Privacy Policy for the Lock Screen for Kurio App

The Lock Screen for Kurio App should only be set up by parents or guardians who must be aged 18 and over. While it may be used by children who are authorised by a parent or guardian it should only be set up by one of their parents or a guardian who must be aged 18 or over as we do not knowingly collect or solicit any information from anyone under the age of 18. If you have any questions please contact kuriolockscreen@iconlogin.com.

When You as a parent or guardian use the Lock Screen for Kurio App You should be aware that IconLogin may collect certain information about You such as Your name, contact details, information about the Kurio Device. Please see section 2 of this Privacy Policy below for more details of exactly what information about You that We may collect. Please note that during the set up process, an email address is needed to validate the use of the Lock Screen for Kurio App.

When an authorised child uses the Lock Screen for Kurio App IconLogin does not collect information about the child although it may collect information about the Kurio Device and its use.

IconLogin collects information so that We can provide You with support for the Lock Screen for Kurio App, run Our business, contact You as a parent or guardian and comply with the law and/ or regulations. Please see section 4 of this Privacy Policy below for more details of exactly what information We may collect.

If You do not agree to Us collecting and using the information then You must not use the Lock Screen for Kurio App.

Privacy Policy for IconLogin Limited

IconLogin Limited, a company registered in England & Wales with company number 07862679 and registered address Blythe Farm Mill Street, Gamlingay, Sandy, Bedfordshire, SG19 3JW United Kingdom (“IconLogin/ We/ Us/ Our”) is committed to protecting and respecting your privacy.

This policy, together with the Terms and Conditions for www.iconlogin.com and www.iconloginsocialmedia.com (“Our Sites”) and the Terms of Use for the Lock Screen for Kurio App (“App”), set out the basis on which any personal data We collect from You, or that You provide to Us, will be processed by Us. Please read the following carefully to understand Our views and practices regarding Your personal data and how We will treat it. By visiting Our Sites, using the App and giving Us information You acknowledge the practices described in this policy.

We are registered with the Information Commissioners Office (“ICO”) as both a Data Controller and a Data Processor in accordance with applicable data protection laws, Our ICO registration number is ZA008218 and you can access Our data protection register entry here.

Our Sites may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.

ABOUT THE KURIO CHILDRENS TABLET

The Kurio Childrens Tablet (“Kurio Device”) is developed and sold by CIDE INTERACTIVE S.L.U., a Spanish corporation with registered office at Viladecans Business Park, Edificio Brasil, C/ Catalunya, 83-85 Pl.1 B1, 08840 Viladecans, Barcelona, Spain.

The Kurio Device is an educational and fun electronic device used by children where their parents or guardians (“You”/ “Your”) authorise usage by controlling access and setting the usage parameters via a higher level access that gives You overall control of the Kurio Device. The children have their own picture passwords but unlike We do not collect any personal information and unlike You they do not have the ability to reset passwords or access the set up parameters.

Information We may collect from you

We may collect and process the following information in accordance with applicable data protection laws and/ or statutory regulations:

  • the email address provided by You when You first set up the App, to validate such set up and for password reset purposes.
  • the personal information about You that You may provide during the set up as one of the password reset options. This information is in response to three control questions: (i) Where You were born? (ii) What is Your favourite colour? and, (iii) Who is You favourite singer/ band? We offer an alternative reset option that does not require providing us with this information.
  • information provided when We are contacted via phone, email or an online form with an enquiry, a report of a problem with Our Sites or the App or in response to a communication from us, We may be provided with certain personal data such as name, email address and information contained in the correspondence (which could tell Us something about the individual’s preferences). The individual contacting Us is in control of the personal data and other information that they share with us. We need this information to be able to respond to the enquiry and to administer Our business.
  • details of Your interactions with and any transactions You carry out in relation to the App. We need this information to be able to support the App and related keypads and to meet Our legal and regulatory obligations;
  • information provided when individuals visit Our Sites or the App. We capture access data such as IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, date and time of the access, requests made, the amount of data transmitted and the requesting provider. This information does not allow Us to identify You or a child. We may also capture other information about visits to Our Sites such as site usage and traffic patterns. Whereas We may be able to identify an individual Kurio Device and therefore You from this information, the purpose of collecting information is to administer, maintain and improve the App and Our Sites and not to analyse individual visits to The App or Our Sites (please see the “purposes for processing” section below for further details); and
  • information about when and how individuals use the App. Information may include country of origin, type of Kurio Device used, number of sessions (a session is when You look at items in the relevant App menu), number of wake up events (a wake up event is when You wake up Your Kurio Device and look at the screen), number of unlock events (an unlock event is when You use an App to unlock Your Kurio Device) and demographic, age, location and interest data. All of this is anonymised and aggregated so that it cannot be tied to individual users. This information is used by Us and the third parties who provide the Licensed Images (defined in the relevant App Terms of Use found here) and is anonymised and aggregated.

Where You provide Us with information about other people, You warrant that You have the authority to pass this information to Us.

We are required to comply with certain legal and regulatory requirements, and may process Your personal data for compliance with such legal or regulatory obligations, to which We or regulators or law enforcement agencies are subject.

Note that if any of Your personal details change during Your use of the App or Our Sites, You are responsible for updating them by accessing the relevant section of the relevant App, or by contacting Us at kuriolockscreen@iconlogin.com.

Purposes of processing

Any personal data We process will be used in accordance with applicable data protection laws and/ or statutory regulations. We have described below Our purposes for processing personal data.

We may use information You give to Us or that We collect from You:

  • to provide the App and related keypads, other products and services, administer user accounts and run Our business;
  • We have a legitimate interest in the processing of the personal data of Our users in order to provide the App and related keypads, other products and services, administer user accounts and run Our business;
  • to communicate with You:
  • We have a legitimate interest in the processing of the personal data of Our users in order to respond to enquiries, requests, complaints or comments that users submit to Us;
  • to administer, maintain and improve the App and Our Sites:
  • We use “cookies” to monitor user traffic patterns and site usage. This helps Us to understand how Our users and potential users use the App and Our Sites so that We can develop and improve the design, layout and functionality of the App and Our Sites. A cookie is a piece of information that is stored on in the relevant App on Your Kurio Device or Your computer’s hard drive and which records Your navigation of a website so that, when You revisit that website, it can present tailored options to You based upon the stored information about Your last visit. You can normally alter the settings of Your browser to prevent acceptance of cookies. If You do not want Us to deploy cookies in Your browser, You can set Your browser to reject cookies or to notify You when a web site tries to put a cookie on Your computer. However, rejecting cookies may affect Your ability to use The App or some of the products and services on Our Sites; and
  • We have a legitimate interest in the processing of the personal data of Our users in order to administer, maintain and improve the App and Our Sites;
  • to notify You about changes to the App, Our Sites and other products and services;
  • for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We have a legitimate interest in the processing of the personal data of Our users for Our internal operations;
  • as part of Our efforts to keep the App and Our Sites safe and secure. We have a legitimate interest in the processing of the personal data of Our users to keep the App and Our Sites safe and secure;
  • to comply with any legal or regulatory obligations to which We or regulators or law enforcement agencies are subject. This processing is necessary for compliance with a legal obligation to which We, Our users or the regulator/ law enforcement agency are subject; and

If You have any questions about how We use Your data please contact Us by email at kuriolockscreen@iconlogin.com.

Disclosure of your information

We may share Your personal information with any member of Our group, which means Our subsidiaries, Our ultimate holding company and its subsidiaries, as defined in section 1159 of the United Kingdom’s Companies Act 2006.

We may share Your information with selected third parties including:

  • business partners and sponsors, We may share country of origin, type of Kurio Device used, number of sessions (a session is when You look at items in the relevant App menu), number of wake up events (a wake up event is when You wake up Your Kurio Device and look at the screen), number of unlock events (an unlock event is when You use the relevant App to unlock Your Kurio Device) and demographic, age, location and interest data. All of this information is anonymised and aggregated so that it cannot be tied to individual users; and
  • suppliers and sub-contractors for the performance of The App and running of Our business, for example, to validate the email address that You provide Us with We may disclose Your email address to Our third party suppliers and/ or sub-contractors.

We may disclose Your personal information to third parties:

  • in the event that We sell or buy any business or assets, in which case We may disclose Your personal data to the prospective seller or buyer of such business or assets or if IconLogin Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;
  • if We are under a duty to or permitted to disclose or share Your personal data in order to comply with any legal or regulatory obligations, or in order to enforce or apply the Terms of Use for the relevant App – see here – or the Terms and Conditions for Our Sites – see here, or any other agreements; or to protect the rights, property, or safety of IconLogin Limited, Our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; and

Where We store your data

We may transfer Your personal data outside of the UK to set up and support the App and Our Sites, for example, where We use third party suppliers and sub-contractors. We currently use third party suppliers with servers and operations located in the US. If We sell or buy any business or assets and would be required to disclose Your personal data to the prospective buyer or seller of such business or assets, or if We or substantially all of Our assets are acquired by a third party, We may, to the extent that any of these situations occur, be required to transfer Your personal data outside of the UK.

Where the transfers are not to countries that provide an adequate level of protection, We put appropriate safeguards in place to cover transfers of Your personal data including, for example, signing standard contractual clauses/ data protection clauses adopted by the European Commission, or where applicable, relying on Privacy Shield certification where Our suppliers are located in the US. Please click here for a link to the standard contractual/ data protection clauses and click here for more information about the Privacy Shield for US companies.

Retention of your data

We take appropriate measures to ensure that any personal data is kept secure. We will store Your personal data for the duration of Your use of The App and/ or Our Sites. If You delete Your account or any App, We will continue to store Your personal data for a period of time in line with legal, regulatory, financial and business requirements. We will also keep a record of any correspondence in line with legal, regulatory, financial and business requirements.

Access to information and Your rights

As a result of Us collecting, controlling and processing Your information, You have the following legal rights:

  • to access personal data held about You;
  • to request Us to make any changes to Your personal data if it is inaccurate or incomplete;
  • to request Your personal data is erased where We do not have a compelling reason to continue to process such data in certain circumstances (please note that this is likely to result You being required to cease using the Lock Screen for Kurio App);
  • to receive Your personal data provided to Us as a Data Controller in a structured, commonly used and machine-readable format where Our processing of the data is based on: (i) Your consent; (ii) Our necessity for setting up and supporting the App against App specific Terms of Use that You are required to acknowledge and agree by clicking on “Accept Terms & Conditions” when the relevant App is downloaded; or (iii) steps taken at Your request prior to entering into any agreement with Us and the processing is carried out by automated means;
  • to object to, or restrict, Our processing of Your personal data in certain circumstances;
  • to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect You;
  • where Our processing of Your personal data is based on Your consent, You have the right to withdraw consent at any time by contacting us; and
  • to lodge a complaint with a data protection supervisory authority. The supervisory authority in the UK is the ICO.

To exercise any of Your rights as set out above, please contact Us at kuriolockscreen@iconlogin.com or contact our Data Protection Officer at info@iconlogin.com or call them on +44 20 7720 8000, or write to them at Blythe Farm Mill Street, Gamlingay, Sandy, Bedfordshire, SG19 3JW United Kingdom.

Changes to Our privacy policy

This Privacy Policy was last updated in January 2019. We reserve the right to modify this Privacy Policy at any time and, where appropriate, You may be notified of changes We make to this Privacy Policy. Please check back regularly to keep informed of updates or changes to this Privacy Policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be sent to kuriolockscreen@iconlogin.com