Last Updated: February 2021
What this policy is all about
- This policy is all about explaining to you in a transparent, clear, simple and user-friendly manner what and how information about you may be collected, used, disclosed, transferred, and stored when you use our “Storytime: Learn English, Powered by Disney” App and related Services. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
- This privacy applies to all information collected through our App and/or any related services, activities, sales, marketing or events.
Table of Contents
“Affiliates”: means any entity which is controlled by, controls or is in common control with the Company.
“App”: means the "Storytime: Learn English, Powered by Disney", or any other commercial name as may be applicable from time to time, (or any other similar commercial name as may be applicable from time to time), digital interactive multi-platform application accessible across and downloadable through digital stores such as the Apple App Store, Google Play, etc., designed to run on compatible mobile devices, such as smartphones and tablets and allows users to learn English language words by watching storytelling video clips and other content based on Disney movies and tv series, playing interactive games and doing various activities, all designed and developed by the Company in cooperation with the Walt Disney Family of Companies (“Disney”).
“Content”: means text, graphics, images, music, software, audio, video, audiovisual works, sound and audio recordings, works of authorship of any kind, and information or other materials that are published, displayed, posted, generated, provided or otherwise made available through the Services. Content includes without limitation User Content (as defined below).
“Company” "we", "us" or similar terms " collectively refers to La Mark Vision Ltd. (or "Kantoo", La Mark's brand name), its parent corporations, subsidiaries and/or its affiliates.
“Services”: means collectively the App, all App elements and features, including, but not limited to, the Content, User Content (if any), the storytelling video clips, interactive games and other activities as available from time to time on any of the App versions, accessible over the Supported Platforms and the services offered to you through the App by the Company.
“Supported Platforms”: means the platforms through which a user can access and use the App, including, but not limited to, Android and IOS based mobile platforms, including mobile phones, devices and tablets alike.
“Third-party partners”: means analytics tools, advertising & marketing networks, third-party SDKs and/or APIs or other external providers whose code we have added to our App.
“User Content”: means any Content that users (including you) may provide from time to time, to the extent applicable, to be made available through the Services.
“User Data”: means any information collected from the App about a particular user or device, such as a user ID, event data, or profile, in connection with such user's use of the Services.
“You”, “your”, “user” or similar terms: means the end-user that has downloaded and installed the App on his/her device and has subscribed to use the Services via the digital stores or other direct channels.
The terms "processing", "controller" or "processor" as may be used in this policy, will have the meanings given in the GDPR, irrespective of whether European Data Protection Legislation or Non-European Data Protection Legislation applies.
The terms “including” and “such as” are illustrative and not limitative.
WHAT USER DATA IS COLLECTED
|Contact Information||Email Address: When you download and install the App for the first time, we will ask you to sign-up either by using an email address (if you are under 18 you must ask a parent or a legal guardian to sign-up and provide its own email address for such purposes) (the "Registered Email") or your Facebook, Google or Apple account login information:||Registered Mail: We, or our third-party partners, will use your Registered Email to authenticate your account (or your parents’ if you are under 18) by sending you a temporary password via email|
|Facebook: If you use your Facebook Account for signing up purposes, we will receive your email address as permitted by your Facebook profile settings to authenticate you. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed or shared with us.|
|Google: If you use your Google Account for signing up purposes, we will receive your email address as permitted by your Google profile settings to authenticate you. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed or shared with us|
|Apple: If you use your Apple ID for signing up purposes (available on iOS-based devices only), we will receive your username and email address associated with your account to authenticate you. If you choose not to share your Apple registered email address with us, Apple will supply us with an alternative email address through which we will be able to communicate with you. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed or shared with us|
|Location||Information about the approximate location of a user or device with a lower resolution than a latitude or longitude (such as your country). This is used to customize the language and individualize the content and features of the App. It also allows us to serve you with appropriate regional content occasionally. Overall, this is necessary information for the proper functionality of the App.|
|User Content||Audio Recordings||User’s voice recordings that are captured when user says, speaks out loud or repeats English words on the App for learning and practice purposes. Use of this data is limited to returning pronunciation scores and providing user with immediate feedback on his/her language fluency; this data is not retained in our systems.|
|Identifiers *Other than the identifiers listed here, no Device ID (such as IDFA) or other unique identifiers for tracking purposes are tied to the App or your device.||User ID||Username, account ID, assigned user ID, customer number, or other account-level ID and other unique identifiers tied to the App that can be used to identify a particular user or account.|
|Device Characteristics||Some technical information is automatically received about your mobile device, tablet, or other devices you use to access the Services, such as device type and model, CPU, system language, platform type (iOS/Android), memory and OS version. This information enables App functionality and customization of the Services.|
|Purchase History||An account’s or user’s subscriptions purchase history.|
|Data Usage||Product Interaction||Such as App launches, taps, clicks, scrolling information, video views, saved place in a game activity or video, or other information about how the user interacts with the App.|
PURPOSES FOR USING AND PROCESSING USER DATA
User Data collected from the App about a user or device, is used and processed by us, or our third-party partners, for the following purposes:
|Authentication||To recognize a specific device or app on your device, identify you as a registered user, remember your preferences and your account log-in credentials (i.e. every time you enter the App on the same device you are recognized and automatically logged, unless of course you had previously logged out), identify if and when you’ve logged into the Services, recognize you across different devices, maintain your language preferences across App’s use sessions, verify your identity before we deal with any matter related to your account, if you wish to sign in from a different device or need to re-install the App on your device for any reason, etc.|
|Communications||To communicate with you to update you about new movies and other activities on the App, offers and promotions, send you direct marketing communications, inform you about your child’s progress from time to time, your purchases or other subscription matters, provide customer support, and send you technical notices, updates, security alerts, and administrative messages. We will also use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services if necessary. If at any time you are not interested to receive communications from us, you can "opt-out" from within the communication itself. We will also use your email to respond to any questions, requests or other communications that are initiated by you.|
|App Functionality||To enable features, prevent fraud, implement security measures, ensure server up-time, minimize app crashes, improve scalability and performance, perform customer support.|
|In-App Optimization||To improve App’s “look and feel” and add new features as well as storytelling movies and related learning materials based on the analysis of aggregate usage information to determine which features and content our users find most useful.|
|In-App Personalization & Customization||To customize the language and individualize the content and features of the App according to user’s region or country, provide personalized content to make user experience more relevant, interesting, and engaging, etc.|
|Safety and Security||To verify accounts and activity, authenticate you when you log in, to monitor suspicious or fraudulent activity and to identify potential safety and security violations.|
|Advertising, Marketing & Promotions||To drive engagement and maximize what you get out of the Services via promotional notifications sent to you by email, in-app messages (banners, etc.), or push notifications, about upgrades, special offers, new features, survey requests and newsletters that may be of specific interest to you, draw your attention on content tailored to meet your preferences, share data with advertising networks which display and promote our ads, etc. - you have the right to object to such processing of your information at any time by choosing the "opt-out" option from within the email itself and/or update your preferences in the "App Notifications" settings on your device.|
Post-install Activity: The nature of user’s cross-platform, cross-device activity and behavior inside the App used for purposes of authentication and analysis of user interaction with the various features within the App. Examples of this might include how often the user visits the App, what storytelling video clips user prefers to watch, how user interacts and engages with the various features, including the Content, interactive games, quizzes and activities, engagement times etc.
Based on criteria such as user behavior, habits and interests, we use this information for audience segmentation purposes. No cookies or other mobile solutions are used for tracking purposes.
|Research & Development||By using collective learnings about how you use our Services and feedback provided directly to us, to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.|
|Internal Purposes||To perform auditing, data analysis and research to improve the performance of the Services and the App’s functionality, etc.|
OUR THIRD-PARTY PARTNERS
We currently use, integrate into and add to our App the following third-party services, technologies, tools, SDKs, API’s and otherwise code; the following list may be amended to include additional ones or exclude existing ones from time to time:
- Facebook Single Sign-On (SSO) We have implemented Facebook SSO feature to allow you to log into our App using your Facebook account, without the need to create new usernames and passwords. When you log into our App with your Facebook account, we may ask you for permissions to access a subset of your data stored on Facebook such as your email address and public profile. By signing in using your Facebook account, you agree to comply with Facebook applicable terms, policies and practices, including, without limitation, the Facebook Platform Terms at: https://developers.facebook.com/terms/#login and the Facebook Business Tools Terms at: https://www.facebook.com/legal/terms/businesstools/update .
- Google Sign-in. This feature gives you the choice to sign-in using your Google account. Google may collect activity information about you when you use the Services. By signing in using your Google account, you agree to comply with Google terms available at: https://developers.google.com/terms/#a_your_end_users; and any additional supplemental Google terms in effect from time to time. If you wish to opt-out of the collection and use of information for ad targeting please use your device's ad tracking settings.
- Sign in with Apple. This feature is available on iOS-based devices only and allows you to sign-in the App using your Apple ID. If you choose to do so, we will only receive from Apple your username and registered email address associated with your Apple ID, or a random email address that routes emails to your inbox if you choose not to share with us your Apple registered email address, and a unique stable identifier that allows us to set up your user account in our system. Apple will not track users as they interact with our App.
- AppsFlyer. This is a tool that allows us to collect certain data regarding user behavior during use of the App and interaction therewith, for purposes of attribution and marketing analytics, to enable us to measure and analyze certain events and actions within the App, improve the Services and identify and protect against fraudulent behavior. For these purposes, user ID, platform type, general location, device type, etc. is provided to AppsFlyer.
- DeltaDNA Tool. This is a software tool that allows us to use certain platform services for purposes of marketing campaigns management and evaluation, push notifications, etc. to users of our App. For these purposes, user ID, device type, country, transaction ID, email, platform type (iOS/Android), subscription status and any interaction with App’s UI is sent to DeltaDNA.
- SoapBox System. This is a speech recognition and machine learning technology created by SoapBox Labs Ltd., which is interfaced with our App to recognize user’s voice and speech in real-time when he/she says or repeats English words while using the Services; voice recordings and other voice data from users, which is captured and/or generated pursuant to this technology when users interact with the Services are not retained in our systems, the voice data passed to SoapBox Labs is de-identified and no other data relating to the identity of the User is received by the SoapBox system. De-identified voice data may be retained and used by SoapBox Labs for product development and enhancement purposes only.
- Firebase. An analytics events-based platform that enables us to improve our App, optimize its performance and customize user experience by analyzing current user behavior and activity on the App, generating predictions about future user behavior, performing A/B testing, using Remote Config based on certain activities (analytics events) in the App, etc. For these purposes, Firebase collects User Data from our App as it deems necessary for the said processing purposes.
- SendGrid. Email platform solution that facilitates email communications with users. Email addresses of users that have ‘unsubscribed’ from receiving direct communications are stored to ensure that no emails are delivered to such users.
The above third-party partners of the Company are deemed “processors” that “process” User Data for and on behalf of the Company. By using our Services, you hereby agree to the collection, access, transfer, use, process and storage of your User Data by the above third-party partners for the purposes identified above.
Please always refer to such third-party services' privacy policies for more information about their own practices, procedures and data collection policies, which are separate and independent from this policy.
If you use our App, we may also collect the following information:
(a) Device Access: We may request access or permission to certain features from your mobile device, including your mobile device's microphone, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
(b) Push Notifications: We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
SHARING USER DATA
We do not share or disclose User Data with any third party, except:
- To our third-party service providers who provide to us App related services, such as attribution, analytics, application development, hosting, maintenance, backup, storage, etc., which may need to access or use certain information about you. Any such information does not include user’s personal data that can directly identify an individual. These providers are authorized to use User Data only as necessary to provide these services to us, including compliance with policies and procedures designed to protect your information.
- In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect the Company or our customers from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information.
- As part of any merger or acquisition of the Company, in which case User Data may be transferred to the surviving or acquiring entity.
STORING & SECURING USER DATA
The security, integrity and confidentiality of your User Data are extremely important to us. We take reasonable precautions — including administrative, technical, and physical measures —to safeguard your User Data against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction and implement measures, such as encryption, to mitigate those risks. However, you must understand that while we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
We use AWS around the world as our data hosting service providers to host and store the information we collect from you and we use technical measures to secure your data. Your use of the Services followed by your submission of any information represents your agreement to such cross-border flow and access by entities around the world of your data.
HOW LONG WE RETAIN YOUR DATA
We keep any data received from or about you (including device information) in connection with your use of our App for the shortest possible time that is necessary to provide to you the Services and for no longer than the period of time in which you have an account with us unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
YOUR DATA PROTECTION RIGHTS
For the purposes of the laws of certain jurisdictions, the Company is deemed a data "controller" in connection with the collection, use and process of User Data as prescribed under this policy.
Company shall comply with all applicable laws related to its status as a data controller and shall only use the data as described in this policy.
The laws of certain jurisdictions may provide users with various rights in connection with the processing of User Data, including:
- The right to access: You have the right to ask for copies of your personal data.
- The right to rectification: You have the right to ask from us to correct any information about you that you believe is inaccurate. You also have the right to request the Company to complete information about you that you believe is incomplete.
- *The right to erasure: You have the right to ask that we erase your personal data.
- *The right to restrict processing: You have the right to ask that we restrict the processing of your personal data.
- *The right to object to processing: You have the right to object to the Company’s processing of your personal data.
- *The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you.
* Please note these rights may be limited in certain circumstances as provided by applicable law.
If you would like to exercise any of these rights, please email us using the contact details below. We will respond to your requests within a reasonable timeframe in line with applicable laws and regulations.
CHILDREN & PRIVACY
Our Services are intended for use by children. We take children's privacy very seriously and therefore we strongly recommend to parents and/or guardians to be actively involved in their children’s online activities and interests. Company recognizes the need to provide extra privacy protection regarding data that may be collected from children while accessing and using our Services, in compliance with applicable laws and regulations.
If data is collected while your child is using the Services, Company adopts further measures in order to protect such child's privacy, including: (i) to inform parents regarding the types of User Data collected and the uses made of such information as set forth below; (ii) to allow parents to refuse to the collection and use of User Data from their children in accordance with applicable law; (iii) to limit the collection of User Data to the minimum possible; and (iv) to allow parents, upon specific request and subject to the provisions of section 4 below, to have their child's User Data collected by the Company or even their entire account with us deleted and removed. In any event that we collect data from a child, we will retain that information only for as long as it is reasonably necessary to allow your child to use our Services or as required by law.
- Registration. If a person who intends to register for the Services indicates that he/she is under 18 years old, such person will be considered a "minor" under this policy and will be asked to get a parent or a guardian to continue with the registration and subscription process; such parent/guardian will be required to register as described in this policy, even if registration is intended for his/her child's use of the Services. During registration we only ask for limited information about your child including age and gender, to customize the Content to suit your child’s age and preferences.
- User Behavior. We also use technologies and in-app analytics practices that help us understand how your child interacts and uses the various features, content, interactive games, quizzes and activities inside the App to provide the most enjoyable and engaging learning experience. Persistent identifiers collected for the sole purpose of providing support for the internal operations of the App and the data generated is principally used for customization and personalization purposes. No other personal information is collected about your child.
- Parental Notice. We make reasonable efforts, taking into account available technology, to ensure that a parent of a child receives direct notice of our practices with regard to the collection, use, or disclosure of data from children.
- Parents' choices and controls. Consistent with applicable law, parents can at any time refuse to allow us to collect and use their child's data gathered while using the Services. To the extent permissible by applicable law, parents can specifically request from us through "contact us", to : (i) review their child’s data collected; or (ii) remove or delete from our records such data or any part thereof collected by the Company. Bear in mind however that a request to delete and/or remove your child's data from our records or your account with us shall lead to the termination of your or your child's ability to access and use the Services.
- Parents' Zone. A dedicated "parents' zone" within the App will include account settings and other important information intended for use by parents only.
La Mark Vision Ltd. is the owner and controller of your User Data. If you have questions or concerns about how your data is handled, please direct your inquiry to La Mark Vision Ltd. at: firstname.lastname@example.org or +972-9-9606666. If you wish to send us a letter by post, you may do so at: La Mark Vision Ltd., 33 Havatzelet Hasharon str., Herzeliya, Israel