Smartots Privacy Policy

Govela Limited, DBA SmarTots (“SmarTots”) and its subsidiaries respect the privacy rights of our users and are committed to protecting the information collected through our online services, online products, and websites (together “Services”). So we have developed privacy policies to explain how we at SmarTots collect, use, disclose, transfer, and store the information collected in connection with our Services. If you reside in the United States and are accessing our Services from the United States, you will be subject to the SmarTots Privacy Policy-U.S.A. (http://smartots.com/privacy_policy#usa) and SmarTots Privacy Policy – U.S.A. – COPPA (http://smartots.com/privacy_policy#usa_coppa) below. If you reside outside of the United States, you will be subject to our international privacy policy, SmarTots Privacy Policy – International (http://smartots.com/privacy_policy#international), also provided below.

SmarTots Privacy Policy-U.S.A

Effective Date: February 27, 2012

SmarTots is committed to ensuring that there are quality online activities for children. SmarTots offers an online subscription service for parents who wish to oversee their child’s use of various mobile applications (the “SmarTots Product”). SmarTots highlights mobile applications on its website that it believes might be of interest to parents of preschool children. The majority of these mobile applications are created by third party application providers not affiliated with SmarTots, but SmarTots also has developed some of the applications. For ease of reference, mobile applications developed by SmarTots are referred to as “SmarTots Applications” and third-party applications and SmarTots applications collectively referred to as Applications”).

This Privacy Policy (the “Policy”) applies to www.SmarTots.com (the “Site”), the SmarTots online service and mobile application (referred to as the “SmarTots Service”, and SmarTots Applications, (collectively, “Services”), all of which are owned and operated by Govela Limited, DBA SmarTots (“SmarTots,” “us” or “we”). This Privacy Policy does not cover applications created by third parties. Please refer to the applicable mobile application to review their privacy policy. In this Policy, we will refer generally to all of our Services, unless it is necessary to distinguish among our Site, the SmarTots Applications, and our other Applications. In this Policy, we also discuss the information that we share and obtain from third-party developers of non-SmarTots applications that we feature on our Site. We refer to those developers as “App Developers.”

This Policy describes how we collect, use, and disclose personally identifying information (“Personal Information“) about parents, and other users of the Site and Services who are 13 years of age or older. For information about how we collect and use Personal Information about children under 13 years of age, through SmarTots Applications, please review our SmarTots Children’s Privacy Policy http://smartots.com/privacy_policy#usa_coppa. This Policy incorporates by reference the SmarTots Terms of Service (“Terms”), including their limitation of liability, which are available at http://smartots.com/terms_of_service#usa.

How the SmarTots Product Works

SmarTots has developed an innovative tool (the “SmarTots Product”) for parents to track their child’s use of select mobile applications, which may include SmarTots Applications. Interested parents will sign up for the SmarTots Product through our Site, a SmarTots Application, or a third-party application that is part of the SmarTots network. Parents may select among the applications listed on the Site (which include all Applications), and download applications of interest. SmarTots will collect data from those applications, including IP address, device type, as well as participant performance data, to compile a report for parents. SmarTots only collects data from the Applications within its network.

The Types of Personal Information We Collect and How We Use It

We may collect Personal Information about you directly from you, through your use of the Site or Services, or from third parties. In general, we collect the following types of information about you:

Account Information for SmarTots. You can register for our SmarTots Product via either a mobile application in our SmarTots approved network or our website directly. If you sign up for an account or register for our Service, we ask you for your name and email address, as well as a password. We also may collect the first name, age, gender of your child(ren), and other optional information such as your contact information and your location (see below) and certain demographic information.

Account Information for SmarTots Applications: As stated above, in addition to the SmarTots Product, we develop our own applications that may be of interest to you. Our SmarTots Applications have integrated SmarTots’ functionality; therefore, if you download a SmarTots Application, then we will track your child(ren)’s progress in the application and will provide you with reports of your child(ren)’s progress.

Information that We May Collect About You Through All of Our Services (including all Applications):

• Transaction Information. We may collect information about your transactions with us and with some of our business partners, including information about your use of Services that we offer.
• Contact Information. In the course of using the Site or Services, we may ask you to provide us with contact information that can be used to contact or identify you, including your home phone number, email address and mailing address.

• Mobile App User Information. When you launch our SmarTots Product or any SmarTots Application, or use or register to join our Services via a SmarTots-enabled mobile app created by a third-party publisher (a third party that has developed its own mobile app that is connected to our Service), we collect your device type, the unique device ID issued by the smartphone provider and/or your mobile provider (“Device ID“), Operating System being used, browser version and IP address, if applicable. We use the Device ID to authenticate users, and to understand how users use our Service or third-party services that they access through our Services. In addition, we may use this information for advertising purposes. For example, our Services may serve ads that contain links to other SmarTots-enabled mobile apps that are connected to our Service, and your Device ID enables us to track when you click on these ads. Our use of your Device ID enables us to identify you personally, and we store this information in connection with your SmarTots User account information in order to make your log-in faster.
• Other Information. We may also collect other information about your use of our Services and Applications, and may, from time-to-time, ask users to participate in surveys.

Information We Collect About You from Facebook: We also may permit you to log into the SmarTots Product through third party social networking sites such as Facebook. If you log into our Site using your Facebook log in credentials, in accordance with Facebook’s log in process, you will be directed to enter your user ID (often your email) and your password. We store the information that we receive from you through Facebook. For information about how Facebook may disclose your information, including any information that you make public, please consult the applicable site’s privacy policy. We do not have any control over how any of these sites uses or discloses the Personal Information that you provide to them.

If you sign into our service through Facebook, after entering your email address and Facebook password, we will request your permission to: access your basic information, including, your name, profile picture, gender, networks, user ID, list of friends, and any other information that you have chosen to make public; send you email; access your data at any time even if you are not currently logged into Facebook; and access your profile information, including your birthday and current city. Please note, if you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. For information about how Facebook may disclose your information, please consult the Facebook Privacy Policy. We have no control over how Facebook uses or discloses the Personal Information that you provide to it. We store the information that we receive from Facebook along with other information that we collect from you or receive about you.

How We Use Your Personal Information

In general, we use the Personal Information we collect about users for the following reasons:

• to provide our Services, including to generate reports for parents about their children’s use of SmarTots-enabled apps, and to fulfill requests
• to contact parents via email and otherwise about information, products or services we think may interest them
• to display targeted advertising and to customize the content we display to users
• to respond to request or inquiries from parents, and for other customer-service related purposes
• to enforce this Policy and our Terms
• to assign ratings to Applications
• to process payments
• to analyze how people use our Site, Service, and SmarTots-enabled apps
• to improve the design, content and performance of our Site and Services
• to post to your Facebook news and
• for market research purposes.

Notwithstanding anything else in the Policy to the contrary, we may freely use aggregate and non-personally-identifying information about users for marketing, research and other purposes and will provide aggregate statistical information to developers who integrate our SDK in their applications and provide their applications through our website.

How We Disclose Your Personal Information

SmarTots may share Personal Information about users with select third parties, such as service providers and business partners, as stated below:

Third-Party Business Partners. From time to time, we may partner with outside third parties to provide you with additional content, products, or services that we believe may be of interest. For example, we may partner with a greeting card company, software manufacturer, or telephone provider to offer you electronic cards, games, or telephone messaging. We may share aggregate information with our third-party business partners, but, if you are located in the United States, we will not disclose your Personal Information with these partners. We emphasize that we do not disclose your information with third parties for direct marketing purposes in the United States.

Facebook. Parents will have the option of sharing their reports through our Facebook application. Any information that you post to Facebook may be viewable by other Facebook users. We have no control over how Facebook uses or discloses the personal information that you provide to it.

App Developers. We will provide App Developers with statistical aggregate information only. At no time will we disclose personal identifiable information to any App Developer.

Service Providers and Agents. We may disclose the Personal Information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf. These third parties have agreed to maintain the confidentiality, security and integrity of this Personal Information and to only use such information for the purposes for which they have been engaged by us.

Business Transfers. If we are acquired by or merged with another company, if substantially all or a part of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring company.

In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.

To Protect SmarTots and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms or this Policy, or to protect SmarTots in litigation.

Notwithstanding anything else in the Policy to the contrary, we may freely share aggregate and non-personally identifying information about users with App Developers and third parties for marketing, research and other purposes. For example, we may share demographic information about the use of SmarTots-enabled apps with marketing partners and third party advertisers who may use the information to determine what types of advertising content to display to users.

Cookies and Log Data

When you interact with our Site, we strive to make your experience easy and meaningful. We or our third-party service providers may use cookies, web beacons (clear GIFs, web bugs) and other technologies to track user activity and collect Site data.

Cookies. Cookies are alphanumeric identifiers that websites transfer to your computer's hard drive through your web browser for record-keeping purposes. Cookies cannot damage user files, nor can they read information from a user's hard drive. Cookies allow websites to “remember” certain information about a user’s activities on a website. We use cookies at our Site to determine the number of unique visitors to the Site and to track other information about user activities on the Site. We do not store any Personal Information in cookies, but we do we link or combine information collected through cookies to any Personal Information submitted by users when participating in our activities. We also use cookies to store user preferences and to allow you to remain logged in as you use our Site.

Disabling Cookies. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, you may still browse our Site, but some of our features may not work.

Web Beacons (Clear Gifs/Web Bugs). We or the third parties we employ may use web beacons (a.k.a. Clear Gifs/Web Bugs) on our Site to help us better manage content on the Site. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer's hard drive, web beacons are embedded invisibly on web pages. We may also use web beacons in our HTML-based emails, to let us know which emails have been opened or forwarded by recipients.

Third-Party Service Providers. As noted above, we may employ third-party service providers to perform Site functions for us, such as serving customer content, collecting IP address and anonymous traffic data, or performing site analytics. These vendors may place and read cookies or web beacons on your browser to perform these functions.

Third-Party Advertisements. In addition, we may participate in third party ad networks and make available to our Site users specific offers from third-party companies. These companies and ad networks may utilize cookies and web beacons in connection with the delivery of their offers and to serve ads based on your use of our Site or other internet sites. Their use of cookies and other tracking technologies is subject to their respective privacy policies, not this one. We will not share your Personal Information with these third parties.

Opting Out of Third-Party Ad Networks. If you wish to opt-out of receiving cookies from certain third party ad networks, you may do so through the Network Advertising Initiative cookie opt-out page, which can be found at http://www.networkadvertising.org/managing/opt_out.asp. You may also visit www.AboutAds.info to learn more about online advertising, and to opt-out of certain online behavioral advertising activities.

Marketing Communications

We may contact you about announcements, newsletters and promotional materials related to our Services or other products, service or information we think may interest you, and to offer you opportunities to participate in surveys, contests or sweepstakes via our Services. If you decide at any time that you no longer wish to receive such promotional communications from us, you may unsubscribe by following the unsubscribe instructions provided in any of these email communications. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails from us, we may continue to send you e-mails about your account, any services that you have requested or received from us or for other customer services purposes.

User Generated Content

Users may post content on certain portions of our Site and through our Services, including, for example, user reviews of various applications, blogs and user comments. SmarTots is not responsible for the privacy of any information that you choose to submit through this Application, Site, our Services, or through any public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.

Surveys

SmarTots may conduct user surveys. We use the information we collect from these surveys to improve our content, Site and Service. While we may share aggregate information about survey responses with advertisers and business partners, we do not share any Personal Information about survey respondents.

Third-Party Applications

The App Developers may collect and use Personal Information about your children. The privacy practices of these developers are not subject to this Policy – you should review the privacy policies for any mobile apps that your child uses.

How We Protect Your Personal Information

SmarTots has taken steps to secure the Personal Information that we collect, including limiting the number of people who have physical access to our database servers as well as electronic security systems and password protections which guard against unauthorized access.

Changes to this Policy

We reserve the right to amend this policy at any time. If we do so, we will change the effective date above. We encourage you to review this privacy policy from time to time. Please check this page periodically for changes. If we materially change our practices with regard to Personal Information we have previously collected from you, we will endeavor to provide you with notice, such as, where appropriate, email notice or notice posted at our Site.

How to Contact Us

You may contact us using the following information:

Contact Form: http://www.smartots.com/contact

or

Govela Limited

Room 1708 Nan Fung Tower

173 Des Voeux Road Central

Hong Kong

 

SmarTots Children’s Privacy Policy - U.S.A. COPPA

Effective Date: February 27, 2012

SmarTots is committed to ensuring that there are quality online activities for children. SmarTots offers an online subscription service for parents who wish to oversee their child’s use of various mobile applications (the “SmarTots Service”). The SmarTots Service is directed towards parents of preschool-aged children. We do not collect personal information from any child under 13 unless the child’s parent first subscribes to our Service. At SmarTots, parents will have the ability to see their child’s usage of various mobile applications (created largely by third party application providers not affiliated with SmarTots).

SmarTots highlights mobile applications on its website that it believes might be of interest to parents of preschool children. The majority of these mobile applications are created by third party application providers not affiliated with SmarTots, but SmarTots also has developed some of the applications (“SmarTots Applications”).

Once a parent has signed up for the SmarTots application, SmarTots will collect information about a child’s usage of applications that are SmarTots-enabled. SmarTots does not control the scope of information that a third-party application requests from the child/parent during the sign-up process. Please refer to each application for information about their data collection practices. In this Policy, we describe our collection of information about children.

I. About COPPA

The Children's Online Privacy Protection Act (“COPPA”) requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under the age of 13. Under COPPA, we also are required to obtain parental consent before we collect personal information from children under the age of 13. For more information about COPPA, click here.

In this policy, we use the following terms:

“Parent” includes legal guardians.

“Child” means a child that is under the age of 13.

“Personal information” means individually identifiable information about a child that is collected online, such as first and last name, a home address, an e-mail address, a telephone number, or any information collected from an individual and combined with such identifying information.

II. Scope of this Policy

This Policy applies to www.smartots.com (the “Site”) and mobile application (referred to as the “SmarTots Service”), and SmarTots Applications, (collectively, “Services”), all of which are owned and operated by Govela Limited, DBA SmarTots (“SmarTots,” “us” or “we”). . This Policy describes how we collect, use and disclose personal information collected from children under 13 years old at our Site and through our Service.

This policy incorporates by reference the Terms of Service (“Terms”), including their limitation of liability. To view the Terms, click here, http://smartots.com/terms_of_service#usa. To view our general Privacy Policy for the United States, which applies to the information we collect from parents and other Site visitors or users, click here. Before using this Site or registering for the Service, please read this Policy, as well as our Terms and general Privacy Policy for the United States.

BY USING OR ACCESSING OUR SITE OR SERVICE, OR BY PERMITTING YOUR CHILD TO USE OR ACCESS OUR SERVICE, YOUR ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS POLICY.

III. About Us

The SmarTots Service and Site are owned and operated by:

Govela Limited, DBA SmarTots, Inc.

Room 1708 Nan Fung Tower

173 Des Voeux Road Central

Hong Kong

Email: info@smartots.com

The Site is directed toward parents, not children. We do not knowingly collect personal information from children through our Site. Parents may register themselves at our Site and add their children to their account; however, children may not register for our Site or Service.

The Service is available for use by parents to gather information about how their children use SmarTots-enabled mobile apps. The Service only is available after a parent has registered through our Site. Children under the age of 13 are not allowed to subscribe themselves to the Service.

IV. Types of Personal Information We Collect From Children Under 13 and How We Use It

We do not ask children under 13 to directly provide us with any personal information. Rather, when a parent registers for our Service, we collect information about his or her child’s usage of SmarTots-enabled mobile apps, including:

• the device type, device operating system, browser type, unique device ID issued by the smartphone provider and/or your mobile provider and IP address, if applicable
• the date and time spent on, and total usage of, SmarTots-enabled apps
• the time spent on apps in particular categories (e.g., math, reading, science, entertainment)
• the activities participated in while using SmarTots-enabled apps, including screen shots or photos
• the other statistics and information based on the above or on a child’s use of SmarTots-enabled apps

When a parent registers for our Service we ask the parent to disclose the following:

• the parent’s first and last name, email address, password and year of birth
• their child’s first name, age and gender, and any other information the parent decides to submit
• other optional information such as a child’s photo

When a child uses one of our SmarTots Applications, we collect the following information:

• the device type, device operating system, browser type, unique device ID issued by the smartphone provider and/or your mobile provider and IP address, if applicable

If the parent is using one of our SmarTots Applications and has registered for SmarTots’ services, then we collect

• the device type, device operating system, browser type, unique device ID issued by the smartphone provider and/or your mobile provider and IP address, if applicable
• the date and time spent on, and total usage of, SmarTots-enabled apps
• the time spent on apps in particular categories (e.g., math, reading, science, entertainment)
• the activities participated in while using SmarTots-enabled apps, including screen shots or photos
• the other statistics and information based on the above or on a child’s use of SmarTots-enabled apps

V. How We Use the Personal Information We Collect From Children Under 13

We use the information we collect about children under 13 for the following purposes:

• to provide the Service, including to generate reports for parents about their children’s use of SmarTots-enabled apps
• to respond to request or inquiries from parents, and for other customer-service related purposes
• to enforce this Policy and or Terms
• to assign ratings to SmarTots-enabled apps
• to process payments
• to send emails to parents about information we think may interest them and to customize the information we send to parents, via email or otherwise
• to improve the design, content and performance of our Site and Services
• to analyze usage and popularity of the Site and Service, as well as of SmarTots-enabled apps
• to customize the content we display, including to display targeted advertising

Parents may request information from us on the type of data being collected, view their child’s information, and, if they choose, prohibit us from further collecting or using of their child’s information. For more information on how to do this, see the section below entitled “How To Review, Delete or Alter the Information Collected From Your Child.”

VI. To Whom We May Disclose the Personal Information We Collect From Children

We do not sell, rent or trade personally identifiable information about children under 13 with any third parties. We may, under certain circumstance, disclose personal information about children under 13 under the following circumstances:

• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. These third parties have agreed to maintain the confidentiality, security and integrity of personally identifiable information and to only use such information for the purposes for which they have been engaged by us.
• Business Transfers: If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring company.
• In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
• To Protect SmarTots and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms or this Policy, or to protect SmarTots in litigation.
• Aggregate, Anonymous or De-Identified Information. We may also share aggregate or anonymized information about children with app developers and non-affiliated third parties for advertising, marketing or research purposes. For example, we may share demographic information about children’s use of SmarTots-enabled apps with marketing partners and third party advertisers, which may be used to determine what types of advertising content to display. We do not share your child’s personally identifiable information with any third parties for marketing, advertising or research purposes.

A parent can disable, delete or modify any of his or her child’s information. For more information on how to do this, see the section below entitled “How To Review, Delete or Alter the Information Collected From Your Child.”

Please note that parent’s may choose to share information about their children’s use of SmarTots-enabled apps and the Service through multiple methods, including via social networking sites such as Facebook. If a parent has chosen to share this information, we have no control over – nor does this Privacy Policy apply to – how that information is shared or used under such circumstances.

VII. How To Review, Delete or Alter the Information Collected From Your Child

You can review your child's personal information at any time. You may revoke consent to collect your child’s personal information at any time. You can also have your child's personal information deleted and refuse to permit further use of such information by us.

If you wish to view, delete or modify the information we have collected about your child or delete your child’s account, you may do this by sending us a request using the contact form: http://www.smartots.com/contact or by e-mailing us at: info@smartots.com.

VIII. How We Protect Your Personal Information

SmarTots takes your privacy very seriously and employs commercially administrative, physical and electronic measures to safeguard your information from identity theft and unauthorized access. SmarTots has taken steps to ensure that personally identifiable information collected is secure, including limiting the number of people who have physical access to our database servers as well as electronic security systems and password protections which guard against unauthorized access.

IX. Other Information Parent’s Should Know

We only collect the personal information about your child that is necessary to provide our service. We will never condition a child’s participation upon the disclosure of personal information, other than that which is necessary to provide our Service to you.

X. Third-Party Apps

The developers of SmarTots-enabled apps may collect and use personal information about your children. The privacy practices of these developers are not subject to this Policy – you should review the privacy policies for any mobile apps that your child uses.

XI. Changes to this Policy

We reserve the right to amend this policy at any time. Please check this page periodically for changes. We will post a notice on this website if and when this policy changes to alert visitors that a new policy is in place. If we intend to use or disclose your child’s personal information in a manner materially different from that stated at the time of collection we will notify you via email and obtain your consent to such changes.

XII. How to Contact Us

You may contact us using the following information:

Contact Form: http://www.smartots.com/contact

or

Govela Limited

Room 1708 Nan Fung Tower

173 Des Voeux Road Central

Hong Kong

 

SMARTOTS PRIVACY POLICY - INTERNATIONAL

Last updated: 27 February, 2012

1. INTRODUCTION

1.1 Govela Limited, DBA trading as SmarTots ("SmarTots", "we" or "us") is committed to preserving the privacy of all visitors to this website. This policy (together with our terms and conditions (available at http://smartots.com/terms_of_service#international) sets out the basis on which any Personal Information (as defined below) we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it.

1.2 By using this website or any of our services, or by providing us with your Personal Information (as defined below), you hereby indicate your explicit consent to the collection, use, processing, handling and transfer of the information that you provide to us in accordance with the terms of this policy.

1.3 This policy is current as of the “last updated” date set forth above. We reserve the right to change the contents of this website, including this policy at any time, by posting such changes on the website. It is your responsibility to familiarise yourself with the policy regularly to ensure that you are aware of any changes. Your continued use of this website following the posting of any such changes will constitute your acceptance of the revised policy.

2. COLLECTION OF YOUR INFORMATION

2.1 When you visit or register with our website or subscribe to our services (either via an application in our SmarTots approved network or via our website), you may be asked to provide us with your Personal Information. "Personal Information" is information that you provide to us which personally identifies you directly or indirectly, and includes without limitation your name, telephone number, identification number, email address, credit card details, and photograph. You may choose not to provide us with your Personal Information, but you may not be able to access fully our website and services.

2.2 We may also collect information about your usage of this website as you browse our website (see section on "cookies" below), as well as information about you from messages you post to the website and emails or letters you send to us.

2.3 In addition to the above, we may also collect other, non-personally identifiable information ("Non-Personal Information") that you may provide to us as part of our registration, administration and personalization processes. Non-Personal Information include, without limitation, your Internet Protocol ("IP") address, Internet browser type and version, Device ID (as defined below), operating system (“OS”), your geographic location and user preferences. We may also collect information about your transactions with us and with some of our business partners, including without limitation information about your usage of our services. Certain Non-Personal Information may be considered as a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified, but the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information.

2.4 When you launch any of our approved applications or subscribe to our services via any mobile application or mobile device, we will collect other Non-Personal Information, including without limitation information concerning your mobile device type, the unique device ID issued by the Smartphone/tablet provider and/or your mobile provider for your iOS device ("Device ID") and your IP address. We may use this Non-Personal Information to authenticate and understand usage of our services or other third party services.

2.5 Further, our services and our approved applications may serve advertisements that contain links to other applications connected to our services, and your Device ID enables us to track any clicks you may choose to make in respect of such advertisements. Our use of your Device ID does not enable us to identify you personally, but we may (i) use and store this information to better understand your usage of our services and (ii) store this information in connection with your SmarTots user account information to make your log-in faster.

2.6 We may provide aggregate and non-personally identifiable information about users for marketing, research and other purposes and will provide aggregate statistical information to developers who integrate our software development kit (“SDK”) in their app and provide their app(s) through our website.

2.7 We occasionally conduct user surveys to better target our content to our audience. In that regard, we sometimes share aggregated demographic information (which contains no Personal Information) obtained in these surveys with advertisers and partners. Save as provided in this policy, we not share any Personal Information with any third party.

3. USE OF THE INFORMATION WE COLLECT

3.1 Your personal information will enable us to provide you with access to all parts of our site and will be used for the following purposes:

3.1.1 to provide our services, including to generate reports for parents about their children’s use of SmarTots-enabled apps, and to fulfill requests

3.1.2 to contact parents via email and otherwise about information, products or services we think may interest them;

3.1.3 to display targeted advertising and to customize the content we display to device and app users;

3.1.4 to respond to request or inquiries from parents, and for other customer-service related purposes;

3.1.5 to enforce this policy and our terms and conditions;

3.1.6 to assign ratings to SmarTots-enabled apps;

3.1.7 to analyze how people use our Site, Service, and SmarTots-enabled apps;

3.1.8 for market research purposes;

3.1.9 administering our business activities ;

3.1.10 administrating and operating our website, products and services;

3.1.11 providing you with the products or services you have requested;

3.1.12 processing your payment;

3.1.13 improving our website, services and products; and

3.1.14 keeping you up-to date with our products and services.

You acknowledge and agree that we may make available or disclose to third parties information about you in connection with any of these purposes. This may include, amongst other things, passing your details on to payment processing agencies, such as PayPal in order to administer your account and process payments

3.2 We may also use your Personal Information to provide you with other information about our other products or services which may be of interest to you via email. You may opt-out from receiving this information at any time by send an email to our co-founder, Victor Wong, at http://www.smartots.com/contact. Please insert "unsubscribe" as the appropriate subject heading in your email.

4. DATA RETENTION

We will retain the personal information provided by you for as long as is reasonably necessary for the purposes listed in this policy.

5. DISCLOSURE OF INFORMATION

5.1 The information you provide to us will be held on our computers in locations which may be outside your jurisdiction and may be accessed by or transferred to our staff, to any member of our group of companies and/or third parties for the purposes set out in this policy or for other purposes approved by you.

5.2 We may disclose your Personal Information to third parties acting on our behalf or who are our subsidiaries or affiliates. These third parties may assist SmarTots with various activities, including without limitation processing information, fulfilling and delivering orders, processing credit card payments, record keeping, internal administration, website administration and operation, preparing communications, and/or providing technical and administrative support. However, we do not give these third parties an independent right to share or use your Personal Information. Furthermore, these third parties have agreed to maintain the confidentiality, security and integrity of this Personal Information and to only use such information for the purposes for which they have been engaged by us.

5.3 From time to time, we may partner with outside third parties to provide you with additional content, products, or services that we believe may be of interest. For example, we may partner with a greeting card company, software manufacturer, or telephone provider to offer you electronic cards, games, or telephone messaging. To the extent permitted by applicable law, we may disclose your Personal and Non-Personal Information to such third parties for marketing and research purposes.

5.4 Some of the parties to whom we may transfer your Personal Information may be located in countries outside of your jurisdiction, including without limitation the United States of America. By using our website or services or providing us with your Personal Information, you hereby indicate your express, explicit consent that we may transfer your Personal Information to places outside of your jurisdiction in accordance with this policy.

5.5 We may also pass aggregate information concerning the usage of our site and services, demographics and locations onto third parties, but this will not include information that can be used to identify you.

5.6 If we sell, assign or transfer the assets of our business, or if our business is merged, or enters into a joint venture with another business entity, we reserve the right to sell or transfer the databases maintained by us in connection with our business (which may contain any Personal Information provided by you).

5.7 We may disclose personal information in response to a legal process, for example, in response to a court order. We also may disclose such information in response to a law enforcement agency’s request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, non-compliance with of our terms and conditions, or as otherwise permitted or required by law and consistent with legal requirements.

6. COOKIES AND WEB BEACONS

6.1 As with many other commercial websites, our website utilises a standard technology called "cookies" and web server log files to collect information about how our website is used. Information gathered through cookies and web server logs allow us to monitor website traffic and improve our website, as well as to personalise the content of the site for you.

6.2 A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. At SmarTots, we do not store any Personal Information into cookies, but we do link or combine information collected through cookies to any Personal Information submitted by our users for the purpose of providing activity reports and better recommendations. Also, we link the login data to our users' Personal Information to allow you to remain logged in as you use our Site.

6.3 Our web pages may also contain electronic images (called a "single-pixel GIFs" or "web beacons") that allow us to count the number of users who have visited that page. If you visit these web pages, your browser may send your cookies to these pages.

6.4 Also, if you click on the advertisements in our website or applications, the advertisement service providers may place or recognize their own unique cookie on your browser, and may use Non-Personal Information about your visit to this Site and other sites, such as the number of times that you have viewed an advertisement, to provide other advertisements about goods and services that may be of interest to you.

6.5 Internet browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that you may not be able to access some parts of our website or use some of our services.

7. IP ADDRESSES

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. Each time you visit our website or access our services, our web server automatically recognizes and collects your IP address, as well as other technical information about your web browser and domain name. IP addresses are collected by our web server as part of demographic and profile data known as traffic data so that data (such as the web pages you request) can be sent to you.

8. SECURITY

8.1 We are committed to protecting the security of your Personal Information. We use a variety of security technologies and procedures which aim to protect your Personal Information from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.

8.2 We employ various measures to ensure that your Personal Information is secure, including limiting the number of people who have physical access to our database servers as well as electronic security systems, Secure Sockets Layer (SSL) encryption, and password protection systems.

8.3 Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.

9. OTHER WEBSITES

Our website may contain links to other websites and/or content offered by other websites, including the social networking sites. These other sites maintain their own policies regarding cookies and the collection, use and handling of Personal Information. It is up to you to review those policies yourself. If you share, post or circulate Personal Information (including without limitation the Personal Information of a Child (as defined below)) through these websites, you do so at your own risk. SmarTots, its affiliates, employees, officers and agents shall not be responsible for the privacy practices of these websites.

10. PERSONAL DATA OF MINORS

10.1 SmarTots’ website, products and services are designed for parents. As such, in order to provide our products and services to you, it is necessary for us to collect the Personal Information of your child, including without limitation your child’s name, gender, birthday and photograph. By providing us with Personal Information of a child under the age of 13 (“Child”), you hereby expressly warrant and represent that:

10.1.1 you are the parent or legal guardian of the Child;

10.1.2 you have the legal right, permission and/or authorization to provide the Child's Personal Information to us for the purpose of using our website, products and/or services and that you have all the necessary consent as may be required by any applicable law to provide us with the Child's Personal Information; and

10.1.3 your provision of the Child's Personal Information is compliant with all applicable laws and regulations, including without limitation the Data Protection Directive 95/46/EC of the European Union and other data privacy laws;

10.2 By providing us with Personal Information of a Child, you indicate your explicit consent to the collection, use, processing, handling and/or transfer of the Child's Personal Information by SmarTots in accordance of this policy and the terms and conditions.

10.3 We do not knowingly collect or solicit Personal Information directly from anyone under the age of 13. If you are under 13, please do not attempt to send any information about yourself to us, including without limitation your name, address, telephone number, or e-mail address. In the event that we learn that we have collected Personal Information from a child under the age of 13, we will delete that information as quickly as possible.

11. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

11.1 You are entitled to see a copy of the personal information about you that we have collected and that we maintain. If you wish to do this, please email us at http://www.smartots.com/contact. We may charge a small fee to meet out costs in providing you with these details.

11.2 You may ask us to make changes to the information provided by you and/or held about you, to ensure that it is accurate and kept up to date. You may also request that we cease processing your personal information and that we delete you from our database or records. If you wish to do this, please email us at http://www.smartots.com/contact. We may charge a small fee to meet out costs in providing you with these details.

11.3 You may also access your profile at our website, where you can update or correct your name, email address, children’s name, children’s age, and children’s picture(s). Once logged in, you can access you profile by clicking “settings” and then “edit family profile.”

12. EXEMPTION OF LIABILITY

SmarTots, its affiliates, employees, officers and agents shall not be liable for (i) any disclosure of your Personal Information (and/or Personal Information other persons which you have provided) as required by law or relevant governmental authority; (ii) any disclosure of your Personal Information (and/or Personal Information of other persons which you have provided) as a result of your own actions or negligent acts; or (iii) any consequence resulting from Acts of God beyond SmarTots' control; (iv) any collection, use, handling or disclosure of your Personal Information (and/or Personal Information of other persons which you have provided) by other third party websites; (v) any inaccuracies in your Personal Information (and/or Personal Information of other persons which you have provided) which you have submitted to SmarTots and (vi) any disclosure of Personal Information of a Child by you.

13. CONTACT US

All comments, queries and other requests relating to our use of your information should be addressed to the customer services team at http://www.smartots.com/contact or myprivacy@smartots.com or by post to Govela Limited, Room 1708 Nan Fung Tower, 173 Des Voeux Road Central, Hong Kong.