Effective Date: December 15, 2017
- Your use of websites affiliated with the Company (www.copernicuslabs.com, www.copernicusgames.com, www.copernicusstudios.com, www.langalab.com), collectively referred to as the “Site”.
- Your use of mobile applications affiliated with the Company, collectively referred to as the “Application”.
- The term “Service” or “Services,” as used in this Policy, include both the Site and the Application.
This Policy may be updated from time to time. We will provide notice of any substantial changes to our Policy by posting a revised version to our website. If there is a substantial change, we may notify you by email and ask you to renew your consent or the consent of a parent or legal guardian for applicable Services. Our Policy will indicate the date it was last updated.
By using our Services you are consenting to our Processing of your information as set forth in this Policy. “Processing” means using cookies on a computer or using or touching information in any way, including, but not limited to, collecting, storing and deleting, using, combining and disclosing information and transferring it to third parties in the United States and internationally.
You are entitled to withdraw consent to the use and disclosure of your information at any time, except toward the use of such information for the fulfillment of the Company’s legal obligations.
Where parental consent is required for children under than age of 13 to use the Service via your account, you are confirming that you have the right to consent on such child’s behalf to the Company’s collection, use and disclosure of their personal information as described below in “Privacy Practices for Children Under 13.”
Privacy Practices for Children Under 13
Our Service is intended for families and users of all ages. This may include children under 13, and we recognize the need to provide additional privacy protections for such children who use the Service. We ensure that our Policy and our information practices adhere to the United States Children’s Online Privacy Protection Act (“COPPA”) and other applicable data privacy laws and all other applicable legislation.
The Company may collect personal data from children under 13. For those Applications that may collect personal data, we will not do so without parental consent, which is required before children can play the game. User information collected is limited to what is necessary in order to provide our Services (such as saving user progress and temporary audio files for the purpose of instructing a verbal command or request via our speech recognition engine).
Please see our ‘Apps and Data Collected’ (http://copernicuslabs.com/apps-data-collected/) which explains which types of data are collected in connection with a particular application.
When we intend to Process personal information from children, we take additional steps to protect children’s privacy, including:
- Notifying parents about our information practices with regard to children, including explaining the types of personal information we may collect, use and process from children, the use we make of that personal information, and whether and with whom we may share that information.
- Obtaining consent from parents for the collection, use and Processing of personal information from their children and explaining that they can agree to the collection and use of their child’s information, but still not allow disclosure to third parties.
- Giving parents access or the ability to request access to personal information we have collected, used or Processed from their children and the ability to request that the personal information be changed or deleted.
Information We Collect
There are two types of data that may be collected:
- The first one is called Personal Data. This is personally identifiable information that identifies a user as an individual. The Company may collect Personal Data you voluntarily provide via the Service.
- The second type is Non Personal Data which doesn’t directly identify an individual or which may have been personal information but has had the personally identifiable information removed. The Company may collect Non Personal Data about the use of the Services to help us improve our Services.
Personal information includes, but is not limited to, Personal Data such as your name and email address, and, for children under 13, persistent identifiers and voice recordings. We use your Personal Information mainly to provide our Services and administer your inquiries.
How We Use Personal Data
- During the account registration process, we ask you or your child to provide certain information for notification and security purposes, including a parent’s or guardian’s email address (in order to obtain their consent), a username, and a password. It is recommended that your username and password DO NOT reveal any personal information about you such as your real name, age or location.
- We may also use your Personal Information to contact you about new features and to send push notifications if consent to receive them has been given.
- We may use your email address to send newsletters, marketing or promotional materials, and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
- We may use your email address to send you general service and account related announcements and to respond to support requests. You cannot opt out of service and account related emails as long as your account is active.
- We use persistent identifiers (persistent cookies and persistent user data) which is stored on your local device in order to:
- Save your registration ID and login password for future logins.
- Save user progress/customizations across multiple devices.
- We collect data generated by the user playing the game, their preferences, scores and settings. This data is used for internal purposes only in order to:
- guarantee educational efficacy of our games.
- customize the content.
- iterate/improve our sites and applications.
- Some of our Services may use our own proprietary speech recognition engine (SRE) for the purpose of verbal instruction or commands as a part of the gameplay. For example, the Service may prompt the child to say out loud the name of an object shown to them on the screen. Our Services will not incite users to speak freely or ask for personal information, such as the child’s name.
- Our SRE runs on a secure Server controlled by the Company. Your child’s speech is recorded and transmitted to the Server from the Service when the speech mode is activated (speech mode is either activated by the user tapping the character or a microphone icon on the screen when prompted or by the game at designated periods). This then triggers the speech detection, audio processing, and word recognition in real time. Your child’s speech recordings are not saved and are deleted from the Server after Processing.
- The Service will request access to your device’s microphone. You will need to allow access in order to use the Service. Any data that is recorded will not be accessed by the Application unless the Application is in speech mode, and all the data is deleted every few seconds.
Non Personal Data
Non personal data is “Non-Identifying Information”. This includes information about your preferences and computer or mobile device, such as operating system and software version.
Cookies and Persistent User Data
Our Service may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We do not link the information we store in cookies to any Personal Information you submit while using our Services.
We do not currently support “Do Not Track” requests. To determine whether any of the third party services we use honors the “Do Not Track” requests, please read their privacy policies. If we do so in the future, we will describe how in this Privacy Statement. More information about “do not track” is available at www.allaboutdnt.org. You may also use a program such as http://optout.networkadvertising.org/#!/ to opt out of being tracked.
This information is for internal use only and can’t or will not be shared. We use this information to monitor and analyze use of the Services, for the Service’s technical administration, to increase the functionality and user-friendliness of our Services, and to better tailor the Services to our users’ needs.
We may also use third parties from time to time to deliver a service, such as payment processing, sending emails, infrastructure and IT services, or helping with customer or technical support. If you’d like more information on this, please contact us at firstname.lastname@example.org.
In addition to sharing your Personal and Non Personal Data with third parties to help us operate, analyze, and improve our Sites and Services as disclosed above, we may disclose this information to additional parties if we believe we are required to by law, by a judicial proceeding, to protect the Company’s rights and properties, or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose the Company or a user of its Services to legal liability.
In addition, the Company may disclose your information in the event of a change or proposed change in the ownership of the Company; for example, a sale, a merger, or bankruptcy.
Changing or Deleting Your Information
All registered users of the Company Services may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the record.
The Company is concerned with safeguarding your information. We employ reasonable administrative, physical, and electronic measures designed to help protect your information from unauthorized access. No security, however, can eliminate the possibility that your information may be accessed by an unauthorized third party and we cannot guarantee that your information will remain secure in all situations.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email, mail, telephone, or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. We reserve the right to choose which method we use to contact you about such an event.