Mobile App Privacy Policy
Effective as of December 22nd, 2022
This Mobile App Privacy
Policy describes how Rebel Girls, Inc., d/b/a Rebel Girls Media, Inc. in
California and our subsidiaries and affiliates (collectively “Rebel Girls,”
“we”, “us” or “our”) handle personal information that we collect through our
mobile application (the “App”) and other digital properties and activities that
link to or are described in this Mobile App Privacy Policy.
Table of Contents
Personal information we collect
How
we use your personal information
How
we share your personal information
Changes
to this Privacy Policy
Children’s
Mobile App Privacy Policy
●
the email address associated
with the account used to authenticate to the App;
●
Content bookmarks the user creates to
organize specific items of content, such as favoriting content or adding
content to playlists;
●
Settings and notifications
preferences,
such as whether the user’s device may be sent push notifications, if the user’s
App is set to “Relax Mode”, and if the user's App is set to
"Auto-play";
●
Communications that we exchange,
including when you contact us with questions, feedback, or otherwise;
●
Survey data about your interests,
experience using our App, and other information that you provide when you agree
to answer our polls and questionnaires; and
● Other information that we may collect which is not specifically listed here, which we will use as described in this Mobile App Privacy Policy or as otherwise disclosed at the time of collection.
●
Device data, such as your mobile
device’s operating system type and version, manufacturer and model, screen
resolution, device type (e.g., phone, tablet), mobile device carrier,
radio/network information (e.g., WiFi, LTE, 3G), and timezone.
●
Online activity data, such as screens you
viewed, how long you spent on a screen, navigation paths between screens,
information about your activity on a screen, access times, and duration of
access.
We use your personal
information for the following purposes or as otherwise described at the time we
collect it:
●
provide, operate and improve the App and our business;
●
establish and maintain your account in the App;
●
communicate with users about the App, including by sending
announcements, updates, security alerts, and support and administrative
messages;
●
personalize the user experience in the App based on your
preferences and settings; and
●
provide support for the App, and respond to your requests,
questions and feedback.
●
comply with applicable laws, lawful requests, and legal
process, such as to respond to subpoenas or requests from government
authorities;
●
protect our, your or others’ rights, privacy, safety or
property (including by making and defending legal claims);
●
audit our internal processes for compliance with legal and
contractual requirements and internal policies;
●
enforce the terms and conditions that govern the Service;
and
●
prevent, identify, investigate and deter fraudulent,
harmful, unauthorized, unethical or illegal activity, including cyberattacks
and identity theft.
Retention. We retain personal information where we have an ongoing
legitimate business need to do so (for example, to provide you with a service
you have requested; to comply with applicable legal, tax or accounting
requirements; to establish or defend legal claims; or for fraud
prevention). Whether the retention period is sufficient to fulfill such
purposes is the primary criteria for determining the duration of the retention
period. When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize it or, if this is not
possible (for example, because your personal information has been stored in
backup archives), then we will store your personal information and isolate it
from any further processing until deletion is possible.
We may share your personal information with the
following parties and as otherwise described in this Mobile App Privacy Policy
or at the time of collection:
Service
providers. Companies and individuals that provide
services on our behalf or help us operate the App or our business (such as
information technology, customer support, surveying, marketing, and App
analytics).
Professional
advisors. Professional advisors, such as lawyers,
auditors, bankers and insurers, where necessary in the course of the
professional services that they render to us.
Authorities and others. Law enforcement, government
authorities, and private parties, as we believe in good faith to be necessary
or appropriate for the purposes described above.
Business transferees. Acquiring and other
relevant parties (and their advisors) to
business transactions (or potential transactions) involving a corporate
divestiture, merger, consolidation, acquisition, reorganization, sale or other
disposition of all or any portion of the business or assets of, or equity
interests in, Rebel Girls or our affiliates (including, in connection with a
bankruptcy or similar proceedings).
Access and
update your account. You may review and update certain account information,
preferences, and settings in the App.
Opt-out of
marketing communications. You may opt out of marketing-related emails by following
the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive
service-related and other non-marketing emails.
Close your
account.
If you wish to close your account in the App, select the “Delete account”
option in the App settings, or contact us.
Parental
choices and rights. The Children’s Mobile App Privacy
Policy below
explains Rebel Girls’ privacy and parental consent practices with respect to
information that may be collected from children through the App, and describes
your rights over such information.
●
Mailing address: 421 Elm Avenue, Larkspur, CA 94939
The Rebel Girls App
is a rich audio library of audio stories, activities, and soundscapes
celebrating the adventures and accomplishments of women from around the world
and throughout history. We encourage children to use the App with the
permission of their parents. The privacy of both children and parents is
extremely important to us.
This Children's
Mobile App Privacy Policy explains the privacy and parental consent practices
of Rebel Girls with respect to information that may be collected through the
App from children. For the purposes of
this Children’s Mobile App Privacy Policy, when we refer to a “parent”, we are
referring to the relevant child’s parent or legal guardian, and when we refer
to a “child”, we are referring to children under the age of 13 and slightly
older teenagers in the European Economic Area and the United Kingdom.
Parental consent and rights
Under the Children's
Online Privacy Protection Act ("COPPA"), a federal law in the United
States, a parent's consent is required for the online collection of personal
information from a child, as well as for the use or disclosure of that
information. We will not collect, use, or disclose such personal information
from the child if the parent does not provide such consent. We will obtain
parental consent captured through the process of subscribing and paying for the
App, unless another manner of parental consent is necessary. We encourage any
parent that believes we have collected personal information from their child
online without the parent's consent to contact
us.
Parents can request
to review if Rebel Girls is in possession of their child’s personal information
and ask us to delete or change their child's personal information, or refuse to
permit its further collection or use, by contacting
us.
To complete such
requests, parents may need to provide information to identify their child and
the information we may have about the child.
Information we collect through the App
The Rebel Girls App
is downloadable from the Apple App Store, which requires authentication with an
Apple ID. Apple IDs belonging to children must be created by a parent. Apple
provides parents with a tool to approve or reject when their child wants to
download or buy a mobile application via the Ask to Buy feature.
Approvals granted by the parent can be revoked at any time.
When the App is
downloaded and logged into, only personal information related to the parent is
captured, as described in the How we use your personal
information section of the Mobile App Privacy Policy above.
When using the App,
“persistent identifiers” about the device being used are captured, but this
does not permit the collection or transmission of an IDFA (unique mobile ad ID)
or any identifiable personal information about children, their location, or
their devices.
After parental
consent is granted when subscribing to the App, children may choose to answer
in-App polls and questionnaires to share their experience using our App,
interests, such as if they prefer dogs or cats, and other information. Answers are meant to be anonymous and not
traceable to the user.
How we use the information collected through the App
We may use the
unidentifiable information we collect about children through the App for any
purpose permitted by applicable law, including maintaining and improving the
App or other services that Rebel Girls provides.
How we share information collected through the App
We may share the
unidentifiable information we collect about children through the App with
service providers engaged by Rebel Girls to maintain the App, our Board of
Directors, funders, partners, financial supporters and sponsors of the App or
Rebel Girls for various reasons, such as understanding how to increase the
effectiveness of Rebel Girls’ services and the traffic and trends occurring on
the App.
Notwithstanding any
other provision of this Children’s Mobile App Privacy Policy to the contrary,
we reserve the right to disclose any information generated through App to
others, consistent with applicable law and as we believe to be appropriate (a)
under applicable law, (b) to our third-party service providers, (c) to comply
with legal process, (d) to respond to governmental requests, (e) to enforce our
Terms of Use, (f) to protect our operations, (g) for assistance in fraud
detection and prevention, (h) to protect the rights, privacy, safety or
property of Rebel Girls, the user, or others, (i) to
permit us to pursue available remedies or limit the damages that we may
sustain, and (j) in connection with a disposition of all or a substantial
portion of our business, assets or stock, such as a sale, merger,
consolidation, reorganization, joint venture, assignment or bankruptcy or
similar proceedings.
EEA and UK rights
Under certain
circumstances, children may have certain rights – including those set out
below:
● Access. Provide information about our processing of their
personal information and give access to their personal information.
● Correct. Update or correct inaccuracies in their personal
information.
● Delete. Delete their personal information.
● Transfer. Transfer a machine-readable copy of their personal
information.
● Restrict. Restrict the processing of their personal information.
● Object. Object to our reliance on our legitimate interests as the
basis of our processing of their personal information that impacts your
rights.
You may submit these requests by emailing them or
sending them to our postal address provided above in the How
to contact us
section.