The short version!
- Our top priority is the well-being and privacy of the children that use our products and services, including the App.
- We’ve got various safeguards in place to keep children safe. For instance, we never seek to collect personal information about a child unless you, as their parent or guardian, decide to voluntarily provide it to us.
- We strive to provide you with access to and control over the information you give us.
The longer version
At Pok Pok Inc. (“Pok Pok”, “we” or “us”), we value the trust you have placed in us, and we are committed to creating a safe and secure online environment that family members of all ages can enjoy.
This policy applies globally, but we have included additional information below for residents of the European Economic Area, the United Kingdom, Switzerland and California.
We do not collect...
- Biometric or health data;
- Personal information about your child through our App; or
- Any personal information about your child at all, unless you, as their parent or guardian, voluntarily provides it to us (for example, if you send us an email that includes your child’s personal information).
For access and control information for parents, see “Parental access and control” below.
Information we collect and use from the App
We collect personal information and usage information when a parent (“parent” or “you”) downloads and uses the App. We generally do not ask that you or your child share any personal information about your child with us while signing up for or using the App. We will never insist on receiving that information.
Information you provide us
When you subscribe for services through our App, Apple may share your information with us (if you have consented to Apple sharing such information). We may collect additional information from you if you contact our technical support team, send us an email, complete a user survey, or otherwise communicate with us about the App.
The drawings your child may make using our drawing toy are only temporarily stored on your device and we have no access to them. When you decide to share a drawing, it will be saved temporarily on our servers, but we won’t be able to identify your child based on the drawing. We won’t use the drawing for any reason other than to help you share it.
Subscription payments are processed through the Apple App Store. We do not collect or see your payment information, only a unique Subscriber ID that Apple creates for the subscription. Apple describes this process here. Information on Apple’s privacy practices more generally is available here.
We may collect information about your device, including hardware model, operating system version, preferred language, and unique identifiers. We do not link this data with your subscription or any other data you provide us. We use device information for internal operations of the App and to personalize the user experience.
Anonymous usage data
While it’s not personal information, we collect anonymous usage data. This usage data includes information like how long an activity is played with and if there are any technical issues or “bugs”. We analyze this information to learn more about how the App is being used, and how we can maintain and improve the App. We never try to use this information to identify a specific user.
Other information we collect and use
We may collect personal information when you contact with us, when you use our website or when you engage with us over social media. We collect and use this information so that we can:
- Communicate with you and keep you updated on Pok Pok;
- To identify and authenticate you;
- To provide you with information that you request from us, and to receive feedback from you;
- Enable you to participate in promotions and surveys;
- To understand how you use our products, content and services, for data analytics, statistical analysis, internal business purposes, and product development purposes;
- To manage our business and day-to-day business and operational needs; and
- Comply with any legal requirements or defend our legal rights.
If you submit a job application to us, we will use the information relating to that application (such as your employment history) to assess your suitability to any of our job postings. We may also collect information from third parties about you, such as references you list, for the same purpose.
Additional information collected through our website
We use Google Analytics to better understand your use of our website. Google Analytics collects information on user behaviour on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Google uses the data collected through cookies to track and examine the use of the website, to prepare reports on its activities, and share them with other Google services. Advertising identifiers for mobile devices (such as Android and iOS Advertising Identifiers) are also collected. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network.
Google will not associate your IP address with any other data held by Google. To learn more about Google Analytics, click here. You can deactivate the Google Analytics function with a browser add-on, which you can download here. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.
De-identified, aggregate or anonymized information
We may also de-identify, aggregate or anonymize information to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with: (a) our affiliates and business partners to understand and improve Pok Pok’s and the App’s performance and to develop better apps in the future; and (b) third parties for other analytical purposes. At no time will such information personally identify, or be used to identify, any individual.
How and when we may share your information
We do not sell or lease your personal information to third parties.
We may share your information for three main reasons: (a) with our affiliates and service providers; (b) for legal reasons; and (c) for business reasons.
(a) Affiliates and service providers
We may share your information with our affiliates and business partners to assist us in providing you services, perform functions on our behalf or for our internal business purposes. For example, we may share your information with our affiliate studio, Built by Snowman Inc., for internal management and administrative purposes.
We may also share your information with other organizations (e.g. service providers) that assist us in providing the App or that provide us with other services. When we share information with service providers, we require them to commit to protecting your personal information in line Pok Pok standards, and limit use and disclosure of the information for the specific purposes for which we supplied it.
We do not share personal information belonging to children with service providers unless the service is necessary to providing the App.
(b) Legal reasons
In rare circumstances, we may share your information about you if we reasonably believe that it is needed to:
- Comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
- Protect the rights, property, and safety of us, our users, or others; or
- Detect and resolve any fraud or security concerns.
(c) Business reasons
We may share personal information with business partners where it is relevant to a business transaction, such as the sale of Pok Pok to another company, as part of a corporate re-organization or to pursue a partnership or investment opportunity.
Getting and withdrawing your consent
You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.
You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting the Privacy Officer (see ‘Contact information’ below) and, subject to any legal constraints, we will comply with your request.
Parental access and control
As a parent, you have the option to control some of the information you share with us and your other devices. This includes data and subscription options, and whether you want to receive updates meant for parents and educators. You can control this information by selecting the Parental Area icon in the App.
Remember that you can also access and restrict changes to privacy settings by activating Apple’s Screen Time function on the device and selecting “This is My Child’s [Device].” Click here for more information.
For information on how to access your or (if applicable) your child’s personal information, see “Accessing your information” below. Remember that the App does not collect your child’s personal information.
International transfers of information
Some of our service providers and business partners may be based outside of Canada. This means your information may be accessible to law enforcement authorities outside of your jurisdiction, in accordance with the laws of that jurisdiction.
We protect your information by limiting access to it on a strict “need-to-know” basis, and we implement reasonable physical, organizational and technological safeguards as appropriate.
We only keep your information as long as it is operationally or legally necessary. After that, we will either destroy or de-identify the information.
Accessing your information
When requested in writing, we will inform you of the existence, use, and disclosure of your and, if applicable, your child’s personal information that we maintain.
To access your personal information, submit a written a request that identifies yourself, the information you want to review and how we can contact you (see ‘Contact information’ below for how to contact us). We may not be able to provide you with all the information you request, depending on the circumstances, and there may be a charge for copies of your personal information.
Correcting your information
We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make any appropriate updates needed. You can review your personal information by looking at the App settings, reviewing the correspondence we send to you, or by requesting access to your personal information, as described above.
Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honour Do-Not-Track requests sent by your browser.
Additional information for European residents
Basis of Lawful Processing
European data protection laws require us to be specific about our reasons or grounds for using your personal information. Pok Pok processes the personal information of individuals located in the EU, Switzerland or UK on these grounds:
- Consent. When you have provided your consent to our collection of your information;
- Legitimate interests. When we have a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests; and/or
- Legal obligation. When we need to comply with a legal or regulatory obligation.
Pok Pok may process your personal information on more than one ground depending on the reason or grounds for using your personal information. Please contact us if you need details about the specific grounds we are relying on to process your personal information.
Data subject rights
If you are a European, in addition to the access and correction rights outlined above, you may be entitled, subject to certain conditions, to exercise some or all of the following additional rights:
- Deletion. The right to request that we delete your information.
- Restrict processing. The right to request that we limit or cease the processing of your information.
- Portability. The right to request that we transfer your information that we have collected to another organization or directly to you.
In order to exercise these rights, contact our Privacy Officer using the contact information outlined below.
Additional information for California residents
If you are a California resident, you can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required by law.
- You can ask us what personal information we have about you, including a list of categories of your personal information that we have sold and a list of categories of your personal information that we have shared with another company for a business purpose.
- You can ask us to delete your personal information.
- You can ask that we stop selling your personal information.
In order to exercise these rights, contact our Privacy Officer using the contact information outlined below.
Mailing address: 111 Queen St. East, Toronto, ON. M5C 1S2
Please note that we may need to confirm your identity or request additional details in order to process your request.
We may modify this notice from time to time and will post the most current version online. If our privacy practices change in such a way that requires us to obtain parental consent, we will confirm that you are the parent or guardian responsible for the account and ask for your consent. If you disagree, we will tell you about any alternatives, including closing your account.
Last updated: May 21, 2021.