HeyKiddo
Privacy Policy
[v. August 2023]
Policy Statement
HeyKiddo recognizes and
respects the privacy of all people who access and use the HeyKiddo™
App (defined below), including our users. The terms "user(s)" or "you" or
"individuals" as used in this policy all mean and refer to you, the
end user, who has downloaded the HeyKiddo App and is authorized to access and
use the application in accordance with the terms of service. HeyKiddo recognizes the importance of protecting personal data and
only collects and uses data as reasonably necessary to fulfill the purposes
described in this policy. We will protect individual's information through
compliance with this policy.
Questions About this Policy
All individuals should read
this policy carefully to understand the practices HeyKiddo follows regarding
personal information. If any individual
has any questions about this policy, or if an individual believes the
individual's privacy has been compromised in the course of using the HeyKiddo
App, please contact HeyKiddo's designated agent at: [insert]
Scope of this Policy
This policy describes the
types of information we may collect from, or about, individuals and how we
collect, use, maintain, protect and disclose that information.
HeyKiddo has created and
developed a mobile application that, among other things, enables caregiving
adults to anticipate, detect and address social and/or
emotional difficulties in the children and others they care for and to further enable caregiving adults
to gain insights to promote wellbeing. The mobile application is
available for iOS and on the Android systems and may use the trademarks and/or
trade names "HeyKiddo", or another name or logo determined by HeyKiddo. For purposes of
this policy, we will use the term "HeyKiddo App" to refer to the mobile application.
HeyKiddo also owns and operates a
website and may build, maintain and offer other online and digital platforms,
software, tools, social media and other formats in the future. To the extent the privacy practices
implicate the website, it is noted below. Use of the HeyKiddo App is subject to the terms and conditions of
use found here: [insert]
General (Non Personal)
Information Collected
HeyKiddo collects
information about each individual's activity while using the HeyKiddo App. The
activity information we collect may include session clicks or usage flows, scrolling
information, the individual's session length (how long an individual uses the
HeyKiddo App), engagement behaviors (the types of resources and features
accessed, information viewed or accessed while using the HeyKiddo App) and
other similar analytics. HeyKiddo also collects information about an
individual's device type and operating system type. (In the future, if
applicable, HeyKiddo may collect the individual's purchase history and search
history when using the HeyKiddo App, the Internet Protocol addresses, and the
geographic location of the device used to access the HeyKiddo App). HeyKiddo
might use a third-party vendor to collect and track this information, such as
Google Analytics. Activity information does not include personally identifiable
information (which is covered by the paragraph below), but it may be stored in
an access log or related tracking database. HeyKiddo may use activity
information for analytics and to measure or understand how the HeyKiddo App is
used and how to improve the HeyKiddo App, including for example, to customize
the mobile application for different user segments, implement new ideas,
uncover insights and/or better understand individual's usage to support and
retain users.
When and How Personal
Information Is Collected
HeyKiddo obtains personal
information about individuals when users register to use the app (and create
individual profiles). Although HeyKiddo does not intentionally collect
personally identifiable information at other points in time, it is possible
that HeyKiddo will collect personally identifiable information when users engage
with the App or when HeyKiddo renders support to users. These collection points
are described below.
Customer Service and Support
In the event an
individual seeks customer support (regarding a problem the individual
experiences with the HeyKiddo App), the individual may be asked to provide
contact information, a summary of the problem, and any other documentation,
screenshots or information that would be helpful in resolving the issue.
Personally identifiable information collected during the customer support
process will be subject to this policy, whether the individual is a technical
contact, opens a support ticket, speaks to a HeyKiddo representatives
directly or otherwise engages with HeyKiddo's support team.
Age and Geographical Restrictions
HeyKiddo does not knowingly collect, maintain or disclose
personal information from people under the age of eighteen. It only collects, maintains
or discloses personal information from people under the age of eighteen that is
specifically supplied and submitted by authorized caregivers. All individuals
under the age of thirteen are prohibited from using the HeyKiddo App. For
people over the age of thirteen, but under the age of sixteen, parental
authorization is required to use the HeyKiddo App.
HeyKiddo does not knowingly collect, maintain or disclose
personal information from people outside of the United States or from residents
of countries other than the United States.
Information That Is and
Is Not Collected
Type of Personal Information Collected at Registration
HeyKiddo collects some or all of the following types of
personally identifiable information about an individual, which is required for the
individual to create a profile, also known as an account:
●
name and username
●
email address
●
phone number
●
birthdate
●
location (such as
state in the US and other elements of location)
●
user ID, encrypted user
password
HeyKiddo also collects some or
all of the following types of personally identifiable information about an
individual's child(ren) or others for whom the individual provides care:
●
user relationship to
child
●
child name
●
child's birthdate
●
child's gender
●
child's ethnicity
The individual represents that
it has all right and license to provide all information about the individual's
child(ren) (and others for whom the individual provides care) to HeyKiddo.
HeyKiddo may also collect the
following types of personally identifiable information about the individual, or
the child(ren) which the individual optionally elects to provide:
●
pronouns
●
gender identity
In the future, HeyKiddo may collect some or all of the following types
of information about an individual:
●
telephone number
●
address
●
other information requested and/or the individual provides
Type of Information Collected While Using the App
HeyKiddo collects generalized non-specific information,
such as behavioral goals and associated behaviors, about children (and others
in the care of users). This information
does not constitute personally identifiable information as it cannot be used to
either directly or indirectly distinguish or trace an individual's identity.
The kinds of information HeyKiddo collects while using the HeyKiddo App may
include:
●
developmental areas
●
daily mood
●
daily situations
●
behavior
●
other information potentially
impacting the child(ren) or caregiver
Type of Personal Information Not Collected
HeyKiddo does not collect social security numbers,
driver's license numbers, passport numbers, state identification card numbers,
immigration status, genetic data and union membership information.
HeyKiddo does not collect or track information about
individuals when individuals leave the HeyKiddo App and access and use a
third-party service.
Although HeyKiddo may link users to the
child(ren) and others for whom they provide care, HeyKiddo does not collect or
store data by household.
HeyKiddo does not collect medical
records, individually identifiable health information or any other information
relating to past, present or future physical or mental health conditions of any
individual. Similarly, HeyKiddo does not collect educational information or student
records.
Login Details
Login details for each individual, such as a password, are the
responsibility of that individual. The individual is fully accountable for any
use or misuse of the HeyKiddo App and the personally identifiable information
contained therein as a result of sharing or providing login details to someone
else. HeyKiddo recommends that individuals change their passwords frequently
and at least every six months.
Aggregated Information
/ Anonymized Data
HeyKiddo may use anonymous,
statistical or aggregated information (including anonymous location
information), in a form that does not enable the identification of a specific
user, to properly operate the HeyKiddo App, to improve the quality of the
HeyKiddo App, to enhance the individual's experience, to create new services
and features, to change or cancel existing content or service, and for further
internal, business and statistical purposes. Additionally, HeyKiddo may share
such aggregated and anonymized data to third parties for research purposes and
to effectuate the other purposes described in this paragraph (such as to Google
Analytics). Although we describe how we use aggregated information, aggregated
and/or anonymized data does not constitute personal data and is not subject to
this privacy policy. From time to time, HeyKiddo may release non-personally
identifying information in the aggregate, such as by publishing a report on
trends revealed through the usage of the HeyKiddo App.
Automated
Decision Making
The HeyKiddo App does not
contain any automated decision making, such as an electronic process to approve
or reject a user from accessing content. However, the HeyKiddo App does use artificial intelligence to classify
or process information as maybe necessary to render content (including to make
content and resource recommendations based upon user input and search terms),
demonstrate trends and enable individuals to efficiently use the HeyKiddo App. content
and resource recommendations based on user input and search.
Use of Information
Collected
Generally, HeyKiddo uses personal information to provide the HeyKiddo
App. Specifically, HeyKiddo uses and process individuals' information, using
different technologies for the following purposes:
●
To operate the HeyKiddo
App
●
To conduct the
business of HeyKiddo and to fulfill and follow and enforce this privacy policy
and the terms and conditions
●
To help improve the
reliability of the HeyKiddo App
●
To customize
and personalize the user experience, to tailor content, to deliver relevant information, to allow
individuals to track mood and behavioral trends and for other usage within the HeyKiddo
App
●
To communicate with
individuals about the HeyKiddo App, including for example sending individuals
technical notices, updates, security alerts, and administrative messages (and
to contact individuals when HeyKiddo reasonably believes it necessary to do so)
●
To troubleshoot and resolve
technical issues, to respond to requests for assistance, to repair and improve the
HeyKiddo App and to ensure the HeyKiddo
App are working as intended, such as tracking outages (Only where necessary, we may share
information with a third-party for the purpose of responding to support-related
requests, such as with the payment processor)
●
To send updates,
notices, announcements and additional information related to the HeyKiddo App
(including through push notifications)
●
To comply with, or as
required by, any applicable law and to assist law enforcement agencies (if
legally mandated, HeyKiddo's opinion) or in response to legal processes and law
enforcement requests and as necessary or appropriate, in HeyKiddo's view
●
To take any action in
any case of dispute, or legal proceeding of any kind between an individual and the
HeyKiddo App, or between an individual and other users
in connection with or associated to the use of the HeyKiddo App (to the extent HeyKiddo
may become involved in such disputes as described in the terms and conditions)
●
In the future,
HeyKiddo may develop tools that enable it to use the data to identify and
prevent fraud, misappropriation, infringement, identity theft and other illegal
activities and misuse of the HeyKiddo App and to protect against harm to the
rights, property or safety of HeyKiddo, users (and other individuals)
●
To identify trends and
improve HeyKiddo App and to develop new products, features and technologies
that benefit users (and possibly to offer third-party products)
● To conduct research (subject to the limitations described in the paragraph entitled, "Research Information")
●
To create aggregated
and/or anonymous data (where such data does not enable the identification of a
specific user) and provide that anonymized data to third parties to assist HeyKiddo in achieving
its business objectives as described in this
policy
HeyKiddo does not provide the personal information to third
parties who share or rent information for direct marketing purposes. HeyKiddo
may provide.
Unless and until HeyKiddo receives notice of an individual's request
to delete its account or the data is deleted in accordance with the automatic
data deletion process described below, whichever is first, all individuals
hereby consent to the use of individual information in accordance with this
policy.
Research
Information
Some users will take part
in research studies with or on behalf of HeyKiddo. For each such user,
additional or different rules pertaining to the collection, maintenance and
usage of data may apply. (For example, the data collected about research
subjects is not subject to the automatic data deletion procedures.) All use of
data from research subjects will be in accordance with the applicable research
study materials, including the relevant consent forms, and Institutional Review
Board protocols.
Financial
Information
As described in the terms and conditions, all
transactions involving the purchase of a subscription to use the HeyKiddo App will
be completed through the use of a third-party payment processor selected by HeyKiddo.
Users must submit a valid payment card (debit, credit), bank account
information, routing number, and other information as may be required by the
applicable third-party payment processor. HeyKiddo does not operate, own, or
control payment processor; thus, all financial transactions, including the use
of the User's payment card and transfers of funds to and from the User's bank
account are governed by the applicable application store and/or the payment
processor's policies (including privacy policies), procedures and agreements
with the user, as applicable. HeyKiddo may keep limited payment information in
its database, such as a customer ID, to enable the third-party processor to
communicate with HeyKiddo about whether a subscription is active, payments are
made, and other similar payment terms.
Business
Partners
HeyKiddo may also collect,
store, hold and manage personal information through cloud based or hosting
services or a third party or a party affiliated or connected to HeyKiddo or in
connection with Apple, Google or their related entities and vendors, as
reasonable for business purposes, which may be located in the United States, in
the European Union or other countries, including those potentially different
than the location of the individual. In any event, HeyKiddo will ensure that
any such usage will conform to this policy.
Web Site
HeyKiddo does not currently collect personal information about
individuals when they interact with the HeyKiddo website, but we may do so in
the future. If we do, we will update this policy with more specific information
about website tracking and usage. In the meantime, we do collect non-personally
identifying information of the sort that web browsers and servers typically
make available, such as the browser type, language preference, referring site,
and the date and time of each visitor request. Our purpose in collecting
non-personally identifying information is to better understand how HeyKiddo's
visitors use its website.
"Cookies" and Other Tracking Devices
A "cookie" is a small data file sent to a browser from a web
server and stored on the user's computer. If an individual accesses the HeyKiddo
website using a computer, HeyKiddo may, use cookies for various purposes (such as to avoid re-entering a
username and password each time an individual logs in), to facilitate the use of the website, to collect
statistical information, to verify information, and to customize usage to an
individual's preferences and for information security purposes. Some of the
cookies may expire when a session ends; other cookies may be saved on a
computer's hard drive. Individuals who do not wish to have cookies placed on
their computers should set their browsers to refuse cookies before using the HeyKiddo
website, with the drawback that certain features of the HeyKiddo website may
not function properly without the aid of cookies. HeyKiddo may engage third
parties to assist in analyzing our business such as Google Analytics to track
and report on website traffic. We may provide these third parties non-personal
information directly from the cookies to conduct this analysis.
Information Security
HeyKiddo implements
systems, applications and procedures to secure individuals' information, to
minimize the risk of damage, theft, and loss of information. HeyKiddo uses
commercially reasonable efforts to protect all personal information, such as in
the following ways:
●
Encryption - Encryption technologies protect the information by
scrambling it as it is sent from one computer or device to another.
●
System monitoring - Regularly reviewing
activity logs allows HeyKiddo to identify potential problems. HeyKiddo also has
systems in place to automatically block and help prevent unauthorized access to
information. We also review our information collection, storage and processing
practices, including physical security measures, to guard against unauthorized
access to systems.
●
Patches - HeyKiddo updates its systems at routine intervals to
use current security technology.
●
Limited Access - HeyKiddo restricts access
to personal information to those people who need to know that information in
order to conduct HeyKiddo's business.
●
Security Measures for Storage - HeyKiddo uses only those
hosting providers that meet security requirements necessary to protect the information.
HeyKiddo uses commercially
reasonable efforts to document these information security procedures in
applicable policies.
These measures cannot
provide absolute assurance. Therefore, HeyKiddo does not guarantee that it's
systems and databases will be immune from misuse, abuse, malfunction or illegal
interception or access. Thus, all disclosure of personal information is "as is"
and without HeyKiddo's warranty, guarantee, or liability.
Automatic Data
Deletion
Personally identifiable
information related to inactive accounts - meaning registrations for which no
subscription fee has been paid - will be deleted from the HeyKiddo App every
ninety (90) days. Thus, if a user desires to resubscribe after the expiration
of the 90-day window, the user's historical data will no longer exist, and the
user will be required to input new information. Data that is not personally
identifiable information will not be automatically deleted and, instead, it
will be aggregated or anonymized and used as described in this policy. For
example, all users have an ID associated with their account. When data from an
inactive account is deleted, the user ID and associated name and email address
will be deleted, but other information, such as those that detect and shows
trends among age groups or gender identities will be aggregated and anonymized and
otherwise rendered incapable of being reconstituted to link to an individual.
Data Retention
In some cases, notwithstanding the
automatic data deletion process, HeyKiddo may retain information collected
about individuals if necessary to satisfy the purpose for which the information
was collected, or as contractually obligated, or as required by law, whichever
is longer. This means we might retain information about you both while you are
an active user of the HeyKiddo App and after you cease to be an active user,
such as if HeyKiddo is under a contractual obligation or a court order to
retain the information.
Your Rights to Change,
Update, Delete Personal Information and Opting-Out
If you do not agree with this policy, do not create a profile or
access or use the HeyKiddo App. For all individuals who have created a profile,
or access or use the HeyKiddo App, but do not agree with this policy and wish
to change, update or delete personal information or opt-out, follow the
procedures set forth below (all users are citizens of the United States and to
the extent the HeyKiddo App becomes available for non-US citizens in the
future, the following may not apply):
Delete Your Account
If an individual wishes to delete
the individual's account, the individual must send an email to the designated
agent at support@hey-kiddo.com stating that the individual
wishes to delete an account and cease of use of the HeyKiddo App. Upon receipt
of such a request, HeyKiddo will use reasonable efforts to delete such
information, however information may not be deleted immediately from back-up
systems. HeyKiddo will begin a process designed to safely and fully delete the
data from storage systems, databases and other infrastructure used in
connection with the HeyKiddo App. This process may take several days from the
time of commencing the deletion process. As with any deletion process, things
like routine maintenance, unexpected outages, bugs, or failures in our
protocols may cause delays in the processes and time frames defined in this
policy.
If an individual does not notify
the designated agent, data will be deleted from the HeyKiddo App (and the
back-end database) in accordance with the automatic data deletion process
described above.
Access, Modify and Update your Information
You have the
ability to access and update certain information about yourself from
within the HeyKiddo App. For example, you can access your profile information
and update your email address within your profile settings.
Delete the Mobile Application
If you no longer
wish to use the HeyKiddo App, you may delete the mobile application and
deactivate your use of the HeyKiddo App. Deactivating your account does not
delete your information. Your information will remain in the systems of HeyKiddo
unless and until you submit a request to delete your account as described above
or upon the automatic data deletion process.
Request That We Stop Using Your Information: In some cases, you may ask HeyKiddo to
stop accessing, storing, using and otherwise processing your information where
you believe we don't have the rights to do so. If you believe an account
was created for you without your permission or the caregiving adult is not
authorized to provide your information or you are no longer an active user, you
can request to delete your account as described above. If you
provided consent to use your information for a limited purpose, you can
withdraw that consent by sending notice to the designated agent, but this will
not affect any prior processing of your personal information. When you make
such requests, we may need time to investigate the basis of your request.
If there is a dispute as to whether we have the right to continue using your
information, we will restrict any further use of your information until the
dispute is resolved.
Understanding What Data Is Being Processed
If you would like to
understand or confirm what personal data is being processed about you, please
contact support@hey-kiddo.com and we will take commercially reasonable
steps - or those required by law - to provide the applicable information or
confirmation.
Turn off Cookie Controls
Within the context
of the HeyKiddo website, you can set your browser to reject browser-based
cookies and/or to adopt the "Do Not Track" feature (to the extent
your browser offers it).
Opt-In and Opt-Out Of Communications
HeyKiddo offers a
newsletter and other informative content for which users will enroll when they
register for the HeyKiddo App. You will be able to opt-out by clicking the
unsubscribe link within each email, or if available, update your email
preferences within your profile, or contact the designated agent and
request that your contact information be removed from our promotional email
list or registration database. HeyKiddo may offer users the ability to
receive promotional communications, marketing materials and updates, and to the
extent such communications are provided, the user should follow the same
opt-out process as described in this paragraph. Notwithstanding the foregoing,
some states require that users have the right to opt-in to particular types of
communication and HeyKiddo will take steps to identify those states and
implement the different formats, as practicable.
Data Portability
Data portability is
the ability to obtain some of your information in a format you can move from
one service provider to another. In the context of the HeyKiddo App, you
may request an extract of your data, and within a reasonable time within
receipt of such request, we will provide you with an electronic file (or
possibly a screen shot) of your basic account information. Individuals
may then transfer that data to any chosen service provider.
Denying a Deletion Request
We may deny your
deletion request if retaining the information is necessary for us:
●
Complete the
transaction for which we collected the personal information, provide a good or
service that you requested, take actions reasonably anticipated within the
context of our ongoing business relationship with you, or otherwise perform our
contract with you
●
Detect security
incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities
●
Debug products to
identify and repair errors that impair existing intended functionality
●
Exercise free
speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law
●
Comply with a legal
obligation or the law (such as California Electronic Communications Privacy Act
(Cal. Penal Code § 1546 seq.))
●
Engage in public or
peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when the
information's deletion may likely render impossible or seriously impair the
research's achievement, if you previously provided informed consent
●
Enable solely
internal uses that are reasonably aligned with consumer expectations based on
your relationship with us
●
Make other internal
and lawful uses of that information that are compatible with the context in
which you provided it
Changes to Our Privacy Policy
It is our policy to post any changes we make to our
privacy policy here: [insert]. If we make material changes to how we treat
individuals' information, we will place a notice within the HeyKiddo App or in
another easily identifiable location. The date the privacy policy was put into
effect, or last revised, will remain at the top of the page. In any event, any
changes to this privacy policy will be effective immediately on posting, unless
otherwise stated or required by applicable law.
Assignment of Terms
and Related Entities
If HeyKiddo organizes the
operation of the HeyKiddo App within a different framework, or through another
legal structure or entity, or if HeyKiddo is acquired by, or merged into or
with another entity, or if HeyKiddo enters bankruptcy, these terms shall be
equally applicable to the surviving entity; provided however, that those
entities agree to be bound by the provisions of this privacy policy. Therefore,
we may change ownership or corporate organization while providing the HeyKiddo
App and if we do, we may transfer some or all of the personal information about
you in connection with any merger, acquisition, sale of assets (or business
line), change in ownership or control, or financing transaction.
ADDITIONAL
REQUIREMENTS FOR SPECIFIC INDIVIDUAL STATES AND COUNTRIES
Some states in the United States provide
you with specific rights to access, modify, and delete your personal
information. Some states also have rules and obligations for HeyKiddo to follow
about how we communicate privacy-related information to you. This privacy
policy is designed to comply with the various state requirements. We recognize,
however, that states enact new laws, or change their laws, in the privacy area
frequently. Therefore, we may maintain a separate URL for state-specific and
country-specific privacy laws.
Residents of
California
This section briefly
addresses the residents of California, since many of our users are located in
that state. The California Consumer Privacy Act (CCPA) requires specific
disclosures for California residents. This policy conforms to the requirements
of the CCPA in the sections above by providing the following information:
●
the categories of
information HeyKiddo
collects
●
the sources of the
information that is being collected
●
why HeyKiddo collects
data
●
how HeyKiddo uses
information
●
the circumstances in
which HeyKiddo
may share information
The CCPA requires a
description of data practices using specific categories, which are all denoted
by the section titles contained in this policy. Additionally, HeyKiddo will not
discriminate against any individual for exercising privacy rights in compliance
with the CCPA.
In accordance with the CCPA, HeyKiddo provides all
individuals with the right to access information and request that HeyKiddo
delete that information. You also have the right to request that we disclose
certain information to you about our collection and use of your personal
information in the past 12 months (including the categories, sources, and
specific personal information we collected about you, our business purposes for
collecting that information, the categories of third parties with whom we
shared that information, and information about the sale of that information). To
exercise these rights to access, review, update and delete information, as well
as export and download a copy of it, individuals must send a verifiable request
to [insert]. If any individual has any questions related to rights under the CCPA,
the individual (or an authorized agent) can also contact HeyKiddo at the
address listed in the questions section above.
Only you or a person registered with the California
Secretary of State that you authorize to act on your behalf, may make a
verifiable consumer request related to your Personal Data. You may also make a
verifiable consumer request on behalf of your minor child. You may only make a
verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must provide sufficient
information that allows us to reasonably verify you are the person about whom
we collected personal information (or you are an authorized representative) and
it must describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
We try to respond to a
verifiable consumer request within 45 days of its receipt. If we require more
time (up to 90 days), we will inform you of the reason and extension period in
writing.
The CCPA defines the terms "sell" and "sale" very broadly,
and although we do not intend to sell any of your data, if any of our
activities fall within the definition of "sale", as used in the CCPA, you would
have the right to opt out of the sale. If you wish to exercise this right,
please submit a request to: [insert]
Accessibility Standards
This privacy policy may be available in a format in the future that
complies with the W3C Web Accessibility Initiative, which brings together
people from disability organizations, industry, research labs and government,
to develop guidelines to help make the Web accessible to people with cognitive,
auditory, physical, speech, neurological, and visual differences. Presently,
the HeyKiddo App and the web site implement numerous technology tools and meet
various requirements for compliance with certain disability standards.