General

Keepy Inc. and its affiliates (collectively, “the Company,” or “we”, “us”, “our”) respect your concerns about privacy and value our relationship with you. This Privacy Policy (“Policy”) describes the types of information we collect through Keepy, how that information may be used and/or with whom it may be shared; and how you can reach us to update your contact information, access and control the use of the information we collect or get answers to questions you may have about our privacy practices.

This Policy applies solely to information collected through the Company’s mobile Applications, web sites, and their respective interactive features, applications, widgets, blogs and contents whether accessed via computer, mobile device or other technology (collectively, the “Services”).

Please read this Policy carefully, because by using the Services you are acknowledging that you understand and agree to the terms of this Policy.

In addition, please review our Terms of Use, which governs your use of the Services and any content you submit to the Services. Defined terms used in the Terms of Use may be used in this Privacy Policy and will have the same meanings.

1. Information Collected on Our Services

Information You Provide To Us

  • When you use the Services or create a profile by registering with us (“Profile”), Keepy may collect any Personal Information you provide, such as your name, address, phone number, email address, demographic information, date of birth, and gender. Keepy may also ask you to provide other information about yourself, such as demographic information or certain information about your preferences, product use, and interests.
  • Keepy collects your Creative Materials and Keepies (as those terms are defined in the Terms of Use), as well as any comments or other content or communications you may submit through Keepy.
  • We will collect Personal Information about your child that you submit to us, including your child’s name, gender, date of birth, and photo.
  • If you want to add a family member or other third party to have access to your Profile, we will collect that person’s name, email address, and phone number.
  • Keepy may collect Personal Information when you request information, participate in some promotion or other feature of the Services, or otherwise communicate or interact with us.

If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information.

Information provided about your children, and Creative Materials, and Keepies will be considered Personal Information.

Information Collected by Automated Means

Whenever you visit or interact with the Services, Keepy, as well its third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Services are accessed and used (“Usage Information”). Usage Information may include, in part, device type, operating system, the page served, the time, how many users visited the Services, and the preceding page views. Usage Information is generally non-identifying, but if Keepy associates it with you as a specific and identifiable person, we treat it as Personal Information.

In the course of collecting Usage Information, Keepy also automatically collects your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Services. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. When you visit the Services, we may view your Device Identifier. We use this information to determine the general physical location of your Device and understand from what regions of the world the visitors to the Services come. We also may use this information to enhance the Services.

Keepy may also use web beacons (also known as web bugs, pixel tags or clear GIFs), which are tiny graphics typically embedded invisibly on web pages (or in an e-mail) with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising.

Cookies

Cookies are data files placed on a Device when it accesses the Services. Keepy may use four types of cookies for the following purposes:

  • Necessary Cookies – Necessary Cookies are essential to navigate and use the Services.
  • Statistics Cookies – Statistics cookies collect anonymous data for statistical purposes on your use of the Services. We use information supplied by statistics cookies to help understand how you use the Services, to monitor aggregate usage and web traffic routing, and to improve and customize the Services. These cookies don’t contain Personal Information and are generally set by independent analytics companies.
  • Preferences Cookies – These cookies are used during your visit to the Services to remember information you have entered or choices you make, and they permit us to remember your preferences for future visits.
  • Marketing Cookies – These cookies are placed by third party advertising companies to collect information about your activities to deliver targeted and relevant ads to you and to track ad performance. These third party companies have their own privacy and cookie policies, and they may use their cookies to target advertising to you on other websites, based on your use of the Services.

Note that this Privacy Policy covers only our use of cookies and does not include use of cookies placed on your Device by third-party services providers.

You can manage and disable statistics cookies, preferences cookies or marketing cookies through our Cookie Management Tool or by sending an email to [email protected]. You can prevent cookies from being placed on your Device through your browser settings by following the instructions set out at allaboutcookies.org. Most browsers also provide the ability to let you review and erase cookies. You can also opt-out of third party targeting or advertising cookies through the Digital Advertising Alliance, the Network Advertising Initiative or the European Interactive Digital Advertising Alliance.

Please be aware that if you disable or reject cookies, some features and services on our Services may not work properly because we may not be able to recognize and associate you with your Profile. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.

Information We Receive from Third Parties

Keepy collects any Personal Information that a Subscriber submits about you to invite you to have access to their Profile or become a Fan of a particular child’s Creative Materials.

In addition, Keepy may collect and use information from other third parties pursuant to such third party’s information collection practices, which are typically outlined in a policy like this one, provided on the third party’s website or application. We also may supplement the information we collect about you through the Services with other information from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from these third parties with information we collect through the Services. In those cases, we will apply this Policy to any Personal Information received.

2. How We Use the Information Collected

We may use Personal Information and other information we collect for purposes including:

  • to provide the Services, provide information you request, and to process and complete any transactions in connection with the Services;
  • to request feedback and to otherwise contact you about your account or your use of the Services;
  • to communicate with you and respond to your emails, submissions, questions, inquiries, comments, requests, and complaints and to provide customer service;
  • to personalize and improve the Services and users’ experiences, to increase the functionality and user friendliness of the Services, to deliver advertisements, content, or features that match user profiles or interests, and to provide recommendations as to other advertisements, content or features that may be of interest to users;
  • to monitor and analyze Services usage and trends and otherwise measure the effectiveness of the Services;
  • to provide you with news and information about our or third party offers, promotions, products, and services we think will be of interest to you;
  • to send you confirmations, updates, security alerts, and support and administrative messages, to detect and prevent fraud, and to otherwise facilitate your use of, and our administration and operation of, the Services; and
  • to notify you about important changes to our Services.

We process this information given our legitimate interest in (i) improving the Services and our users’ experience with it, (ii) protecting the Services, (iii) measuring the adequate performance of our contract with you and where it is necessary to process such data for adequate performance of the contract with you, (iv) undertaking marketing activities to offer you products or services that may be of interest to you, subject to your request to opt out of such marketing activities, and (iv) complying with applicable laws. Please review “Your Rights and Choices” below.

3. How We Share Personal Information

We will not share your Personal Information with third parties except as described below:

Third Parties Providing Services on Our Behalf

In order to carry out your requests, to make various features, services and materials available to you through the Services, and to respond to your inquiries, we may share your Personal Information or Usage Information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that host or operate our Services, analyze data, provide customer service, manage payments or to advertisers, sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance (such as in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list).

With Your Consent

Keepy will share Creative Materials and Keepies you choose to share through the Keepy Community or to social media in accordance with your election.

While using our Services, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

Business Transfers

Your Personal Information may also be used by us or shared with our subsidiaries, affiliates and other entities in the family of companies controlled by Keepy for internal reasons, primarily for business and operational purposes.

As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or a portion of our assets, Personal Information, Usage Information, and any other information that we have collected about the users of the Services may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided through the Services in a manner that is consistent with this Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosure

We may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier, to third parties to comply with a legal obligation, when we believe in good faith that the law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our Terms of Use or other applicable policies, to respond to an emergency, or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Services, or the public.

4. Your California Privacy Rights

If you are a California resident and you decide that you do not want us to share your Personal Information with third party companies for their marketing and promotional purposes, please send an e-mail to [email protected] .

In this e-mail, state that you would like Keepy not to share your personal information with third parties for their marketing purposes. Your opt-out request will be processed within thirty (30) days of the date of which we receive it.

5. Your Rights and Choices

We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all the features of the Services. You may exercise any of the rights described in this section below by sending an email to [email protected]. Please note that we may ask you to verify your identity before taking further action on your request.

Accessing, Modifying and Deleting Your Information

Through your Profile, you can delete your registration information, profile picture and comments, and if you are a Parent Subscriber you can access, edit or delete Creative Materials and Keepies posted to the Services.

If you no longer want to use the Services, you may request that we delete your Profile by sending us email to [email protected]. You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons, and we may retain and use Personal Information as necessary to comply with our legal obligations and for our legitimate business interests, such as fraud detection and prevention and enhancing safety.

Opt-Out

You may always direct us not to use your Personal Information to provide you with information or offers, or not to send you newsletters, e-mails or other communications by sending us an e-mail at [email protected] or [email protected] or by following the removal instructions in the communication that you receive.

Data Portability

In some jurisdictions, applicable law may entitle you to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Withdrawing Consent and Restriction of Processing

Where you have provided your consent to the processing of your Personal Information by Keepy, you may withdraw your consent at any time by changing your Profile settings or by sending a communication to Keepy specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (i) you contest the accuracy of your Personal Information; (ii) the processing is unlawful and you oppose the erasure of your Personal Information; (iii) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to your right to object to processing (below) and pending the verification whether the legitimate grounds of Keepy override your own.

Objection to Processing

In some jurisdictions, applicable law may entitle you to require Keepy not to process your Personal Data for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, Keepy will no longer process your Personal Information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

6. Data Retention

The length of time we retain your Personal Information depends on a number of factors relating to our business needs and legal requirements. In general, we will keep Personal Information for such time as required by applicable law or to exercise our legal rights.

In accordance with our routine record keeping, we may delete certain records that contain Personal Information, including Creative Materials, you have submitted through the Services. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information.

7. Links to Other Sites

The Services may provide links to other websites that we do not own or operate. This includes links from advertisers, sponsors and partners may use our logo(s) as part of a co-branding agreement. To the extent that any linked websites are not part of the Services, we do not control, recommend or endorse and are not responsible for these websites or their content, products, services or privacy policies or practices.

8. The Security of Your Personal Information

We maintain certain administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Services and provide us with your information at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

9. Consent to Processing and Transfer of Information

The Services are operated in the United States. Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to, those in the country where you reside and/or are a citizen.

10. Children’s Information

Protecting the privacy of children is especially important to Keepy and, due to the nature of our Services, we collect Personal Information about Children. However, we do not allow children under 16 years-of-age (“Child” or “Children”) to use the Services or create a Profile, we do not knowingly collect or maintain Personal Information from Children, and no part of the Services is directed to Children. If you are a Child, then please do not use or access Services at any time or in any manner. If we learn that Personal Information has been collected on the Service from Children without verifiable parental consent, then we will take the appropriate steps to delete this information.

If you are a parent or guardian and discover that your Child has provided Personal Information or obtained a Profile on the Services, then you may alert us at [email protected] and request that we delete that Child’s Personal Information or Profile from our systems.

11. Updates to Our Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Policy from time to time. If we make any material changes to this Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes became effective.

12. Questions

Please contact us at [email protected] if you have any questions about this Privacy Policy.