Last updated: August 16, 2022
Effective date: August 19, 2022
BABYBUS Co. Ltd., and its affiliated companies (collectively referred to as “Babybus”, “we”, or “us”) respect 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 our privacy policy (“Privacy Policy”)which describes our privacy practices while you use our Apps. Please read it 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 playing our Apps.
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 requirement of the U.S. Children's Online Privacy Protection Act ("COPPA"), the General Data Information 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, (subject to applicable laws and regulations) the English version will prevail to the extent of the inconsistency.
In short, we collect information directly or passively and we aim to minimize how much personal information we collect from users.
(1) Information we collect directly from you
Currently, we do not collect any information directly from you, such as biological information, location information, contact information, etc. If we change the type of information collected, we will mention it in our privacy policy and send a notification to users.
(2) Information we collect passively:
We also collect certain information automatically through your use of our Apps. This type of data does not identify you personally but may uniquely identify the device you are using. Under some legislation, these data might be considered as personal information:
(1)Internet Protocol (IP) address; (2) Broad geographic location (e.g. country or city-level location) based on your IP address; (3) Log and usage data, such as game progress, game time, achievements, and error and crash reports; (4) Device information, including the device type, device model, device maker, device operating system and its language or other technical data. We use these information to: (i) allow you to connect to the server; (ii) operate, provide, maintain, protect, manage, customize our Apps and the way in which we offer them; (iii) enhance the experience with our Apps, detect fraud, security or technical issues in connection with the Apps.
We do not sell any of your personal information with or to any independent third parties. Situations where we will disclose or allow a third party to collect your information are:
(a) Our affiliated companies
We may share information with companies within the Babybus group, which includes our subsidiaries (i.e., any organization that we own or control) that were registered globally (e.g.Babybus (Fujian) Network Technology Co., Ltd., Japan Babybus Co., Ltd., Singapore Babybus Pte. Ltd.). These companies will use your personal information in the same way as we do under this Policy.
We see this processing as necessary for the purposes of the legitimate interests pursued by us. However, your consent to such processing will be requested as appropriate under applicable law.
(b) Authorized third parties
Currently, we do not authorize any independent third party to collect or process personal information for us.
(c) Business transfers
We may transfer our information bases 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, information 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 would 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 the personal information we have collected in connection with that account. Please keep in mind that a request to delete personal information may lead to the deletion of an account.
Parents can request access to and delete their children's personal information by logging into the children'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 privacy@babybus.com.
Data protection law is jurisdiction-specific and we seek to abide by all relevant applicable laws.
(1) For EEA(European Economic Area) Residents, please read Part 5.2(Your rights as an EEA resident) , Part 5.5 (EU&UK representative)
and Part 6(International Transfer) of the Privacy Policy carefully.
(2) For California Resident, please read Part 5.3(Your rights as a California Resident) of the Privacy Policy carefully.
(3) For other residents, please read Part 5.1 (General rights), and other parts if applicable carefully.
Your rights is determined by the country in which you reside. Many counties have specific laws relating to privacy. We seek to abide by all relevant national laws.
(1) Right to Know
If you request in writing via email, we will provide you a copy of your personal information in an electronic format after passing our verification process.
(2) Right to Rectify
If we process your personal information, we shall endeavor to ensure by implementing suitable measures that your personal information is accurate 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 obtain rectification of your inaccurate personal information without undue delay and you can modify the information you provided via email.
(3) Right to Delete
You have the right to delete your personal information by contacting us at privacy@babybus.com. You acknowledge and agree that as a result of deleting your Babybus account, you will lose access to our services, including the Babybus account, subscriptions and App-related information linked to such account and lose the possibility to access other services through the Babybus account.
(4) Other Rights
You may request any other rights as provided herein or regulated in the applicable laws from authorities (including but not limited to the GDPR and the CCPA) by sending an email at privacy@babybus.com. Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information from.
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 object, we will no longer process your personal information unless there are compelling and prevailing legitimate grounds for processing as described in Article 21 of the GDPR; in particular, if the information is necessary for the establishment, exercise or defense of legal claims. You also have the right to complain to 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 Information 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 information 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 information that we hold about you, i.e. the right to require free of charge, (i) information regarding whether your personal information is collected, used, disclosed, or sold, (ii) categories of your personal information that has been collected in the preceding 12 months, (iii) categories of sources from which your personal information is collected, (iv) business or commercial collecting or selling your personal information (if any), (v) disclosure of sale of your personal information (if any): i.e. the categories of your personal information 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 information was disclosed or sold (if any), statement regarding whether we have actual knowledge that we sell your personal information if you are under 16 years of age; and you have the right to request us to provide a duplicate of your personal information undergoing processing, subject to submitting a verifiable request in the form of email to privacy@babybus.com.
(2) Right to Opt-Out of the Sale of Personal Information (if any)
You have the right to opt-out of the sale of your personal information (if any) and request us to make a statement regarding whether or not we have sold your personal information 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
You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal information. 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. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, in order to protect the user’s information and information security, we are entitled to denying such request.
5.4. EU&UK representative
For EU or UK data subjects, you have the right to make inquiries to us or complaints to the supervisory authority (“SA”) regarding our data processing activities. For questions, or to exercise your rights as an EU or UK data subject, please contact our EU or UK representative.
UK representative
Rickert Services Ltd UK
-BabyBus Co., Ltd. -
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
art-27-rep-babybus@rickert-services.uk
EU representative
Rickert Rechtsanwaltsgesellschaft mbH
- BabyBus Co., Ltd. -
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-babybus@rickert.law
When you reside in Japan, the Act on Protection of Personal Information(“APPI”) of Japan applies to the collection and processing of your personal data by us.
As specified in this Privacy Policy, our servers and main business operations are located globally. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on servers in the manner described in this Privacy Policy.
If you have any questions about this Policy, you may contact us at privacy@babybus.com .
We store information on the server closest to the end user's location to provide a secure and fast service The locations of servers for the game services include:
(1) the United States, in which the CCPA and the COPPA shall govern our services conducted as stipulated in this Privacy Policy;
(2) Hong Kong; and
(3) Germany （where EEA users' data is stored), in which the GDPR shall govern our services conducted as stipulated in this Privacy Policy.
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.We use European Commission-approved contract clauses or other appropriate safeguards that are defined in Art. 46 GDPR to protect your personal information.
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 appropriate measures to guarantee your rights in conformity with this Privacy Policy.
We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed. Upon the expiration of such period, your personal data will be deleted or anonymized, as requested by applicable law.
If you have any questions about this Privacy Policy or have any requests for resolving issues regarding your personal information while using our services, please contact us as soon as possible by emailing us at privacy@babybus.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 protect your information.