Last Updated [September 1 2020]
“App” in this document refers to the FRIEDA’S FIRST WORDS application.
“the Company” in this document refers to IXI DESIGN LLC.
Thank you for choosing to be part of the ‘FRIEDA’S FIRST WORDS’ community. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and practices of these sites and cannot accept responsibility or liability for their respective privacy policies. You are free to refuse our request for your personal information, with the understanding that we may be unable to provide you with some of your desired services.
Personal Data collected for the following purposes and using the following services may include:
Access to Third-Party Accounts
Gmail account or Apple account access (users are given option to use either an account login or Gmail or Apple ID login)
Google Play & Family Link
Firebase Dynamic Links
Google Firebase Privacy and Security or visit https://firebase.google.com/support/privacy
Further Information about Personal Data
Rights for registered California Users under the age of 18
California’s “Online Eraser” law, part of California’s Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
In response to this request, the Company may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Company’s servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
In this Privacy Notice, we describe what types of information that is collected/recorded by ‘FRIEDA’S FIRST WORDS’ app, how we use it, and what rights you have in relation to it. We hope you take the time to read through it carefully and if there are any terms within this notice that you disagree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through ‘FRIEDA’S FIRST WORDS’.
By using our app and agreeing to the terms and services, you hereby consent to our Privacy Notice and agree to its terms.
Information We Collect
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using ‘FRIEDA’S FIRST WORDS’.
Unless specified otherwise, all Data requested by ‘FRIEDA’S FIRST WORDS’ is needed in order for ‘FRIEDA’S FIRST WORDS’ to provide its services and failure to provide this Data may make it impossible for ‘FRIEDA’S FIRST WORDS’to provide its services. In cases where ‘FRIEDA’S FIRST WORDS’ specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Company.
Users are responsible for any third-party Personal Data obtained, published or shared through ‘FRIEDA’S FIRST WORDS’and confirm that they have the third party’s consent to provide the Data to the Company.
Account Registration: When you register for an account with ‘FRIEDA’S FIRST WORDS’, the following information is requested:
E-mail address (18+ years of age)
Acknowledgements must be accepted:
I have read and accept the Terms and Conditions
I have read accept the Privacy Notice
I am at least 18 years of age
Sign-In: Information requested to sign-in to your Parent/Teacher/Legal Guardian ‘FRIEDA’S FIRST WORDS’ account: Gmail Account (email and password) or “Create an Account” (email and create a password).
How We Collect Information & How We Use It
The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of ‘FRIEDA’S FIRST WORDS’ (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Company.
The updated list of these parties may be requested from the Company at any time.
Mobile Device Data
Google Play may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
If you use the ‘FRIEDA’S FIRST WORDS’ app, Google Play may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of ‘FRIEDA’S FIRST WORDS’ you accessed.
The information is primarily needed to maintain the security and operation of ‘FRIEDA’S FIRST WORDS’ for troubleshooting Google Analytics/Google Firebase purposes.
We use the information we collect or receive:
To facilitate account creation and logon process
If you choose to link your account with us to a third-party account (such as your Google), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
We may use your information to request feedback and to contact you about your use of our Services.
To enable our communications with you the user.
We may use your information in order to enable our communications with you.
To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you
We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies
To protect our Services
We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
Our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
Fulfill and manage your orders
We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services. We specifically use your account information and device identifier to keep count of the number of devices on which you are using your account so that the total number of devices on which you use one account does not exceed our allowed limits and also to prevent unauthorized usage of your account.
To respond to legal requests and prevent harm
If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To deliver and facilitate delivery of services to the user
We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users
We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
Legal Basis of Processing
The Company may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
processing is necessary for compliance with a legal obligation to which the Company is subject.
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Sharing of Information
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
We do not make any warranty regarding such third-party websites that may market our app and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.
Social Media options on ‘FRIEDA’S FIRST WORDS’
‘FRIEDA’S FIRST WORDS’ gives the user the option to share the link for the application with his or her contacts if he or she decides so, and such sharing which is user initiated may include social media or other means of sharing which is left to the discretion of the user.
Third Party Privacy Policies
International Transfer of Information
We may transfer, store, and process your information in countries other than your own.
We utilize webhosting services from third party webhosts and we also use Google firebase servers for out databases to store login information and other information that has been named in this document in order to facilitate the proper functioning on the app. Their servers may be located in various centers, and countries and we do not control where these servers are located. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.
Children’s Online Privacy Protection
‘FRIEDA’S FIRST WORDS’ does not ask for personal information from anyone under the age of 18 years. Only persons 18 and over are authorized to create an account or login into the thus created account. Every one who creates an account has to state that they are 18 or older by clicking the box that the indicates that they are 18 or over.
‘FRIEDA’S FIRST WORDS’ prevents young children from accessing the payment pages or order pages or download pages or any websites from ‘FRIEDA’S FIRST WORDS’ by providing a ‘gate’ which requires them to perform a mathematical operation that is beyond the capabilities of most young children and thereby doing what is reasonably possible to ensure that the aforesaid access approval is only for anyone who is 18 and over.
GDPR Data Protection Rights
We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
‘FRIEDA’S FIRST WORDS’ does not knowingly collect any Personal Identifiable Information from children (anyone who is under the age of 18). If you think that your child provided this kind of information on ‘FRIEDA’S FIRST WORDS’, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Retention of Personal Information
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
Safety and Security of Personal Information
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that others will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk..
How to Review, Update, or Delete your Personal Information We Collect
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to email@example.com. Such requests to be entertained must be accompanied by documentation that verifies the identify of the person making such request and to ensure that the person making such requests is the same as the person whose records are in question in that particular case. This is necessary to ensure that unauthorized persons do not write in and demand changes to your account.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We request you to review this privacy notice frequently and periodically to be informed of how we are protecting your information.
Information Not Contained in this Policy
More details concerning the collection or processing of Personal Data may be requested from the Company at any time. Please see the contact information at the end of this document
Contact Us About This Notice
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org or by post to: