Updated: 15 October 2021
WHAT PERSONAL INFORMATION WE COLLECT, HOLD AND USE
Personal information we may collect and hold includes:
1. Personal Identifiers: first name, last name, date of birth, gender, username, or similar identifier and title, persistent online identifiers
2. Contact Data: billing address, email address and telephone numbers
3. Third-Party Contact Data: name (or nickname), phone number and photo (optional)
4. Financial Data: payment card details
5. Transaction Data: details about payments to and from you and other details of products and services you have purchased from us
6. Usage Data: information about how you use our website and mobile app and fall reporting (time and velocity of fall events.
7. Device Data: Phone Number, IMSI, Device ID, network information, request logs and Chat Handles, internet protocol (IP) address, internet service provider (ISP), browser type and version, operating system, time zone setting and location, device type and ID, date/time stamp, location data, and other technical information from the devices you use to access our website or mobile app.
8. Profile Data: username, password, security pin and preferences
9. Audio and Visual Data: call recordings and pictures (optional).
10. Location Data: Geographical location data and safe zone parameters
(With some of our products, such as Spacetalk™, we collect the geographical location of a smartphone or smartwatch. This data can be used to locate the carrier or wearer of the device. Location Data is collected solely for the purposes of assisting parents and caregivers to determine the location of the wearer or carrier of the device, under the explicit or implicit consent of that person. The services deal with location, so in order to work, the services need to know your location. Whenever you open and use/interact with our services on a mobile device, watch or go to one of our sites, we use the location information from your mobile or watch or other tracking device to tailor the services experience to your current location (we’ll show your location). The services may also use your mobile device’s background location to provide the services. If you have background location turned on, the services will, from time to time, inform us about your device’s location even if you are not directly interacting with the services. How we collect this data is detailed below. Where we collect user data in a service we will comply with the relevant Apple App Store and Google Play Store requirements.)
11. Health Information: weight, average activity levels, movement/physical ability, medical conditions, medication/prescriptions.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal information from a variety of sources and methods.
Information You Voluntarily Provide
We will generally collect the above personal information from you directly. We collect personal information from you in various ways such as when you communicate with us, when you fill in an application or form or survey, if you apply for a job with us, if we provide a product or service to you, or when you participate in any of our activities. We may also retain any messages you send through the service. We may also retain fall reporting (time and velocity of fall events). We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also use this information to correspond with you, and to address any issues you raise about the Services.
Information We Collect When You Use Our Services
We may also collect data and personal information about individual from third parties and automatically, including through Web Servers and Location Data (as further set out below):
Website Servers: When you access our website and online services the Web Server Data listed above is collected. We advise Google Analytics Demographic and Interest reporting may be used to develop specific offers or advertising from time to time.
Location Data: we may collect this data in a variety of ways, including:
• Global Positioning System (GPS);
• Nearby Wi-Fi networks;
• Mobile cell tower triangulation;
• Near Field Communication;
We send the location of the wearer’s device to our servers when you pair the device with a Spacetalk app user account and grant the device access to location services. Please note that we store or transmit actual location data away from the device itself on our servers, the degree of accuracy that the location data is stored is the same as what is accessible to the holder of parental responsibility through the Spacetalk app.
Information We Collect From Third Parties
We collect personal information from other sources including our trusted partnerships with service providers and where we operate accounts email platforms, advertising networks, and social media platforms. We may also receive personal information from retailers in connection customer service inquiries. The collection, use, and disclosure of personal information received from third parties is governed by the third parties’ privacy policies. Please carefully review these third-party privacy policies to understand how your information may be collected, used, and disclosed by these third parties.
THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
We collect personal information which is reasonably necessary for one or more of our functions as noted above and including to:
• maintain your account and contact details;
• allow you to download and purchase our products and services;
• process transactions and end user related information, including confirmations and invoices;
• communicate with you;
• provide you with access to protected areas of the site;
• verify data for accuracy or completeness;
• improve the quality of our services and develop new ones;
• help our services deliver more useful, customized content such as location tracking and children’s reward programs;
• keep you posted on software updates, technical updates, security alerts and support and administrative messages;
• send marketing communication to you;
• conduct surveys to determine use and satisfaction;
• comply with our legal obligations;
• protect a person’s rights, property or safety;
• credit reporting purposes;
• as necessary to comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities; and
We will not use or disclose this data for a secondary purpose unless you consent to us doing so, or under the circumstances involved we believe you would reasonably expect us to use or disclose the data for a secondary purpose and that that secondary purpose is related to the primary purpose.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
Internal Third Parties
Because Spacetalk is part of a global business and group of companies, information may be shared with our parent, subsidiaries and affiliated entities. Information will be treated confidentially and only disclosed on a need to know basis.
We work with other companies that help us provide our Services to our customers, and we may provide data to these companies for the purpose of providing the services and products to you and to facilitate our interests as stated above. Those service providers will only be provided with access to your information as is reasonably necessary for the purpose that we have engaged the service provider, and we will require that such third parties comply with our standards.
We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy.
Subject to applicable law, we may disclose personal information i) if we are required to do so by law, regulation or legal process, such as a subpoena; ii) in response to requests by government entities, such as law enforcement authorities; iii) when we believe disclosure is necessary or appropriate to prevent physical, financial, or other harm, injury, or loss; or iv) in connection with an investigation of suspected or actual unlawful activity.
Information You Instruct Us to Share
We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to or to third parties you consent to us sharing your persona data with. If you choose to do so, your personal information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
Sale of Personal Information
Like most companies, we allow certain third-party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our website, which is then associated with your browser or device. These companies may use this data to serve you more relevant ads as you browse the internet. Under some state laws, this type of sharing may be considered a “sale” of personal information. Spacetalk has no actual knowledge of any sales of personal information of minors under 16 years of age.
QUALITY OF PERSONAL INFORMATION
We take all steps reasonable in the circumstances to ensure that the personal information we collect from you is accurate, up to date and complete. Where we collect data from you directly, we rely on you to supply accurate data and we may not consider that further steps are required. We will also ensure that all steps reasonable under the circumstances to ensure that the personal information we use or disclose is, when considered in relation to the purpose for which we are using or disclosing the data, accurate, up to date, complete and relevant.
CALIFORNIA PRIVACY RIGHTS.
If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain privacy rights related to the personal information we collect about you. Please see below to learn more about your rights under the CCPA
Request to Know
You may request no more than twice in any 12-month period and, subject to verification of your identity and certain exemptions, we will provide:
· The categories of personal information we collected about you.
· The categories of sources from which the personal information is collected.
· The categories of personal information sold or disclosed to a third party.
· The categories of third parties to whom such personal information is sold or disclosed.
· Our business or commercial purpose for collecting or selling personal information.
· The specific pieces of personal information we collected about you.
Request to Delete
You may request that we delete personal information we have collected from you, subject to verification of your identity and the exceptions provided by law.
Request Not to Sell Personal Information
You also have the right to opt-out from having your personal information sold to third parties.
Exercising Your CCPA Rights
If you are a California resident and would like to submit a CCPA request, you or your authorized agent may email us at firstname.lastname@example.org. For more information about opting out of any sales of personal information you can also visit the Do Not Sell My Personal Information Link.
Please note that these rights apply only to select California consumers and currently exclude job applicants, employees, and business contacts. Only you, or an agent you authorize to act on your behalf may make a verifiable consumer request related to your personal information. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That agent must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.
What Are My CCPA Non-Discrimination Rights?
We will not discriminate against you for exercising any of your CCPA rights, which means we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
How Will You Verify My Identity If I Make a CCPA Request?
The verifiable consumer request must:
· Include your full legal name, email, and phone number.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will use this information to verify your identity using reasonable methods to process your rights request. These methods may include matching information you provided to us with information already maintained by us. Depending on the nature of the request, we may require additional verification actions be taken, including but not limited to providing a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.
We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you. You are not required to have an account with us to make a verifiable request.
Other California Privacy Rights.
California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted via email to email@example.com and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address to process your request. Within thirty days of receiving such a request, we will provide a list of the categories of personally identifiable information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, if any, along with the names and addresses of these third parties, if any. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Currently, we do not respond to browser DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
CANADIAN PRIVACY LAWS
For Canadian residents whose personal information is subject to Canadian privacy laws, the following provisions are also in effect.
Transfer and Storage of Personal Information
Canada’s Anti-Spam Law
In accordance with Canada’s Anti-Spam Law, we obtain your consent in order to send you commercial electronic messages by email or text message. You may unsubscribe from receiving marketing communications from us, such as announcements about new products, services or features. Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you electronically for other purposes, for example, to provide electronic communications you have consented to receive or if you contact us with an inquiry.
Withdrawal of Consent, Access and Correction
You may withdraw your consent for the collection, use or disclosure of your personal information by notifying our customer service team at firstname.lastname@example.org, however, such withdrawal shall not have retroactive effect. You may also make a request to access or correct your personal information by making a request in writing.
PRIVACY – ENQUIRIES, REQUESTS, COMPLAINTS, BREACHES
If you think your personal information, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with a representative of our customer service team as soon as possible.
We will take all reasonable steps to ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.
CHANGES TO THIS POLICY