Last Updated: September 24, 2018
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.
This MPP and certification seal confirm that 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 frequent 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
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 (e.g. Flurry).
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: By contacting us for support or to provide feedback
· Share with a Friend: Visitors can provide their email address and a friend’s email address to recommend our App via email. We use such information only to fulfill the visitor’s request and do not store that information for any longer than reasonably necessary to send the relevant email.
· Share via Social Network: Visitors can connect to Facebook and Twitter to share our Apps with their friends. This is done through Facebook and Twitter’s platforms. We do not store any information about your Facebook or Twitter accounts and will never post on your behalf.
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 reduce the repetition in the promotional messages that users see on our Apps;
· to understand what devices and operating systems our Apps are used on;
· to diagnose and fix technology problems.
Your device ID and IP address are collected through the restricted version of Flurry (www.flurry.com), which is owned by Yahoo (https://info.yahoo.com/privacy/us/yahoo/). 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 additional 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 the technical information (i.e., device ID and IP address) required for the support of our internal operations. If parents believe that we have unintentionally collected their Childrens’ 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”). These Service Providers are Flurry (owned by Yahoo) and Parse. Their respective privacy policies can be found at https://info.yahoo.com/privacy/us/yahoo/ and https://parse.com/about/privacy. We use Flurry to help us understand how our Apps are used. Information collected includes behavioral data such as screens visited, duration of visit, and actions taken within the app as well as anonymized data that can include mobile carrier, mobile device branding, operating system and screen resolution. We use Parse as a cloud server to host content that we provide in the parents’ section of our Apps. This includes content for cross promoting our other kids Apps. In addition, Parse provides anonymized usage data including number of installs and active usage.
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 collected through an App 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.
5. SECURITY OF YOUR INFORMATION
We strive to maintain the security of information but cannot guarantee that information security measures are fail-safe or guarantee that information on our Apps may not be accessed, disclosed, altered, or destroyed. Our Apps maintain technical and organizational steps to keep information collected secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections to guard against unauthorized access.
In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent you have given us your e-mail address, we may notify you by e-mail. By providing us with your email address, you automatically consent to this method of notification under this paragraph.
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.
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7. CONTACT INFORMATION
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:
Attn: Privacy Certified Program
420 Lexington Avenue, Suite 2240
New York, NY 10170
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.