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EYEZY PRIVACY NOTICE

Last updated 1 February, 2022

This Privacy Notice explains what personal data is collected when you use our mobile applications, websites and the services provided through them (together “App” or “Service”), how such personal data will be processed.

BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY NOTICE, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY NOTICE FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or by us if you purchased it directly from our websites; and (c) delete the App from your devices.

TABLE OF CONTENTS

  1. CATEGORIES OF PERSONAL DATA WE COLLECT
  2. HOW WE COLLECT INFORMATION
  3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
  4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
  5. WITH WHOM WE SHARE YOUR PERSONAL DATA
  6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
  7. INTERNATIONAL DATA TRANSFERS
  8. DATA RETENTION
  9. DATA SECURITY
  10. CALIFORNIA PRIVACY RIGHTS
  11. CHILDREN’S PRIVACY
  12. PERSONAL DATA CONTROLLER AND PERSONAL DATA PROCESSOR
  13. DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR
  14. CHANGES TO THIS PRIVACY NOTICE
  15. CONTACT US
  1. CATEGORIES OF PERSONAL DATA WE COLLECT
    1. Personal Information: eyeZy App collects “Personal Information” from you at various times and places on the Site and eyeZy Application. Personal Information means information relating to a particular individual, such as the individual’s name, postal address, email address, and telephone number. Personal Information also includes your “Children’s Personal Information,” as defined below.
    2. Children’s Personal Information: With your consent, We may collect your “Children’s Personal Information.” Children’s Personal Information may include information you voluntarily submit to us such as your child’s first, middle and last name, date of birth, age, gender, and profile photo, or it may include information we collect from your child as a result of your use of the Services, such as your child’s device access times (e.g., we may collect information relating to how long your child uses or accesses his or her device to support our “allowance” feature), device identifier numbers, serial numbers, geolocation information, and other internet, device, or electronic network activity information, including, but not limited to, encrypted screenshots generated by eyeZy Application account and the transcribed content from the screenshots (e.g., through optical character recognition), as authorized by you (“Screenshots”). Screenshots may capture your children’s browsing activity, search activity, messaging activity, and other information regarding your child’s interaction with an internet website, application, advertisement, device, or interactions with a device in general.
    3. In order to provide the Services, we may also collect from your child’s device information relating to which apps are installed on your child’s device and information relating to your child’s device permission status (e.g., if your child has disabled the usage permissions on his/her device required to provide the Services, that information may be collected or if the device can no longer be “seen”). We may also collect information from your child’s device about your child’s usage and activity in connection with the Services (e.g., error/crash reporting, usage analytics such as screen views, your child’s use of any hyperlinks available within the Services, time on page, and page hits).
    4. For additional information about our practices regarding Children’s Personal Information, please see Section 1 (Children’s Privacy).
    5. In regard to the European Union, our collection of personal information from a child is limited and controlled by the parent.
    6. Non-Personal Information: Non-Personal Information means information that does not identify, and cannot reasonably be used to identify, an individual. We collect Non-Personal Information, for example, when we track the total number of visitors to the Site, the number of visitors to a particular page of the Site, and/or other such technical information. This data may be used to diagnose problems with the Services, gather demographic and geographic information to improve our Services or marketing efforts, improve our Services, and for similar purposes. Non-Personal Information includes aggregated and/or de-identified information. We reserve the right to use and disclose Non-Personal Information in its sole discretion.
    7. We also collect, automatically, information about how you have used eyeZy Application: about your schedules, your devices’ operating systems, IP address, etc. We analyse this information to troubleshoot any issues users encountered, to work out how our products are being used and how to improve them.
    8. If you turn on the location tracking feature on a device, we also collect that device’s location data, as well as any geo-fence zones you set up. Location data is used solely for the delivery of the location tracking feature and is deleted from our systems 14 days after it is collected.
  2. HOW WE COLLECT INFORMATION
    1. Voluntarily Provided Information: We may collect Personal Information, including your Children’s Personal Information, whenever you voluntarily provide such information including, for example, when you conduct business with us, use our Services, request information or materials from us, create or update your eyeZy account, when you voluntarily send Screenshots, or when you communicate with us about questions or concerns.
    2. Examples of the type of information you may voluntarily provide include: Your first name, last name, email address, and any updates to that information thereafter; Information relating to your child, such as your child’s name, age, birthdate, gender, and profile photo (see clause 1.2. (Children’s Personal Information) for more information); and If you sign up for any of our paid Services, your credit card or debit card information (such as card type, last four digits of your card, and expiration date) and other financial data and transaction history that we need to process your payment and provide the paid Services.
    3. Services-Related Information: We may collect Personal Information, including your Children’s Personal Information, as a result of your use of the Services. This includes, for example: Custom word lists you create to allow the Services to flag specific words of interest to you and the number of times the words appear within screenshots; Information you may provide to us relating to the desired preferences of the Services (e.g., determining the preferred units of measurement for geofencing notifications). Schedules you may create as part of the Services (e.g., to schedule device access for your child’s device and related screen time allowance information); and Information relating to which apps are installed on your child’s device and information relating to your child’s device status/permission status (e.g., if your child has disabled the usage permissions on his/her device required to provide the Services, that information may be collected or if the device can no longer be “seen”) (see clause 1.2. (Children’s Personal Information) for more information).
    4. Information Obtained from Third Parties: In limited circumstances, we may collect your Personal Information from third parties. For example, the payment processors we work with generally provide us with information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments if you authorize automatic renewals, and your card’s type, expiration date, and certain digits of your card number. We do not collect your Children’s Personal Information from third parties.
    5. Cookies and Similar Technologies: When you use the Services, we and certain third parties may use “cookies” and similar technologies like pixels, web beacons, and local storage (collectively, “Collection Technology") to collect information. We do not use Collection Technology to collect Children’s Personal Information. For example, when you use our Services, we may use Collection Technology to collect certain device information, such as: device operating system, device operating system version, IP addresses, access times, browser type and language, browser version, and device identifier numbers. We may also use Collection Technology to collect information about your usage and activity related to the Services (e.g., error/crash reporting, usage analytics, your use of any hyperlinks available within the Services, time on page, and page hits), and chat analytics when the chat feature is used.
    6. You have the right to choose whether or not to accept cookies. However, they are an important part of how the Services work, so you should be aware that if you choose to refuse or remove cookies, it could affect the availability and functionality of the Services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser.
    7. Removing or rejecting browser cookies does not necessarily affect third-party flash cookies or other web trackers, which may be used by us or our partners in connection with the Sites. To delete or disable flash cookies, please visit this site for more information. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://www.allaboutcookies.org/.
    8. Third-Party Analytics: We may use third-party analytics tools including, for example, Google Analytics, to help us measure traffic and usage trends for the Services. These tools may collect your Personal Information, including Children’s Personal Information, sent by your devices or our Services that assists us in improving the Services. You can read Googles’ privacy policy, which applies to Google Analytics, by visiting this link.
  3. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

    We process your personal data:

    1. To provide our Service. This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
    2. To customize your experience. We process your personal data, in particular, such as your characteristics and preferences, to adjust the content of the Service and provide content tailored to your personal preferences.
    3. To manage your account and provide you with customer support. We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms of Use or this Privacy Notice.
    4. To communicate with you regarding your use of our Service. We communicate with you, for example, by push notifications. To opt out of receiving push notifications, you need to change the settings on your device.
    5. To research and analyze your use of the Service. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use data for statistical analysis purposes, to test and improve our offers.

      To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Find more in Appsflyer’s Privacy Notice.

      We use Facebook Analytics, which is a service is provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our app, how often users make purchases, and other interactions. Find more in Facebook’s Privacy Notice.

      To analyze how visitors use the Service and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our website and users’ interactions within the website. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses the information here.

    6. To send you marketing communications. We may process your personal data for our marketing campaigns. We may add your email address to our marketing list, provided we receive consent or otherwise establish legal basis for sending you marketing communications. As a result, you will receive information about our products, such as for example, special offers. If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails. We may also show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.
    7. To process your payments. We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.
    8. To comply with legal obligations. We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
  4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users). In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

    We process your personal data, in particular, under the following legal bases:

    Legal Basis Purpose
    Consent To send you marketing communications
    To perform our contract with you To provide our Service (in accordance with our Terms of Use), to customize your experience, to manage your account and provide you with customer support, to communicate with you regarding your use of our Service, to process your payments
    Our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data to research and analyze your use of the Service, to communicate with you regarding your use of our Service, to enforce our Terms of Use and to prevent and combat fraud
    Legal obligation to comply with legal obligations.
  5. WITH WHOM WE SHARE YOUR PERSONAL DATA.
    1. We do not sell, use, or disclose to third parties any data for any purpose, except following cases: We may share your Personal Information to third parties as listed below. Disclosure of Children’s Personal Information shall occur in accordance with Section 11.
    2. With Your Consent: We may share your information, including Personal Information, with another company when you allow us to do so (i.e., when we have obtained your consent).
    3. Service Providers: We may share your information, including Personal Information, with third parties to assist in our business operations (e.g., to process payments, store data, deliver information, and perform other similar functions); administrative functions; marketing functions; and/or to provide the eyeZy Application services you have requested (collectively, “Service Providers”). Service Providers are prohibited from using your Personal Information for purposes other than those requested by us or required by law.
    4. Major Transactions: We may share your information, including Personal Information, as part, of or in connection with, a merger, acquisition, assignment, as part of debt financing, the sale of company assets, or in any similar transaction, or to the extent as may be required in the unlikely event of insolvency bankruptcy, or a receivership.
    5. Professional Advisors: We may share information with our legal, financial, and other advisors in connection with the corporate transactions described above or in connection with the management of our business and operations. Disclosures Under Special Circumstances: We may share your information, including Personal Information, when we believe doing so may be appropriate, including but not limited to when it may be legally required, necessary to comply with laws, or in response to lawful requests or legal process. We may also share such information where we believe it may limit our liability in an actual or potential lawsuit, or where otherwise necessary to protect our rights, interests and/or property (including, without limitation, to enforce our agreements), or the rights, interests and/or property of our agents, independent contractors, customers, and others.
  6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS.

    To be in control of your personal data, you have the following rights:

    1. Accessing / reviewing / updating / correcting your personal data. You have the right to review, edit, or change the personal data that you had previously provided to us in the profile section of the App. If you would like to receive a copy of data we process, please send us a data access request.
    2. Deleting your personal data. You can request erasure of your personal data, as permitted by law. When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.
    3. Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof. Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above:
    4. The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
    5. The right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or other file format.
    6. OPTING OUT OF PROMOTIONAL EMAILS. We allow you to choose which forms of communication you receive from us. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receiving promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
    7. To exercise any of the available to your privacy rights, please send a request to [email protected]

  7. INTERNATIONAL DATA TRANSFERS.

    We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Use and for purposes indicated in this Privacy Notice. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

  8. DATA RETENTION

    We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Notice (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

  9. DATA SECURITY.

    We have adopted technical and organizational measures to preserve and protect your personal data from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed. Although we have exercised high levels of care in providing secure transmission of information between the Application and our servers and in storing that information on our systems, no method of transmission over the Internet, or of electronic storage, is 100% secure. As such, we cannot ensure or otherwise guarantee the security of information transmitted to us over the Internet.

  10. CALIFORNIA PRIVACY RIGHTS.

    This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

    For more details about the personal information we have collected, including the categories of sources, please see Section 1 above. We collect this information for purposes described in Section 2 of this Privacy Notice. We may also share your information with certain categories of third parties as indicated in Section 4. Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

    California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected] We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

    Access rights under California’s Shine the Light. California also provides its residents with additional access rights. Under Shine the Light law, the residents may ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute. To obtain this information from us, please send an email message to [email protected], which includes “Request for California Shine the Light Privacy Information” on the subject line and your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

  11. CHILDREN’S PRIVACY.
    1. We do not sell products or services to children. The Services are not intended for children to submit Personal Information to Eturi without the consent of their legal guardians. In compliance with the Children’s Online Privacy Protection Act (“COPPA”), please see below:
      1. The types of Personal Information we collect from children are detailed above in Section 1.2. (Children’s Personal Information).
      2. How we collect information from children is detailed above in Section 2 (How We Collect Information).
      3. We use Children’s Personal Information for the purposes listed below:
        • Provide, develop, maintain, operate, and improve our Services,
        • Process and fulfill a request or other transaction submitted by you, including, for example, to respond to comments and questions and provide customer support
        • Communicate with you including, for example, to send you Services-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
        • Communicate with you including, for example, to send you Services-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages
        • To meet or comply with any applicable law, regulation, legal process or other legal obligation, protect or prevent harm, fraud, or financial loss; or promote, detect, investigate and help prevent security, fraud or technical issues; and protect our legitimate business interests and legal rights, and for corporation transactions, which refers to transfers of Personal Information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.
        • For European Union data subjects, our collection of personal data from a child is limited and controlled by the parent.
      4. We may share or disclose Children’s Personal Information in a limited number of instances, including the following:

        We may share Children’s Personal Information with our Service Providers if necessary for them to perform a business, professional, or technology support function for us. Please see Appendix A for a list of Service Providers (i.e., third-party operators) who may collect Children’s Personal Information through the Services. Please contact us at the mailing address, email, or phone number with questions about our, or our Service Providers’, privacy policies and practices.

        We may disclose Children’s Personal Information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child; (iii) to protect the security or integrity of our Services; or (iv) enable us to take precautions against liability. We will not collect more information from your children than is reasonably necessary to provide the Services.

        In accordance with COPPA, you may upon request, review the Children’s Personal Information we have collected from your child, such as name, address, telephone number, email address, and direct us to delete such information, and/or refuse us to allow any further collection or use of your Children’s Personal Information.

  12. PERSONAL DATA CONTROLLER AND PERSONAL DATA PROCESSOR.

    Data protection laws in certain jurisdictions differentiate between “controller” and “processor” of Personal Data. If you are visiting our Website, using the App and the Services, the Data Controller is the Fortunex Limited. In situations in which Personal Data is processed by Fortunex Limited. on behalf of You, in particular when you provide us with the personal data of third parties while connecting the device, or using location feature via SMS, etc., Data Controller is You and Fortunex Limited is the Data Processor.

  13. DATA PROCESSING ON YOUR BEHALF: WE AS A DATA PROCESSOR
    1. Target Device Data. We start collecting data from a target device associated with the account, which may include personal data relating to you, to a target device user(s) or to third parties (“Target Device Data”, including information about a target device, phone number, contacts, messages and SMS). In accordance with applicable privacy law, to the extent that it applies to us, you are the Data Controller of this Target Device Data and you appoint us as a Data Processor of such data for the purpose of providing the Service.
    2. Your use of Target Device Data. As Data Controller, you warrant that you have the appropriate authority, or have obtained a valid consent from third party as may be required by data privacy laws, to collect and process the Target Device Data and you agree to process and use the Target Device Data in accordance with this Privacy Notice, the Terms and applicable law, and only for the explicit purposes of the Service. You will protect the confidentiality of any accessible Target Device Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your account and/or Target Device Data
    3. Data Processor Obligations. To the extent that we are Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any Target Device Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to Target Device Data only to those employees who need to know it to enable the Processor to perform the Services; (c) only process the Target Device Data as specified by this Notice and in accordance with your instructions, and (d) will not use the Target Device Data for any purposes other than those related to the performance of the Service or pursuant to your written instructions. Upon the expiry or termination of this agreement by way of de-registration, or upon your request, we will cease any and all use of the Target Device Data and will destroy or return it to you except as provided above with respect to backed-up data and termination. We will not disclose Target Device Data to any third party without your prior written consent or pursuant to court or administrative order.
    4. Warranties. You are solely responsible for use of the account and the processing of personal data associated with your account, which includes, among others, collecting, storing and analyzing personal data from a target device. You warrant, as the one responsible for Target Device Data that we process on your behalf as Data Processor, that (a) you have informed any user(s) that are 13 years old or more regarding your usage of the Service, and have obtained consent from such user(s) for this kind of activity, as provided in our Privacy Notice, and (b) you comply with all applicable legislation with respect to data privacy, including children’s data privacy. You agree to fully comply with this Privacy Notice.
    5. Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of Target Device Data and other third-party personal data submitted to our systems during the course of use and provision of the Service.
  14. CHANGES TO THIS PRIVACY NOTICE.

    We may modify this Privacy Notice from time to time. If we decide to make material changes to this Privacy Notice, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Notice. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Notice.

  15. CONTACT US

    If you have any questions about this Privacy Notice, please contact us in one of the following ways:

    E-mail us at: [email protected]

    Fortunex Limited, Georgiou Griva Digeni, 113, Astromeritis, 2722, Nicosia, Cyprus