Version Date: 01.05.2019
The Goozby App is being made available during development and will contain errors and bugs. We would love to hear from you with feedback or any issues you are facing email@example.com
1. Providing Services For Children
We have worked hard to ensure Goozby is designed ethically and in accordance with the 5 Rights Framework - taking the existing rights of children and young people (under 18), and applying them to the digital world.
Goozby Services are intended to be used mainly by children. Whenever we collect personal information from a child, we only keep the information for the time we need it to provide a service or for the time it’s legally required to be kept on record.
While children can choose whether to share their information with us, there are features of our Services that won’t function if they haven’t given us their information. Where personal information is needed for features to function, we’ll only ask for information that is reasonably required to take part in the activity.
If we discover that we’ve unintentionally collected information from a child in a way that doesn’t meet with our policy, we will delete the information immediately.
2. What We Information We Collect
When creating a user profile on the App, you create a name (Username) for your Goozby. This Username may then publicly available inside the App only. This does not require the use of any personal information and we recommend you do not use an personal information (such as your real name or your date of birth) as part of your user name.
Inside the App you are able to create your own Goozby (Goozby Avatar) which will then be publicly available alongside your Username inside the App only. We also ask for you to decide the gender of your Goozby Avatar so that we can provide the best accessories for customisation and the best user experience.
Your Month and Year Of Birth
We ask for your month and year of birth so that we know if you are over 13 or not. If you are under 13 we need a parent or guardian to sign up on your behalf. Your month and year of birth is never made public within the App or anywhere else on the Services.
We ask for your email address so that we can validate who you are and to be notified by email about information that you have indicated is of interest to you (we will always give you a clear opt out). Your email address is never made public within the App or anywhere else on the Services. We will not share your email with anyone else. If you are under 13 then we request that your parent or guardian provide their email address instead as a means of giving consent for you to use the Services.
We ask you to indicate interests from a list provided so that we can make sure you set goals based on what you want to achieve and that the rewards we offer you are things that are relevant to you. Your interests are never made public within the App or anywhere else on the Services.
Feedback on a product survey, or reporting a problem
Product surveys may be used to improve our products and services and we only collect your contact information if you have indicated that you wish us to contact you with follow up information. If you have contacted us to report a problem, once you are satisfied the issue is resolved we will delete your contact information unless otherwise indicated.
Information From Research/workshops
User research and workshops are used to inform and improve the design of products and services created by Humankind Technologies. On all of our projects we start by undertaking a Data Impact Assessment and Ethics Compliance. This ensures we think about the level of information we need and consider things like consent carefully before starting work. User research is conducted after obtaining specific consent from participants. This consent will explain what data is being collected, how it will be stored and how it will be used. In general terms we keep the amount of personally identifiable information in our research to a minimum.
When we hold the personal data of a person under the age of 18, for example a child who engages in our products or a child who contributes to a workshop, we will make certain that the child (and/or the parent of the child if under 13) understands beyond doubt the ways in which their data may be used. It is our policy not to share a child's data unless it is for reasons that are transparent accountable, understood and in the child's best interests. Guidelines on protecting children’s data can be found on the ICO site here
Contact Information Specifically For Events or Newsletters
Humankind Technologies operates an email newsletter for the Goozby brand. This is used to update partners and customers on important company news and events. The subscriber data is only used for the purposes of operating these services and subscribers have the ability to unsubscribe at any time. If anybody has given us their contact information in relation to one of our events then this information is only used to contact them in relation to this event and will only be stored for further marketing purposes if explicit consent is given. If you are under 13 then we request that your parent or guardian provide their contact information instead.
We access your location while you are using the App in order to provide you with certain key features like tracking your screentime accurately, reminding you to take a break and knowing when you’ve taken a break. By default, Location functionality is turned off. You must enable this functionality to make it possible for you to use the App. This location information is not stored anywhere, not sent to any server and not shared with anyone.
Time Spent On Your Device
To deliver the Services we collect information about how long and when you are using your mobile device.
Crashes and Error Logs
We also collect app usage information, such as error logs and crash recovery logs.
Other Non-personal information
We collect non-personal information about users whenever they interact with the App. Non-personal information includes the number, and frequency of visitors to the App and the length of their stays, browser name, the type of computer, and technical information about the means of connection, such as the operating system. We also collect your IP address solely for the internal support of the Services, such as system administration, and in case requested by law enforcement.
Be mindful that if you do enable a prevent cookies functionality on your device, some of our services and functionalities on the site will no longer work.
We also collect information from other trusted sources, so we can update or add to the personal information we’ve collected ourselves.
3. Why We Collect Information on the Services
We use the information you give us to provide you with the Services. This may involve using the information we collect on how you use the Services and the content you interact with to tailor your view of a service or personalise the content and features made available to you. We may also send you service-related mobile app push-notifications, including announcements and administrative messages. We will also use your information to provide you with any technical and other customer support you need. We will use your information for these purposes because it is in our legitimate interests to ensure that service is being offered to you at a high standard and to your satisfaction.
To Provide the Services
We collect non-personal information from your use of the Services to understand how our customers interact with the Services, so we can improve it and develop new services to meet our customers’ needs. We may also use this information to conduct statistical analysis and for business planning. We do this because it is in our legitimate interests to ensure that the Services offer customers the best experience.
To Improve our Services and Product Offerings
We collect non-personal information about users whenever they interact with the Services. Non-personal information includes the number and frequency of visitors to the Services and the length of their stays, browser name, the type of computer, and technical information about the means of connection, such as the operating system. We also collect your IP address solely for the internal support of the Services, such as system administration, and in case requested by law enforcement. We encrypt the IP address and adopt and implement appropriate and reasonable security practices regarding access to it.
To Defend our Legal Rights
We may also use your information to prevent potentially illegal activities, protect the safety of our users and others, enforce our terms of service and comply with our legal and regulatory obligations, requests from government bodies or courts, or respond to litigation. Typically, we will do this because it is necessary in order to comply with a legal or regulatory obligation to which we are subject (e.g. complying with subpoenas, search warrants and court orders).
We may combine all the information we collect from or receive about you for any of the foregoing purposes. Further, we may aggregate your information with other users’ information and use it for statistical analysis, research and reporting purposes. We may also share this information with our business partners and research institutions. This aggregated information cannot be used to identify you.
4. How Long We Keep Your Information
We will keep your information only for long as it is necessary for the purposes described above (to provide you with the Service, for our legitimate interests as described above and in order to comply with our legal and regulatory obligations). This period will vary depending on your interactions with the Services. For example, we may retain your account data for a reasonable period of time after your last activity. This is to enable you to easily come back and start using the service again. We may also keep a record of correspondence with you relating to the Services, for example, if you have made a complaint, for as long as is necessary to protect us from a legal claim. In all cases, where we no longer have a need to keep your information, we will delete it.
5. How We Protect User Information
Humankind Technologies takes reasonable steps to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide via the Services. We ensure that all data is stored securely. Our security software is kept up to date and appropriate back up and recovery solutions are in place. We adopt and implement appropriate and reasonable security practices regarding the collection, storage and processing of the information we collect, such as encryption. We also put in place physical safeguards such as limited employee access and confidentiality agreements with employees and contractors.
Despite our best efforts, no security measure is ever perfect or impenetrable. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, data, we will promptly assess the risk to people's rights and freedoms and if appropriate report this breach to the relevant parties and to the regulator (Information Commissioner's Office)
Humankind Technologies is registered with the information commissioner's office (ICO) as an organisation that processes personal data. The ICO registration number is ZA473047 and expires on 10 November 2019"
6. Sharing Users’ Personal Information
We do not sell, trade, or rent your personal information to others, and will not do so except as required by law or in connection with a merger, asset sale or similar business transaction (as described below). We may share aggregated demographic or non-personal information not linked to any personal information regarding visitors and users with our business partners, company affiliates and advertisers/reward providers.
We enable trusted third party partners including trusted research institutions and charities to use anonymous data on user habits for social, economic and health research, under controls designed to protect yours and your child's privacy.
We use third-party service providers (as set out below) to help us operate our business and the service or administer activities on our behalf.
Humankind Technologies, like many other website and app operators, uses third parties to provide certain services. Below is a list of third party services we use to store and process your data, a description of how we use them and links to the privacy policies of these parties:
Law enforcement requests
We may disclose your personal information: (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to permit us to pursue available remedies, including commencing or responding to any claims; (d) to enforce the terms and conditions of the Services; (e) to protect the rights, property, or personal safety of Humankind Technologies, its users or the public; or (f) or other illegal activity or for risk management purposes.
In addition, your personal data may be disclosed as part of any proposed or actual merger, sale, and transfer of Humankind Technologies’ assets, acquisition, bankruptcy, or similar event.
7. International Data Transfers
We work with external Service providers, some of which are based outside the European Economic Area (EEA). We do so in order to provide you with our services and for the other purposes outlined above. Please be aware that the data protection laws in some of these countries may not offer the same level of protection as those in your country of residence. Before transferring your information in this way, we will take reasonable steps to ensure that suitable safeguards are put in place aimed at ensuring that an appropriate level of protection applies to the privacy of your personal information and we will comply with all applicable laws.
8. Advertisements and Rewards
We may serve advertising and rewards on the Services from child-friendly brands. Advertising and Rewards enable us to keep the Services free to use. Any ads and rewards we serve will vetted and assessed for appropriateness by our internal monitoring and compliance team. Such advertisements and rewards will only be targeted based on the context or content you are viewing and the interests you have selected on the Services, and not on your browsing behaviour.
9. Access, Modify, Delete and Other User Rights
Notwithstanding the limited nature of the personal information we collect from or about the users of our Services, users or their parents have the right to request access to review, modify and correct personal information about a user. We will take reasonable steps to verify your identity, such as requiring an email and Username. Users or their parents may also contact us to request certain information regarding our disclosures to third parties for their direct marketing purposes. However, we do not share information with third parties for this purpose.
Depending on the country from which you are using the Services, you may have the right to have the information you have provided to us and which we use to provide the Services to you in a machine-readable format. This right enables you to move your information from one provider to another, for example, so that the other provider can continue to service your needs effectively.
If you would like to delete the information that we have collected from your use of the Services, please contact us at firstname.lastname@example.org.
We may be required to retain some or all of this information in order to enable you to use the Services and features, and to ensure that these function properly. We may also retain such information where required by law, to resolve disputes, troubleshoot problems, enforce our terms and conditions of use and enable us to defend our legal rights. We may only be able to provide the Services if we have your information, so deletion of your information will require deletion of your account and termination of your ability to use the Services.
If a user or parent wishes to exercise any of the above rights, please contact us at email@example.com
10. Change of Mind or Objection
Where you have given us consent to use your information for any of the above purposes, you have the right to withdraw that consent at any time. You may also have a right to object to our use of your information where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to our processing on this ground. Please contact us at firstname.lastname@example.org about exercising these rights.
11. Contact us
If you have any questions, need information or require assistance, please do not hesitate to reach out to us by sending us an email at email@example.com