However, this may limit your experience when interacting with our Website.
• Voluntarily provided information such as information provided by you when you use the Application, or during the Application onboarding process, including Personal Information and financial information in case of paid subscribers.
• Information obtained from third parties (such as through our payment processors). Please note that we do not collect your Children’s Personal Information from third parties.

4. HOW WE USE THE COLLECTED INFORMATION

We use the information collected from you and your child’s device for the following purposes:

• Provide, support and operate the Services as well as to further develop, enhance and improve your user experience with our Services. Note that all collected information is visible to you as part of the Application.
• Communicate with you, including for support purposes, and for sending you Services-related information such as invoices, updates, security alerts.
• Comply with applicable legal obligations; and
• We may also use or share Non-Personal Information to operate our business, including for debugging, support, security, billing and auditing, business analysis and improving our Services.

5. HOW WE SHARE YOUR INFORMATION

We may share your information with:

• Service providers – We share your information with our service providers for the purpose of receiving services such as to process payments, reporting and data storage. A list of our third- party service providers is available under our End User License Agreement available at https://familykeeper.reasonlabs.com/terms-of-use/, and we encourage you to review it.
• Our corporate affiliates – from which we receive services such as IT, security, and other internal operations.
• In connection with corporate transactions, or in the event of bankruptcy or a comparable event.
• To comply with applicable laws and as we believe to be necessary or appropriate under applicable law, including to establish or exercise our rights and/or to enforce our policies (including our EULA and this Privacy Policy), including investigations of potential violations thereof.

6. HOW TO CONTROL YOUR INFORMATION

• Opting Out – If you opt-out of providing the information required to be submitted for the creation of your account, you may not be able to use the Application and the services offered by the Application. However, you are advised that you may opt-out of receiving marketing messages.
• Correction and Deletion of Personal Information – You may ask to review, and if required, correct the Personal information we have collected on you. If you wish to do so, please contact us at support@familykeeper.co. We may also send you periodic reminders to make sure of all your information is up to date. If at any point you would like us to delete any information we have about you and/or your child, please contact us at the e-mail address set forth in this Section above. You may also delete your account entirely through the Application. Deleting your account will erase all of you and your child’s information, including from our server.

Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information related to others and to ask you to provide further information to better understand the nature and scope of information that you request to access. Such additional information will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).

7. GENERAL DATA PROTECTION REGULATION (“GDPR”)

Please note that you have the right to request from us access to and rectification or erasure of you and your child’s information we process as controllers, or to restrict or to object to processing of you and your child’s information in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please contact us at support@familykeeper.co. Please note that we will process your request subject to verification of your identity. To the extent we have not addressed your concerns, you also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile).

We act as controllers and process personal data on the basis of legitimate interest: When we process you and your child’s information for the purpose of providing and optimizing our services and our internal operations, we process such personal data on the basis of our legitimate interest. We may also process you and your child’s information for compliance with applicable legal obligations.

8. U.S. CHILDREN’S PRIVACY RIGHTS

We do not knowingly collect or maintain personal information collected by the Services from children under the age of 13 or 16 (in accordance with applicable State law), except to the extent that the U.S. Children’s Online Privacy Protection Act or other or applicable State law permits us to collect and maintain such information with parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act or other applicable State law without your required consent, please contact us at support@familykeeper.co and we will make reasonable efforts to delete the information from our records. Our services may link to other websites or applications so be advised that we are not responsible for the privacy practices of such other websites or applications as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or applications and we shall not be responsible for any such use. We will not collect from your child more information than is reasonably necessary to provide and operate our Services.

In accordance with COPPA, you may (upon request), access the Children’s Personal Information we have collected from your child to (i) review it; (ii) have it deleted; and/or (iii) prevent further use or collection of it. To exercise your rights and receive further information, please contact us by email at support@familykeeper.co.

In compliance with the COPPA, we will request that you as a parent or the legal custodian provide your parental consent during the account setup.

9. HOW WE PROTECT YOUR INFORMATION

We use up-to-date technology to secure your Personal Information, including the use of appropriate administrative, physical and technical safeguards, to protect information in connection with your account. However, no method of transmission over the internet, or method of electronic storage is guaranteed to be completely secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we and our service providers cannot guarantee or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.

10. U.S STATE PRIVACY LAWS

If you are a resident of California or Virginia, the California Consumer Privacy Act (the “CCPA”), the California Privacy Rights Act (the “CPRA”) and the Virginia Consumer Data Protection Act (the “VCDPA”) (and/or similar state laws, as applicable) apply to you, and this section explains your rights under State privacy laws and contains disclosures required by law. For the purposes hereof,** we collect personal information as a business (as defined under applicable privacy state laws). Such information is used and disclosed for “business purposes”. Please note that under the CCPA, CPRA or VCDPA (and/or similar state laws, as applicable) you may the following rights (each, to the extent available under the law which applies to you):

1. Right to Know: You have the right to know the categories and specific pieces of personal information that are being collected about you.
2. Right to Disclose: You have the right to ask that we disclose certain information about our collection and/or use of your personal information during the past 12 months.
3. Right to Delete: You have the right to ask that we delete the personal information we have collected from you and retained.
4. Right to Opt-Out: You have the right to opt out of the 'sale' of your personal information by a business.
5. Right to Equal Service and Price: You have the right not to receive discriminatory treatment for exercising the mentioned rights.

To submit a request for exercising your rights, please contact us at the following address: support@familykeeper.co. Note that the processing of your request is subject to verification of your identity. You may also appoint an authorized agent to exercise these privacy rights on your behalf (subject to certain limitations such as identity verification process and the submission of written approval to act on your behalf). This Privacy Policy describes what personal information we may collect and its sources, how it is deleted and retained. Furthermore, we have provided information about our processing of your information. Note that we may share (as such term is defined under the CPRA) information with third parties such as business partners who have accepted our contractual limitations as to their disclosure, use, and retention of such personal information. Nevertheless, for the purposes and intents of the CCPA or CPRA, we do not sell your personal information.

11. STORAGE AND TRANSFER OF PERSONAL INFORMATION

As FamilyKeeper operates globally, your Personal Information may be stored or processed or stored in multiple locations, such as Israel, Europe or the United States. We may also store and process your Personal Information in other jurisdictions, including countries that may have less protective data protection laws than the country in which you are located (including the European Economic Area), but will do so solely for the purposes specified in this Privacy Policy and in accordance with applicable laws, customary industry standards, and such appropriate lawful and contractual terms requiring adequate data protection. Such transfers can be made to countries which are recognized as providing an adequate level of legal protection, or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, such as signing Standard Contractual Clauses which were published and authorized by the relevant European Economic Area authorities.

12. RETENTION OF PERSONAL INFORMATION

We retain the data collected from you for as long as your account is active. If you decide to delete your account, your data will be retained for an additional period of 30 days, following which, it will be deidentified.

13. COOKIES AND DATA COLLECTION TECHNOLOGIES.

We utilize cookies and other similar technologies (“Cookies”) on our Website.

Cookies collect information about the use of our Website, and provide users with basic functionality; such as allowing you to save your account credentials to your browser.

We use third-party service providers to aggregate non-personally identifiable Website data. These third parties, such as Google Analytics, use Cookies and tracking pixels placed on our Website to collect, analyze, and generate reports on Website usage for us. Google’s ability to share and use information collected by Google Analytics regarding your use of and visits to the Website is restricted by the Google Privacy Policy and the Google Analytics Terms of Service. You can learn more about how Google processes and collects data specifically with respect to Google Analytics by pressing here. Additional information regarding your option to opt-out of the analytics service is available here. Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please note that some of the features on our Website depend on cookies to properly function. For more information about cookies, you may find the following websites helpful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

The Cookies used for our Website are not connected to our Application in any way and cannot be tied to your Application activity.

14. CONTACT US

Reason Cybersecurity Ltd.
support@familykeeper.co
121 Menachem Begin Street, Tel-Aviv, Israel
Attn: Data Protection Officer

15. MODIFICATIONS TO THE PRIVACY POLICY AND LANGUAGE

We reserve the right, at our discretion, to revise or update this Privacy Policy at any time, provided that any such changes will always take into consideration your rights under applicable law. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Website (or as otherwise indicated at the time of posting), except that express notifications will be sent to you when this is required under applicable law. Your continued use of the Services after the amendments to this Privacy Policy have entered into effect will constitute your acceptance thereof. Make sure to review our Privacy Policy periodically. If you do not accept this Privacy Policy, you must discontinue use of the Services. The original English version of this Privacy Policy can be translated into other languages. In the event of inconsistency or discrepancy between the English version and any other language version, the English language version shall prevail.

16. REPRESENTATIVE FOR DATA SUBJECTS IN THE EU AND UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/12015696620