Last updated April 15, 2021
SINGAPORE BABYBUS PTE. LTD., having its registered address at 101A UPPER CROSS STREET #11-16 PEOPLE'S PARK CENTER SINGAPORE (058358) (hereinafter referred to as “Babybus”, “we”, or “us”) respects the privacy of its users, both parents and children (hereinafter referred to as “you” or “user”). We believe that it is important for you to make informed decisions regarding the use of our applications(“Apps”). Therefore, we have provided two copies of our privacy policy (“Privacy Policy”)–one for children, and one for grown-ups, which describes our privacy practices while you use our Apps. Please read the kid-friendly version, or scroll down for the grown-up version carefully as it will help you understand what we do with the information that we collect.
If you are a minor child or under the legal age to consent, please read the following privacy with your parent. Also, you must obtain parental consent before registering our App.
Babybus is committed to protecting the privacy of children who use our Apps. This privacy policy explains our information collection, disclosure, and parental consent practices concerning the information provided by children. Accordingly, this Children Privacy Policy aims to comply with requirements of the U.S. Children's Online Privacy Protection Act ("COPPA"), the General Data Protection Regulation and(“GDPR”) and any other applicable laws. We reserve the right to amend this Privacy Policy.
We may translate this Policy into other languages. If there is any difference between the English version and any other language version of this Agreement, then the English version will prevail to the extent of the inconsistency.
Under COPPA and GDPR, we need to obtain parental consent before collecting information from children. In order to reach this goal, we will ask the user to answer a series of knowledge-based challenge questions that would be difficult for someone other than the parent to answer.
In short, we collect information directly or passively. We won’t require a child to disclose more information than is reasonably necessary.
(a) Information we collect directly from your child(either directly from your child or from a third party)
(i) gender, nickname and birth year--we use this to personalize the child’s experience, including providing direct access to content that we find to be appropriate and relevant to make the experience more personal.
(ii) Email address--we use this information to create your account, to respond to your inquiries, and to send your newsletters regarding our products.
(iii) Voice and audio recordings--we may collect the voice and audio recordings of your child. For example, in the “Let’s Play” part, after your child has triggered the action, we will record his/her voice or audio on the devices, and then store the recordings on his/her accounts.
(iv) Transaction Records--we use this information to maintain a record of your transaction history. Please be aware that we do not collect your payment details. The payments for subscriptions are subject to the payment terms and conditions of the third party payment processor (e.g. Apple Pay) or mobile platform (e.g. iOS Platform, Android Platform, etc.) from which you make your purchase. Babybus does not control or manage the payment process.
(v) personal information that is already associated with your Integrated Service account(such as Facebook, Google or Apple)--If you decide to register through or grant access to a third party social networking or integrated services, such as Facebook, Google or Apple, we may also collect personal information that is already associated with your Integrated Service account. You may also have the option of sharing additional information with Babybus through Integrated Service.
(vi) GEO location data--we use GPS and other technologies to collect geolocation data that tells us your current location(based on your IP address). We will use this information solely to determine the user’s country to provide applicable content.
(b) Information we collect passively:
We also collect certain technical non-personal information, such as (1)IP Address; (2)Cookies; (3)Device ID and Device Information IMEI, MAC, Advertising ID) and (4) marketing analytic data (e.g. engagement data and search terms); (5) Log and usage data. We use this information to: (i)allow you to connect to the server; (ii)operate, provide, maintain, protect, manage, customize our Application and the way in which we offer them; (iii)enhance the experience with the Application; audit and track usage statistics and traffic flow, and detect fraud, security or technical issues in connection with the Application.
For more details, as well as the legal basis, please read the part 2(What information do we collect and why we use it?) of the Adult Privacy Policy.
(a) Authorized third-parties. We authorize these third-party service providers to use personal information only for to provide specific services. Current authorized independent third parties are as follows(the corresponding privacy policy has been listed:
(i) Singsound: provide speech recognition and natural language processing service (http://www.singsound.com/privacy_h5.html)
(ii) Google Pay: provide payment service
(https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en)
(iii) Apple Pay: provide payment service
https://www.apple.com/legal/applepayments/privacy-notice/
(b) Companies within the Babybus corporate group. All related group companies may only use your personal information in accordance with this privacy policy.
(c) Business Transfers. We may transfer our databases containing personal information in the event of a merger, acquisition, reorganization, bankruptcy or other similar events, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again.
(d) Law Enforcement related disclosure. We may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
We may take proper physical, technical and administrative measures based on the existing technologies to prevent the illegal copying, loss, misuse, unauthorized access, download, disclosure, and changes of your child's information security. These measures include, but are not limited to, SSL, encrypted storage, data center access control, and dedicated network channels and proxies.
Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal information, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.
At any time, parents can refuse to permit us to collect further personal information from their children and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete information may lead to the deletion of an account.
Parents can request access to and delete their child's personal information by logging on to the child's account.
Parents can also contact us to request access to, change, or delete their child's personal information by sending an email to us at support@superjojo.com.
Besides, if we ever make significant changes to the types of personal information we collect from children, or how we use it, we will notify parents to obtain parental consent or notice for those new practices.
Data protection law is jurisdiction-specific and we seek to abide by all relevant applicable laws.
For California Resident, please carefully read Part 4.1(Your rights as a California Resident) of the Adult Privacy Policy.
For EEA(European Economic Area) Resident, please carefully read Part 4.2(Your rights as an EEA resident) and Part 5(International Transfer) of the Adult Privacy Policy.
For the above-mentioned purposes in the applicable law, we will keep the necessary information collection time until the user expresses his willingness to opt-out or delete his or her personal information. Or change the information on our system without notice if we believe that such information is no longer needed.
If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing us at support@superjojo.com.
We may occasionally update this Privacy Policy. When we do, we will indicate the date that this Privacy Policy was last updated. Any changes we make will be effective immediately upon notice. 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 encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
Depending on how you interact with the application, we can collect information in the following ways:(i) automatically – Babybus collects information automatically transmitted from the device; (ii) provided by you voluntarily – meaning, if and when you choose to provide us with information such as through a registration process, newsletter registration, etc.
The table below details the information we collect, and why we use it:
Type of information | Why we use it | Legal basis |
Information you provide to us (either directly or through a third party). | ||
gender, nickname and birth year | To create the account, you as a parent will be requested to provide your child’s. We will use such information to personalize the child’s experience, including providing direct access to content that we find to be appropriate and relevant based on the child’s age, gender and nickname is to make the experience more personal. | Necessary to perform our contract with you to provide services |
Voice and audio recordings | We may collect the voice and audio recordings of your child. For example, in the “Let’s Play” part, after your child has triggered the action, we will record his/her voice or audio on the devices, and then store the recordings on his/her accounts. | with your consent |
email address | We will only use this information to: (i) respond to your inquiries directly on a one-time basis and providing you with the support you have requested. (ii) send the newsletter related to our Application and to keep you up to date regarding new products, related news, updates, etc.(you can unsubscribe it at any time by clicking the option within the body of the newsletter). | Necessary to perform our contract with you to provide services |
personal information that is already associated with your Integrated Service account | If you decide to register through or grant access to a third party social networking or integrated services, such as Facebook, Google or Apple, we may also collect personal information that is already associated with your Integrated Service account. You may also have the option of sharing additional information with Babybus through Integrated Service. | with your consent |
Transaction Records | We use this information to maintain a record of your transaction history. Please note that we do not collect your payment details. The payments for subscriptions are subject to the payment terms and conditions of the third party payment processor (e.g. Apple Pay) or mobile platform (e.g. iOS Platform, Android Platform, etc.) from which you make your purchase. Babybus does not control or manage the payment process. | Necessary to perform our contract with you to provide services |
GEO location data | we use GPS and other technologies to collect geolocation data that tells us your current location(based on your IP address). We will use this information solely to determine the user’s country to provide applicable content. | Necessary to perform our contract with you to provide services |
Information automatically generated as part of the App. | ||
We also collect certain technical non-personal information, such as: (i) IP Address (ii) Cookies (iii) Device ID and Device Information (IMEI, MAC, Advertising ID) and marketing analytics data (e.g. engagement data and search terms) (iv) Log and usage data | We use this information to: (i) allow you to connect to the server; (ii) operate, provide, maintain, protect, manage, customize our Application and the way in which we offer them; (iii) enhance the experience with the Application; (iv) audit and track usage statistics and traffic flow, and detect fraud, security or technical issues in connection with the Application. | Necessary to perform our contract with you to provide services |
We do not sell any of your or your child’s personal information with or to any independent third parties. Only where necessary will we disclose your personal information with third parties. Situations where this occur are:
(i) Authorized Disclosures – we may disclose personal information to third parties when you consent to a particular disclosure. Please note that once we share your information with another third party, that information becomes subject to the other third party’s privacy practices.
(ii) Authorized third-parties. Service providers may only use personal data for the purpose of providing certain services. The currently authorized independent third parties are as follows:
SDK name | Service Provider | Purpose | Privacy Policy |
Singsound | Singsound（先声智能） | provide speech recognition and natural language processing service | |
Google Pay | Google Inc. | Payment | https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en |
Apple Pay | Apple Inc. | Payment |
(iii) Companies within the Babybus corporate group that process your personal information in order to operate our Services. All related group companies may only use your personal information in accordance with this privacy policy.
(iv) Business Transfers – we may transfer our databases containing personal information if we sell our business or any part of it. In that event, our affiliated companies or acquiring companies will assume the rights and obligations as described in this Privacy Policy.
(v) Law Enforcement related disclosure – we may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property or of any person, suspected fraud and violations of our terms and agreements and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
Your rights will be determined by the country in which you reside. Many counties have specific laws relating to privacy. Babybus seeks to abide by all relevant national laws.
(1) Right to Know
If you request in writing, we can offer you a duplicate of your private information in a digital layout after passing our verification process. you could additionally get entry to or alternate your Personal Data through logging into your account and modifying your profile on the Parent Center.
(2) Right to Rectify
When we process your personal information, we will endeavor to take appropriate measures to ensure that your personal information is correct and up-to-date for the purposes for which it was collected. If your personal information is inaccurate or incomplete, you have the right to have your inaccurate personal information corrected immediately and you can change the information you have provided through the Parental Center.
(3) Right to Delete
You acknowledge and agree that by deleting your Babybus account you will lose access to our services, including the Babybus account, subscriptions and application-related information associated with that account, and that you will no longer have access to other services can. via the Babybus account.
(4) Other Rights
You can request any other right provided herein or governed by the applicable laws of the authorities (including but not limited to the GDPR and the CCPA) by sending an email to support@superjojo.com. Once we have received your request by email, we will immediately go through a verification process asking you to provide information to confirm that you are the user from whom we have collected information.
GDPR grants EEA residents certain privacy rights regarding the personal information we collect. You have the following rights in addition to your rights to know, correct, update, or request the deletion of your personal information.
(1) Right to Object
When our processing of your personal information is based on legitimate interests according to Article 6(1)(f) of the GDPR, you have the right to object to our processing. If you raise objections, we will only process your personal information if there are compelling legitimate reasons of processing as described in Article 21 of the GDPR; In particular, if the information are required for the establishment, exercise, or defense of legal claims. You also have the right to lodge a complaint with a supervisory authority.
(2) Right to Restrict Processing
You have the right to restrict the processing of your personal information under the conditions set out in Article 18 of the GDPR.
(3) Right to Personal Data Portability
You have the right to receive your personal information in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR.
The California Consumer Privacy Act (“CCPA”) grants California residents certain privacy rights regarding the personal information we collect. You have the following rights in addition to your rights to know, correct, update, or request the deletion of your personal information.
(1) Right to Know About Personal Information Collected, Disclosed, or Sold
You have the right to access your personal data that we hold about you, (i) information whether your personal data is collected, used, disclosed, or sold, (ii) categories of your personal data which has been collected in the preceding 12 months, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or selling your personal data (if any), (v) disclosure of sale of your personal data (if any): i.e. the categories of your personal data which has been disclosed or sold (if any) to third-parties in the preceding 12 months, the categories of third parties to whom your personal data was disclosed or sold (if any), statement regarding whether we have actual knowledge that we sell your personal data if you are under 16 years of age; and you have the right to request that we provide a duplicate of your personal data being processed, provided that a verifiable request is sent in the form of an email to support@superjojo.com. You can also exercise the right to access your personal data through the Parent Center. In our reasonable and unilateral judgment, if your verifiable request interferes with or interferes with the rights or freedoms of other users, or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the resulting administrative costs) or refuse to respond to the request.
(2) Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
(3) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
With regard to the data protection rights granted by the CCPA, you have the right not to be discriminated against by us, which means that we will not provide any economic incentives, price or performance differences for you to exercise your rights under the CCPA. unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.
(4) Right to Authorize an Agent to Make a Request on Your Behalf
You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. If you are using an authorized agent to send any of the above requests, you may need to provide signed permission to authorize your agent to verify your own identity and your agent's official permission to send that request. In the case of failure to provide any of the requested materials, to protect the user’s data and data security, we are entitled to denying such a request.
You acknowledge and agree that your data is processed on our servers or our processors’ servers which are not located in your country of residence and which our support, engineering and/or our affiliates around the world can access. The servers may locate in a country without an adequate level of protection pursuant to Article 45 of GDPR and appropriate safeguards pursuant to Article 46 of GDPR. This means, under certain applicable laws（such as GDPR）, we can only transfer your data internationally on the legal basis of your consent.
However, we will only keep your data for as long as your account is active or is only necessary to provide your services unless they are deleted in accordance with your request or in accordance with legal requirements and matter where the servers are located, we will make great efforts to take the appropriate measures (including but not limited to signing a data process agreement with our service provider) to guarantee your rights in conformity with this Privacy Policy.
For the above-mentioned purposes in the applicable law, we will keep the necessary information collection time until the user expresses his willingness to opt-out or delete his or her personal information. Or change the information on our system without notice if we believe that such information is no longer needed.
We may update this privacy policy from time to time. When we do this, we will include the date this Privacy Policy was last updated. Any changes we make will take effect immediately upon notice. 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 encourage you to review this privacy notice frequently to be informed about how we are protecting your information.
If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing us at support@superjojo.com.