Woobo Speech Processing & Parent Applications Privacy Policy
Last updated: September 20, 2017

We at Woobo are committed to your privacy. As you use the Woobo Site and our Services, we want you to understand how we are using information and the ways in which we protect the your family’s privacy.This Privacy Policy discusses:

  • Information Woobo collects
  • How we use information we collect
  • Information this Privacy Policy does not cover
  • Woobo’s data security and storage practices
  • International users
  • kidSAFE Safety + COPPA Privacy Rules
  • Privacy Policy updates, and
  • How you can contact Woobo.

We encourage you to read this Privacy Policy to understand what we do with the information we collect from you and through our Site, your or your child’s use of the Woobo Toy, and the speech processing Services. We have tried to keep this policy as simple and easy-to-read as possible. If you do not understand any capitalized terms, they are defined in the glossary below. All references to “you” or “parent” in this Privacy Policy shall include parents and legal guardians, and all references to “children” or “child” shall mean children under 13 years old.

Woobo respects your family’s privacy and is committed to protecting your personal information. If you have any questions, please contact us at support@woobo.io.

Data Controller and Owner
Woobo Inc
198 River Street
Cambridge, MA 02139

Owner contact email: support@woobo.io

Information We Collect
We collect three types of data about you and your children:

  • Information that you or others provide to us;
  • Information gathered from the Voice Recordings; and
  • Technical data passively collected from all visitors to the Woobo Site.

 

Information You Provide

When using the Woobo Site and Services, and when you sign up for a Woobo Account, you may provide us with a combination of Personal Information and Non-Personal Information. Personal Information is information that you provide to us which personally identifies you, such as your name, e-mail address, phone number, password selected to use our Services, and your child’s first name or nickname, month and year of birth, and gender.

When you register on the mailing list or for our newsletter, your email address will be added to our contact list. We may also collect other information that you directly provide to us, such as when you send us an email, participate in our surveys, provide or request information from customer support, or otherwise submit information to us through our Services. Such information may include Personal Information such as your name, email, your telephone number, and your location.

Non-Personal Information cannot reasonably be used to identify you. You may provide this information when you register for a Woobo account or otherwise complete a transaction using the Woobo Site.

Voice Recordings

You and your child can interact with the Woobo Toy by pressing its ear and speaking to it. The Woobo Toy’s ear will light up with a blue LED light when it is listening to you or your child, and we may capture voice recordings during those interactions. These Voice Recordings of children under age 13 are considered Personal Information under the Children’s Online Privacy Protection Act (“COPPA”). Woobo obtains parental consent for their children’s use of the Services using parental email, which is an approved method under COPPA. By creating an Account, certifying through parental email, and using the Services, you certify that you provide such consent and are responsible for all activities under your Account.

We cannot prevent children from providing additional Personal Information when they interact with the Woobo Toy, and such information may be recorded in the Voice Recordings and documented in the transcriptions derived from Voice Recordings. We do not routinely monitor the Voice Recordings, but it is our policy to delete such Personal Information disclosed in the Voice Recordings and transcriptions if we become aware of it. Please contact us if you have reason to believe that your child has disclosed additional Personal Information in a Voice Recording, and we will be happy to delete it.

You and your child may not access or share your child’s Voice Recordings, unless you contact us via email at support@woobo.io to specifically request a copy of your child’s Voice Recordings that are still on our servers. There are no means by which you or your child may make any Personal Information publicly available through the use of our Services, other than as described in this Privacy Policy.

The Woobo Toy and Parent App also allow parents and their child to exchange personal voice messages. These voice messages are stored locally in the child’s Woobo Toy and in the Parent App for you and your child to retrieve and play back. While the voice messages may be temporarily stored in our servers during the transmittal process, Woobo does not listen to, retain after delivery, or transcribe voice messages between parents and children. There are no voice message-forwarding capabilities. Unless you or your child replay a voice message in front of others, there are no means by which you or your child may make any Personal Information publicly available through the use of our voice messaging Services.

Passively-Collected Data

Like most Web-based services, we automatically receive and record information on our server logs from your browser when you use the Woobo Site. We may use a variety of methods, including Beacons and Cookies, to collect this Passively-Collected Data. The information that we collect with these automated methods may include, for example, your IP Address, Cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the Woobo Site, and the “referring URL” (that is, the page from which you navigated to the Woobo Site). We may also collect information when you use the Parent App, such as your device model and name, and mobile network information. We may also automatically collect certain logistical information in server logs, such as information about how you use various features of the Services, and length and frequency of each use.

The following is a non-comprehensive list of the application programming interfaces the Site currently uses, each of which use Cookies:

  • SumoMe (for mailing list and newsletter);
  • MailChimp (to sync subscription data for e-mail services); and
  • Google Cloud Speech API (offline voice recognition and transcription technology).

By using the Site, you agree to comply with the respective terms of use and privacy policies of the Site’s respective API providers and all applicable laws and regulations.

We may combine Personal Information with other information we collect from your activity on the Woobo Site, information we receive from other companies or publicly available information. If we combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy.

Information We Collect About Your Child

As described above, we collect information you provide about your child, including your child’s first name or nickname, month and year of birth, and gender. We also collect Voice Recordings made during your child’s interactions with the Woobo Toy’s voice recognition features, as well as any information disclosed in those Voice Recordings, including your child’s Personal Preferences.

 

How We Use Information We Collect

Woobo uses the information we collect to establish, maintain, and enhance our relationship with you and your child.We obtain your consent for your child’s use of the Services by email, which is an approved method under COPPA. By creating an Account, certifying through email, and using the Services, you certify that you provide such consent and are responsible for all activities under your Account.

Woobo may also use the parental email and other information you provide, or that we automatically collect, through you and your child’s use of the Services, the Parent App and your Account, as follows:

  • We use your contact information to get verifiable parental consent for your child’s use of the Woobo Toy and Services. We use the information we collect when you create a Woobo Account, including your name, your child’s name, and your email address, to obtain your consent pursuant to COPPA for your child’s use of the Woobo Toy and our Services. Your consent is required for Woobo to collect and use the Personal Information we collect from your child’s Voice Recordings. Your child will not be able to interact with the Woobo Toy unless and until we receive your consent. If you do not provide consent within two (2) weeks of creating your Woobo Account, we will delete your online contact information from our records.
  • We use the information we collect to display and personalize content on the Woobo Site and to communicate with you. We use the information we collect to provide and maintain our Services; to enhance your user experience; to send you notifications, confirmations, updates, product announcements, security alerts, and administrative messages; and to otherwise facilitate your and your child’s use of, and our administration and provision of, the Services.
    When you sign-up for an Account, we use the Personal and Non-Personal Information you provide to create and maintain your Account. We also use your child’s age to tailor the Woobo Toy’s interactions with your child.
    Woobo uses Passively-Collected Data to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Woobo Site; (b) monitor your use of and participation in the Services; (c) customize our Services to you, including by providing you with recommendations; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) administer, operate and improve the Woobo Site and our other Services and systems. If we combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy.
    We also track your child’s use of the Woobo Toy to understand your child’s Personal Preferences, so that the Woobo Toy can interact with your child on topics of his or her particular interests.
  • We use Voice Recordings to improve upon our Services, and to develop new products and Services. We also use the information we collect to enhance and personalize our Services.
    We use Voice Recordings only for limited purposes, as described in this Privacy Policy: We use Voice Recordings to provide and maintain the speech processing services. We may also collect, use, store, process, convert, transcribe, analyze or review Voice Recordings (along with text and transcriptions derived from Voice Recordings) in order to develop, test or improve our voice recognition technology, develop artificial intelligence algorithms, improve the relevancy of results provided by our Services, and for other research and development purposes.
    We do not share the Voice Recordings or transcriptions thereof with our service providers or any third parties.
    The Woobo Toy does not solicit Personal Information from your child, other than their first name and recordings of their voice, as described in this Privacy Policy. The Woobo Toy will specifically not ask your child to disclose his or her birthday, home address or other such identifying information.
    Woobo never uses Voice Recordings or their content, including any Personal Information that may be captured in the Voice Recordings, to contact children or to advertise to them.
    We store Voice Recordings only as long as necessary to transcribe the content for these purposes, after which the Voice Recordings are permanently deleted from our servers. You may request deletion of your child’s Voice Recordings and associated logs and transcripts by emailing us at support@woobo.io, in response to which we will permanently delete the Voice Recordings, logs and transcripts from our servers.
  • We use the information we collect for customer service. During customer service communications, we may collect information in order to respond to your communications and requests, provide customer service, request feedback, and otherwise contact you about your use of the Services. During these customer service communications, we do not anticipate obtaining Personal Information about your child other than the information we already have (that is, your child’s first name or nickname, month and year of birth, and gender). We may monitor and analyze demographic trends relating to customer service requests.
  • We use your email address to send you information about products and Services that we believe will be of interest or useful to you. We use your email address to send you product announcements, commercial or promotional information, updates to our Terms of Use and Privacy Policy, and security alerts. You can unsubscribe from certain categories of our emails by following the instructions included therein.

Information we share with others. Your privacy is important. We are committed to protecting information that identifies you personally, where you have chosen to keep it private. While we may share Non-Personal Information, we will only share your Personal Information in the following circumstances:

  • With Woobo service providers. When Woobo hires a service provider to help operate the Woobo Site or our business (including vendors and payment processors), Woobo may give access to certain Personal Information necessary for the service provider to undertake its work, in which case we will require those service providers to honor the privacy of your Personal Information. Woobo currently uses the following third party service providers to provide its Services. In doing so, it discloses only your email address (but no other Personal Information about your or your child) to these service providers:SumoMe Mailing List or Newsletter (operated by Sumo Group, Inc.): By registering for the Woobo newsletter or joining Woobo’s mailing list, your email address will be added to the SumoMe contact list. Your email address may also be added to the mailing list when you create a Woobo Account, sign up for our Services, or make a purchase from us. Sumo Group, Inc. does not disclose your email address to any third parties.MailChimp (operated by The Rocket Science Group, LLC): Woobo sends email messages using MailChimp’s email message-sending services. The Rocket Science Group, LLC does not disclose your email address to any third parties.
  • With Woobo affiliates and partners. We may share some or all of your Personal Information with our affiliates and partners (including a parent company, subsidiaries, other companies that we control or that are under common control with us, and joint venture partners), in which case we will require those affiliates and partners to honor your Personal Information. At this time, Woobo does not have any parent company, subsidiary, other company in its control or that is under common control with it, or joint venture partner, and we do not currently share your Personal Information with any affiliates or partners.
  • In the event of merger or sale. If Woobo is involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of its business, Personal Information may be transferred with the business.
  • When legally obligated or to protect from harm. Woobo may share Personal Information (as well as Non-Personal Information) when we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (a) satisfy any requirement of law, regulation, legal process or enforceable governmental request; (b) enforce or investigate a potential violation of the Terms of Use; (c) detect, prevent or otherwise respond to fraud, security or technical concerns; or (d) protect the rights, property or safety of Woobo, its users or the public against harm.

We aggregate and anonymize data. We may use information we collect in aggregated forms. That is, we may combine information about our users, including aggregated demographic information about children, with that of others in an anonymous manner to create Aggregate Information. Aggregate Information does not contain or constitute Personal Information. In such cases, there will be no identifying information disclosed about you or your children. When we employ non-Woobo companies to anonymize or aggregate data on our behalf, we will protect your Personal Information by following our requirements for sharing Personal Information with third party service providers.

We may also share transcripts, text, or data created from the Voice Recordings that no longer contains a child’s voice, with service providers or other third parties. These transcripts, text and data will contain only Non-Personal Information (not voices and not Personal Information) that cannot be used to identify any individual.

We will not identify you or your child personally to third parties, except in accordance with this Privacy Policy. We do not sell personalized demographic data or user information.

Information this Privacy Policy Does Not Cover

This Privacy Policy does not apply to the following:

  • Information we gather through public sources.
  • Information you give to third party websites. From time to time, you may be able to follow a link to the websites of other companies or individuals from the Woobo Site. These third-party websites may collect Personal Information about users, and Woobo’s Privacy Policy does not extend to these external websites and third parties. Please refer directly to these third-party websites regarding their privacy policies.

Our Data Security and Storage Practices

We work hard to protect Woobo and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. Woobo follows industry standards and best practices to help protect your Personal Information from unauthorized access, use and disclosure. For example, we store the personal information we collect on computer systems with limited access, which are located in controlled facilities. When we transmit highly confidential information (such as a credit card number or password) over the Internet, we protect it through the use of encryption, such as the Secure Socket Layer (SSL) protocol. Woobo stores and processes Personal Information in databases hosted in the United States. We make good faith efforts to store data securely, but do not guarantee the safety of data.

Your Wi-Fi credentials are stored in an encrypted section of the Woobo Toy so that it can connect to our servers and the Parent App via the Internet. Voice messages are also stored locally on the Woobo Toy.

Please be aware that, despite our efforts, no security measures are impenetrable. Unfortunately, we cannot guarantee that any method of data transmission will protect against any interception or other type of misuse.

Your Choices Regarding the Use of Your Information

You may request access to and correction of the Personal Information we retain. Under COPPA, parents have the right to review or have deleted any Personal Information, including Voice Recordings that are still on our servers, collected from their child that Woobo holds. You may also refuse to permit further collection or use of your child’s Personal Information, including Voice Recordings. If you request that we delete Personal Information, including but not limited to Voice Recordings, they will be permanently deleted and we will no longer retain that Personal Information in any form. If you wish to review or have us delete such Personal Information or Voice Recordings, please email us at support@woobo.io.

If you wish to stop further collection or use of your child’s Personal Information, including Voice Recordings, or to delete your email address, you may choose to permanetly delete your Account by emailing us at support@woobo.io. Please note that, by permanently deleting your Account, you will disable the functionality of the Woobo Toy. To reinstate functionality at a later date, you may set up a new Account using a different email address.

You may also opt out of receiving emails from us at anytime by following the unsubscribe instructions in those emails.

International Users

The Woobo Site is intended for users in the United States. By accessing the Woobo Site or providing us data, you agree that we may use and disclose the data we collect as described herein or otherwise communicated to you, transmit it outside of your resident jurisdiction, and store it on servers in the United States. For more information, please contact us at support@woobo.io.

kidSAFE Safety + COPPA Privacy Rules

Woobo follows kidSAFE Basic Safety Rules in its gathering and use of Personal Information about children, including safety measures, procedures for handling safety issues, parental controls over their children’s accounts, and age-appropriate content and marketing.

Woobo also adheres to the kidSAFE Basic COPPA Privacy Rules, as set forth in this Privacy Policy.

Privacy Policy Updates

We occasionally update this Privacy Policy to reflect changes in our Services and customer feedback. When we post changes to this Policy, we will revise the “last updated” date at the bottom of this statement. If there are material changes to this Privacy Policy or in how Woobo uses your Personal Information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to keep informed about how Woobo is protecting your information.

How You Can Contact Us

If you have questions about this Privacy Policy or any privacy-related matter, or any concerns about your privacy, or to request access to or deletion of your or your child’s Personal Information, please contact us at support@woobo.io.

You may also write to us at:
Woobo, Inc.
Attn: Woobo Privacy
198 River Street
Cambridge, MA 02139

Glossary

Account
In order to use the Services and for your child to be able to interact with his or her Woobo toy, you must register for a Woobo Account through the Parent App. When you sign up for a Woobo Account, you may provide us with a combination of Personal Information and Non-Personal Information. By creating an Account and using the Services, you certify that you provide consent for use of the Services by you and your child, and that you are responsible for all activities and use of the Services under your Account.

Aggregate Information
Aggregate Information means information about groups or categories of Site users that does not identify and cannot reasonably be used to identify an individual user. Aggregate Information is a type of Non-Personal Information.

Application Program Interfaces (APIs)
An API is a set of routines, protocols, and tools for building software applications that define the methods of communication among various software components.

Beacons
Web Beacons are electronic files that may be used in the Site and Services, and in emails from us relating to the Site and the Services. We may use Web Beacons to monitor user activity on the Site, such as to count Site visits, understand how our Site is used, and to tell if an email has been opened.

Cookies
A Cookie is a small file containing a string of characters that is sent to your computer when you visit a website. Cookies used cannot read data from your hard drive. When you visit the website again, the Cookie allows that site to recognize your browser as a previous visitor. Cookies may store user preferences and other information. You can set your browser to refuse all Cookies or to indicate when a Cookie is being sent, or to clear out Cookie information. However, some features or Services of the Woobo Site may not function properly without Cookies.

IP Address
Every computer connected to the Internet is assigned a unique number known as an Internet protocol (IP) address. Because these numbers are usually assigned in country- and ISP-based blocks, an IP Address can often be used to identify the country and ISP from which a computer is connecting to the Internet.

Non-Personal Information
Non-Personal Information is information that does not directly identify and cannot reasonably be used to identify an individual user.

Parent App
The Parent App refers to the mobile application through which a parent can use the Services, monitor their child’s interactions with the Woobo Toy, and send voice messages to their child through the Woobo Toy. In order to use the Services and for your child to be able to interact with his or her Woobo toy, you must register for a Woobo Account through the Parent App.

Passively-Collected Data
Passively-Collected Data is data we automatically receive and record on our server logs from your browser when you use the Woobo Site. We may use a variety of methods, including Beacons and Cookies, to collect this information and recognize it as yours. The information we collect using these automated methods may include a user’s IP Address, Cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the Woobo Site, and the “referring URL” (the page from which you navigated to the Woobo Site).

Personal Information
Personal Information is information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, e-mail address, telephone number, Social Security number and financial account number. Personal Information does not include information available from public sources. When Non-Personal Information is directly or indirectly associated with Personal Information, Woobo protects this Non-Personal Information as it does Personal Information.

Personal Preferences
Woobo tracks your child’s favorite categories of information and types of interactions, as determined by how he or she interacts with and uses the Woobo Toy. For example, Woobo may learn that your child enjoys books and games relating to space and astronomy. Woobo may then use this information to customize the Woobo Toy’s future interactions with your child.

Services
The Woobo Services are defined to include the Woobo Site, its features, applications, data and products, including speech-processing services relating to your child’s interactions with the Woobo Toy.

Voice Recordings
The Voice Recordings are defined as the sound recordings made when your child presses the Woobo Toy’s ear and speaks to interact with the Woobo Toy. The Woobo Toy’s ear will light up with a blue LED light when it is listening to your child. The Woobo Toy does not otherwise listen or record unless it has been activated by pressing on its ear.

Woobo
As used in this Privacy Policy, the terms “Woobo” or “we” or “us” or “our” refers to Woobo, Inc.

Woobo Site
The term Woobo Site includes all internet-based properties owned and operated by Woobo, including but not limited to the Woobo Toy, Parent App, and web applications.

Woobo Toy
The term Woobo Toy refers to our interactive companion doll with voice speaking and recording capabilities for the purposes of engaging with and educating children.

Last updated: September 20, 2017