Privacy Policy for Applications
1. About This Privacy Policy
GPOY Ltd., having its registered address at Flat 13, 180 Albany Street, London, UK, NW1 4BF (hereinafter referred to as “Speechstart”, “we”, or “us”) respects the privacy of its users, both parents and children (hereinafter referred to as “you” or “user”).
We believe that it is important for you to make informed decisions regarding the use of our applications based on your understanding of what information we collect through the use of our applications, what we do with such information, how we process it, with whom we share it, as well as your rights and choices regarding your information processed by us. Therefore, we have provided this privacy policy (hereinafter referred to as “Privacy Policy”) which further describes our privacy practices while you use our applications.
This Privacy Policy is part of and incorporated by reference into the End User License Agreement governing the use of all Speechstart Applications (hereinafter referred to as “Application”).
We recommend that you read this Privacy Policy in full to ensure you are fully informed.
2. Types of Information We Collect
We may collect different categories of information from you, either personal or non-personal information, as defined below and depending on the nature of your interaction with the Application.
Non-personal information is information that may be made available or gathered through your use of the Application and may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, type of operating system, type of device, language preference, the time and date you access our Application, your actions within our Application (e.g., registration, pages viewed, etc.), the URLs from which you were directed to our Application, search queries within our Application, etc., and approximate geo-location (country). To clarify, based on this type of information we are not aware of your identity.
Personal information is individually identifiable information, namely information that identifies an individual or that can, with reasonable effort, identify an individual. Personal information includes information voluntarily provided by you as well as certain identifiers, such as an internet protocol (hereinafter referred to as “IP”) address.
You are not required by law to provide us with certain personal information. You can always refuse to provide certain personal information; however, you acknowledge that such refusal may prevent you from engaging in certain activities within the Application.
In the event we combine personal information with non-personal information, the combined information will be treated as personal information for as long as it remains combined.
The table below details the information we collect, why, and how we use it:
| Type of Information | How We Use It |
|---|---|
| Subscription To use the application and related activities, you as a parent will be required to sign up for a subscription through your app store account. | We will use this information for the purpose of performing our contract with the parent and provide access to requested activities within the Application. |
| Child Profile To create the child(ren)’s “profile”, you as a parent will be requested to provide your child’s gender, first name, and birth month and year. | We will use such information to personalize the child’s experience, including providing direct access to content that we find to be appropriate and relevant for the child, based on the child’s age and screener report. Gender and name are used to make the experience more personal. |
| Support Inquiries If you contact us for support or other inquiries or if you leave a comment through any available communication channel, you will be required to provide us with a valid email address and you may provide us with your name. | We will use this information solely for the purpose of responding to your inquiries on a one-time basis and providing you with the support you have requested. |
| Newsletter Subscription If you voluntarily subscribe to our newsletter, you will be asked to provide us with a valid email address. You can unsubscribe at any time using the unsubscribe option within the newsletter or by contacting customer support at [email protected]. | We will use the email address to send you information related to our Application and to keep you up to date regarding new products, related news, updates, etc. |
| Third-Party Integration If you decide to register through or grant access to a third-party social networking or integrated service (hereinafter referred to as “Integrated Service”), such as Facebook, Google, or Apple, we may collect personal information already associated with your Integrated Service account. You may also have the option of sharing additional information with Speechstart through an Integrated Service. | We will use this information to personalize your experience while using the Application and to operate, maintain, enhance, and provide all features of our Application. |
| Identifiers | We collect, use, and share identifiers solely for the purpose of providing support for internal operations and/or in compliance with COPPA regulations. |
| Approximate GEO Location Data | We will use this information solely to determine the user’s country to provide applicable content. |
| Device Permissions – Camera, Storage, Phone, Microphone Prior to the Application installation process, you will be requested to provide access permission to your device’s camera, storage, phone use, and microphone use. Access is required to enable certain features of the Application such as allowing the child to use the camera and to utilize face or voice detection features. WE WILL NOT SAVE OR COLLECT ANY VOICE RECORDS OR PHOTOS STORED ON THE DEVICE. | |
| Device Permissions – Installed Applications Prior to the Application installation process, you will be requested to provide permission to access the list of applications installed on your device. | We will use this information solely for the purpose of recommending content you do not already have. |
| Payment Details The use of some features of our Application will require payment. | We do not collect your payment details. Please note that payments for subscriptions are subject to the payment terms and conditions of the third-party payment processor (e.g., Stripe) or mobile platform (e.g., iOS Platform, Android Platform, etc.) from which you make your purchase. Speechstart does not control or manage the payment process. Please review the relevant terms and conditions of the applicable third-party payment processor or platform provider before signing up for any subscriptions, as they will collect, use, and process your information (including payment information) in accordance with their privacy policies. |
| Technical Non-Personal Information We also collect certain technical non-personal information related to your use of the Application, such as the amount of time you spend viewing certain portions of the Application. | We use this information for: (i) operating, providing, maintaining, protecting, managing, customizing, and improving our Application; (ii) enhancing your experience with the Application; (iii) auditing and tracking usage statistics and traffic flow, and detecting fraud, security, or technical issues in connection with the Application; (iv) performing research, for analytical and statistical purposes, to improve our Application. |
In case we need to collect additional personal information beyond what is mentioned above, we will send an applicable request to a parent and obtain consent prior to the collection, if required under applicable law.
We may use data in an aggregated, non-specific format for analytical purposes. This information is anonymous and will not be linked to any personal information. We may share such statistical information with our partners without restrictions.
Speechstart uses the device’s TrueDepth camera system to track the movement of your eyes and mouth. This allows for a unique user experience — a game you can play with your face. In order for this functionality to be possible, the app requires access to your device’s camera. This access can be toggled on or off at any time in your device’s settings.
The camera images and resulting depth data are used solely for gameplay purposes. The live video feed is never used, and its data is never stored locally or remotely. Camera access is required to retrieve depth data from Apple’s APIs.
This data is stored on the device only for the duration of your current game session. Each time the home screen is presented or the app is closed, the data is deleted. This data is used to enhance your gameplay experience and prevent accidental jumps.
Face data is never stored remotely, given to third parties, or used for any non-gameplay purposes. The face data remains on your device and never leaves it.
3. How We Collect Information
Depending on the nature of your interaction with the Application, we may collect information as follows:
- Automatically: Speechstart collects information automatically transmitted from the device.
- Provided by You Voluntarily: For example, when you provide information during a registration process, newsletter subscription, contacting us, etc.
4. Disclosure of Information
WE DO NOT DISCLOSE, SHARE, SELL, RENT, OR OTHERWISE DISTRIBUTE ANY OF YOUR OR YOUR CHILD’S PERSONAL INFORMATION WITH OR TO ANY INDEPENDENT THIRD PARTIES, unless as specified herein:
- Authorized Disclosures: We may disclose personal information to third parties when you consent to a particular disclosure. Please note that once we share your information with a third party, that information becomes subject to the third party’s privacy practices.
- Business Transfers: We may transfer our databases containing personal information if we sell our business or any part of it. In such an event, our affiliated companies or acquiring companies will assume the rights and obligations described in this Privacy Policy.
- Law Enforcement Related Disclosure: We may be required to share information (including personal information) if required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, or property, suspected fraud, or violations of our terms and agreements, and in response to legal processes, court orders, or subpoenas, or to establish or exercise our legal rights.
- Business Partners, Service Providers, Affiliates, and Subcontractors: We may disclose information (including personal information) to our trusted affiliates, personnel, licensors, contractors, service providers, subcontractors, and business partners who assist in providing the Application and its features. We authorize these third-party service providers to use personal information only for the purpose of providing the specified services.
- Identifiers: We may share identifiers for the purpose of operating our business and providing the Application, such as detecting fraud, security, or technical issues.
- Consent to Share Consumption Data with Apple: By using our app and making in-app purchases, you consent to our sharing of data regarding your usage and consumption of purchased content with Apple, as part of our efforts to resolve refund requests. This information may include details about how you have accessed and interacted with the purchased content. The purpose of sharing this data is to help Apple make an informed decision regarding refund requests. We ensure that such data sharing is done in compliance with Apple’s policies and only as necessary to process your requests.
5. Data Retention
We retain the collected information as long as it remains necessary for the purposes set forth above, in accordance with applicable laws, or until individuals express a preference to opt-out or delete their personal information. We may, at our sole discretion, delete or amend information from our systems without notice once it is no longer needed for such purposes.
6. Surveys and Contests
From time to time, we may conduct an email survey or an online contest and collect personal information, demographic information, usage information, and other materials that you voluntarily submit to us for internal analysis, marketing, and brand development. Participation in a survey or online contest is completely voluntary. We will use the information to make our services more appealing to users. Information gathered via surveys shall be anonymized and aggregated. We may use information gathered via contests for the purposes of administering the contest and to contact you in accordance with the contest’s terms and conditions.
7. Protection of Personal Information
We have implemented reasonable security measures to protect the confidentiality, security, and integrity of the collected information, and to prevent unauthorized access or use in a manner contrary to this Privacy Policy. Although we use commercially reasonable efforts to ensure your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.
8. Third Party Sites and Services
This Privacy Policy applies solely to information collected by Speechstart through the Application and does not apply to any other websites, applications, or services. Portions of the Application may involve linking to or using third-party services such as icons, shortcuts, applications, or other access methods. Although we make our best efforts to review such services and ensure their suitability for children, we have no control over third-party services, and all use of such services is at your own risk. We cannot accept responsibility for the privacy practices of any third-party services and are not responsible for content provided by them. Speechstart does not endorse any third-party services, and we urge you to exercise caution and review their privacy practices.
14. Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your personal information to us at [email protected]. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal information within 45 days of receiving your complaint.
15. Changes to This Privacy Policy
This policy may change from time to time, and we will post the amended terms and notify you by email in the event of substantial changes. Amended terms will take effect immediately for new users and 10 days after they are posted for existing users. You should review the Privacy Policy periodically to remain informed of any changes. Your continued use of the Application following any changes to this Privacy Policy (as of the “Last Updated” date below or as otherwise notified) signifies your acceptance of those changes. If you do not agree to the revised Privacy Policy, please refrain from using our Application and contact us at [email protected].
16. Contact Us
If you have any comments or questions about our Privacy Policy, please contact us at [email protected].