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.
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: firstname.lastname@example.org
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 full name, date of birth, phone number and country code, etc.
· Children’s Personal Information – with your consent, we may collect your Children’s Personal Information, which may include information you voluntarily provide us during the setup of the account such as your child’s name, phone number and country code, date of birth. Note that while provision of a child’s phone number is required in order to use the Application, you do not have to provide any additional Children Personal Information as you can use pseudonyms instead of actual names, etc. We may collect additional information from your child as a result of your use of the Services, such as your child’s device status (e.g., whether the device is on or off and battery level), device identifiers (Android ID) geolocation, contact numbers and names, and other Internet or electronic network activity information (such as browsing history). For the purpose of providing the Services, we may also collect information from your child’s device regarding which apps are installed on his or her device, including information related to Google Play Store purchases. Specifically, in order to provide the Services, we may collect information concerning your child’s use of the following apps and/or features: Facebook (e.g., activities which your child has performed on Facebook, such as likes, comments and other interactions), YouTube (such as video titles and channel name), as well as activity logs and text data from the following applications: Instagram, Odnoklassniki, VKontakte, WhatsApp, Viber, Messenger, SMS, AliPay and QQ. We may further collect information from your child’s device about your child’s phone calls, such as the phone number calling or being called, the type of call (incoming or outgoing), call’s duration, date and time, and the app through which the call was made. 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.
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.
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.
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.
· 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 certain features within the services offered by the Application (such as SMS/MMS monitoring, location services, etc.) by re-configuring the Application. To do so, simply enter the “Settings” menu within the Application and enter your desired configuration.
· 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 email@example.com. 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 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 firstname.lastname@example.org. 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.
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 email@example.com.
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.
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.
The California Consumer Privacy Act (“CCPA”) gives California residents certain rights over their Personal Information, such as (subject to certain exceptions): (a) You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months; (b) You have the right to request that we delete any of your personal information that we collected from you and retained; (c) You have the right to opt out of the sale of your personal information by a business. As stated above, however, we do not sell personal information; (d) You may exercise all of the above rights at all times and we will not unlawfully discriminate against you for exercising them. To exercise your rights and receive further information, please contact us by email at firstname.lastname@example.org.
We will store the personal information collected from you for as long as it is reasonably necessary for us to provide you with the Services, or for as long as we have a legitimate interest to do so, but not longer than required or permitted by law.
Reason Cybersecurity Ltd.
121 Menachem Begin Street, Tel-Aviv, Israel
Attn: Data Protection Officer
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