Effective Date: March __, 2018

 

COOLPAD DYNO WATCH PRIVACY POLICY

 

Welcome to the Coolpad Dyno family!

 

This Coolpad Dyno Watch Privacy Policy (the “Privacy Policy”), which is a material part of the End User Agreement, describes how we, Coolpad Technologies, Inc., a Delaware Corporation (“Coolpad”) collect, use, and protect your data, with respect to our Coolpad Dyno watch (the “Watch”), mobile application (the “Parent Application”), website (the “Website”), and related services (altogether the “Services”). As described further herein, Coolpad allows you to access, review, modify, or delete your data, in addition to revoking your consent to allow us to collect personal information.

 

You understand and agree that our Services are based on technical support from your mobile carrier. Our Services are provided according to your agreements with your carrier. You understand and agree that we are not responsible for the actions of your carrier. You agree to carefully review the terms and conditions of your carrier, as a condition for your use of the Services.

Please read this policy in its entirety, including our Children’s Privacy Policy section, before using the Services.   All references to “children” or “child” in this Privacy Policy shall mean children under 13 years of age, and all references to the term “parent” shall include legal guardians.  The Children’s Privacy Policy will control over any conflicting provisions in the larger Privacy Policy.

 

DATA COLLECTED FROM PARENTS AND ADULTS

 

The Parent Application is used in conjunction with the Watch, so that parents may call, monitor and locate their child. The Services are provided to facilitate and support that purpose. Coolpad utilizes several methods, including email authorization and monetary transactions, to verify that a parent purchases and sets up the Dyno watch and related Services.

 

Coolpad does not keep your personal information longer than reasonably necessary to provide the Services. We will not require you to disclose more information than is reasonably necessary for us to provide the Services.

 

INFORMATION WE COLLECT

 

Information Parents Provide Directly

 

  • Registration Data. When a parent installs the Parent Application, we will ask the parent to log in with his or her Facebook or Gmail account. We may also collect parent’s name, email address and phone number as part of the registration process.

 

  • Child Profile Data. When a profile is created for a child, parents may be asked to provide parent name, child name, date of birth, and phone number for their child. Parents may also optionally submit an image to use with the child’s profile.

 

  • If a parent contacts us directly, we may receive additional data about the parent. For example, when a parent contacts our customer service team, we may receive the parent’s name, email, mobile phone number, the contents of messages or attachments, and other data you choose to provide.

 

  • Voice Messages. The Parent Application allows parents to exchange voice messages with their children. Recent voice messages sent by the child are stored locally on the Watch for parents to retrieve and play back. Over time, the oldest messages on the Watch will be deleted as new messages are received. Coolpad does not listen to or transcribe voice messages sent to and from the Watch. There are no voice message forwarding capabilities in either the Watch or the Parent
  • Contact Data. Parents may choose to permit the Parent Application to access contact data on the parent’s device.  If they do so, we may access and store names and contact information.  Parents can also add contacts to their child’s Dyno Watch by entering this information into the Parent Application. This contact information will not be used except as described in this Privacy Policy.

 

Information Collected Automatically When A Parent Uses the Services

 

  • Device Data. When a parent uses the Coolpad Services, we will receive some data about their device name, operating system and its version number, geographic region and language, settings, device identification numbers (IMEI, ESN, MEID, and SN), in addition to the service provider’s network ID, MAC address, IP address, and the settings of the device accessing such services. Coolpad collects this data to inform you about system and application updates.

 

  • Location Information. When a parent opens and uses the Parent Application on their device, Coolpad will receive precise location information. This data allows us to know where you and your children are and to help approximate distance apart.  We may also collect your precise location even when the Parent Application is only running in the background. If you label certain locations such as “home” or “school,” we receive that data, too.
  • Task Data. Coolpad will receive data about the to-do events that parents create for their child using the Services, such as the date, time, or the event details.

 

  • Parent Application Use Data. When parents use the Parent Application, we may automatically receive information regarding how you have used our Parent Application, including your choices, the contents that you viewed, pages that you may have visited, individuals who you have interacted with, and other information that you may have accessed.

 

  • User Feedback. If the Watch or Parent Application experiences any errors, parents can choose to send the error information to Coolpad so that Coolpad or a designated service vendor can provide them with troubleshooting services. Coolpad may collect relevant information about the issue, such as the wearable device model, application name and version, device identification number, and error logs.

 

  • Statistics and Analysis Data. Coolpad may collect certain data for statistics and analysis, including your wearable device name, device version, device identification numbers (IMEI, ESN, MEID, and SN), the coarse geographic location information of your device (such as the ID of the area where your device is located), your service provider’s network ID (PLMN), how you use the Parent Application, and the IP address you use to access the Internet.

Information Collected by the Website

 

The Website is a general audience website meant to be accessed and used by adults.  The Website is intended to offer parents a way to learn more about Coolpad’s products and the Services.  The Website is not intended for children, does not market to children, and does not knowingly collect personal information from children.

 

  • Technical Information. When you access the Website, we may receive information such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Website, your IP address or device ID, the operating system of your computer or mobile device, and other similar technical information

 

  • Browsing Information. When you use a web browser to access the Website, we may receive information through the use of cookies (small snippets of code), beacons (code or pixels stored in your browser), and other similar technologies, such as browser fingerprinting (tracking the unique signatures of browsers of different devices). This information may include statistics and analytics about your use of the Website, including details about how and where the Website was accessed, how often a user visits the Website, the date and time of user visits, and actions taken on the Website.

 

  • Advertising Partner Information. We may partner with third party advertisers, ad server companies, and ad networks (“third party advertising companies”) that use cookies, beacons, tags, tracking pixels and scripts and other tracking technologies in order to collect data such as IP address, device ID, and other information about your computer or device, as well as Internet and online usage information and information about certain activities on the Services. These third party advertising companies may use such information and information about your visits to the Service and other websites and services in order to provide advertisements about goods and services of interest to you. If you do not wish to receive such advertisements, please visit http://www.networkadvertising.org/choices.

 

 

 

DATA COLLECTED FROM CHILDREN

Coolpad takes the privacy of its users, especially child users, seriously. As such, Coolpad has undertaken efforts to comply with the Children’s Online Privacy Protection Act. This includes taking steps to ensure that a parent or legal guardian purchases and sets up the Dyno watch and related Services on behalf of their children and consents to the data collection practices set forth below.  To learn more about COPPA, you may consult this simple one-page informational guide from the kidSAFE Seal Program – www.kidsafeseal.com/knowaboutcoppa.html.

The Watch is the only area of the Services intended to be used by children.  The Parent Application and Website are designed for parents and are not intended to be used by children.

Coolpad does not keep children’s personal information longer than reasonably necessary to provide the Services. We will not require a child to disclose more information than is reasonably necessary for us to provide the Services.

INFORMATION WE COLLECT

Information Children Could Provide Directly

  • Phone Calls. Child users of the Watch may initiate a call with others using the Watch.  Parents may check call history on the companion application to be informed of such calls. On the watch itself, the parent can also check on Recent Calls to see whom their children have made a call to.
  • Text Messages. Child users of the Dyno watch may share with other users pre-written text messages. In all such cases, the text messages are pre-written by the parent using the Parent Application. It is advised that the parent exercise reasonable caution in pre-writing such messages.
  • Voice Messages. Child users of the Watch may send voice messages to other users. These messages are audio files that include recordings of the child’s voice.  Recent voice messages are stored locally on the Watch for you and your child to retrieve and play back.  Coolpad does not listen to, retain after delivery, or transcribe voice messages sent from the Watch. There are no voice message-forwarding capabilities in either the Watch or the Parent Application.
  • Contact Information and Friending. Child users of the Watch can add other Dyno Watch users as friends. When a child uses the Watch to add another friend using the built-in friending features (which requires close proximity between the two Watches), each child’s name and phone number will be shared with the other child user.  If the parent has uploaded an image of their child to the child profile, each child user will also share this image with the other user as part of the friending process. A parent may delete any friends that their child has added using the Parent Application.

Information Collected Automatically When A Child Uses the Watch

 

  • Location Information. When a child uses the Watch, we will receive precise location information about that child. We may also collect a child’s precise location while the Watch is powered on, even when a child is not actively using the Watch. This information is only visible using the Parent Application, and no location information can be shared between child users.

 

  • Watch Use Data. When a child uses the Watch, we will automatically receive information regarding how the child has used our devices, including his/her choices, the features that he/she has used, and individuals with whom he/she has interacted.

 

  • Statistics and Analysis Data. Coolpad may collect certain data for statistics and analysis, including the Watch’s device name, device version, device identification numbers (IMEI, ESN, MEID, and SN), the coarse geographic location information of the Watch (such as the ID of the area where your device is located), the service provider’s network ID (PLMN), and the IP address used to access the Internet.

 

 

HOW WE USE INFORMATION

 

We use or may use information we collect for a variety of purposes, including:

 

  • Determining Location. Precise location information about parents and children is used to inform parents where their children are and to help approximate distance apart.  Parents can review this information using the Parent Application.  Location information is also used to determine if a child leaves or enters zones established by parents in the Parent Application.

 

  • Operating and Improving the Services. We use information collected from parents and children to operate and improve the Services, allowing us to provide a better user experience, customize content, improve our products, improve the security of Coolpad’s networks and Services, and facilitate and perform additional functions related to the Services.

 

  • Sending Marketing Communications. Coolpad may use parent’s contact information, including parent’s full name and parent’s email address, to suggest and offer additional Services. Parents may request that Coolpad not do this, by contacting us as provided below, and by unsubscribing from any Coolpad mailing or email list.

 

 

HOW WE SHARE INFORMATION

 

Coolpad does not use personal information for third-party marketing purposes, and Coolpad is not in the business of selling your personal information. Coolpad may disclose your personal data as follows:

 

  • To Third-Party Vendors. Coolpad may share parent’s and children’s personal information with third-party vendors dedicated to facilitating the Services on behalf of Coolpad.  Coolpad has obtained contractual assurances from these vendors that they would not use this personal information other than to facilitate the Services, in a manner consistent with this Privacy Policy and the End User Agreement, and that the vendors would respect the privacy of users. Neither Coolpad nor its vendors will use parent’s or children’s personal information for third-party marketing purposes.

 

  • Business Transfers. Parent’s and children’s information may also be disclosed to purchasers, creditors, or other interested parties where Coolpad is purchased, reorganized, or otherwise involved in a merger, insolvency, or bankruptcy proceedings. Should that happen, Coolpad will request that consent be sought prior to any such disclosure.

 

  • Legal Disclosures. Parent’s and children’s personal information may be disclosed to protect the safety of a child, or to help protect the security and integrity of the Services.  Coolpad may disclose your personal information when required by the law, legal proceedings, litigation, or public/governmental authorities.

 

  • Carrier Statistics. Coolpad may share some aggregate statistics, that do not identify any individual user, with your carrier to help troubleshoot and improve the Services.

 

ACCESSING AND UPDATING INFORMATION

 

Parents will be responsible for the accuracy of the personal data submitted through the Parent Application. Although Coolpad will make a commercially reasonable effort to keep your personal information accurate, parents will ultimately be responsible for the accuracy of any data submitted.

 

  • Access, Modification, and Deletion. Parents may access, modify, and delete personal information regarding them or their child by contacting us directly as provided below.

 

  • Revoking Consent. Parents may also contact us to revoke their consent to the further collection and use of personal information from them or their child.  If a parent revokes consent to the collection of personal information that is necessary for the provision of Services to them or their child, such Services may no longer be available.

 

  • Third-Party Vendors. To the extent that any third-party vendor is hosting personal information on behalf of Coolpad, when a parent requests that personal information be modified or deleted, Coolpad will so dictate to its vendors.

 

Please note that if information has already been destroyed because it is no longer reasonably necessary to fulfill the Service, the information will no longer be accessible.

 

 

ADDITIONAL PROVISIONS

 

HOW WE PROTECT YOUR INFORMATION; SECURITY AND PASSWORDS

 

Coolpad takes reasonable preventive measures, including but not limited to, technical, physical and administrative safeguards to protect personal information from unauthorized access, disclosure, use, change, damage, or loss.  Although we take the utmost care to protect personal information, please note that no application, websites, computer system, internet or network transfer, terminal storage and transfer, or wireless connection are absolutely secure.

 

CALIFORNIA SHINE-THE-LIGHT

 

Except for vendors which it uses to facilitate and fulfill the Services, Coolpad does not offer or provide personal information it collects through the Services to third parties for marketing purposes.  For further questions, please contact us using the information below.

 

UPDATES TO THIS PRIVACY POLICY

 

This Coolpad Dyno Watch Privacy Policy is effective as of the date at the top of this document. Coolpad may update or amend this Privacy Policy from time to time. If we do, we will post the changes here and update the Effective Date above.

 

If we make any material changes to this policy, Coolpad will notify you of the changes through its website, by email, or other communication. If we make any material changes in the way we collect or use a child’s personal information, we will obtain the prior verifiable consent of a parent or legal guardian, if required.

 

We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. By continuing to use the Services, you are agreeing to this Privacy Policy and any updates we make to it.

 

CONTACTING US

 

If you have any questions, comments, or suggestions about this Privacy Policy, your personal data or your consent choice, please feel free to contact us by calling customer service hotline at (877)-606-5753, which is available 24-hours, or by email at legal.us@coolpad.com.

 

Our customer support team can also be reached at the following address:

 

Coolpad Technologies, Inc.

10188 Telesis Court, Suite 550

San Diego, CA  92121