Rooplay Privacy Policy
Introduction

At Rooplay, we are committed to protecting you and your family's personal information. We want Rooplay to be a safe and enjoyable environment for everyone. In this Privacy Policy, we'll explain what we do with the information we may collect from you as part of providing the Rooplay service.

The Rooplay system, across all the platforms (Android, iOS, Web and TV), is designed for children and we have prepared this Privacy Policy for you, the parents and guardians.

Rooplay is listed by the kidSAFE Seal Program and we comply with the Children's Online Privacy Protection Act (COPPA), a U.S. law, and the General Data Protection Regulation (GDPR), an EU law that governs the use and collection of information online from kids under the age of 16. To learn more about COPPA, please click here and about GDPR click here.

Part 1 - The Purpose

This Privacy Policy aims to give you information about the personal information relating to you (your personal data) which Rooplay collects about you – and what we do with it. This includes any data you provide during the sign up process, use of the Rooplay app, website, TV, or by signing up to our newsletter.

There may be specific occasions when we collect or use personal data about you and we may provide further information on what information we are gathering and why. This Privacy Policy is designed to supplement any other notices and won't override them.

Rooplay as The Controller

Rooplay is the trade name of Rooplay Media Ltd. company with offices at #103 – 1715 Cook Street, Vancouver, BC, Canada, V5Y 3J6.

A Controller is the person or entity which decides the purposes for which any personal data will be used. As Rooplay controls the Rooplay app and the data collected, Rooplay is the data controller and responsible for your personal data.

Contact Details

Full name of legal entity: Rooplay Media Ltd. as Rooplay

Email address: support@rooplay.com

Postal address: #103 – 1715 Cook Street, Vancouver, BC, Canada, V5Y 3J6

If you have any questions about this Privacy Policy, or if you would like to exercise any of the rights to which you are legally entitled (see information on this, below), please contact us using the details set out below.

We take data protection issues very seriously at Rooplay and are confident that the processes we have in place will keep your personal data safe.

Changes to the Privacy Policy

The date of the latest version of the Privacy Policy is set out above. We have recently refreshed our Privacy Policy following a change in the law on data protection, although since we have always safeguarded your data, we have not had to make any changes operationally. Our Privacy Policy will be updated from time to time – you can always come back here and check for any changes. Alternately, any material changes to the Privacy Policy will be highlighted in our newsletters if you choose to receive them, or flagged within the Rooplay app.

Third-Party Links

Our App/website may include links to third-party websites. Clicking on those links may allow third parties to collect or share data about you. When you leave our website, be sure to read the Privacy Policy of any website you go to – we don't control these third-party websites.

Part 2 - The Data We Collect About You

Personal data, or personal information, means any information about an individual which can identify that individual. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together into the following categories:

Please note that any processing of financial data is carried out by the payment provider chosen by the user e.g. ITunes, Google Play, Mobile Operator Billing etc. As such, Rooplay does not collect, store or have access to any financial data.

We also collect, use and – where necessary to provide the Rooplay service – we might share what we will call Aggregated Data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data (using the definition above) to calculate how many subscribers are using a particular feature of the Rooplay mobile app or website. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, then we treat the combined data as personal data – which will always be used in accordance with this Privacy Policy.

We do not collect any data which is not necessary to provide the Rooplay service to you.

Part 3 - How is your personal data collected?

If you would like to create a Rooplay account, then we will need some personal data from you. If you don't provide that personal data, then we may not be able to create a Rooplay account for you. We will let you know if this is the case.

We use different methods to collect data from and about you including through:

Part 4 - How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the circumstances set out below. These are called lawful bases for processing:

We do not generally rely on your consent as a legal basis for processing your personal data (except for marketing, on which see more below). We only use your data where it's necessary to provide you with the Rooplay service you have asked to receive – so we are using your personal data to enable us to perform our contractual obligations to you. It is, however, important to Rooplay that you have understood and agreed with what Rooplay is doing with your data as set out in this Privacy Policy – and so we have tweaked our account-creation process for new users. We now ask you to tick a box to confirm that you are happy for us to use your personal data as set out in this Privacy Policy. Because we take data and privacy so seriously, it will not be possible for new users to create an account with Rooplay unless they have ticked this box.

To use your Contact Data to send you newsletters, we need you to indicate your consent by ticking the relevant box during the sign up process. You can withdraw consent to receiving these communications at any time by contacting us using the contact details above – or by using the opt out link in any newsletter emails.

Purposes for which we will use your personal data

To create a Rooplay account for you, we will use your identity and contact information in performance of this contract with you.

To process and deliver your Rooplay subscription, we will use your identity, contact, transaction, and marketing and communications information, in both the performance of this contract with you, and/or as is necessary for our legitimate interests (i.e. to allow you to access the Rooplay app).

To provide the Rooplay app to you, we will use your identity, technical, usage, data, profile, and marketing and communications information, in both the performance of this contract between us, and as is necessary for our legitimate interests (i.e. to deliver the best service to you and improve the Rooplay app).

To manage our relationship with you, which might include asking you to leave a review or take a survey, we will use your identity, contact, profile, and marketing and communications information, in the performance of this contract between us, and/or as is necessary to comply with a legal obligation, and/or as is necessary for our legitimate interests (i.e. to keep our records updated and to study how customers use our products/services).

To enable you to participate in a promotion, competition or complete a survey, we will use your identity, contact, profile, usage and marketing and communications information, in the performance of a contract between us, and/or as is necessary for our legitimate interests (to study how customers use the Rooplay app).

To administer and protect the Rooplay app and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), we will use your identity, contact, profile, usage and technical information, as is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), and/or as is necessary to comply with a legal obligation.

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, we will use your technical, usage, and profile information, in the performance of a contract between us, and/or as is necessary for our legitimate interests (to keep the Rooplay app and our website updated and relevant, to develop our business and to inform our business strategy).

To make suggestions and recommendations to you about goods or services that may be of interest to you, we will use your identity, contact, technical, usage, profile, and marketing and communications information, as is necessary for our legitimate interests (to develop our products/services and grow our business).

Part 5 - Marketing and Opting Out

We want to provide you with choices regarding certain personal data uses, particularly around marketing. Where you have provided your consent, we will send you newsletters. You can tell us to stop sending you newsletters whenever you would like to, by using the contact details above, or by using the opt-out link in the newsletters we send.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Rooplay app and website may become inaccessible or not function properly.

Cookies are small text files that we place in visitors' computer browsers to store their preferences. Our cookies themselves do not contain any personal data. Our cookies may reference the personal data you provided during registration. We reference the information you provided via an encrypted identifier. Where we link these unique identifiers with your personal information, we will treat the unique identifiers as personal data as long as they are linked.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate Rooplay. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your internet browser's "help" file.

When your kids use Rooplay, we collect certain non-personal information by placing and accessing Rooplay cookies on the device they are using. Cookies do not contain any personal data, so we do not use cookies (or other covert or non-consensual methods) to acquire contact information about your kids or other users of the device.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose which is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will let you know and we will explain the legal basis which allows us to do so.

Please note that where we have to carry out processing where required by the law, we may process your personal data without your knowledge or consent.

Part 6 - Disclosures of your personal data

We may have to share your personal data with third parties set out below, for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Notice to California Residents:

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Rooplay to third parties for the third parties' direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California. To make such a request, please send an email to support@rooplay.com or write us at:

Rooplay Media Ltd.
#103 – 1715 Cook Street,
Vancouver, BC
Canada
V5Y 3J6

Please contact us if you would like further information regarding the transfer of your personal data.

Part 7 - Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Part 8 - How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.

Part 9 - Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternately, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contacting Us

If you wish to contact us about any privacy questions or concerns you may have, please do contact our team via the website.

You can also write to us at our parent company, Rooplay Media Ltd., at our postal address:

#103 – 1715 Cook Street,
Vancouver, BC
Canada
V5Y 3J6

Or email address:
support@rooplay.com