IDEO - MOBILE PRIVACY POLICY
Last Updated: April 17, 2020
Thank you for using an App published by IDEO LP (“IDEO”, “we”, “us” or “our”). We respect the privacy rights of users of our mobile application(s) (“App” or “Apps”), especially children who may use our Apps with parental supervision. To further this commitment, we have adopted this mobile privacy policy (“Mobile Privacy Policy” or “MPP”) to describe how we collect, use, disclose, store and protect your information. By using our Apps, you are accepting the practices described in this MPP. If you do not agree with the terms set forth in this MPP, please do not use our Apps.
IDEO may update this MPP at any time, as features and regulations evolve. When we update this MPP, we will revise the “Last Updated” date above. If we make any material changes in the way we collect, use or share your personal information, we will notify you by prominently posting notice with the updated version of the App. We will not change how we handle previously collected information without providing notice and obtaining parental consent, where necessary. We encourage you to revisit this MPP frequently to stay informed of our current privacy practices.
As IDEO is a US headquartered business, our Sites based in the USA will process your personal information. IDEO maintains a data processing report under applicable law which sets out the location where your personal information may be processed, which is available on request where appropriate.
European Union and/or Swiss individuals with enquiries or complaints regarding our Privacy Policy, please contact us at privacynotice@ideo.com.
ESRB CERTIFICATION
We are a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program. To help protect your privacy, we have voluntarily undertaken this privacy initiative. As a licensee in this privacy certification program, we are subject to audits of our Apps and other enforcement and accountability mechanisms administered independently by the ESRB. All of our Apps containing the ESRB certification seal have been reviewed, and certified, by ESRB to meet established online information collection and use practices.
About the ESRB
The Entertainment Software Rating Board (ESRB) is a non-profit self-regulatory body that assigns age and content ratings for video games and apps so parents can make informed choices. It also enforces advertising guidelines adopted by the video game industry and helps companies implement responsible online and mobile privacy practices under its Privacy Certified program. The ESRB was established in 1994 by the Entertainment Software Association (ESA). For more information, please visit www.esrb.org.
TABLE OF CONTENTS
1. Collection and Use of Information
4. Storage and Transfer of Information
5. Security of Your Information
1. COLLECTION AND USE OF INFORMATION
On our Apps, we collect personal information in two forms – information you provide to us and information we collect automatically. We may combine your personal information with non-personal information received in connection with demographic, market or other analytics services.
Information you provide to us: IDEO does not request any information from children within the child-directed portions of our Apps. Parents may voluntarily provide personal data in the age-gated parents section of our Apps. We will explain how we will use the information and use it only for that purpose. All data collected is for internal use only and is solely intended for understanding and improving our services. Areas where parents may provide personal information include:
· Correspondence you send directly to us: You could disclose personal information (e.g., your email address) when youcontact us for support or to provide feedback. We will delete this information promptly after we respond to you.
· Information we collect automatically: We collect some information automatically when you use our Apps, such as your mobile device identifier (“device ID”), Internet Protocol address (“IP address”), and operating system. We use the information that is automatically collected to support the internal operations of our Apps. Some types of internal operations include:
· to monitor metrics such as total number of visitors and traffic;
· to understand which activities and services are most popular;
· to understand flow through our Apps;
· to understand what devices and operating systems our Apps are used on;
· to diagnose and fix technology problems.
This information is only used for the purpose it was collected for, which is to provide analytics on the App it is connected with. This data is not shared with any third parties.
These Apps and children: On Apps that are directed to users under the age of 13 (“Children”), in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not collect personal information from Children other than to support our internal operations or, potentially, pursuant to COPPA’s one-time contact exception. If parents believe that we have unintentionally collected their Children’s personal information, they may contact us (at ToyLabApps@ideo.com) to request the deletion of the information.
2. DEVICE ACCESS
Please note we ask for your permission to access your device’s microphone and photo album. The use of these tools is solely for activities found within the app. We use the microphone so that users can blow into the device and inflate their balloons. The photo album is used to save images of the Balloonimals to your device’s photo album when users “take a photo” of a Balloonimal within the App. Users do not have the ability to upload any photos from their device to the App.
3. THIRD-PARTY DISCLOSURES
Behavioral Advertising: There is no behavioral advertising on our Apps, which means that you will not see any advertising that is targeted to you based on your combined activity on our Apps and your activity on other sites and apps.
Service Providers: In order to provide the best App experience, we contract with third parties to provide certain services to facilitate the operations of our Apps (“Service Providers”), such as Amazon Web Services.Our Service Providers will be given access to your personal and non-personal information only as is reasonably necessary to provide the services for which they are contracted. We only work with companies that follow this Mobile Privacy Policy in their handling of personal information and agree not to use your information for any other purposes.
Law Enforcement and Safety: We or our Service Providers may access, preserve and share your information when we have a good faith belief that it is necessary to: (i) respond to a legal request (like a search warrant, court order or subpoena) or otherwise to take action because we believe it is required or advisable under the law; (ii) detect, prevent and address fraud and other illegal activity; (iii) respond to your requests for customer service; or (iv) limit our legal liability or to protect the rights, property, or personal safety of ourselves, any user of our Apps, a third party or the general public including as part of investigations.
Business Transfer: If we sell or otherwise transfer part or the whole of IDEO or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your personal information, and any other information collected through our Apps may be among the items sold or transferred. The buyer or transferee will be required to honor the commitments we have made in this MPP.
4. STORAGE AND TRANSFER OF INFORMATION
Your information may be stored on the servers of our service providers, including Amazon Web Services. Please note that information we collect from you may be stored and processed in the United States or any other country in which we or our service providers maintain facilities. We or our service providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. We encourage you to review Amazon Web Services terms of service agreements and privacy policies before providing information to them.
5. SECURITY OF YOUR INFORMATION
We use reasonable physical, procedural, technical and administrative security measures to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
6. OTHER WEBSITES AND SERVICES
Our Apps may link to other websites or apps, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours (“Third Party Platforms”). Note that no outside links are available in the kid-facing portion of the Apps but that there may be opportunities to leave the App within the age-gated parents’ section. We are not responsible for the practices employed by any websites or services linked to or from our Apps, including the information or content contained within them.
When you go via our link to Third Party Platforms, you become subject to their terms of use and privacy policies rather than ours. You should review these other third party privacy policies regarding any personal information that they may collect about you.
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7. CONTACT INFORMATION
The Apps are operated by IDEO LP, located at 780 High St. Palo Alto, CA, 94301, USA, 650-289-3400, ToyLabApps@ideo.com. Please contact us if you have any questions about us, or our Service Providers, or this Mobile Privacy Policy.
As aforementioned, IDEO is a licensee of the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at https://www.esrb.org/privacy/contact.jsp, or via email at privacy@esrb.org.
8. YOUR CALIFORNIA PRIVACY RIGHTS
Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customers’ personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please send us an e-mail or write us using our contact information in the above section.
California Consumer Privacy Act of 2018
Categories of Personal Information Collected
In the last 12 months, we have collected email addresses and IP addresses directly from users for the purpose of providing the apps to you, and allowing certain features such as “share with a friend.” (Our “share with a friend” feature has since been removed from our apps.) We do not share this information with third parties except for vendors required to run the service.
We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration.
Rights of California Residents
Right to Know: If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
· The specific pieces of personal information we have about you;
· The categories of personal information we collected, sold or disclosed for a business purpose about you within the last 12 months;
· The categories of sources from which the personal information was collected;
· The purposes for which the information was collected or sold; and
· The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity.
To submit a request, please contact us by email at privacy@ideo.com, or click here to access our online data request webform. Within 10 days of receipt, we will let you know we received your request. We will provide a substantive response within 45 days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request, but if applicable, we will refer you to the applicable sections of this Privacy Policy that address our data collection and use practices. If we deny your request, even if only in part, we will explain the reason in our response.
Right to Delete: If you are a California resident, you may submit a verifiable request for us to delete any personal information we have collected about you. To submit a request, please contact us by email at privacy@ideo.com, or click here to access our online data deletion webform. Within 10 days of receipt, we will confirm receipt of your request. We will provide a substantive response within 45 days, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you to request that information. If we are not able to verify your identity, we will deny your request to delete. If we deny your request, even if only in part, we will explain the reason in our response.
Right to Opt-Out: We do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration.
Right to be Free from Discrimination: We may not discriminate against you because you have chosen to exercise your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
Exercising Your Rights: To submit a verifiable request or to otherwise contact us for more information about how to exercise your rights, please follow the instructions above.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent is able to (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Contact Us
If you have any questions or concerns about our privacy policies or practices, please contact us at privacy@ideo.com.
