Effective date: March 1, 2020.
1. The Services. Human Tech Labs, Inc. (“HTL” or “we” or “us”), is a Delaware Public Benefit Corporation. Our Services assist you in monitoring the use of computer devices and applications under your control by children under the age of 18. The Services allow you to determine the devices and applications to be monitored for each of your Covered Account(s). The HTL Services automatically deploy the configuration and the instructions given by you and you are solely responsible for the configuration of the Services for your Covered Account(s).
2. Data Collection by HTL. The personal data about you or your Covered Accounts (hereinafter the "Data") that can be collected by us through the use of the Services or the Site are as follows:
a. Browsing. We automatically collect information when you visit the Site including your device's IP address, browser and operating system, and statistics about how you use the Site. If you connect to our Site using a mobile device we may also collect information about your device including the operating system and browser used and a unique device identification number. We may collect information from the online interactions of subscribers through other websites, such as social media sites, email accounts or other interactive sites when you identify those sites to us.
c. Third Party cookies. We allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. For instance, we allow Google Analytics to place cookies through our Site to collect aggregated information about use of our Site and Site visitors to assist us in our analysis to provide better services to you. These third parties may collect information about a consumer's online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.
d. Do-Not-Track. We do not use technology that recognizes a “do-not-track” signal from your web browser.
e. Web-forms. If you submit any webform to us, we collect the data indicated in the forms indicated in and submitted through these forms by you, including name and email address. Required data in order to send the webform is indicated. This data is used for processing your request and contacting you for further communication.
f. Registration Data. On registering for HTL Services, we will collect the following personal data: name, company/institution (if applicable to Services chosen), email address, payment information (if applicable) and at least one user name (“Registration Data”). This data is obligatory and if it is not provided, an account cannot be created.
g. Covered Account Data. On your behalf, as a principal function of the Service, we collect and process personal data relating to your Covered Accounts. Our system uses proprietary algorithms to review Covered Account(s)' online interactions through their registered devices and applications including interactions of Covered Accounts with social media sites, including posts, comments, profile information, and other communications.
h. Location information. We may collect location information of devices connected to our Site. In addition, we may request location information, for instance about the city where your child’s social media posts are being made, so that we may provide context for our analytics.
3. Use of Data Collected by HTL.
a. Registration Data. We are responsible for processing your Registration Data, which is used for communications with you and for the provision and management of your use of our Services. It is also used to measure and improve the Services and functionality and to provide customer service, send email notifications and (unless no longer in the distribution list) newsletters, or communications, in general, about the Services, products and novelties, and offers or promotions offered by us. We will use the Registration Data for these purposes and to comply with the Terms of Service applicable to your Services and other legal notices.
b. Covered Account Data. You and, if applicable, your registered Administrators and Users (collectively, your “Authorized Users”), will be sent notification emails and other reports concerning certain Covered Account Data monitored by the Services. Your Authorized Users will have access to all Covered Account Data in our possession for review and, if necessary, correction. Your Authorized Users may request access to such Covered Account Data by e-mailing our customer support at email@example.com.
d. Commercial Communications. By filling in and sending your Registration Data to us, you expressly consent to receive electronic commercial communications regarding the subject matter of the Services, and other services including alerts, notices, newsletters, offers and promotions. If you do not wish to receive such information from us, you can expressly opt out by sending a notification to firstname.lastname@example.org.
4. Children's Privacy. The Site and Services are designed to be a tool for parents and others to use to facilitate safe online interactions for children under their custody or control. Only those over the age of 18 may subscribe to our Services. This Site is not designed nor intended to be attractive to children under the age of 13. While our Services include analysis of online interactions by children, we do not knowingly collect data from children under the age of 13 without first receiving verified consent. If you are under 13 please do not submit any information to us.
5. Data Processing on Your Behalf: HTL as Data Processor.
a. User Data. Upon your registration for, and deployment of, the HTL Services, we start collecting Data from the devices and applications associated with your Covered Account(s), which may include personal data relating to you, to your Covered Accounts or to third parties, including information about your devices used by Covered Accounts, including websites and applications that your Covered Accounts use, and contacts, connections, messages and other communications, posted and received by your Covered Accounts (collectively, “User Data”). In accordance with applicable privacy law, to the extent that it applies to the Services, you are the Data Controller of this User Data and you appoint us as a Data Processor of such User Data for the purpose of providing our Services. User Data is not our property or under our control and is only monitored by us for purposes of providing the Services. Any User Data that combines personally identifiable information with non-personally identifiable information will be treated as personally identifiable information. We will take reasonably appropriate steps to maintain the accuracy any User Data we collect.
f. Data removal. We generally retain your User Data on an identifiable basis for 90 days, after which it is deleted. We may retain portions of your User Data indefinitely as needed for the purpose of providing reports to you concerning your Covered Account(s). If you wish to remove all the User Data in your HTL account, please uninstall HTL from your devices, and send an email (as set out below), with a digital copy of your ID or other identification document to prove your identity. Once your identity is confirmed, we will immediately remove all your Data from our active systems and back-ups within fifteen (15) days from confirmation of identity (except as indicated below). Each Covered Account’s User Data is controlled by the Covered Account and/or you as a Data Controller. We do not control any User Data and can not and will not provide access in response to any Covered Account’s request to review or correct errors in his/her User Data. We will forward any such requests received by us to you and you will be responsible for responding to any such requests.
g. Warranties. You, as the party responsible for User Data that we process on your behalf as Data Processor for the provision of the Services, represent and warrant to us that:
i. You comply with all applicable laws with respect to the monitoring and control of devices and applications used by you or your Covered Accounts; and
ii. You have all legally required informed consents from each and every data subject, including without limitation, each Covered Account, whose personal data are submitted to us in the course of the provision of the Services or collected and transmitted to us by the Services.
h. Indemnity. You agree to indemnify and keep us harmless from all claims, damages and losses we may suffer relating to or arising out of the processing of User Data and other third party personal data submitted to our systems during the course of your use and our provision of the Services.
6. International Transfers of Data. We use third party technological services for the provision of Services, whose providers may process Registration Data and User Data collected in the course of providing us their services indicated below, as sub-processors. You authorize us to subcontract the following services and the corresponding transfer of User Data to the entities and countries listed below:
a. Data hosting and information systems: Amazon Inc., USA;
b. Support and user support / help desk: intercom.com Inc., USA;
c. Electronic communications: Google Inc., USA;
d. Sending of commercial emails: Rocket Science Group Llc (Mail Chimp), USA
These companies are all within the EU-US Privacy Shield
7. Data Security. We have adopted technical and organizational measures to preserve and protect your Data (including User Data) that we monitor from unauthorized use or access and from being altered, lost or misused, taking into account the technological state of art, the features of the information stored and the risks to which information is exposed, including without limitation encryption of all Data at rest and in transit. Further, we engage a third party to audit our security policies, procedures and standards on an annual basis. However, due to the nature of the information and related technology, we cannot ensure or guarantee the security of your Data and expressly disclaim any such obligation. If we learn of a security breach, then we will attempt to notify you electronically as soon as reasonably possible so that you can take appropriate steps. You have a role in the security of your information and you are responsible to make sure your log-in information is kept from other people. If your log-in information is lost or stolen, you can change your email/user name or password on the Account page of the Site. If we receive instructions using your log-in information we will consider that you have authorized the instructions.
8. Analytics and other anonymous data use. For the purpose of analyzing and improving our Services, we anonymize your Data and store and process this anonymized data. This anonymized data is used only for our internal analysis to determine how our Services are used, measuring their effectiveness, and providing general customer service.
b. the collection and processing of User Data on your behalf, as indicated herein; and
Your consent to personal data collection and processing may be revoked, without retroactive effects, in accordance with applicable law.
11. Your California Privacy Rights. California residents are permitted by California law to request information about the way we share certain categories of information with others for their marketing purposes. Please email us at email@example.com to request this disclosure.
12. Links to Other Sites. We may permit others to link to this Site or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.