StoryToys Apps Privacy & Security Policy

10 September 2021

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StoryToys Privacy Notice

1 Who we are

StoryToys Limited, a private limited company incorporated under the laws of Ireland under company registration number 459470 and having its registered office at Exchequer Chambers, 23 Exchequer Street, Dublin 2, Ireland (“StoryToys”, “we”, “us”, “our”) is the controller for the purpose of this privacy notice.

2 Who does this notice apply to?

Our website https://storytoys.com/ is intended for use by adults who wish to learn about our products and services, and who wish to purchase, through a user account on our website, subscriptions to access digital content on the mobile applications we make available for download through app stores from time to time (each a “StoryToys App”). As such, any feature of the website that permits the input of personal data, for example by placing an order for a paid subscription or subscribing to newsletters or other publications, are only intended for use by an adult and is generally placed in areas of our website directed to adults only.

Each StoryToys App is intended for use by children under adult supervision. We do not knowingly process children’s personal data. StoryToys Apps provide numerous activities and features for children that do not require the processing of personal data. Any feature of a StoryToys App that allows in-app purchases is only intended for adults, and is operated by the relevant App Channel Provider (as defined below).

This notice applies to you when you access, browse and use our website (through various domains) and StoryToys Apps, join our mailing lists to receive our newsletter communications, and interact with us on the website, our social media pages, by telephone, email and by other means.

If you are an educator and have received a complementary subscription for a StoryToys App, to the extent that you disclose to us an email address of any other person (e.g. an email address of a student’s parent) you confirm that you have their prior authority to disclose their email address to us.

StoryToys Apps are only available for download from app stores made available by authorised app channel providers (for example, Apple’s App Store, Google Play, Amazon Appstore or such other app store as we may authorise) (an “App Channel Provider”). If you make any in-app purchases on a StoryToys App, the privacy notices of the relevant App Channel Provider will also apply in respect of the personal data it controls and processes.

We strive to comply with the United States’ Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA please consult this simple one-page information guide from the kidSAFE seal program: http://www.kidsafeseal.com/knowaboutcoppa.html

3 Types of personal data we process

“Personal data” means information about an individual from which that person can be identified. It does not include information where an individual’s identity has been removed (anonymous data). Throughout this privacy notice we use the term “processing” to refer to all activities involving your personal data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of it.

The personal data we receive about you depends on how you interact with us, and whether you are using our website or a StoryToys App. For this reason, we have distinguished parts of this privacy notice to describe our data protection practices in relation to our website and StoryToys Apps.

Website: Typically, we process the following kinds of personal data when you use our website:

Identity and Contact Data includes your name, email address, country of residence, authentication token for social media accounts and any personal data provided when contacting us, and in respect of educators only, the school you are affiliated with, your role/job title, class (grade) type and the city or town and country where your school is located;
Profile Data includes your email address, password (which we pseudonymise), login and user account details, preferences, subscriptions purchased, gift codes and their expiry dates, the online channel through which you created your user account, feedback and survey responses;
Transaction Data (Website) includes details about payments from and to you and other details of digital content you have subscribed for with us. However, this does not include payment card or bank details, as you provide this information directly to the secure payments service providers we make available to you on our website;
Technical Data (Website) may include internet protocol (IP) address, browser type and version, time zone setting and location, country and language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
Usage Data (Website) includes information about how you use our website such as the services you view or search for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks and mouse-overs), traffic data, web logs and other communication data and the resources that you access; and
Marketing and Communications Data includes your preferences in receiving electronic newsletters and marketing communications from us and your communication preferences.

StoryToys Apps: Typically, we process the following kinds of personal data when you use a StoryToys App:

- User Account Data includes your email address, the online channel through which you created your user account, country of residence, subscriptions purchased, gift codes and their expiry dates, and in respect of educators only, your name, the school you are affiliated with, your role, class (grade) type and the city or town and the country where your school is located;

Transaction Data (App) relates to your making of an in-app purchase on a StoryToys App. However, your App Channel Provider only provides us with aggregated information so that we know how many users purchase content for StoryToys Apps via the App Channel Provider, but we do not know the actual identity of those users (including you). Please consult your App Channel Provider’s privacy notices for information on how they process this type of personal data;

- Technical Data (App) except as described below in respect of our older apps, StoryToys Apps do not collect your device ID. Instead, we create an anonymous ID in respect of your device, which is a random alphanumeric value but not linked to a device ID, so that we know generally the time zone setting and location, country and language, browser plug-in types and versions, operating system and platform and other technology on the devices used to access StoryToys Apps, but not specifically relating to you or your device. For certain older StoryToys Apps, namely Chug Patrol (iOS), Mother Goose Club, Beauty & The Beast (Google Play), The Very Hungry Caterpillar Play & Explore (Google Play), for which we may process an IDFA (Identifier for Advertising) or Google advertising ID, we may process in respect of your device the time zone setting and location, country and language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access StoryToys Apps;

Usage Data (App) except as described below in respect of our older apps, StoryToys Apps do not collect your device ID. Instead, we create an anonymous ID in respect of your device, which is a random alphanumeric value but not linked to a device ID, so that we know generally (but not specific to you) information on use of a StoryToys App, length and frequency of use, content use (e.g. pages, game play or video watched), information regarding the volume and status of data transmission, page interaction information, activity completion information, click-through statistics, and the date and time users access certain parts of a StoryToys App. For certain older StoryToys Apps, namely Chug Patrol (iOS), Mother Goose Club, Beauty & The Beast (Google Play), The Very Hungry Caterpillar Play & Explore (Google Play), we may process an IDFA (Identifier for Advertising) or Google advertising ID, which may allow us to know in respect of your device information on how you use a StoryToys App, length and frequency of use, content use (e.g. pages, game play or video watched), information regarding the volume and status of data transmission, page interaction information, activity completion information, click-through statistics, and the date and time you access certain parts of your StoryToys App.

Website and StoryToys Apps: We also collect, use and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or StoryToys App feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any special categories of personal data about you (this is personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership; genetic data; biometric data for the purpose of uniquely identifying an individual or data concerning health or sexual orientation). Where we need to collect personal data by law, or under our www.storytoys.com/terms and you do not provide that personal data when requested, you may not be able to subscribe for or use some of our products or services. We will let you know at the time of collecting personal data from you whether you must provide the personal data in order to receive any of our products or services, and whether the provision of personal data requested by us is optional.

4 How your personal data is received

We may receive your personal data through various means including:

Direct interactions: As a user of our website, you may give us your Identity and Contact Data, Profile Data and Transaction Data (Website) by creating and managing your user account, purchasing and subscribing for our products, using gift codes, selecting preferences, filling in website forms, sharing product details or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you enter a promotion or survey, give us feedback or contact us.
Automated technologies or interactions: As you interact with our website we collect Technical Data (Website) and Usage Data (Website). We collect this by using cookies, tracking codes and other similar technologies. We may also receive Technical Data if you visit other websites using our cookies. Please see our www.storytoys.com/cookies for further details.
Third party sources:

For website users only, we may receive personal data about you from third parties, as set out below:

Technical Data (Website) from the following parties: We use Google Analytics to better understand the use of our website (which is intended for adults only). These features use cookies and anonymous identifiers to collect information and help target advertising; we also receive this kind of data from advertising networks such as Google Ads;
Identity and Contact Data and Transaction Data (Website) from providers of payment services, namely Stripe;
Identity and Contact Data when you create a user account or login using the services of third parties such as Facebook, Apple or Google; and
Identity and Contact Data (specifically your email address) from Mailchimp when you subscribe for our newsletters.

For StoryToys Apps only, we may receive personal data about you from third parties, as set out below:

Transaction Data (App) from App Channel Operators when you make in-app purchases through an App Channel Operator. However, the App Channel Operator provides us with aggregated and de-identified information so we do not know it is specific to you or your device. Please refer to your App Channel Operator’s privacy notices;
Technical Data (App) and Usage Data (App) from App Channel Operators relating to analytics. However, the App Channel Operator provides us with aggregated and de-identified information so we do not know it is specific to you or your device. Some App Channel Operators seek your express agreement before they will share this de-identified analytics information. Please refer to your App Channel Operator’s privacy notices; and
Technical Data (App), namely an IDFA (Identifier for Advertising) or Google advertising ID linked to a device, from Appsflyer if you use certain older StoryToys Apps, namely Chug Patrol (iOS), Mother Goose Club, Beauty & The Beast (Google Play), The Very Hungry Caterpillar Play & Explore (Google Play).

5 How we use your personal data

We have set out below a description of the ways we typically process your personal data when you use our website and StoryToys Apps, and the legal reasons we rely on to do so.

Website only

Purpose / activity	Type of Data	Grounds for processing
To allow you to create and manage a user account or an educator account on our website; to pseudonymise passwords; to subscribe for digital content on StoryToys Apps; to facilitate your payments for digital content; to remind you if you have not completed your online subscription order; to receive and manage your feedback and survey responses; to receive and manage referrals; and to conduct profiling based on the preferences you choose in your user account to ensure you receive relevant content.	Identity and Contact Data Profile Data Transaction Data (Website)	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary for our legitimate interests of enabling users to create and develop personalised accounts; to request and manage subscriptions and free trials for our services; to enable educators to invite parents to use our services; and for running and managing our services.
To fulfil your subscription for digital content; to send you confirmations and updates relating to your orders; to manage cancellations in accordance with our Terms of Sale and other policies and to provide customer service and support.	Identity and Contact Data Profile Data Transaction Data (Website)	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests of providing a good purchase experience.
To respond to queries submitted through the website, telephone, social media or other means and to manage our relationship with you including: (i) notification of changes to our services, Terms of Sale; Terms of Use; Cookies Policy, Privacy Notice or other policies; (ii) to operate customer feedback and survey facilities; (iii) managing complaints and disputes; (iv) administering your marketing and communication preferences; and (v) administering your data protection, privacy and other rights including to allow you to download personal data into a portable file.	Identity and Contact Data Profile Data Transaction Data (Website) Technical Data (Website) Usage Data (Website) Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests for responding to queries; attracting new users and customers; running our business and to develop new business; managing disputes or complaints; protecting our interests; keeping our records updated and to gauge consumer satisfaction with our services and/or the products they purchase.
To administer and protect our business, products, services, networks, systems, the website and data and property hosted on or made available through the website including implementing and monitoring security measures and access authentication controls; troubleshooting; data and usage analysis; testing; system maintenance; user support; reporting; hosting of data; and to use the outcome of support services to improve and protect our services, networks and systems. To anonymise personal data for statistical purposes, and to pseudonymise passwords for security purposes.	Identity and Contact Data Profile Data Transaction Data (Website) Technical Data (Website) Usage Data (Website) Marketing and Communications Data	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests for running our business; network and systems security; to identify and/or prevent unlawful activity or other misconduct; manage disputes and to protect our interests; collate statistical information to enhance our services and business; and in the context of a business reorganisation or group restructuring exercise.
To use data analytics and other technologies to monitor usage of the website; measure the performance of the website and to optimise the website; improve our services, marketing strategy and output, user interactions, relationships and experiences. We may also process information collected when you browse and use our website to set default options for you (such as language and country).	Technical Data (Website) Usage Data (Website)	Necessary for our legitimate interests to obtain insights into how our services are used; improve the services; identify technical issues; fix technical issues; keep our website updated and relevant; balance web traffic; develop and manage our business and strategies for growth and marketing.
To make suggestions and recommendations to you about products, features, promotions and/or services that may be of interest to you; deliver relevant content and ads to you on our website and third party websites and apps and to measure and understand the effectiveness of this.	Identity and Contact Data Technical Data (Website) Usage Data (Website) Marketing and Communications Data	Necessary for our legitimate interests to develop and improve our products and services, to grow our business, to inform our marketing and advertising strategy and output and to conduct marketing and advertising.
We may allow you to link your social media or your third-party accounts to our website, in which case we keep a record of your social media handle and other information made available to us according to your social media or third party account settings. We do this so you can more easily login to your user account and so we can understand the products you like, how you might share your likes with your friends, which in turn helps us to improve any recommendations we make to you or the ads we send you.	Identity and Contact Data Profile Data Technical Data (Website) Usage Data (Website) Marketing and Communications Data	Necessary for our legitimate interests to develop and improve our products and services, to grow our business, to inform our marketing and advertising strategy and output and to conduct marketing and advertising.
If you post comments about StoryToys, tag us or post photos to our social media pages we may process this information to highlight our products and branding or to respond to you.	Identity and Contact Data Profile Data	Necessary for our legitimate interests to develop our products and services and to gauge and react to consumer sentiment which helps us improve our products and services.

Marketing: We would like to send you information about our products, insights and offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email. We will only ask whether you would like us to send you marketing messages when you subscribe to our mailing list on our website. You can unsubscribe at any time by using the ‘unsubscribe’ link in our marketing emails. You can also manage your personal data associated with your user account via the Account page. If you tell us you do not want to receive marketing messages it might take a few days for all our systems to be updated to reflect this. Please note that opting out of marketing messages will not stop service communications (including service-related push notifications), such as order confirmations or updates.

Advertising: If you agree, we may use cookies and similar technologies that allow us to include ads for our products on other websites and apps, such as social media. The ads you see are based on information we hold about you or your previous use of our website (e.g. your search history and the content you read on our website) or on StoryToys adverts you have previously clicked on. For more information on our use of advertising technologies and cookies, please see our Cookie Policy.

StoryToys Apps only:

Purpose / activity	Type of Data	Grounds for processing
To allow you to access a user account or an educator account on a StoryToys App, to the extent that you have created one through our website. If you buy premium access to a StoryToys App through an App Channel Provider (but not through our website) you will not have a user account for that app, and so this section would not apply to you.	User Account Data	Necessary for the performance of a contract with you. Necessary for our legitimate interests of enabling users to access personalised accounts through a StoryToys App.
To manage our relationship with you including: (i) notification of changes to our services, Terms of Sale; Terms of Use; Cookies Policy, Privacy Notice or other policies; (ii) providing user support; (iii) sending you service notifications; (iv) managing complaints and disputes; and (v) administering your data protection, privacy and other rights.	User Account Data Technical Data (App) Usage Data (App)	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests for responding to queries; providing good user experience; running our business and to develop new business; managing disputes or complaints; protecting our interests; keeping our records updated.
To administer and protect our business, products, services, networks, systems, StoryToys Apps and data and property hosted on or made available through the StoryToys Apps including implementing and monitoring security measures and access authentication controls; troubleshooting; data and usage analysis; testing; system maintenance; user support; reporting; hosting of data; and to use the outcome of support services to improve and protect our services, networks and systems. To anonymise personal data for statistical purposes.	User Account Data Technical Data (App) Usage Data (App)	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests for running our business; network and systems security; to identify and/or prevent unlawful activity or other misconduct; to collate statistical information to enhance our services and business; and in the context of a business reorganisation or group restructuring exercise.
To use data analytics and other technologies to monitor usage of StoryToys Apps for example time spent and activity completions; to measure the performance of StoryToys Apps and to optimise them; to improve our services, user interactions, relationships and experiences. We may also process information collected when you use StoryToys Apps to set default options for you (such as language and country).	Technical Data (App) Usage Data (App)	Necessary for our legitimate interests to obtain insights into how our services are used; improve the services; identify technical issues; fix technical issues; keep StoryToys Apps updated and relevant; balance web traffic; develop and manage our business and strategies for growth and marketing.

Generally, we do not rely on consent as a legal grounds for processing personal data although we will request your consent (i) before sending you direct marketing communications by electronic means (e.g. via email); and (ii) before setting non-essential cookies or similar technologies on your device.

6 Disclosure of your personal data

We may have to disclose personal data with the parties set out below for the purposes set out in the tables above.

Service providers: Companies and businesses that provide products and services to us such as professional advisors, auditors, IT systems suppliers and support, data storage solutions, IT developers, insurance providers, analytics companies, website hosting providers, software as a service, third party survey solutions, payment and subscription providers and other service providers.
Public and Government Authorities: Entities that regulate or have jurisdiction over us. We will disclose personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities. We may also do so where we consider necessary in order to enforce our legal notices and other policies published on our website and StoryToys Apps and other agreements we may have with you, and/or to protect the rights, property and/or safety of our staff, users and others.
Corporate activity: If we acquire other businesses or merge with them it may be necessary for us to disclose your personal data to them and their professional and other advisors in the course of the transaction

7 International transfers

In some circumstances, it may be necessary for us to process or transfer your personal data outside of the European Economic Area for the purposes described in this privacy notice. In which case, we comply with Irish data protection law when doing so, such as by ensuring that the country or territory where your personal data will be processed is deemed by the European Commission to have an adequate level of protection for personal data or by using a lawful safeguard, such as the European Commission’s standard contractual clauses. For further information, including details of the specific legal mechanism used to ensure the lawful transfer of your personal data, please use the information provided in the Contact us section below.

8 Security

We have security measures in place intended to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to obligations of confidentiality and to maintain appropriate technical and security measures for your personal data. You recognise that no entity can keep data fully secure. If you have reason to believe that any of your personal data is no longer secure, please tell us immediately by contacting us using the information provided in the Contact us section below.

9 Updating your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed, using your Account page, if any of your personal data changes during your relationship with us. You can also contact us using the information provided in the Contact us section below to update your personal data.

10 Data retention

We retain your personal data for as long as you continue to have a user account or educator account on our website and/or where you continue to use a StoryToys App and for as long as we are required to keep it to ensure we meet our legal requirements. If you no longer wish to have a user account you can delete your user account through the Account page of your user account. You can also delete your StoryToys App from your device at any time. However, we may have a requirement to keep some of your personal data even after you have asked us to delete it. We will only keep what we need to, and only to make sure we can meet our legal or regulatory requirements, resolve disputes, prevent fraud and abuse, and/or enforce our Terms of Service.

11 Your legal rights

Under certain circumstances, you may have the following rights:

Access. You have the right to request a copy of your personal data we control.
Correction. You can request to have any incomplete or inaccurate personal data we control corrected.
Erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following our receipt of your request.
Object. You may object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you wish to object to processing on this ground because you consider it impacts your fundamental rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
Restriction. You can ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish its accuracy; (ii) where you consider our use of the personal data is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
Data portability. You can ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to process or where we processed the personal data to perform a contract with you. If you have a user account or an educator account with us, we provide a facility to download certain of the personal data we hold about you.
Withdraw consent. If you provided your consent to the processing 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 wish to withdraw your consent, we will take steps to ensure we no longer process your personal data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

Exercising your rights: In order to exercise one or more of your rights in respect of your personal data, please contact us in writing using the information provided in the Contact us section below.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of StoryToys to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Privacy Notice applies only to their activities within the State of California. To make such a request, please contact us in writing using the information provided in the Contact us section below.

Data Protection Commission (DPC): You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie). However, we would appreciate the chance to deal with your concerns before you contact the supervisory authority and therefore ask you please contact us in the first instance.

12 Tips, warnings and third party links

Your use of any app store is subject to the terms and conditions of the relevant App Channel Provider and is at your own risk.

From time to time game publishers (such as StoryToys) are the target of third parties acting illegally and masquerading as legitimate game companies. The StoryToys Apps will never be made available to download from sources other than from an App Channel Provider approved by us. If you are in doubt about the authenticity of any source of a StoryToys App, please let us know using the Contact us information below.

Our website and StoryToys Apps may include links to third party websites and other online assets. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third party websites and are not responsible for their privacy notices. When you leave our website and/or any StoryToys Apps, we encourage you to read the privacy notices of every website you visit. Please see our Cookies Policy for details of the cookies served by us and third parties and how to control these.

Care should be taken when accessing any third party apps or websites which you may be able to access via our website, a StoryToys App or through the StoryToys account pages in the app store of an App Channel Provider. If you identify any suspicious activity connected to the use of an app store we suggest you contact the App Channel Provider immediately. If you find anything suspicious or encounter suspicious activity in relation to your use of our website or and StoryToys App, please contact us immediately using the Contact us information below.

13 Changes to this privacy notice

We will change this privacy notice from time to time and any changes will be contained in a revised privacy notice posted on the website and on StoryToys Apps. This version of the privacy notice was last updated on September 10, 2021. Historic versions of our privacy notice can be obtained by contacting us using the details below.

14 Contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us by email at [email protected] or write to Data Protection Manager, StoryToys Limited, Exchequer Chambers, 23 Exchequer Street, Dublin 2, Ireland.