Application Privacy Policy
1 ABOUT THIS PRIVACY POLICY
Autsera Ltd. having its registered address at 5 Elephant Lane, London, SE16 4JD, United Kingdom (hereinafter referred to as “Autsera”, “we”, or “us”) respects the privacy of its users, both parents and children (hereinafter referred to as “you” or “user”). We believe that it is important for you to make informed decisions regarding the use of our applications based on your understanding of what information we collect through the use of our applications, what we do with such information, how we process it, with whom do we share it, as well as your rights and choices regarding your information processed by us. Therefore, we have provided this privacy policy (hereinafter referred to as “Privacy Policy”) which further describes our privacy practices while you use our applications.
This Privacy Policy is part of and incorporated by reference into the End User License Agreement (website) governing the use of EmoGami and other Autsera applications (hereinafter referred to as “Application”).
We recommend that you read this Privacy Policy in full to ensure you are fully informed.
2 TYPES OF INFORMATION WE COLLECT
We may collect different categories of information from you, either personal or non-personal information, as defined below and depending on the nature of your interaction with the Application, all as detailed below.
Non-personal information is information that may be made available or gathered through your use of the Application and may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, type of operating system, type of device, language preference, the time and date you access our Application, your actions within our Application (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Application, search queries within our Application, etc., and approximate geo-location (country). To clarify, based on this type of information we are not aware of your identity.
Personal information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identifies an individual. Personal information includes information voluntarily provided by you as well as certain identifiers, such as internet protocol (hereinafter referred to as »IP«) address.
You are not required by law to provide us with certain personal information. You can always refuse to provide certain personal information; however, you acknowledge that such refusal may prevent you from engaging in certain activities within the Application.
In the event we combine personal information with non-personal information, the combined information will be treated as personal information for as long as it remains combined.
The table below details the information we collect, why and how we use it:
| Type of information | How we use it |
| To use the Application and related activities, you as a parent will be required to sign up for a subscription through your app store account. | We will use this information for the purpose of performing our contract with the parent, and provide access to requested activities within the Application. |
| To create the child(s) »profile« you as a parent will be requested to provide your child’s gender, first name and birth month and year. | We will use such information to personalize the child’s experience, including providing direct access to content that we find to be appropriate and relevant for the child, based on the child’s age and screener report. Gender and name is to make the experience more personal. |
| If you contact us for support or other inquiries or if you leave a comment through any means of communication available, you will be required to provide us with a valid email address and you may provide us with your name. | We will use this information solely for the purpose of responding to your inquiries directly on a one-time basis and providing you with the support you have requested. |
| If you voluntarily subscribe to our newsletter, you will be asked to provide us with a valid email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting customer support at [email protected]. | We will use the email address in order to send the information related to our Application and to keep you up to date regarding new products, related news, updates, etc. |
| If you decide to register through or grant access to a third-party social networking or integrated services (hereinafter referred to as “Integrated Service”), such as Facebook, Google or Apple, we may also collect personal information that is already associated with your Integrated Service account. You may also have the option of sharing additional information with Autsera through and Integrated Service. If you choose to provide such information, during registration or otherwise, you are giving Autsera will treat the information as personal information and will use it in accordance with this Privacy Policy. | We will use this information to personalize your experience while using the Application and to operate, maintain, enhance and provide all features of our Application. |
| Identifiers | We collect, use and share identifiers solely for the purpose of providing support for the internal operations and/or in compliance with COPPA regulations. |
| Approximate GEO location data. | We will use this information solely to determine the user’s country to provide applicable content. |
| Prior to the Application installation process, you will be requested to provide access permission to your device’s camera, storage, phone use and microphone use. | Access is required to use certain features of the Application such as to enable the child to use the camera through the Application and to use face detection feature or voice detection feature. WE WILL NOT SAVE NOR COLLECT ANY VOICE RECORDS OR ANY PHOTOS STORED ON THE DEVICE. |
| Prior to the Application installation process, you will be requested to provide permission to access the list of applications installed on your device. | We will use this information solely for the purpose of recommending content you do not already have. |
| Payment details – the use of some features of our Application will require payment. | We do not collect your payment details. Please note that payments for subscriptions are subject to the payment terms and conditions of the third-party payment processor (e.g. Stripe) or mobile platform (e.g. iOS Platform, Android Platform, etc.) from which you make your purchase. Autsera does not control or manage the payment process. Please review the relevant terms and conditions of the applicable third-party payment processor or platform provider before signing up for any subscriptions as they will collect, use and process your information, including payment information, in accordance with their privacy policies. |
| We also collect certain technical non-personal information that relates to your use of the Application, the amount of time you spent viewing certain portions of the Application, etc. | We use this technical non-personal information for the purpose of: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our Application and the way in which we offer them; (ii) enhancing the experience with the Application; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow, and detecting fraud, security or technical issues in connection with the Application; (iv) perform research, for analytical and statistical purposes, to improve our Application. |
In case we need to collect additional personal information other than the personal information mentioned above, we will send a parent an applicable request and obtain consent prior to the collection, if required under applicable law.
We may use data in an aggregated, non-specific format for analytical purposes. This information is anonymous and will not be linked to any personal information. We may share such statistical information, without restrictions.
3 HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Application, we may collect information as follows: (i) automatically – Autsera collects information automatically transmitted from the device; (ii) provided by you voluntarily – meaning, if and when you choose to provide us with information such as through a registration process, newsletter registration, contact us communications, etc.
4 DISCLOSURE OF INFORMATION
WE DO NOT DISCLOSE, SHARE, SELL, RENT OR OTHERWISE DISTRIBUTE ANY OF YOUR OR YOUR’S CHILD PERSONAL INFORMATION WITH OR TO ANY INDEPENDENT THIRD PARTIES, unless as specified herein:
- Authorized Disclosures – we may disclose personal information to third parties when you consent to a particular disclosure. Please note that once we share your information with a third-party, that information becomes subject to the other third-party’s privacy practices.
- Business Transfers – we may transfer our databases containing personal information if we sell our business or any part of it. In that event, our affiliated companies or acquiring companies will assume the rights and obligations as described in this Privacy Policy.
- Law Enforcement related disclosure – we may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
- Business Partners, Service Providers, Affiliates, and Subcontractors – we may disclose information (including personal information) to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors and business partners who may use such information to help us provide you with the Application and related features. We authorize these third-party service providers to use personal information only for the purpose of providing the specific services.
- Identifiers – we may share identifiers for the purpose of operating our business and providing the Application, meaning to detect fraud, security or technical issues in connection with the Application.
5 DATA RETENTION
We retain this collected information as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until individuals express a preference to opt-out or delete their personal information. We may, at our sole discretion, delete or amend information from our systems, without notice, once we deem it is no longer needed for such purposes.
6 SURVEYS AND CONTESTS
From time to time we may conduct an e-mail survey or an online contest and collect classical personal information, demographic information, usage information and other materials that you voluntarily submit to us for the purposes of internal analysis, marketing and brand development. Participating in a survey or an online contest is completely voluntary. We will use the information to make our services more appealing to users. Collected information gathered via surveys shall be anonymized and aggregated. We may use your information gathered via contests for the purposes of performing the contest and to contact you as per such contest’s terms and conditions.
7 PROTECTION OF PERSONAL INFORMATION
We have implemented reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.
8 THIRD-PARTY SITES AND SERVICES
This Privacy Policy applies solely to the information collected by Autsera through the Application and does not apply to any other websites, applications or services. Portions of the Application may involve linking to or using third-party services such as various icons, shortcuts, applications or other means of access. Though we make best efforts to review such services and ensure their suitability for children, we have no control over Third-Party Services and all use of such services is at your own risk. We cannot accept responsibility for the privacy practices of any such third-party services and we are not responsible for content made available by them. Autsera does not endorse any third-party services and we urge you to exercise caution in using them and to review their privacy practices.