Effective date: January 27, 2017
The Children's Online Privacy Protection Act ("COPPA") requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 ("Minors"). We do not knowingly collect or solicit personally identifiable information from a Minor without obtaining verifiable consent from that child's parent or guardian ("Parental Consent"), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent ("Required Information"). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent. If you are a Minor, please do not attempt to send any personal information about yourself to us. If you believe that a Minor has provided us with personal information (beyond the Required Information) without our obtaining Parental Consent, please contact us at email@example.com. We do not condition participation in our Services on disclosure of more Personal Information from a Minor than is reasonably necessary for that participation, and we do not retain Personal Information from Minors longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.
Given the nature of our Services, each Parent User is required to provide Parental Consent prior to enabling the Services with respect to their Participating Child's mobile device, regardless of whether the Participating Child is a Minor.
What Information does Latch Mobile Collect?
Information Collected Automatically
We automatically collect the following information from the mobile devices of Participating Children (collectively, the "Participating Device Information"): (i) geolocation data, (ii) motion and speed data, (iii) network, browsing and search activity, (iv) text and multimedia messages, (v) contact information accessed by the Participating Child, (vi) photos and videos received, sent and stored by the Participating Child, (vii) social media activity, (viii) application information and usage data including screen content and interactions, (ix) accounts used or accessed, (x) device settings and configuration, and (xi) wireless connectivity information. The extent to which we collect the foregoing information from any given Participating Child depends on the parameters chosen by the Participating Child's Parent User.
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, "cookie" information, the type of browser and/or device you're using to access our Services, and the page or feature you requested (collectively, "Usage Information"). When you download our mobile application, we automatically collect information on the type of device, name and version of the operating system, name and version of the application, the numerical mobile device user ID, as well as actions performed by the user in accessing the mobile application (all such information is considered part of "Usage Information" as described above). "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.
What does Latch Mobile use Personal Information for?
GenerallyThe information we gather from users enables us to personalize and improve our Services, and allows Parent Users to set up a user account for the Parent User and his or her Participating Children through the Services.
The Personal Information you provide is used for such purposes as responding to your requests for certain information and services, customizing your experience and providing the Services, and communicating with you about the Services.
Personal Device Information
If you are a Participating Child, your Participating Device Information, including any Personal Information included within it, will be stored, analyzed for risks, and parts of it made accessible by your Parent User when associated with an identified risk.
If you are a Parent User and you use our mobile application, we will send push notifications to your mobile device in order to make you aware of certain activities that may occur within your account, such as when one of your Participating Children is in a certain location or accesses a particular website through his or her mobile device browser. You may opt out of receiving these types of communications by turning them off at the device level or by adjusting your account settings.
Latch Mobile uses Usage Information to figure out how often users use parts of the Services, so that we can make the Services appealing and relevant to as many users as possible, and customize and improve those Services. We may link Usage Information to Personal Information that we collect through the Services, but we will only use this linked information internally (for example, to customize your experience), and will not disclose it in linked format to third parties.
We may communicate with you if you've provided us the means to do so. For example, if you've given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by updating your account settings or by using the unsubscribe link included in all communications.
Will Latch Mobile Share Any of the Personal Information it Receives?
We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section:
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us in delivering our Services.
Data Processors: In addition to our own, we may employ third-party data processing services to analyze select Participating Device Information in accordance with our instructions and for the express purpose of providing our Services. Data Processors include Amazon, Google, IBM, Microsoft, and Sunrise Health. Data processors do not have any right to use the Participating Device Information we share with them except in anonymized or aggregated form that would not be personally identifiable, and only to improve their data processing services.
Participating Device Information: If you are a Participating Child, we will share your Participating Device Information with your Parent User. As noted above in the "Information Collected Automatically" section, your Participating Device Information includes certain of your Personal Information.
Communications between Users: Parent Users can communicate with their Participating Children, and vice-versa, via the Services. Any Personal Information that you include in a message to your Parent User or Participating Child (as applicable) will be seen by that recipient.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions.Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We support and recommend the use of additional factors of authentication including hardware and software tokens, mobile authentication apps, and SMS verification.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What Personal Information can I access?
If you are a Parent User, through your account settings you may access, and, in some cases, edit or delete the following information you've provided to us:
- name, password
- multifactor authentication settings
- email address
- physical address
- mobile phone number
- authorized user accounts
- paired devices
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at firstname.lastname@example.org.
If you are a parent or guardian of a Participating Child, you may contact us at any time to ask that (a) we stop collecting Personal Information from the Participating Child, and (b) we delete any Personal Information already collected from the Participating Child. Please note that the terms regarding deleted data outlined below in "What choices do I have?" also apply to deleted Personal Information from Participating Children.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at email@example.com.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete information as explained in the " What Information Can I Access" section above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may delete your account by unregistering from the Services in your account settings. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
We will retain your Personal Information for as long as your account is active or as long as needed to provide you the Services; we also may retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to firstname.lastname@example.org, and we will try to resolve your concerns.
Revision 1.1 (February 20, 2018)