Privacy Policy - FlashGet Kids

1. Introduction and Applicability of This Policy

1.1. Hongkong FlashGet Network Technology Co., Ltd. (“Hongkong FlashGet Network Technology,” “we,” “us,”, or “our”) respects your privacy and values the trust you place in us when you share your personal data with us. This Privacy Policy describes how We collect, store, use, and manage the personal information you provide to Us or that We collect in connection with mobile apps “FlashGet Kids” and “FlashGet Kidsafe” (referred to as the “Applications” and all services provided through Applications, as the “Services”), as well as your choices and rights concerning the collection and use of personal information.

The Privacy Policy applies to all visitors and users who use the Services (hereinafter-“Users” or “You”). Some of our Services are intended for children. This privacy policy contains a section on Children’s Privacy. However, some of the other sections of this privacy policy apply equally to children’s personal information and the personal information of adults. Whenever this is the case, we explicitly state that.

This Privacy Policy is also part of the Terms of Service located at https://kids.flashget.com/terms-of-service (the “Terms of Service”), which You, or if you have not reached the age of majority in your jurisdiction, a parent or legal guardian on Your behalf, must read and accept. The Terms of Service explain your rights and the responsibilities of the Company when you use the Services. Capitalized terms that are not defined in this Privacy Policy have the meaning given in our Terms of Service.

Whenever we refer to a child, we mean a child under the age of 13 for US users and a child under the age of 16 for EU users.

Before accessing or using our services, please ensure that you have read and understood how we collect, store, use, and disclose your personal information as described in this Privacy Policy.

2. Data We Collect and Receive

2.1. In order to provide you with our services, we may collect or receive data, which may include personal information voluntarily provided during the registration process, subscription to the Service, publication of materials, or information collected automatically during the course of providing the Services. Below are the types of data we collect and the purposes for which we use them.

2.2. We collect the following types of information about You and Your child:

2.2.1. Registration and Account Data

The “FlashGet Kids,” which is intended for adults only, allows Users to create profiles. When you create such a profile, we may collect your personal information, such as your email address, username, and IP address.

The “FlashGet Kidsafe” app is intended for children. It can be set up by an adult or a child. If the app is set up by a child, We first request a binding code from the FlashGet Kids app. These apps need to be used together.

2.2.2. Communication Data

Information when you communicate with us whether in person, through our websites, via email, or through other feedback channels provided by us, including:

Your contact details (this may include your social media account if that is the way you communicate with us)
The details of your communications with us
Log files you submitted from within FlashGet for product support

2.2.3. Data Collected Through Use of the Services

2.2.3.1. When You use any of Our Services, the following types of information may be processed:

Your account settings, preferences, IP address, and device information, such as your IMEI, IMSI, MAC, Android ID, operating system version, system language, CPU model, memory, hard disk and its usage, etc.;
Data about Your Use of the Services;
“Tap” behavior information when you use and operate FlashGet (e.g., the behavior of tapping the “Alerts” button or “Device” button).
Payment data, when You purchase any Services from Us, including information necessary to process Your orders with the relevant payment provider, which may include the amount of any transaction but WILL NOT INCLUDE Your name, financial information, or cardholder data, which will only be submitted directly to the payment service provider under secure protocols; You can find further information in the current data protection guidelines of the respective payment providers. When You make in-app purchases within the mobile application, we do not collect or have any access to your name and billing information. This information is collected and stored by Your platform (e.g. Apple Store or Google Play) or Your platform’s payment processor.

2.2.3.2. You agree and authorize our product to obtain data and information from your child’s device. We may collect the following types of personal information regarding child users of the “FlashGet Kidsafe” app:

Geolocation: we collect the location of the mobile device on which the “FlashGet Kidsafe” app is installed using a GPS network in order to get the location of the mobile device to provide our Services. We only store the geolocation data as long as it is reasonable to provide the Service. This can only be displayed within the “FlashGet Kids” app connected with the child profile. During the app’s setup, We will ask whether You want to turn the location permission on. You can later change your choice within the settings of the device.

Listen to the sound around the child’s device per the parent’s request: you, as a parent, can choose to listen live to your child’s device’s surroundings or choose to record these surroundings. Your child needs to have the “FlashGet Kidsafe” app installed. Listening and recording are allowed only for the users with the “FlashGet Kids” app installed and connected with the child’s profile. This information is accessible from the settings of the “FlashGet Kidsafe” app. We do not store sound around the device or audio data on any servers. During the app’s set up, We will ask You whether You want to turn the microphone permission on. You can later change your choice within the settings of the device.

Access to the device usage statistics: you as a parent can view the number of notifications, device screen and application usage time, and cellular data usage data on your child’s device. This can only be displayed within the “FlashGet Kids” app connected with the child profile. During the app’s set up, We will ask You whether You want to turn the user usage permission on. You can later change your choice within the settings of the device.

Access to notification data: you as a parent can view the notification of your child’s device. This can only be displayed within the “FlashGet Kids” app connected with the child profile. We only store the geolocation data as long as 48 hours, and then we delete the notification data related with your profile in the “FlashGet Kids” application. During the app’s set up, We will ask You whether You want to turn the notifications access permission on. You can later change your choice within the settings of the device.

2.2.4. Data Collected Automatically via Cookies and Related Technologies

When you visit our website or use our mobile software, We and Our business partners may collect certain data about your PC or device using technologies such as cookies, web cookies, log files, or any other tracking/recording tools. The information We collect using the tracking technologies includes but is not limited to the IP addresses, browser information, links to/exits and URLs, streaming data and information regarding how you interact with the web links, website, mobile software or Service, domain names, landing pages, page views, cookies data which allow us to uniquely identify your browser and monitor the behaviour of your browser at Our website, type of mobile device or other permanent identifiers. Some or all of this data may be combined with other personally identifying information specified above.

When You access our Service via a mobile device, We may receive or collect device information associated with Your device or Our mobile app, such as your IMEI, IMSI, MAC, Android ID, operating system version, system language, CPU model, memory, hard disk and its usage, etc.

We may use first-party cookies that belong to us and that we place on your device and third-party cookies that another party places on your browsing device when You visit our site. Third parties setting cookies on Our website will be providing a service to Us or a function of the Site, but We do not always control how third-party cookies are used. You should check the third party’s website for more information about how they use cookies.

Cookies or similar technologies stored on your computer or device through which You use the Services have amongst others but without limitation, the following functions: Authentication. If you’re signed in to our Services, cookies help us show you the right information and personalize your experience.

Security. We use cookies to enable and support our security features, and to help us detect malicious activity.

Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.

Marketing. We may use cookies or similar technologies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services and action tags to measure advertising effectiveness and allow more effective targeted advertising, but the use of those third-party cookies would be subject to the service provider’s policies. We do not use or share the child’s personal information for the purposes of targeted advertising.

Performance, Analytics, and Research. Cookies or similar technologies help us learn how well our Sites and Services perform, diagnose or fix technology problems reported by the users or developers. We also use cookies or similar technologies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your computer or your mobile device.

We may use third-party analytics providers software to allow us to better understand the functionality of our software on your device, including but not limited to, Google Analytics, Firebase (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Services, the events that occur within the Services, aggregated usage, performance data, and where our Software was downloaded from. We do not link the information we store within the analytics software to any personal data You submit within the Services.

The following is the non-exhaustive list of third parties that we use for analytics:

Firebase (a country of the owner of this service depends on your country)

Firebase helps us understand clearly how Users behave, which enables You to make informed decisions regarding app marketing and performance optimizations. For more information about Firebase privacy practices, please see https://firebase.google.com/terms/analytics.

Google Analytics (USA)

Google Analytics collects information such as how often Users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. Google’s ability to use and share information collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Service (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing You on return visits to this Site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see the Google Privacy (https://policies.google.com/privacy?hl=en). To prevent Google Analytics from using your data through a web browser, you can get the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/).

2.2.5. Data from iOS MDM
Regarding the FlashGet Kidsafe iOS App, we also collect personal data from Mobile Device Management (“MDM”) and the personal data includes:

Unique Device Identifier(UDID): Only ever used to identify a device for the purpose of mapping a parent’s settings to a specific device to ensure MDM commands are sent to the correct destination.
Device OS Version, Build Version, Supervision Status, Device Name, Device Make, Model Code, Product Name: Used in descriptive text to help parents identify devices paired to their account; additionally, used by our support team to help resolve user issues.
Installed Applications: Used to provide parents the ability to see what the child has installed, and also to select which apps the child should be allowed to use.
As required by Apple policy we do not share any data collected by our service with any third parties for any reason.

2.2.6. Anonymous data

We will also collect anonymised details about visitors to and use of Our Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.

2.2.7. Sensitive Information

We do not collect or process any sensitive information, such as information related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.

3. Children’s Personal Data

3.1. US child users

3.1.1. We care about the safety and welfare of children and value privacy. The Company does not knowingly collect personal information from children under the age of 13 without verifiable consent of a parent or legal guardian. Some of our Services are intended to be used by children under 13. In that case, it’s only with significant parental involvement upon the setup of the Service (e.g., the connection of the “FlashGet Kidsafe” app with the parental “FlashGet Kids” app ) and receipt of verifiable parental consent.

3.1.2. If the Company learns that we have inadvertently collected the personal information of a child without parental consent, we will take appropriate steps to delete this information as soon as possible. Although this is highly unlikely to happen, if you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing support@flashget.com so that we may delete that child’s personal information from our systems and terminate any account your child has created with us.

3.1.3. Verifiable parental consent is obtained using the email plus consent mechanism under COPPA. We will request that You as a parent provide your email address, where we will send you an email to verify your email address and a consent email. During the setup of the “FlashGet Kids” app., you will be required to read the Terms of Service and privacy policy and click “Agree” before binding the child’s device to the “FlashGet Kidsafe” app. The “FlashGet Kidsafe” app cannot be used until you have clicked “Agree”.

We will then send you one more email to confirm that We have received your consent, with information on how to revoke it.

3.2. All child users

3.2.1. Information sharing. The Company may share or disclose a child’s personal information with Our third-party service providers and business partners as described in our Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third-party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Who We Share Your Data With” to learn more about how we share information with our service providers, partners, and others.

3.2.2. Sharing information with other users. The child’s profile information and geolocation, sound around the device or audio data, usage statistics, fitness data, or activity recognition data will be shared with the parent through the “FlashGet Kids” app connected to the same profile as described in this Privacy Policy.

3.2.3. If You would like to review or delete any personal information We have collected from Your child, or to withdraw permission for us to collect any information from Your child, please contact us at support@flashget.com. Please also review the section of the Privacy Policy called “Your Rights and Options” to learn more about how you may control or turn off certain data collection by the Service.

4. How We Use Data

4.1. To Provide the Services to You

To provide the Service to You and to perform Our contract with You, we use Your information, which is necessary:

to register and administer Your User Account, and to verify Your details,
to provide You with the Service upon Your request;
to verify and confirm Your payments;
to communicate with You including via email or push notification about Your account or transactions with Us and send You information about features on Our Services or changes to Our policies;
to provide support including, but not limited to, product updates, product patches, fixes, and other similar communications.

4.2. To make the Service more suitable for Our users

To provide a great Service to Our users, We have a legitimate interest in collecting and processing the necessary information to

update and develop User profiles;
develop and improve the Service and User experience;
manage our relationship with you;
customize your Service experience;
respond to your comments and questions and provide User support;
notify you and provide you with information about the features of our Services, new releases and service developments, and to advertise our products and services;
provide you with special offers inside the Service as well as in other websites and services, and by email;
send you related information, including via email or push notification, such as updates, security alerts, and support messages.

You may opt-out of receiving promotional communications from us. To find out how to do this, please refer to section 10.6. (Opt-Out of Direct Marketing).

4.3. To Keep The Services Safe And Fair

In order to keep the Service and its features safe and fair, to prevent and fight fraud and cheating, and to ensure acceptable use, we have a legitimate interest in processing the necessary data to

analyze and monitor the use of the Services;
take action against fraudulent, cheating, or disruptive Users;

If the data can be used to prove that cheating, fraudulent activity, or Terms of Service violation has occurred, we will further store the data for the establishment, exercise, or defense of the legal claims for the duration of the applicable statute of limitations.

4.4. With Your Consent

4.4.1. We are not required to obtain Your consent for most of the processing activities that we undertake in respect of Your own personal information. For more information on how we receive verifiable parental consent for the collection and processing of children’s personal information, see Section 3 above.

We may, however, need Your consent for certain processing activities. If we need Your consent, we will notify You of the personal information We intend to use and how We intend to use it. With Your consent, we may process Your information for additional specific purposes.

4.4.2. If you have consented to Our use of information, You have the right to change Your mind at any time and withdraw your consent, but this will not affect any processing that has already taken place. To find out how to withdraw Your consent please see section 10.7 (Withdraw consent).

Where we are using your information because we have a legitimate interest in doing so, You have the right to object to that use. However, in some cases, this may mean that You will no longer be eligible to use the Services.

5. Sharing of Your Personal Data

We do not sell, lease, rent or give away your personal data except under the circumstances set out below:

We may share your personal data with other members of our group of companies so we can provide the best services across our group. They are bound to keep your information in accordance with this policy.
We may also share your personal data with certain contractors or service providers. They will process your personal data on behalf of us, for example, database service providers, advertising agencies, or customer relation management service providers. Our contractors and service providers will be required to meet our standards on processing data and security. The information we provide to them, including your personal data, will only be provided in connection with the performance of their functions.

Your personal data may be disclosed or transferred to other third-party organisations under the following circumstances:

If we are discussing selling or transferring part or all of our business – your personal data may be transferred to prospective purchasers under suitable terms as to confidentiality.
If we are reorganised or sold, your personal data may be transferred to a buyer who can continue to provide the Services to you.
If we are required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority to disclose your personal data.
If we are defending a legal claim, your personal data may be disclosed or transferred as required in connection with defending such claim.
If we have obtained your explicit consent in advance.

Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the anonymized data will cease to be personal data.

6. Third-Party Websites and Services

6.1. Third parties may collect Your information. There are a number of places on or through the Services where You may click on a link to access other websites, services, or web resources that are not affiliated or connected with Us and do not operate under this Privacy Policy. For example, if You click on an ad, you may be taken to a website that we do not control. These third-party websites may independently collect information, including Your personal information, from You. We advise you to check the privacy policies of all third-party websites you visit.

7. How We Protect Your Data

7.1. The Company takes precautions – including legal, organizational, administrative, technical, and physical measures in order to protect the personal data of the User, including child User, from any unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. In order to make sure that Your and Your child’s personal data is safe, we communicate confidentiality and security standards to the Company’s employees and strictly monitor the implementation of confidentiality measures within the Company.

8. Storing of Your and Your Child’s Data

8.1. We do not store personal data that can be used to identify a User beyond the time period necessary to complete the function for which information was collected. We store your personal data for as long as Your User account is active, or as long as is needed to provide You with the Service. This also applies to data of child Users.

Note that if you ask us to remove Your personal data, we may retain your information as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

8.2. Storing of the information for marketing purposes: If you have elected to receive marketing notifications from Us, we store information about Your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services.

We store information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created and in accordance with conditions provided in section 2.2.4. (Data Collected Automatically via Cookies and Related Technologies).

9. International Data Transfers

9.1. Our Service is global by nature and Your and Your child’s data can therefore be transferred to anywhere in the world. We transfer, process, and store Your information outside of Your country of residence, to wherever We or Our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer Your information, We take steps to protect it.

10. Your Rights and Options

10.1. You have certain choices available to You when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.

10.2. Your requests and choices may be limited in certain cases, such as when fulfilling Your request would reveal information about another person, or if You ask to delete information which We are permitted by law or have compelling legitimate interests to keep.

10.3. Right to Know Your Personal Data Processed (Right of Access)

If you request, upon verification of your identity, we will provide you a copy of your personal data in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in section 12 (Contact Us) to request assistance.

10.4. Change or Correct Your Personal Data (Right to Rectification)

If available, you can edit some of your personal data through your account. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate, by contacting us as explained in section 12 (Contact Us).

10.5. Delete Your Personal Data (Right to Erasure):

You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and service-related information linked to the Account and the possibility to access the services for which you are using the Account. Please note that once your Account has been deleted, you will lose your user history and all related information.

10.6. Opt-Out of Direct Marketing: You can opt-out of our use of your information for marketing purposes by following instructions in promotional communications or by contacting us, as explained in section 12 (Contact Us). To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites. You can also stop receiving promotional emails from us by clicking on the “unsubscribe” link provided in such emails. You cannot deactivate the messages related to the functionality of the Service (for example, account verification, notification of parental consent, order confirmation, change or update of the Service features, technical and security notifications).

10.7. Withdraw Consent: You may withdraw consent where the processing of your personal information is based on consent, by contacting us as explained in the section “Contact us.” If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

10.8. In most instances, we will respond to all requests within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically.

10.9. You have the right to complain to the Data Protection supervisory authority for unresolved complaints.

10.10. European Union users have additional specific rights:

10.10.1. Request That We Stop Using Your Data (Right to Object): Where the processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise, or defense of legal claims.

10.10.2. Data Portability: Data portability is the ability to obtain some of your personal information in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.

11. Changes to This Privacy Policy

11.1. We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice within the Services or by sending you a notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

11.2. For the users in the USA, Wee will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA.

12. Contact Us

12.1. If you have any questions regarding the Company’s Privacy Policy or the processing of data by the Company, you can contact us at:

Contact E-mail: support@flashget.com