Effective September 1, 2021
Kinoo, Inc. (“Kinoo,” “we,” or “us”) provides a mobile application (the “App”), physical products, promotional websites, and other online or offline offerings we provide (collectively, the “Services”), to allow parents and legal guardians (collectively, “Parents”), their children (“Children” or “Child”), and family members or friends such as grandparents who Parents allow to connect with their Child (“Older Loved Ones”) to play together over online video.
WHAT YOU NEED TO KNOW
We want you to understand our Services and how they work. Here are a few of the key takeaways you should know:
● Parents are in control. Parents control all registration, setup, and coordination with the Child and Older Loved Ones. The Parent has the final say over when and who their Child has permission to communicate with within the App.
● The App is a closed ecosystem. Our Services are not designed to allow Children to access the wider internet or share any data with anyone other than their Parents or approved Older Loved Ones. In the future, we may offer features that allow Parents and Older Loved Ones to share screenshots, videos, messages, or other created content through our App and Services; however, these functions are not available to Children.
● The App contains no third-party advertising technologies. We believe a Child’s experience with their Older Loved Ones is special, and should not be interrupted by third-party ads. Our business is not supported by external advertising.
● We strive to collect only the information we need to make our Services work. The virtual characters “Kodii and Kidoo” within the App are able to understand speech and may respond when you or your Child speak to it – they may also be able to detect other signals such as when you or your Child laugh, look at the screen, or take other actions within the App (such as playing games). The App does not collect any biometric identifying information such as facial geometry or voice prints. In layman’s terms, the App knows that someone is speaking with it, but does not recognize any specific person. The App will not ask for your physical location or other sensitive information, such as race, sexual orientation, or health information.
● Kodii learns from playing and adapts to provide the best experience possible. The App uses artificial intelligence and augmented reality technology, combined with knowledge of child development, to learn from how Children and Older Loved Ones interact with it. The App uses this knowledge to improve the play experience and enable deeper, personalized interactions.
● Our promotional and store websites are designed for Parents and Older Loved Ones, and we use standard web tracking technology on these sites to support our advertising and analytics efforts. We may partner with third parties, who use industry standard technologies such as cookies, to track visitors to our websites for adults. You have control over this tracking, as described in more detail in Section IV below.
We welcome your thoughts and feedback about our practices and this policy. If you have any questions, you can contact us at firstname.lastname@example.org.
|I. PERSONAL INFORMATION WE COLLECT|
|II. HOW WE USE YOUR INFORMATION.|
|III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.|
|IV. YOUR CHOICES.|
|V. DATA RETENTION.|
|VI. SECURITY OF YOUR INFORMATION.|
|VII. CHILDREN’S INFORMATION.|
|VIII. SUPERVISORY AUTHORITY.|
|X. CONTACT US.|
I. PERSONAL INFORMATION WE COLLECT
When you use our Services, we may collect personal information from you. The specific categories of personal information we collect depend on who you are (for example, a Parent, Child, Older Loved One, member of our testing or beta programs, or visitor to our website), and the requirements of applicable law. Please note that the following sections describe our current practices as well as our practices over the preceding 12 months.
Information You Provide to Us Directly.
|Parent:||● full name
● nickname (optional)
● username and password
● email address
|Older Loved One||● full name
● nickname (optional)
|Child||● first name
● nickname (optional)
● gender (optional)
Information Collected Automatically or From Others
Information from the Kodii Connector. The Kodii Connector is a physical device that can be used to interact with the Services. If you connect a Kodii Connector, the device will send a unique device certificate via Bluetooth to your mobile device. Once the Bluetooth connection is established, the device and App will share information over a shared Wi-Fi connection. We will also automatically collect information about how you have configured the device, as well as tracking positional data to enable augmented reality features within the App.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, general location information (e.g., to determine time zone), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services.
Analytics. We may also use Google Analytics and/or other service providers to collect information regarding behavior and demographics on our Services within our websites, App and physical products. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login or payment service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
II. HOW WE USE YOUR INFORMATION.
We use your information for a variety of business purposes, including to:
Fulfil our contract with you and provide you with our Services, such as:
● Managing your information and accounts;
● Providing access to certain areas, functionalities, and features of our Services;
● Communicating with you about your account, activities on our Services and policy changes;
● Undertaking activities to verify or maintain the quality or safety of our Service or devices;
● Processing your financial information and other payment methods for products or Services purchased;
● Analyzing and advertising our Services to Parents and Older Loved Ones;
● Processing applications and transactions; and
● Allowing you to register for events.
Analyze and improve our Services pursuant to our legitimate interest, such as:
● Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
● Measuring interest and engagement in our Services, including monitoring your interactions with the software;
● Undertaking research for technological development and demonstration;
● Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
● Improving, upgrading or enhancing our Services or device;
● Developing new products and services;
● Ensuring internal quality control;
● Verifying your identity and preventing fraud;
● Debugging to identify and repair errors that impair existing intended functionality;
● Enforcing our terms and policies; and
● Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
Provide you with additional content and services, such as:
● Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or services;
● Auditing relating to interactions, transactions and other compliance activities; and
● Other purposes you consent to, are notified of, or are disclosed when you provide personal information.
Automated profiling. We may use technologies considered automated decision making or profiling to personalize and enhance your experience with our Services. For example, “Kodii” may remember that your Child likes certain games or activities to suggest similar games or activities in future sessions. We will not make automated decisions about you that would significantly affect you or your Child, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law. You may escalate any concerns you have by contacting us as set forth below.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
Share Content with Friends. Our App does not allow for sharing content outside the Parent/Child/Older Loved One relationship. However, we may offer sharing functionalities in our websites directed at Parents and Older Loved Ones. For example, our website may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend, such as an email inviting your friend to use our Services.
● Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
● Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
● Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
● Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party sites such as through our website. As noted above, our app and physical product do not contain third party advertising technologies.
Cross-Device Tracking. Your interactions with our Services may be tracked across different websites and different devices. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may share data, such as your browsing patterns or device identifiers, and will match the information of the browser and devices that appear to be used by the same person.
Notice Regarding Third-Party Websites, Social Media Platforms and Software Development Kits. The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage you to read the privacy policies of each website and application with which you interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes, including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
III. DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
We do not share your personal information, except with the following categories of third parties described below. For a list of categories of personal information that we have disclosed about consumers for a business purpose in the past 12 months, please see below:
|Category||Examples||Categories of third parties that may receive the data|
|A. Identifiers.||A unique personal identifier, postal address and postal code, Internet Protocol address, email address, account name, User Agent, Instance ID, Mobile Ad ID, IDFA/Android ID, Analytics App Instance IDs or other similar identifiers.||● Service Providers
● Ad networks (for web advertising to Parents and Older Loved Ones only)
|B. Protected classification characteristics under California or federal law.||Age.||● Service Providers
● Ad networks (for compliance purposes only)
|C. Commercial information.||Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||● Service Providers (e.g., e-commerce platforms)|
|D. Internet or other electronic network activity.||Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.||● Service Providers|
|E. Inferences drawn from other personal information to create a profile about a consumer.||Profile reflecting a consumer's preferences.||● Service Providers
● Advertising networks (Parents and Older Loved Ones only)
|F. Sensory data.||Audio, electronic, or visual information (from video sessions).||● Service Providers
● Other Users (i.e., the other Users you choose to share content with)
While our promotional websites for adults may include third-party advertising technologies as described below, we do not sell your personal information, as the term “sale” is defined under the California Consumer Privacy Act (CCPA), nor have we sold your personal information in the preceding 12 months. We do not have actual knowledge of any sale of personal information of minors under 16 years of age. For more information about each category of third party, see below.
Other Users. We may offer functions as part of the Services that allow you to share Content with others.
Service Providers. We may share any personal information we collect about you with our third-party service providers, who may only use your data to provide services to us. The categories of service providers (processors) to whom we may entrust personal information include, but are not limited to: IT and related services; information and services; payment processors; customer service providers; and vendors to otherwise support the provision of the Services.
Business Partners. We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours, and you will have an opportunity to review the data being transferred before choosing to participate.
Advertising Partners. On our commercial websites for Parents and Older Loved Ones, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your interactions with our promotional websites and advertisements and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information we have collected about you (such as your hashed email address, demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below to opt out.
In addition, we share information in the following scenarios:
Affiliates. We may share any personal information we collect about you with our company affiliates.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store about you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction. We will make this disclosure in accordance with applicable law, and notify you of this change as required by law and/or contract.
International Data Transfers. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
IV. YOUR CHOICES.
You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
Email and Telephone Communications.
We process requests to be placed on do-not-mail and do-not-contact lists as required by applicable law.
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.
“Do Not Track.”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies, Interest-Based Advertising, and Analytics.
As noted above, our websites directed to Parents and Older Loved Ones use various Technologies to provide advertising, analytics, and other services in connection with our Service. You may stop or restrict the placement of these Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices, you may use your device’s platform controls in your settings to exercise your choice.
For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
Your Privacy Rights.
In accordance with applicable law, you may have the following rights:
Access to/Portability of Personal Information. You can receive a copy of personal information we process about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.
Correction. You can request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information.
Deletion. You can request we delete personal information we collect or maintain about you, subject to certain exceptions prescribed by law.
Restriction of or Objection to processing. You can request restriction, withdraw your consent, or object to the processing of your personal information, where such requests are permitted by law.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requiring you to log in to your account or answer questions regarding your activities on our Services. Once you have verified your account ownership, and as permitted under applicable law, you may also provide written confirmation authorizing an agent to exercise these rights for you.
You have a right not to receive discriminatory treatment as a result of your exercise of these rights.
V. DATA RETENTION.
VI. SECURITY OF YOUR INFORMATION.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
VII. CHILDREN’S INFORMATION.
Protecting children’s privacy online is very important to us. We require a Parent’s consent before collecting any information from a Child, and limit personal information collection and sharing to only what is necessary to support the internal operations of our Services.
If you are a Parent and wish to review information collected from your Child, or have that information modified or deleted, you may contact us as described below. If we become aware that a Child has provided us with personal information without the Parent’s consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and if applicable, terminate the Child’s account.
VIII. SUPERVISORY AUTHORITY.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
X. CONTACT US.
455 W Evelyn Ave #2405
Mountain View, CA 94041