LAST UPDATED: 14/01/2020
Privacy Policy
Poio! AS (“Poio”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and through HTML-formatted email messages that we send that link to this Privacy Policy (collectively, including the Websites and Apps, the “Services”). By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.
PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF INFORMATION FROM U.S. CHILDREN UNDER AGE 13 AND CHILDREN OUTSIDE THE U.S. UNDER AGE 16
If you are a California resident, please see “Additional Information for California Residents,” below, for more information about our practices and your rights.
WHAT IS POIO?
Poio provides a game-based learning tool that can be played through our App. The purpose of the game is to teach children to read based on a gamified learn-to-read program called The Poio Method. The game consists of several levels. In order to complete a level, the player must eat all the vowels or collect words for the story book. The main goal is to complete the book.
PERSONAL INFORMATION
“Personal Information” is information that identifies an individual or relates to an identifiable person, including:
The player's first name
The parent's or guardian's e-mail address (required)
The player's year of birth
Data needed to remember and track the player's progression in the game (required).
Please note that if you are accessing our services via the Poio website, we will also collect the following personal information:
Location data
Metadata (e.g. IP-address, device, screen size on login device, operation system, web browser used).
We need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.
If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Personal Information We Collect
As described in more detail below, we may collect, use and disclose Personal Information from adult accountholders. An “adult accountholder” is a U.S. user who is age 13 or older or a user from outside the U.S. who is age 16 or older.
If Poio determine that it has inadvertently gathered Personal Information from users under the age of 13 (for U.S. users) or 16 (for non-U.S. users), Poio wil promptly delete any and all such Personal Information from Poio's records.
How We Collect Personal Information
We and our service providers collect Personal Information from adult accountholders in the following ways:
Through the Services: We collect Personal Information through the Services, e.g., when you create an account.
Offline: We collect Personal Information from you offline, such as when you contact customer service.
How We Use Personal Information
We and our service providers use Personal Information for our legitimate business purposes, including the following:
Providing the functionality of the Services and fulfilling your requests.
To provide the Services’ functionality to you, such as arranging access to your account.
To respond to your inquiries and fulfill your requests.
To complete your transactions.
To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with marketing material that we believe may be of interest to you.
We engage in this activity with your consent or where we have a legitimate interest.
Allowing you to participate in sweepstakes, contests and similar promotions.
We may offer you the opportunity to participate in sweepstakes, contests and similar promotions. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information.
We engage in these activities to manage our contractual relationship with you.
Anonymizing and/or aggregating Personal Information.
We may anonymize and/or aggregate Personal Information so that it will no longer be considered Personal Information. We do so to generate other information for our use, which we may use and disclose for any purpose.
Accomplishing our business purposes.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
Monitor the effectiveness of advertisements (Advertising ID)
Poio produces its own marketing material and buys advertisement slots on advertisement platforms. Such platforms tracks who engages with and clicks on these adds, and whether the advertisement resulted in the consumer installing the Apps on their device. We do this for the purpose of generating advertisement statistics for Poio. Poio utilizes "Appsflyer" in order to enable Poio to identify such advertisement and installation activities.
In particular for iOS users, Poio does not share any personally identifiable information/personal data or device information with any third parties generated by the Poio app. For the protection of child users, the Poio app does not include third-party analytics or third party-advertising. This includes any device, network, or other information that could be used directly or combined with other information to identify users and their devices.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
How Personal Information May Be Disclosed
The Personal Information of adult accountholders may be disclosed:
To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services.
To third-party sponsors of sweepstakes, contests and similar promotions.
By you, on profile pages and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
Other Uses and Disclosures
We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
– This can include laws outside your country of residence.
To cooperate with public and government authorities.
– To respond to a request or to provide information we believe is important.
– These can include authorities outside your country of residence.
To cooperate with law enforcement.
– For example, when we respond to law enforcement requests and orders or provide information we believe is important.
For other legal reasons.
– To enforce our terms and conditions.
– To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In connection with a sale or business transaction.
We have a legitimate interest in using, disclosing, or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
OTHER INFORMATION
Other Information We Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
Browser and device information
App usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you
Aggregated information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
How We Collect Other Information
We and our third party service providers collect Other Information in a variety of ways, including:
Through our website: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
Through your use of the App: When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App.
Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information only to support the internal operations of the Services, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.
If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including adult accountholders that may receive emails from us), measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.
From you: Information such as communications preference may be collected from adult accountholders when they voluntarily provide it.
By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.
How We Use and Disclose Other Information
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
OUR COLLECTION OF PERSONAL INFORMATION FROM CHILDREN
We do not knowingly seek or collect Personal Information from users under the age of 13 (for U.S. users) or 16 (for non-U.S. users). If we determine we have inadvertently gathered Personal Information from users under the age of 13 (for U.S. users) or 16 (for non-U.S. users), we will promptly delete any and all such Personal Information from our records.
We and our service providers collect information that is reasonably necessary to support the internal operations of the Poio Service, as described below.
The Children’s Online Privacy Protection Act of 1998 (U.S.), the Family Educational Rights and Privacy Act (U.S.), the General Data Protection Regulation (E.U.) and other data privacy laws have been established to protect the privacy of minors. We take our compliance obligations under such laws, and the privacy of our users generally, very seriously.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident or household and includes the categories listed below. This section does not expand upon our practices with respect to our collection of Personal Information from children, as described above in section entitled “Our Collection of Personal Information from Children.” This section may, however, give children who are residents of California (and their parents or guardians) additional rights.
The following sections provide details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months:
Categories of Personal Information Collected.
We collected the following categories of Personal Information:
A. Identifiers, such as IP address, parent/guardian email address and online identifiers;
B. Personal information, as defined in the California customer records law, such as parent/guardian contact information;
C. The players data of birth;
D. Internet or website activity information, such as browser and device information, information collected through cookies, pixel tags and other technologies, demographic information and other information provided by you and aggregated information; and
E. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Sources of Personal Information. We may collect this Personal Information directly from California residents themselves, as well as from third-party sources, public databases, and joint marketing partners.
Purposes. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, providing our products and services; developing, improving, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research and data analysis; undertaking quality assurance measures; conducting risk and security control and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.
Disclosures of Personal Information.
The Personal Information of adult accountholders may be disclosed:
To our third party service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, payment processing and other services.
Other Uses and Disclosures
We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
– This can include laws outside your country of residence.To cooperate with public and government authorities.
– To respond to a request or to provide information we believe is important.
– These can include authorities outside your country of residence.To cooperate with law enforcement.
– For example, when we respond to law enforcement requests and orders or provide information we believe is important.For other legal reasons.
– To enforce our terms and conditions.
– To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.In connection with a sale or business transaction.
– We have a legitimate interest in using, disclosing, or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
Sales of Personal Information. We have not sold Personal Information. For purposes of this CCPA Notice, “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
If you are a California consumer, you have the following rights:
(1) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
o The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
o The specific pieces of Personal Information we collected about you;
o The business or commercial purpose for collecting Personal Information about you; and
o The categories of Personal Information about you that we disclosed and the categories of third parties to whom we disclosed such Personal Information.
(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us at privacy@poio.com. In some instances, we may decline to honor your request where, for example, we are unable to verify your request or where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.
(3) Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
THIRD PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.
SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give adult accountholders choices regarding our use and disclosure of their Personal Information for marketing purposes. We will explicitly ask for your consent prior to sending any marketing materials. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email or from within the app.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or suppress your Personal Information
If you are an adult accountholder and you would like to request to review, correct, update, suppress or delete Personal Information, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
RETENTION PERIOD
We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide our Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
As a general rule, your data is stored for as long as you continue to Play Poio. After 365 days of inactivity, all data linked to your account is automatically deleted from our serves, unless further retention is required in accordance with items (ii) and (iii) above. If you do not uninstall Poio from your devices, you will keep a local copy of your data that will be restored if you begin using Poio again. If you uninstall Poio after 365 days of inactivity, all your data will be deleted without the possibility of recovery.
CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).
SENSITIVE INFORMATION
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
UPDATES TO THIS PRIVACY POLICY
We may change this Privacy Policy. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.
CONTACTING US
If you have any questions about this Privacy Policy, please contact us at:
privacy@poio.com; or
Fridtjof Nansens plass 7, 0160 Oslo
Because email communications are not always secure, please do not include sensitive information in your emails to us.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you may lodge a complaint with a supervisory authority competent for your country or region.