Privacy Policy

Kinoo Privacy Policy

Effective July 1, 2022

Kinoo, Inc. (“Kinoo,” “we,” or “us”) provides a mobile application (the “App”), physical products, promotional websites, and other online or offline offerings (collectively, the “Services”), to allow parents and/or legal guardians (collectively, “Parents”), their children (“Children” or “Child”), and family members or friends, such as grandparents, (“Older Loved Ones”) who Parents allow to connect with their Child to play together over online video.

Our Privacy Policy (“Privacy Policy”) is designed to help Parents and Older Loved Ones (referred to in this Privacy Policy collectively as “you”) to understand how we collect, use, and share you and your Child’s personal information, and to assist in exercising the privacy rights available to you.

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

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. We 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 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 and encourage adults to purchase our products and services. As an adult, you can control this tracking by managing your cookie settings (for instance by using the cookie banner that appears on our promotional website) or otherwise by contacting us, as described in more detail in Section 5 below. Our use of behavioral advertising is solely to target adults, not children.

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. Put simply, 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 and Kidoo learn from playing and adapt 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.

We welcome your thoughts and feedback about our practices and this policy. If you have any questions, you can contact us at privacy@kinoo.family.

Contents

PERSONAL INFORMATION WE COLLECT.
HOW WE USE YOUR INFORMATION.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES.
INTERNATIONAL DATA TRANSFERS.
YOUR CHOICES.
DATA RETENTION.
SECURITY OF YOUR INFORMATION.
CHILDREN’S INFORMATION.
OTHER PROVISIONS.
CONTACT US

1. 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 Trusted Tester program, 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.

Your Purchases on Our Website. If you make a purchase on our website, we will collect your billing, payment, and shipping information to complete your purchase. If your purchase is a gift, we will also collect shipping information about the recipient (who may be a Parent or a Child), along with any gift message you choose to send.

Account Creation: To create a user account, we collect the following information:

Parent:	full name nickname (optional) username and password email address
Older Loved One	full name nickname (optional)
Child	first name nickname (optional) age gender (optional)

Note: If you set up an account or submit personal information on behalf of someone else, you represent and warrant that you have first obtained that person’s consent, or in the case of a Child, the consent of the Child’s Parent.

Content You Share. As part of our Services, you and your Child can send “FamilyGrams” and similar communications to Parents or approved Older Loved Ones. These communications may contain personal information, including but not limited to photos, user generated content within activities (such as art), and videos you and your Child create. We store these communications solely as required to facilitate your sharing (or as required by law), but not we do NOT use your communications or content for any marketing, promotional, or third-party advertising purposes.

Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash

Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.

Testing Programs. We have voluntary user-testing programs to test our product including the usability of our App, new game concepts, and other aspects of user experience. Users who participate in our testing programs are called “Testers” and have signed a Trusted Tester Agreement. If you sign up to be a Tester, we will monitor and store your video sessions and interactions with the software, including the name and unique session ID of the participants in the session, either in real-time or via session recordings. We use this data internally to track bug reports and otherwise to improve our Services.

Surveys. We may contact you to participate in surveys, or to have your Child participate in a survey with your consent. If you or your Child participate, you may be asked to provide certain information, which may include personal information, such as your demographic information.

Social Media Content. We may offer forums, blogs, or social media pages on other sites such as Facebook or Twitter. Any content you provide on these third-party channels will be considered “public” and is not subject to privacy protections.

Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Conferences, Trade Shows, and Other Events. We may collect personal information from adults when we attend or host conferences, trade shows, and other events.

Information Collected Automatically or From Others

Information from the Kinoo Wand. The Kinoo Wand (“Wand”) is a physical device that can be used to interact with the Services. If you connect a Wand, 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 the device’s position in three-dimensional space and buttons pressed by the Wand holder 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.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies. Our App and physical products do not contain third-party advertising technologies. However, on our websites for Parents and Older Loved Ones, we, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information from Website Visitors. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our websites.

Cookies. Cookies are small text files placed in your computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, some aspects of the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about your engagement on that web page. The use of a pixel tag allows us to record, for example, that you have visited a particular web page or clicked on a particular advertisement for our Services.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our Service 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 individuals use our Services (see Analytics below);

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 digital properties.

See “Your Choices” below to understand your choices regarding these Technologies.

Analytics. We may also use the following service providers to collect information regarding behavior and demographics on our Services within our websites, App and physical products:

Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.

Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

TikTok Analytics. For more information about TikTok’s use of your personal data, please visit TikTok’s Privacy Policy. To opt out, you can contact TikTok via this form.

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.

Other Social Media Pages. We may offer publicly accessible blogs, forums, social media pages, and private messaging features hosted on other sites. By using these third-party sites, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, Instagram and Twitter (that might include widgets such as the “share this” button or other interactive mini-programs) may be present on our commercial websites and portions of the Services only accessible to Parents and Older Loved Ones. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

2. HOW WE USE YOUR INFORMATION.

We use your information for a variety of business purposes, including to:

Fulfill 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;
Answering requests for customer or technical support;
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 and safety;

Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
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” and “Kidoo” 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.

Notice Regarding Third-Party Websites. 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.

3. 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 (personal identifiers shared in order to provide targeted 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 and shipping partners, analytics providers)
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 Ad networks (shared to provide targeted advertising to Parents and Older Loved Ones only)
E. Inferences drawn from other personal information to create a profile about a consumer.	Profile reflecting a consumer's preferences.	Service Providers Advertising networks (shared to provide targeted advertising to 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)

We do not sell your personal information, nor have we sold your personal information in the preceding 12 months, as the term “sale” is commonly understood. Likewise, we do not have actual knowledge of any sale of personal information of minors under 16 years of age, and we do not disclose "sensitive personal information” as the term is defined under California law. That said, we share the personal identifiers of adults with third-party advertising partners for the purpose of promoting our Services as described above. To the extent that such sharing is considered a “sale” under applicable law, you may limit such sharing by following the instructions found in in “Your Choices” below.

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: shipping providers, IT and related services to support our technology infrastructure;; 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 share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions in “Your Choices” below to opt out.

APIs/SDKs. 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 in “Contact Us” below.

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.

4. INTERNATIONAL DATA TRANSFERS.

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 endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth in Contact Us below.

5. YOUR CHOICES.

General.

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 d, 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.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

Mobile Devices.

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. Additionally, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which you can learn more about at https://globalprivacycontrol.org/. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if our site detects a GPC signal from your device, we will interpret it as a Do Not Sell request under California law.

Opting out of 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 by selecting “decline” when prompted with our site’s cookie banner, using a GPC signal as described above, or you may remove cookies altogether by adjusting your preferences as your browser or device permits. Note that, if you remove or reject all cookies, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. 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 by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

Your Privacy Rights.

In accordance with applicable law, you may have the following rights:

Access to and Portability of Your Personal Information (the “right to know”/ “right of data portability”), including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format;

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;

Request Deletion of your personal information;

Request Restriction of or Object to our processing or sharing of your personal information where such rights are granted under applicable law; and

Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in Contact Us 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.

6. DATA RETENTION.

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. SECURITY OF YOUR INFORMATION.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

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.

8. 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.

9. OTHER PROVISIONS.

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.

Supplemental Notice For Nevada Residents. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at Privacy@kinoo.family with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

10. CONTACT US.

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Kinoo, Inc.

Attn: DPO

1432 Broadway Ste 199

Oakland, CA 94612

Privacy@kinoo.family