1. INFORMATION WE COLLECT

Information provided by you:

• When you register, you will provide us with your name and e-mail address.

• When you create an account for your Child, you will provide us your child’s date of birth and a name for your child’s profile

• When you purchase a subscription to our Services, you will provide payment information, mailing address and telephone number

 

Data related to activities on Website:

• When you access the Website, we collect information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. Cookies allow us to collect information such as browser type, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience when accessing our website. We also use cookies to track responses to our online advertisements on other sites or services.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org. Please consider however that cookies may be necessary to provide you certain features available on the Website (e.g., customized delivery of information).

• When you access the Website, we collect your IP Address. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels and diagnosing server problems. We also derive your approximate location from your IP address.

 

Data related to usage of Parent application:

Parent application refers to the application installed on a smartphone that you would use for settings, purchase of content or subscription, creation of own content and reports access.

• When you install and open our Parent application on a smartphone, we collect your device type, your device ID, and your IP address.

• When you use our Parent application, we record the following data about your profile and child profile settings:

  • Profile relational

  • Profile photo or icon selection

  • Language selection

• When you use our Parent application, we record the following data about your settings and preferences:

  • Content selection

  • Activities selection

  • Content bookmarks

  • In-app preference settings such as activity duration, forbidden activities,...

• When you use our Parent application, we record the following data about your activity inside the application:

  • Scrolling

  • Session duration

  • Usage patterns

 

Data related to activities on Child application:

Child application refers to the application installed on a tablet that your Child would interact with when using our Services.

• When you install and open our Child application on a tablet, we collect your device type, your device ID, and your IP address.

• When you access the Parent menu inside our Child application , we record the data as per described in Data related to usage of Parent application.

• When your child use our Child application, we use your tablet’s microphone and camera to monitor your Child’s activity. Comobi records these audio and video session and retains them until you close your or your Child’s Comobi account. Comobi uses these data to help improve the quality of your Child’s experience, improve the interactivity of the application and enable delivery of content that is best fitted to your Child’s interest and developmental stage. We also use these data for generating activity reports and suggestions that are shared to you through the Parent application.

• When your child use our Child application, we record the following data about your Child’s activity inside the application:

  • Session duration

  • Usage patterns

  • Attentional information

  • Emotional information

  • Expressional information

 

Although Comobi is committed to ensuring the protection of Children’s privacy and data, we understand that some parents may feel discomfort about allowing usage of microphone and camera. We therefore offer the possibility to use our services without collection of such information. Please note however that under such conditions we are only able to deliver limited Services in terms of features, content and experience.

 

Aggregating information:

• We collect information through aggregation. Aggregated information does not identify you or your children. We use aggregated information to compute statistical data about derived from the usage of our website or applications (ex: average time spent on an activity by children )

 

Information Obtained by Third Parties

• We work with a variety of third party advertising networks, marketing analytics service providers and website analysis firms, such as Google, Facebook, Twitter or Instagram (collectively, “Third Party Advertising Service Providers”). These Third Party Advertising Service Providers collect and use personal data about your visits and use of the Website and mobile Application, as well as other websites in order to serve you with advertisements and content tailored to meet your preferences and better understand ad effectiveness. Aggregate demographic and interest data will also be used for market research purposes.

• We use Google Analytics to understand how users engage through the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

• We use Google Analytics to understand how users engage through the Parent application and Child application. [WHAT TO PUT HERE vs what is proposed for website?]

• You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools (NAI: http://www.networkadvertising.org/choices/, DAA: http://www.aboutads.info/choices/).

• In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

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2. HOW WE USE INFORMATION

We use the information listed in article 1. in the following ways:

• To provide you with the Comobi Services usage of Content access you might request (e.g., monthly subscription or Content purchase)

• To provide your Child an interactive experience, and select content that is best fitted to your Child’s interest and developmental stage.

• To send you updates about the Comobi Service (including any updates on product features or policies) through mail or in-application notifications

• To provide you with personally relevant suggestions of new content, product features, promotions or offers.

• To send you feedback on your child's activities progress and interests

• To investigate and prevent activities that may violate our policies or be illegal 

• To gather anonymous aggregate information from all our users to improve our products and services

 

3. HOW WE SHARE INFORMATION

Comobi shares personal data only when it is necessary to offer the Service, legally required, or permitted by you.

 

Your information may thus be disclosed to the following parties:

• To other Comobi service users that you have authorized or subscribed to. After creating a Comobi account for you and your child, these profiles will be publicly associated (including name and picture/photo) and visible to other Comobi users you have authorized or subscribed to.

• To our service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. These providers enable us to bring you the Service and improve the quality of the Service. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to Comobi.

• To relevant authorities in case Comobi is required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will share information with relevant authorities (including government agencies, lawyers, agents or companies) when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the Comobi name, or to prevent imminent harm.

• To a third party in the event of any reorganization, merger, sale, joint venture, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings).

 

Aggregate and anonymous data collected through the Service (website, Parent app, Child app), including activity data, demographics data, preferences data will be shared with third parties for the purpose of improving the Service offer.

 

4. DATA SUBJECT RIGHTS AND DATA RETENTION

At Comobi, we understand and respect your privacy concerns. Accordingly, we provide you with the ability to make choices related to our collection, use, and sharing of your information. We ensure you the following rights (unless provided otherwise by local laws) in regards of any personal data for you or your child that we withhold:

• Right to withdraw your consent to process your personal data at any time, or object the processing of such data

• Right to request access to or erasure of all the personal data we hold about you.

• Right to request export the personal data you have provided us in a format easily accessible

• Right to edit or delete information in your user account

• Right to make choices regarding subscriptions, updates, and product alerts

• Right to choose if you want to receive offers and promotions from us and/or third parties

• Right to delete your or your child account.

Comobi will retain your and your Child data until your or your Child account is deleted, after which point only anonymous data collected through the Service will remain. Therefore, the deletion of your or your Child account is an unrecoverable process as all personal information will be immediately deleted.

 

We are doing our best to comply with applicable regulations and help you feel concern free about the protection of you or your child’s privacy. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

 

For European citizens, you also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

 

5. CHILDREN’S PRIVACY

Comobi provides features and services intended for use by children from age 3 to 7.

 

As a result, the consent of a parent / guardian is always required for usage of our services at the application installation timing. The creation or modification of a child account is only possible through the parent’s application or menu, as well as any content or subscription purchase.

 

We recognize that collecting personal data from children requires adequate privacy protections. Accordingly, Comobi takes the following measures:

• We notify parents or guardians about Comobi’s privacy and information practices and updates regarding children, including what personal data we collect and how we use, share, and protect these personal data

• We do not expose child account information to other users of Comobi service.

• We limit our collection of personal data to no more than necessary to provide our services

• We systematically obtain parental consent before collecting personal data from children

• We allow parents to easily and instantaneously delete personal data about their children through the application

• We allow parents to use Comobi services without collection of microphone / camera data (with limited Features and Service offering) 

• We do not show advertisement on the Child application or anytime during activities intended for Children

 

Instead of any Personally Identifiable Information about the child, we will only store the e-mail address of their parent/guardian.

 

6. THIRD PARTY SERVICES

Our Services contain links to other sites operated by third parties. We do not control such other sites and are not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor to process payments for in-app purchases. Comobi’s inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy

 

The Service may contain links to other websites. We are not responsible for the privacy practices of other websites. We encourage users to be aware when they leave the Service to read the privacy statements of other websites that collect personally identifiable information. This Privacy Policy applies only to information collected by Comobi via the Service.

 

Please note that you may have cookies placed on your computer by third party websites that refer you to our Service. Although we do not share your personal data with these third party websites unless it is reasonably necessary to offer the Service, they may be able to link certain non-personally identifiable information we transfer to them with personal data they previously collected from you. Please review the privacy policies of each website you visit to better understand their privacy practices. 

 

7. SECURITY

Comobi has implemented administrative and technical safeguards we believe are appropriate to protect the confidentiality, integrity and availability of your personal data. 

 

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe the security of your account has been compromised, please immediately notify us in accordance with the “Contact Us” section below

 

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change or modify our Privacy Policy to reflect changes to our information practices. When we do so, we will post a notice that we have made changes to this Privacy Policy on our website, our application and through mail notice for at least 7 days before the changes are made, and we will indicate the date these terms were last revised at the bottom of the Privacy Policy. Any revisions to this Privacy Policy will become effective at the end of that 7 day period.

 

9. CONTACT US

Comobi Co. Ltd., is a company registered at 2F Ginza Ootake Busidence, 1-22-11 Ginza, Chuo-Ku, Tokyo 104-0061, Japan.

Phone: +81 (0)80 8725 5313

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact our Data Protection Officer at privacy@comobi.io.