Effective: March 27, 2019
Collection of Information. You or your child (collectively the “Data Subjects”) may be asked to provide for some or all of the following types of information (the “Personal Data”) in order to register for use of the Services, and subsequently at any time you seek to access various content, contact us with questions or feedback, or access other features of the Services:
1. Account registration/contact information such as name, date of birth, email address, username, and password. Where we ask for age and determine the user is age under the age of 13, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have not received an email providing notice or seeking your consent, please feel free to contact us at firstname.lastname@example.org. Please note that you may choose whether or not to share certain information with us, but certain application features cannot function without it. As a result, you or your child may not be able to access or use certain features if required information has not been provided.
2. Transaction information provided when information is requested or a product or service is purchased from us, such as billing address, telephone number, and payment information.
3. Geolocation information, including location information provided by a mobile or other device interacting with one of our sites or applications or associated with an IP address.
4. Activity information about use of the Services.
In addition, the mobile application component of the Services will be able to access or alter the certain settings of each mobile phone on which the application is downloaded or installed as follows:
1. The mobile application uses Device Administrator permissions for the parental control feature in order to avoid uninstalling of the application by your child.
2. The mobile application will ask for “Usage Data Access.” This allows the application to monitor which other applications are used on the mobile device, and how often, identify the mobile device’s service provider, language settings, and other usage data.
3. The mobile application will ask permission to modify system settings and ask permission to allow the application to show things on top of other apps being used on the mobile device. This may interfere with the use of other applications.
4. The mobile application will ask for permission to take pictures and record video on the mobile device.
5. The mobile application will ask for permission to observe user browser settings to monitor the actions on the mobile device and receive notifications when the application is being accessed and to retrieve window content to inspect the content of a window the user is interacting with.
6. The mobile application will ask for permission to make and manage phone calls.
7. The mobile application will ask permission to set-up a Virtual Private Network (VPN) connection that allows it to monitor network traffic. A key will show on the top of the mobile device’s screen when the VPN is active.
8. The mobile application will ask permission to access each device location.
Use of Information. We generally use the information that we collect about you or your child to:
· Respond to requests for information about our products and services or to otherwise communicate with you about products and services.
· Display content and information that you may be interested in.
· Provide customer service and support and communicate with you about your account;
· Send offers and promotions for our products and services or third-party products and services.
· Personalize content and experiences.
· Otherwise support the internal operations of the Services.
· Detect, investigate and prevent activities that may violate our policies or applicable law.
Disclosure of Information. We may share information that is collected from you or your child in the following circumstances:
1. Third-Party Service Providers. We may share information with our third-party service providers to help us fulfill requests and perform various functions necessary to our provisions of the Services including usage analytics, data processing, and account management and to providers that provide us support services (such as email providers, analytics providers, web hosting providers, payment processors, data enhancement services or fraud prevention providers) or that help us market our products and services.
2. Legal Purposes. We may disclose information we collect when we believe disclosure is appropriate to satisfy any applicable law, regulation, legal process or legitimate governmental request; detect, prevent, or otherwise address suspected fraud, security or technical issues; enforce any applicable terms and conditions, including investigation of potential violations thereof; or protect against harm to the rights, property or safety of TekNekk or its customers or the general public as required or permitted by law.
3. Anonymized and Aggregated Information. We also may share aggregated or anonymized information with third parties, including to help us develop content and
services or modify or improve the Services.
Access to and Accuracy of Your Information. TekNekk provides you with reasonable access to your personal information so that you may review and correct your information if needed. To safeguard your privacy and security, we will verify your identity through various means, such as by requiring a password and user ID, before granting access to your data. We ask that you promptly update your information as and when it changes so that any information used to serve you remains as accurate as possible.
Parental Consent, Access, and Deletion. In the event Teknekk wishes to collect personal information from a child, we will first seek a parent or guardian’s consent by email. If we do not receive parental consent within a reasonable time period, we will delete the parent contact information and any other information collected from the child in connection with that activity.
Parents may refuse to permit us to collect further personal information from their children in association with a particular account at any time, and may request that we delete the personal information that we have collected in connection with that account from our records. Please keep in mind that a request to delete records may lead to a termination of an account or other service.
Where a child has registered for a TekNekk account, we use two methods to allow parents to access, change, or delete the information that we have collected from their children:
2. Parents may contact TekNekk Customer Service to request access to, change, or delete their child’s personal information by sending an email to us at email@example.com. A valid request to delete personal information will be accommodated within a reasonable time period.
In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
Contacting Us. Please email us with any questions or concerns at firstname.lastname@example.org.
ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (THE “EEA”)
The below information applies to any Data Subject resident in the EEA. For purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (the “GDPR”), we act as a “data controller” and our headquarters is located in the United States of America at 3109 Grande Avenue, 446, Miami, Florida 33133. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
GDPR Data Protection Principles. In respect of the collection, holding, storage, use, and processing of your Personal Data:
· We will process the data lawfully, fairly and in a transparent way.
· We will obtain the data only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
· The data we collect will be relevant to the purposes we have told you about and limited only to those purposes.
· We will take reasonable steps to ensure that the data is accurate and kept up to date.
· Subject to applicable legal or other requirements, we will keep the data only as long as necessary.
· We will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
Transfer of Personal Data Outside of the EEA. The transfer of Personal Data from the UK/EEA to entities outside the EEA is governed by data transfer agreements which are in the form of the standard contractual clauses approved by the European Commission (a copy of which can be obtained from us via the contact details below).
Where your Personal Data is processed by third parties outside the EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of standard contractual clauses if the recipients are not located in a
country with adequate data protection laws as determined by the European Commission or certified under the EU-US Privacy Shield framework.
GDPR Data Subject Rights. Under the GDPR, in certain circumstances, an EEA-resident Data Subject has certain individual rights with respect to the Personal Data that we hold about them. In particular, you may have the right to:
· Request access to any data held about you free of charge (although a reasonable administrative fee may be charged if your request is excessive);
· Ask to have inaccurate data amended;
· Request data held about you to be deleted, provided the data is not required by TekNekk to perform a contract, defend a legal claim or to comply with applicable laws or regulations;
· Prevent or restrict processing of data which is no longer required; or
· Request transfer of appropriate data to a third party where this is technically feasible.
Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your Personal Data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. To exercise any of these rights, please contact us by sending an email at email@example.com.
Automated Decision Making. We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. In establishing and carrying out a business relationship, we generally do not use any automated decision making pursuant to the GDPR. We may process some of your Personal Data automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations. We also use assessment tools in order to be able to allow communications and marketing to be tailored as needed.
Data Security. All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator when we are legally required to do so.
Complaints to Local Authorities. As a resident of the EEA, you are also entitled to direct any complaints in relation to our processing of your Personal Data to your national or local data protection supervisory authority.