Privacy Policy and Children's Privacy Policy

Overview

Updated November 1, 2018

Your privacy is important to us at Unruly Studios, Inc. (“Unruly Studios,” “we,” “us,” or “our”).  This Privacy Policy describes the information we collect from you through our interactions with you and through our Services and how the information will be used. Key terms are italicized and underlined (like this) and can be found in the Definitions section below. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy applies when you use our Services, including our Splats, Website, App, and any other online services and connected products we provide. Our Website is also subject to our TERMS OF USE AND SERVICE. Other terms, end-user license agreements, or additional rules may apply to the use of our Splats and App. Each time you use our Services, you agree to this statement. If you don’t agree with all the terms of this statement, please do not use our Services.

The General-Audience Pages of our Website are intended for adults.  We do not knowingly solicit or collect Personal Information from Children on our General-Audience Pages.  If we learn that a Child User has provided us with their Personal Information without prior verifiable parental consent, we will take all reasonable measures to delete such information from our databases and not use such information for any purpose.  If you are under the age of 18 and would like to order our Splats, please have your parent or guardian place order our Splats for you.  

Our Splats and App are generally intended to be used and enjoyed by children, teenagers, and adults of all ages. For this reason, we employ special measures when collecting or processing information or generally avoid or limit the collection of Personal Information from Child-Users through their use of our Splats and App. For more details on our practices related to children, please see the section on Children’s Privacy below.

You do not have to share any Personal Information to access and view our Website.  

If your child is a Classroom User, additional privacy protections apply because your Educational Institution may provide us with Student Data that is subject to the Family Educational Rights and Privacy Act.  For more details on our practices related to Classroom Users, please see the section on Classroom Privacy below.  


Definitions

This Privacy Policy uses certain italicized and underlined terms that have particular meanings. Sometimes, those terms are defined when they are first used. In addition, and for ease of reference, the following terms are defined in this section:

  • App” means any Unruly Studios software application, including, but not limited to, the Unruly Studios Android and/or iPad and/or iPhone and/or web browser software application.
  • Browsing Information” means information about your use of our Services, or your device’s interaction with our Website and App. Browsing Information also includes certain of the information described in the “Information Collected Automatically” section below. This information is linked to a device identifier, such as the Internet Protocol (IP) address of your computer or device. Your Splats includes a product identifier, and through the App, your Splat transmits information to us that we use to provide our Services, assist you in troubleshooting, and improve our products, Services, Website and App. In general, Unruly Studios does not use Browsing Information to identify you, but such information may be paired with Personal Information, or with other information that together, could be used to identify you. Additionally, third-parties, such as analytics companies and advertising service providers may access, collect, store, and use Browsing Information, and they may use it to identify you.
  • Children” or “Child User” means any individual who are not of legal age to consent to the collection and processing of their personal information, specifically individuals under the age of 13.
  • Classroom User” means any student using our Services as part of their classroom learning at and provided by an Educational Institution.  
  • Educational Institution” means a school, school district, licensed childcare facility, or other licensed educational institution or program
  • “General-Audience Pages” means our Website’s homepages, webpages, and subpages that are intended for grown-ups (parents, educators, developers, etc.) to learn about and/or purchase our products and services, which include, but not limited to, our homepage at http://www.unruly-studios.com, our e-commerce page at www.unrulysplats.com, and our teachers’ page at www.unrulysplats.com/educators.
  • Personal Information” means information that directly identifies you, or that can directly identify you, such as your full name, physical address (home, mailing, shipping, and/or billing address), e-mail address, phone number, and/or credit card information. In the case of Children Users, Personal Information may also include the child’s precise geo-location, school name/address, a photo, video, or audio file that contains the child’s image or voice, and/or a persistent identifier (such as an IP Address or device ID) when such information is not used for internal support purposes.
  • Product Use Information” means information related to use of one of our products, such as Splat name, activities coded, Splat usage, or similar information. Product Use Information is linked to the product identification number of your Splat.
  • Services” means all services offered or provided by Unruly Studios, including our Website and related services we provide to you for operating our software, mobile applications, and connected products.  
  • Splats” means the programmable floor tiles offered for sale on our General-Audience Pages, including any corresponding software and mobile applications related thereto.
  • Student Data” means personally identifiable information of a student as defined by the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g).  
  • Website” means all websites operated or under control by Unruly Studios,

HOW WE PROTECT YOUR INFORMATION; SECURITY AND PASSWORDS

Unruly Studios takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information.

CHILDREN’S PRIVACY

We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, please consult this simple one-page informational guide from the kidSAFE Seal Program: http://www.kidsafeseal.com/knowaboutcoppa.html.

Please note that our Splats are aimed to be usable by children, teenagers, and adults of all ages.  However, only parents, legal guardians, or other adults are allowed to make purchases on our General-Audience Pages.

To set up your Splats, a parent or guardian should download the App and assist with account creation (if applicable).

In some instances, we may collect a limited amount of Personal Information from a parent or Child User (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a Child User (e.g., email alerts, push notifications). For these types of activities, we may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of Personal Information prior to collection or immediately after use, parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.).

Our Services, including our Splats and App, do not currently offer any features that would allow a Child User to publicly post or share their, or others, Personal Information with other users via the web or on our Website.

Some features on our App or Splats may allow the local storage of information (including Personal Information such as voice recordings), without the uploading of such information to the web or our servers.

We may collect and process Product Use Information and Browsing Information from a Child User through use of our Splats, but only for purposes of supporting our internal operations, such as to help us:

  • Maintain or analyze the functioning of our Splats;
  • Perform network communications; and
  • Authenticate users of, or personalize the content on, our Splats.

We will not use Product Use Information or Browsing Information, collected through the use of our Splats and App, for behavioral or re-targeted advertising purposes or to allow third-parties to track the activity of a Child User for such purposes.

With proper authentication, a parent or legal guardian always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by Unruly Studios. Please keep in mind that a request to delete such information may limit the child’s access to all or a portion our Services. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us at support@unruly-studios.com. We urge parents to monitor their children’s use of all digital media.

CLASSROOM PRIVACY

We will only access, collect, record, organize, use, or disclose (collectively, “process”) Student Data collected through our Services as permitted by the Educational Institution and this Privacy Policy. We will process the data consistent with all applicable laws, including, but not limited to, Family Educational Rights and Privacy Act.

We are committed to maintaining the security and confidentiality of any Student Data, which we receive from Educational Institutions for Classroom Users. Some of the precautions we take include (a) limiting employee access to Student Data to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to Student Data; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting Student Data with technical, contractual, administrative, and physical security safeguards.

If you child is a Classroom User, please contact your Educational Institution if you need to request to access, make changes to, or delete Student Data on your Classroom User from our servers.  Any request to access, make changes to or delete Student Data must be made by the Educational Institution’s designated administrator for the Classroom User. The administrator will be provided access to the Classroom User’s account in order to update, correct, or delete the information contained therein.

Parents and guardians of Classroom Users should contact their respective Educational Institution for any questions regarding account cancellation and data deletion.  

LINKS TO OTHER WEB SITES

We are not responsible for the practices employed by websites or services linked to or from our Services, including the information or content contained therein. Please remember that when you use a link to go from our Website to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third-party’s own rules and policies. We encourage our users to be to familiarize themselves with the privacy statements of all websites and apps that they visit and interact with.

CALIFORNIA PRIVACY RIGHTS

Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third-parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third-parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to support@unruly-studios.com.

VISITORS RESIDING OUTSIDE THE UNITED STATES

Unruly Studios and its Services are based in the U.S., and Unruly Studios’s offices are headquartered in the U.S. Please be aware that information you provide to Unruly Studios or that it obtains as a result of your use of our Services may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using our Services, including our Website, App, and Splats, or otherwise providing Unruly Studios with your information, you (or a parent/guardian on your behalf) consent to this collection, transfer, storage, and processing of information to and in the U.S. Unruly Studios will take commercially reasonable steps to safeguard your data in accordance with this Privacy Policy, but is not responsible for the privacy and security practices of third-parties.

UPDATES TO OUR PRIVACY POLICY

We reserve the right to update this Privacy Policy from time to time. When we do, we will post them here and revise the date at the top of this Privacy Policy. We encourage you to check this page periodically for any updates. If you continue to use our Services following the posting of an updated version of this Privacy Policy, we will treat your continued use as acceptance of the updated version.

If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian, as applicable and legally required.

CONTACTING US

If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by writing to us at support@unruly-studios.com or Privacy Manager, Unruly Studios, Inc., 2 Avenue de Lafayette, GSV Labs, Boston, MA 02111.

(603) 252-9989