1. Introduction and Applicability of This Policy
1.1. Throughout this document, “Company”, “We”, “Us”, “Our” and “Ours” refer to:
SafeFamily
EIN: 83-2987714
Contact E-mail: contact@vgasoft.vn
Contact Phone: 0589929999
1.2 This Privacy Policy describes how We collect, store, use, and manage the personal information you provide to Us or that We collect in connection with https://safefamily.vn/ (the "Site"), official company communities on social media, mobile apps “SafeFamily” and “Safefamily: for children” (referred to as the "Applications" and collectively with the Site and all services provided through the Site and Applications, as the “Services”), as well as your choices and rights concerning the collection and use of personal information.
The Privacy Policy is applied to all visitors and users who use the Services (hereinafter – “Users” or "You"). Some of our Services are intended for children. This privacy policy contains a section on Children's Privacy. However, some of the other sections of this privacy policy apply equally to children's personal information and the personal information of adults. Whenever this is the case, we explicitly state that.
Whenever we refer to a child, we mean a child under the age of 13, for US users, and a child under the age of 16, for EU users.
Before accessing or using Our Services, please ensure that You have read and understood how We collect, store, use, and disclose Your personal information as described in this Privacy Policy.
2. Data We Collect and Receive
2.1. In order to provide You with Our Services, We may collect or receive data, which may include personal information voluntarily provided during the registration process, subscription to the Service, publication of materials or information collected automatically during the course of providing the Services.
2.2. We collect the following types of information about You and Your child:
2.2.1. Registration and Account Data
The “safefamily” app, which is intended for adults only, allows Users to create a profile. When You create such a profile, We may collect Your personal information, such as email address, gender, or cell phone number. We also may collect Your general location data such as country or region (We do not collect your precise geolocation).
The “Safefamily: for children” app is intended for children. It can be set up by an adult or a child. If the app is set up by a child, We first request a parent's code from the “safefamily” app. These apps need to be used together. The only personal information we ask for within the “Safefamily: for children” is the child's age.
When You as a parent set up the child's “Safefamily: for children,” Your parental “safefamily” app is connected to that child's phone, and You as a parent may create a child's profile within the “safefamily” app by providing the following personal information:
- Child's nickname. This nickname is not displayed publicly.
- Avatar picture. Only a picture that does not identify the child can be used. The Company does not store photos of the child on its server, and only the parent is allowed to access this data.
- GPS watch photos. The Company does not store photos of the child on its server, and only the parent is allowed to access this data.
- We may also collect information from your Contact list for the purposes of setting up a White list option and filling a contact list, choosing numbers to control the watches, and SOS numbers.
2.2.2. Communication Data
When You communicate with Us or submit a report about problems with the Services, post any content or messages, or provide any other information within the Services, We may process all of this information. This data may include:
- data that You post on the Services;
- data sent through "Safefamily: for children";
- data You provide through our support channels.
Children do not have the ability to contact us from within the “Safefamily: for children” app.
2.2.3. Data Collected Through Use of the Services
2.2.3.1. When You or Your child use any of Our Services, the following types of information may be processed:
- general location data, which includes your country, region, city (includes your precise location data);
- language set up on your device;
- data about Your use of the Services;
- payment data, when You purchase any Services from Us, including information necessary to process Your orders with the relevant payment provider, which may include the amount of any transaction, but WILL NOT INCLUDE Your name, financial information, or cardholder data, which will only be submitted directly to the payment service provider under secure protocols; You can find further information in the current data protection guidelines of the respective payment providers. When You make in-app purchases within the mobile application, we do not collect or have any access to your name and billing information. This information is collected and stored by Your platform (e.g. Apple Store or Google Play) or Your platform’s payment processor.
2.2.3.2. We may collect the following types of personal information regarding child users of the “Safefamily: for children” app:
- Geolocation (precise geolocation): we collect and use the unique user ID and location of the mobile device on which the “Safefamily: for children” app is installed using GPS, WiFi, or wireless triangulation in order to get the location of the mobile device to provide our Services. We only store the geolocation data as long as it is reasonable to provide the Service, and then We delete the geolocation data related to Your profile in the “safefamily” app. The Company may maintain geolocation data for a longer period of time only in order to analyse cumulative trends and indicators (improvement of our Services). During the app's set up, We will ask You whether You want to turn the geolocation tracking on. You can later change your choice within the settings of the device.
- Sound around the child's device per request of the parent: you as a parent can choose to listen live to your child's device's surroundings for 20 seconds (if You are within 2 meters of Your child's phone). Your child needs to have the “Safefamily: for children” app installed. Listening and recording are allowed only for the users with the “safefamily” app installed and connected with the child's profile. The child is notified that they may be recorded. This information is accessible from the settings of the “Safefamily: for children” app.
- data on installed applications (name of the installed application, application package ID, date of installation of the application, time of use of the application). This information is necessary for the provision of the Service. With this function the user of the safefamily can limit the time of use of the child's device. For this purpose, We convert the names of the installed application, application package ID, the date of installation of the application, and the time of application use into user-friendly graphs to enable the parent to limit the time of application use by the child.
- Fitness data or activity recognition data: this information may be displayed within the “safefamily” app connected with the child profile.
- Data about features that users use in the app.
- Data about users' taps and swipes in the app which they make by interacting with the application interface.
- Screenshots captured during the app usage.
- Virtual device identifier.
- The Company does not store sound around the device or audio data, usage statistics, fitness data, or activity recognition data on any servers. Only the parent connected to the same child profile is allowed to access this information within their “safefamily” app.
2.2.4. Data Collected Automatically via Cookies and Related Technologies
When you visit our website or use our mobile software, We and Our business partners may collect certain data about your PC or device using technologies such as cookies, web cookies, log files, or any other tracking/recording tools. The information We collect using the tracking technologies includes but is not limited to the IP addresses, browser information, links to/exits and URLs, streaming data and information regarding how you interact with the web links, website, mobile software or Service, domain names, landing pages, page views, cookies data which allow us to uniquely identify your browser and monitor the behaviour of your browser at Our website, type of mobile device or other permanent identifiers. Some or all of this data may be combined with other personally identifying information specified above.
When You access our Service via a mobile device, We may receive or collect and store unique identification numbers associated with Your device or Our mobile app (including, for example, UDID, a unique identifier for advertisers ("IDFA")) device type, model and manufacturer, brand and model of the mobile operating system.
We may use first-party cookies that belong to us and that we place on your device and third-party cookies that another party places on your browsing device when You visit our site. Third parties setting cookies on Our website will be providing a service to Us or a function of the Site, but We do not always control how third-party cookies are used. You should check the third party’s website for more information about how they use cookies.
Please see the Cookie List for more information about the cookies we use on Our website, and how long they will stay on Your device.
Cookies or similar technologies stored on your computer or device through which You use the Services have amongst others but without limitation, the following functions: Authentication. If you’re signed in to our Services, cookies help us show you the right information and personalize your experience.
Security. We use cookies to enable and support our security features, and to help us detect malicious activity.
Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are. They can help you fill out forms on our Sites more easily. They also provide you with features, insights, and customized content.
Marketing. We may use cookies or similar technologies to help us deliver marketing campaigns and track their performance. Similarly, our partners may use cookies to provide us with information about your interactions with their services and action tags to measure advertising effectiveness and allow more effective targeted advertising, but the use of those third-party cookies would be subject to the service provider’s policies. We do not use or share the child's personal information for the purposes of targeted advertising.
Performance, Analytics, and Research. Cookies or similar technologies help us learn how well our Sites and Services perform, diagnose or fix technology problems reported by the users or developers. We also use cookies or similar technologies to understand, improve, and research products, features, and services, including to create logs and record when you access our Sites and Services from different devices, such as your computer or your mobile device.
We may use third-party analytics providers software to allow us to better understand the functionality of our software on your device, including but not limited to, Google Analytics, Firebase, Facebook Analytica (collectively “Third Party Analytics Providers”). This software may record information such as how often You use the Services, the events that occur within the mobile application, aggregated usage, performance data, and where the application was downloaded from. We may link the information We store within the analytics software to personal information You submit within the mobile application.
3. How We Protect Your Data
3.1. The Company takes precautions - including legal, organizational, administrative, technical and physical measures in order to protect the personal data of the User, including child User, from any unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. In order to make sure that Your and Your child's personal data is safe, we communicate confidentiality and security standards to the Company's employees and strictly monitor the implementation of confidentiality measures within the Company.
4. Storing of Your Data
4.1. We do not store personal data that can be used to identify a User beyond the time period necessary to complete the function for which information was collected. We store your personal data for as long as Your User account is active, or as long as is needed to provide You with the Service. This also applies to data of child Users.
Note that if you ask us to remove Your personal data, we may retain your information as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
4.2. Storing of the information for marketing purposes: If you have elected to receive marketing notifications from Us, we store information about Your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services.
We store information derived from cookies and other tracking technologies for a reasonable period of time from the date when such information was created and in accordance with conditions provided in section 2.2.4. (Data Collected Automatically via Cookies and Related Technologies).
5. Your Rights and Options
5.1. You have certain choices available to You when it comes to your information. Below is a summary of those rights, how to exercise them, and any limitations.
5.2. Your requests and choices may be limited in certain cases, such as when fulfilling Your request would reveal information about another person, or if You ask to delete information which We are permitted by law or have compelling legitimate interests to keep.
5.3. Right to Know Your Personal Data Processed (Right of Access)
If you request, upon verification of your identity, we will provide you a copy of your personal data in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in section 12 (Contact Us) to request assistance.
5.4. Change or Correct Your Personal Data (Right to Rectification)
If available, you can edit some of your personal data through your account. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate, by contacting us as explained in section 12 (Contact Us).
5.5. Delete Your Personal Data (Right to Erasure):
You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and service-related information linked to the Account and the possibility to access the services for which you are using the Account. Please note that once your Account has been deleted, you will lose your user history and all related information.
5.6. Opt-Out of Direct Marketing: You can also opt-out of our use of your information for marketing purposes by following instructions in promotional communications or by contacting us, as explained in section 12 (Contact Us). When you make such requests, we may need time to investigate and facilitate your request. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites. You can also stop receiving promotional emails from us by clicking on the “unsubscribe” link provided in such emails. You cannot deactivate the messages related to the functionality of the Service (for example, account verification, notification of parental consent, order confirmation, change or update of the Service features, technical and security notifications).
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android).
5.7. Withdraw Consent: You may withdraw consent where the processing of your personal information is based on consent, by contacting us as explained in the section “Contact us.” If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
5.8. In most instances, we will respond to all requests within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.
5.9. You have the right to complain to the Data Protection supervisory authority for unresolved complaints.
5.10. European Union users have additional specific rights:
5.10.1. Request That We Stop Using Your Data (Right to Object): Where the processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise, or defense of legal claims.
5.10.2. Data Portability: Data portability is the ability to obtain some of your personal information in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.
6. Changes to This Privacy Policy
6.1. We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice within the Services or by sending you a notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.
6.2. For the users in the USA, Wee will obtain prior parental consent if any changes we make to this Policy affect users under the age of 13 in a way that requires such consent under COPPA.