This Privacy Policy describes what information Reason Cybersecurity Ltd. (“we,” “us,” or “our”) may collect and how we may use, store and disclose such information which relates to identifiable individuals (“personal information” and “data subject” or “you”, respectively) when you visit or use our FamilyKeeper application (the “Application”), our website at www.familykeeper.co (the “Website”) and/or any child’s mobile device the Application has been installed on. The Application and the Website shall be collectively referred to herein as the “Services”.
You are not legally required to provide us with any personal information, and may do so at your own free will. If you do not wish to provide us with your and/or your child’s personal information, or to have it processed by us or any of our service providers (as detailed below), please avoid any interaction with us, including visiting our Website and using our Application.
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal information (in general, or specifically with respect to the types of personal information you expect or elect to process of have processed via the Services, e.g., “special categories” under the GDPR), your acceptance of this Privacy Policy and our End User License Agreement available at https://www.familykeeper.co/terms-of-use/, which is incorporated herein by reference, will be deemed as your consent to the processing of your personal information for all purposes detailed in this Privacy Policy. If you wish to revoke such consent, please contact us at support@familykeeper.co.
If you are visiting or using our Services, please read this Privacy Policy carefully and make sure that you fully understand it. If you are a parent or legal guardian and wish to install the Application on a mobile device of a child under your care, we encourage you to discuss our privacy practices detailed below with your child prior to such installation, and to do so in such language and details as befits your child’s age and evolving capacities, at your discretion.
1. THE FAMILYKEEPER APPLICATION
THE APPLICATION WAS DESIGNED AS A SERVICE FOR PARENTS AND OTHER LEGAL CUSTODIANS TO SUPERVISE THE ACTIVITIES, INCLUDING INTERNET USE AND ONLINE COMMUNICATIONS, OF THE CHILDREN IN THEIR CARE, THROUGH THE USE OF THE FAMILYKEEPER CHILD APPLICATION INSTALLED ON THE MINOR’S DEVICE. YOU, AS THE USER OF THE APPLICATION, SHALL BE RESPONSIBLE TO ENSURE THAT THE CHILDREN IN YOUR CONTROL HAVE BEEN DULY NOTIFIED OF THE PURPOSES OF THIS APPLICATION AND THE PERSONAL INFORMATION THAT MAY BE COLLECTED BY THE APPLICATION. THIS APPLICATION IS NOT INTENDED TO REPLACE PARENTAL SUPERVISION AND VIGILANCE, BUT RATHER IS INTENDED TO ASSIST THE PARENTS IN GUIDING THE CHILDREN IN THEIR CARE IN THE PROPER AND RESPONSIBLE USE OF MOBILE DEVICES AND OTHER ONLINE ACTIVITIES. BY USING THE APPLICATION YOU ALSO REPRESENT AND AGREE THAT YOU WILL COMPLY WITH ALL APPLICABLE LAWS, RULES AND REGULATIONS IN CONNECTION WITH YOUR USE OF THE APPLICATION, INCLUDING (AS APPLICABLE) NOTIFYING THE CHILDREN OF THE USE OF THEIR PERSONAL INFORMATION COLLECTED BY YOU THROUGH THE APPLICATION, AS WELL AS ANY OTHER INDIVIDUAL THEIR INTERACTIONS WITH WHOM MAY BE MONITORED BY YOU THROUGH THE APPLICATION, OBTAINING THEIR CONSENT, AND USING SUCH PERSONAL INFORMATION FOR LAWFUL AND LEGITIMATE PURPOSES ONLY.
If you, as a parent or legal custodian, become aware that a child under your supervision has provided us information without your consent, or otherwise has provided us with any information that you would like to have removed, please contact us at: support@familykeeper.co
2. WHAT INFORMATION WE COLLECT
3. HOW WE COLLECT INFORMATION
We collect your information either directly from your interaction with our Services or indirectly in the following ways:
4. HOW WE USE THE COLLECTED INFORMATION
We use the information collected from you and your child’s device, for the following purposes:
5. HOW WE SHARE YOUR INFORMATION
We may share your information with:
6. HOW TO CONTROL YOUR INFORMATION
Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Information related to others and to ask you to provide further information to better understand the nature and scope of information that you request to access. Such additional information will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
7. GENERAL DATA PROTECTION REGULATION (“GDPR”)
Please note that you have the right to request from us access to and rectification or erasure of you and your child’s information we process as controllers, or to restrict or to object to processing of you and your child’s information in accordance with the provisions of the GDPR. To submit a request for exercising your rights, please contact us at support@familykeeper.co. Please note that we will process your request subject to verification of your identity. To the extent we have not addressed your concerns, you also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile).
We act as controllers and process personal data on the basis of legitimate interest – When we process you and your child’s information for the purpose of providing and optimizing our services and our internal operations, we process such personal data on the basis of our legitimate interest. We may also process you and your child’s information for compliance with applicable legal obligations.
8. U.S. CHILDREN’S PRIVACY RIGHTS
We do not knowingly collect or maintain personal information collected by the Services from children under the age of 13, except to the extent that the U.S. Children’s Online Privacy Protection Act permits us to collect and maintain such information with parental consent. If you believe your child has provided us with personal information that is covered by the U.S. Children’s Online Privacy Protection Act without your required consent, please contact us at support@familykeeper.co and we will make reasonable efforts to delete the information from our records. Our services may link to other websites or applications so be advised that we are not responsible for the privacy practices of such other websites or applications as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these websites and/or applications and we shall not be responsible for any such use We will not collect from your child more information than is reasonably necessary to provide and operate our Services.
In accordance with COPPA, you may (upon request), access the Children’s Personal Information we have collected from your child to (i) review it; (ii) have it deleted; and/or (iii) prevent further use or collection of it. To exercise your rights and receive further information, please contact us by email at support@familykeeper.co.
In compliance with the COPPA, we will request that you as a parent or the legal custodian provide your parental consent during the account setup.
9. HOW WE PROTECT YOUR INFORMATION
We use up-to-date technology to secure your Personal Information, including the use of appropriate administrative, physical and technical safeguards, to protect information in connection with your account. However, no method of transmission over the internet, or method of electronic storage, is guaranteed to be completely secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we and our service providers cannot guarantee or warrant the security of any information you transmit to us over the internet. Any such transmission is done at your own risk.
10. CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (“CCPA”) gives California residents certain rights over their Personal Information, such as (subject to certain exceptions): (a) You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months; (b) You have the right to request that we delete any of your personal information that we collected from you and retained; (c) You have the right to opt out of the sale of your personal information by a business. As stated above, however, we do not sell personal information; (d) You may exercise all of the above rights at all times and we will not unlawfully discriminate against you for exercising them. To exercise your rights and receive further information, please contact us by email at support@familykeeper.co.
11. STORAGE AND TRANSFER OF PERSONAL INFORMATION
As FamilyKeeper operates globally, your Personal Information may be stored or processed or stored in multiple locations, such as Israel, Europe or the United States. We may also store and process your Personal Information in other jurisdictions, including countries that may have less protective data protection laws than the country in which you are located (including the European Economic Area), but will do so solely for the purposes specified in this Privacy Policy and in accordance with applicable laws, customary industry standards, and such appropriate lawful and contractual terms requiring adequate data protection. Such transfers can be made to countries which are recognized as providing an adequate level of legal protection, or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, such as signing a Standard Contractual Clauses which were published and authorized by the relevant European Economic Area authorities.
12. CONTACT US
Reason Cybersecurity Ltd.
121 Menachem Begin Street, Tel-Aviv, Israel
Attn: Data Protection Officer
13. MODIFICATIONS TO THE PRIVACY POLICY
We reserve the right, at our discretion, to revise or update this Privacy Policy at any time, provided that any such changes will always take into consideration your rights under applicable law. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Website (or as otherwise indicated at the time of posting), except that express notifications will be sent to you when this is required under applicable law. Your continued use of the Services after the amendments to this Privacy Policy have entered into effect will constitute your acceptance thereof. Make sure to review our Privacy Policy periodically. If you do not accept this Privacy Policy, you must discontinue use of the Services.