GiantLeap Privacy Policy.

Last revised: Septemeber 2019.

GiantLeap Technologies Ltd. (“GiantLeap”, “Company”, “our”, “we” or “us”) respects the privacy of and is committed to protecting the personal information that is collected from or shared by:

 

(i) visitors to its website located at [www.giantleap.tech/privacy] (respectively, the “Visitors” and “Website”);

 

(ii) users of the GiantLeap kid mobile application (respectively, the “Kid App Users” and the “GiantLeap Kid App”);

 

(iii) Kid App Users’ parents or legal guardians who use the GiantLeap web application (respectively, the “Parent Subscribers” and the “GiantLeap Web App”), as well as family members or other key people in the Kid App User’s life, such as teachers, tutors or coaches, who are authorized by the Parent Subscribers to fill out evaluation forms about the Kid App Users (the “Authorized Users”); and

 

The Parent Subscribers and Authorized Users are also referred to collectively in this document as “Subscribers”.

 

The Visitors and Subscribers are also referred to collectively in this document as “User(s)”, “you” and “your.”

 

The GiantLeap Web App and the GiantLeap Kid App are also referred to collectively in this document as the “GiantLeap App”.

 

About our Privacy Policy

This Privacy Policy (the “Privacy Policy”) applies when you visit or use our Website and other services that refer or link to this Privacy Policy, including when you use our GiantLeap App, and is intended to describe our practices regarding the information we may collect from Visitors, Subscribers and from Kid App Users or to which we may have access when Visitors, Subscribers and Kid App Users use or interact with the Website, the GiantLeap App, and any services we may provide thereby (respectively, the “GiantLeap Properties” and the “Services”), the manner in which we may use such information, and the options and rights available to you.

This Privacy Policy may be supplemented by additional privacy statements, terms or notices provided to you.

1. Your Consent

BY ENTERING, CONNECTING TO, ACCESSING AND/OR USING THE GIANTLEAP PROPERTIES AND SERVICES:

 

A) YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW); AND

 

B) IF YOU ARE A SUBSCRIBER, YOU CONFIRM AND REPRESENT THAT YOU ARE ABOVE THE AGE OF 18 YEARS OLD, AND THAT YOU ARE LEGALLY AUTHORIZED TO, AND THAT YOU HEREBY AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY ON BEHALF OF AND WITH RESPECT TO THE KID APP USERS’ USE OF THE GIANTLEAP KID APP ASSOCIATED WITH YOUR GIANTLEAP APP ACCOUNT, AND TO THE COLLECTION AND PROCESSING OF PERSONAL INFORMATION WITH RESPECT THERETO.

 

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of this Privacy Policy. IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN OR OTHERWISE CANNOT LAWFULLY MAKE SUCH ABOVEMENTIONED REPRESENTATION, YOU MAY NOT ACCESS THE GIANTLEAP PROPERTIES OR USE THE SERVICES.

 

PLEASE NOTE: you are not obligated by law to provide us with any personal information about you or about any Kid App User.

2. Information we may collect

We may collect, access and/or process several types of data and information:

 

a. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the individual from whom we have collected the Non-personal Information. Non-personal Information which is being gathered consists of aggregated, statistical or otherwise any technical information and behavioral analysis which is not associated with any identified or identifiable individual. Such Non-personal Information may contain, among other things, aggregated information concerning Users’ device model, operation system and browsers, other technical information regarding devices used by Users to access the GiantLeap App and Website such as language, time zone and mobile operator, duration of usage of the GiantLeap Properties and Services, and clickstream.

 

b.  Other type of information is information related to an identified or identifiable living individual, or such information that, with reasonable efforts, or together with additional information we have access to, enables the identification of an individual (“Personal Information”). For the avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

 

The Personal Information that we may collect and process, consists of the following types of information:

 

  • Users’ contact information voluntarily provided by Users through the Website’s “contact us” or subscribe options.

  • Information voluntarily provided by Users as part of their subscription or registration (as made available by GiantLeap) to the GiantLeap Properties and Services, such as their full name, age, location, physical address, email address, country of origin, place of work or organization, insurance company, ethnicity, etc. 

  • Information voluntarily and actively provided by you through your use of the GiantLeap App, including information regarding the Kid App Users with whom you wish to associate your GiantLeap App account. Such information may consist of a Kid App User’s:

-Full name and birthday (age);

- Assessment scores derived from the Kid App Users’ sessions on the Properties;

- Behavioral and emotional information collected through personal evaluation forms about the Kid App Users, completed by you through the GiantLeap Properties and Services; or

- Profile picture.

 

  • Information concerning the Kid App Users’ use of a mobile device and of the GiantLeap Kid App (i.e. use patterns of the GiantLeap Kid App, number of times Kid App User used their mobile device or Kid App Users’ personal experience feedback and performance metrics with respect to the questions presented through the GiantLeap Kid App playing sessions).

  • Information about the type of User (e.g. Parent Subscribers, Authorized Users or Kid App Users) and their association with the account (as applicable), the GiantLeap App session logs and the GiantLeap App login credentials.

  • Information that is provided to us by job candidates, when they apply for work with us by submission of application through the Website.

 

3. How we collect information

There are two main methods we use:

 

a. We collect information automatically through your use of the GiantLeap Properties and Services. In other words, we are aware of Visitors’, Subscribers’ and Kid App Users’ usage of the GiantLeap Properties and Services, and may gather, collect and record the information relating to such usage, including by using our third party service providers as detailed in Section ‎7 (Sharing Information with Third Parties) below, by issuing a unique install ID (associated with the specific installation of the GiantLeap App), and by using “cookies” and other tracking technologies, as further detailed in Section ‎12 below.

 

b. We collect information which you provide to us voluntarily. For example, we collect the Personal Information that our Users provide us when registering or subscribing to our GiantLeap Properties and Services or when contacting us through the “contact us” option on the Website, etc. We also collect experience feedback provided to us by Kid App Users at the end of our gamified assessments.

 

c. Social Media. We may allow you to share information with social platforms or use social platforms to create your account or to connect your account with the respective social platforms. Those social platforms may give us automatic access to certain personal information retained by them about you (e.g., name, picture, email, etc.). You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information about you retained by the respective social platforms.

 

By associating an account managed by a social platform with your account and authorizing us to have access to this information, you agree that we can collect, use and retain the information provided by these social platforms in accordance with this Privacy Policy.

 

PLEASE NOTE - If you give us Personal Information about someone other than you, you must do so only with that person’s express authorization or such person’s legal guardian’s express authorization (in the case of a minor). You should inform such persons or legal guardians how we collect, use, disclose, and retain their Personal Information according to this Privacy Policy before you provide us with their Personal Information.

 

4. Purposes for which we collection and process information

a.  Legal basis for collecting and processing of Personal Information. We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:

 

  • When performing an agreement with you: Your information may be processed on the basis that such processing is necessary for the establishment and performance of our contractual engagements with you. Under such engagement, we provide Subscribers and Kid App Users with access and use of the GiantLeap Properties and Services, maintain and improve the GiantLeap Properties and Services, develop new services and features for our Users, and personalize the GiantLeap Properties and Services in order to provide Users with a better user experience and enhanced performance.

 

  • Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our GiantLeap Properties and Services; protecting against harm to the rights, property or safety of our Users and Kid App Users or the public as required or permitted by law; enforcing and defending against legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfil our obligations under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our various terms of use or other agreements to which you are a party.

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  • With your consent: Through this Privacy Policy we ask for your active and informed consent to process certain portions of your information for specific purposes and you have the right to withdraw your consent at any time, as specified in Section 8 below.

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b. Personal Information is collected in order to:  

  • Provide, improve and operate our GiantLeap Properties and Services;

 

  • Verify the identity of our Subscribers and Kid App Users for correct provisioning of access to and use of the GiantLeap Properties and Services;

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  • Provide early assessments of a Kid App User’s cognitive abilities and mental health;

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  • Gain statistical data and discover trends in our modern, mobile game-based, assessment process;

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  • Improve the accuracy of the Services by running machine learning algorithms on collected and aggregated data;

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  • Send you updates, notices, notifications, announcements, and additional information related to the GiantLeap Properties and Services;

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  • Provide our Users with technical assistance and support;

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  • Create cumulative statistical data and other cumulative information analysis and/or other conclusive information that is non-personal, of which we might make use in order to operate and improve our GiantLeap Properties and Services and to provide related services;

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  • Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities, including any breaches of this Privacy Policy, of our various Terms of Use, or of any other agreement which you are a party to;

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  • Perform functions or services as otherwise described to you at the time of collection; or

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  • Comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates.

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5. Where we store your Personal Information

Information regarding our Users will be maintained, processed and stored by GiantLeap and our authorized affiliates and service providers in the United States and in Israel, and as necessary, in other territories, in secured cloud storage, provided by our third-party service providers.

 

While the data protection laws in the above jurisdictions may be different from the laws of your residence or location, please know that GiantLeap, its affiliates and service providers that store or process your Personal Information on our behalf are each committed to keeping it protected and secured, pursuant to this Privacy Policy, applicable law, and industry standards, regardless of any lesser legal requirements that may apply in any jurisdiction. Specifically, each of our service providers that stores or processes your Personal Information either (i) assured us that it provides adequate safeguards to protect your rights to privacy, (ii) holds and processes such information on our behalf in a jurisdiction which has been determined to ensure an adequate level protection by the EU Commission, or (iii) if in the US, is certified under the EU-US Privacy Shield framework.    

 

You hereby accept the transfer and storage of information as described above.

 

6. Job Candidates

We may publish open positions on our Website. In such event, GiantLeap welcomes all qualified candidates to apply to any of the open positions posted by sending us their contact details and CV (“Candidate Information”). Since privacy and discreetness are very important to our candidates, we are committed to keeping Candidates’ Information private and use it solely for our internal recruitment purposes (including for identifying candidates, evaluating their applications, making hiring and employment decisions, and contacting candidates by phone or in writing).

 

Please note that GiantLeap may retain Candidate Information for a reasonable time period even after the applied position has been filled or closed. This is done so we can re-consider candidates for other positions and opportunities that may arise, use the Candidate Information as reference for future applications, and, in case the candidate is hired, for additional employment and business purposes related to their work.

 

If you previously submitted your Candidate Information to the Company and now wish to access it, update it or have it deleted from our systems, please contact us at careers@giantleap.tech.

 

7. Sharing information with third parties

GiantLeap may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

a. Third Party Services: We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include:

 

  • third parties providing hosting, database and server co-location services: Google Cloud ML, Amazon EC2 servers and Google Firebase; and

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  • our business, legal and financial advisors (collectively, “Third Party Service Providers”).

 

Such Third Party Service Providers may receive or otherwise have access to your Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing the GiantLeap Properties and Services, and may only use such Personal Information for such purposes and in accordance with this Privacy Policy. Such disclosure or access is strictly subject to the relevant services provider’s undertaking of confidentiality obligations, and the prevention of any independent right to use this data except as required to help us to facilitate or enhance the GiantLeap Properties and Services unless you otherwise provide them directly with your express and separate consent. We remain responsible and liable for any Personal Information processing done by a Third Party Service Provider on our behalf, except for events outside of its reasonable control.

 

b. Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to Personal Information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.

 

c. Protecting Rights and Safety: We may share Personal Information with others, with or without notice to you, if we believe in good faith that this is reasonably required to protect the rights, property or personal safety of GiantLeap, any of our Users, or any member of the general public.

 

d.  GiantLeap Subsidiaries and Affiliated Companies: We may share Personal Information internally within our family of companies or with our affiliated marketing partners (who represent us in your territory), for the purposes described in this Privacy Policy and in accordance with its terms, for which we remain responsible. In addition, should GiantLeap or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our GiantLeap Properties and Services.

 

For the avoidance of doubt, we may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal (including anonymized, statistical or aggregated) Information in our sole discretion and without the need for further approval.

8. Updating, obtaining a copy of or deleting your information

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information, or if you are a Parent Subscriber, the Personal Information of the Kid App Users who are associated with your Parent Subscriber account (which will be deemed hereunder as Subscriber’s Personal Information), that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to us in connection with our use and processing of your Personal Information.

Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.

 

Subject the limitations in law, you may also be entitled to obtain the Personal Information you (or the Kid App User associated with your Parent Subscriber account) directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.

 

You may request that we delete any and all information collected regarding the Kid App User associated with your Parent Subscriber account.

 

If you wish to exercise any of these rights or withdraw your consent, please contact us at: support@giantleap.tech. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or respond to or defend against legal proceedings brought against us or our affiliates, or as we are otherwise permitted under such law applicable to you.

 

To find out whether these rights apply to you and on any other privacy-related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.

 

9. Data retention

We may retain your Personal Information for as long as is legitimately necessary and only to the extent required for the achievement of the purposes listed under Section 4, including without limitation, as reasonably necessary to comply with our legal obligations and/or protect our legitimate interests and, with respect to data used for marketing activity, for as long as we have your consent therefor. We then either delete such Personal Information from our systems or anonymize it without further notice to you.

 

10. Minors and third-party information provided by you

At GiantLeap, we believe in the importance of protecting the privacy of children online.  To subscribe to our GiantLeap Web App as a Parent Subscriber, you must be an adult over the age of eighteen (18). A Parent Subscriber to the GiantLeap Web App is liable and responsible for any use of the GiantLeap Kid App conducted by a Kid App User associated with such Parent Subscriber’s account.

 

To use the GiantLeap Kid App, a minor individual under the age of sixteen (16) (“Child”) must receive informed parental consent from his Parent Subscriber or otherwise from a legal guardian. When Kid App Users use our GiantLeap Kid App to play games, we track their progress and log their performance scores. The data collected in this manner is only used to provide the Company’s cognitive screening and talent mapping services that are designed to help authorized Subscribers understand the developmental progress being made by the Kid App User. Parents or legal guardians are not required to disclose any more personal information about a Kid App User than is necessary to allow the Kid App User to engage in the games. Parents or legal guardians of a Kid App User can always review the personal information we may possess, direct us to delete it or revoke our right to further collection of personal information about a Kid App User.

 

Other than as described herein, our Services are not intended to actively solicit sensitive personal information of any kind from children under the age of thirteen (13). If you believe that we have received information from or about a minor individual under the age of thirteen (13) without the active and verifiable consent of their parents or legal guardians, please contact us immediately at privacy@giantleap.tech

 

We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of eighteen (18) are not registering to the GiantLeap Web App. In the event that it comes to our attention that a person under the age of eighteen (18) subscribed to the GiantLeap Web App, we will prohibit and block such User from accessing the GiantLeap Web App and will make all efforts to promptly delete any Personal Information stored with us with regard to such Parent Subscriber and any Child to whom such Parent Subscriber gave access to the GiantLeap Kid App (if any).

 

If you are submitting to or uploading through the Services any Personal Information pertaining to any minor Child, you hereby represent and warrant that you have received all the necessary legal consents, authorizations or approvals or that you are the parent or legal guardian and have performed all actions required and have the actual authority and legal right to upload, submit, disclose or otherwise share the Personal Information and/or any other form of sensitive information, on the minor’s behalf. 

 

If you are submitting to or uploading through the Services any Personal Information pertaining to any third party, you must do so only with that third party’s express authorization. You hereby represent and warrant that you have received all the necessary legal consents, authorizations or approvals and have performed all actions required and have the actual authority and legal right to upload, submit, disclose or otherwise share the Personal Information and/or any other form of sensitive information, on the third party’s behalf.

 

For more information or questions about how we collect and process the information of minors, or to make a specific request regarding a Kid App User, please contact + (281) 936 4400, or at privacy@giantleap.tech  

 

11. Data security

We take great care in implementing and maintaining the security of the GiantLeap Properties and Services and our Users’ Personal Information that we collect and process. GiantLeap employs industry-standard procedures and policies to ensure the protection of Personal Information, and to prevent unauthorized use of any such information.

 

Please note, however, that regardless of the measures we take and the efforts we make, we cannot and do not guarantee the absolute protection and security of any Personal Information.

 

We strongly encourage you to set strong passwords for your User account and to protect your account against unwanted access on your end (for example, do not share your login credentials with others, or allow them free access to your logged-in devices).

 

If you have any questions regarding the security of our App and Website, please feel free to contact us at [support@giantleap.tech].

 

12. Using cookies and other tracking technologies

We may use certain monitoring and tracking technologies (such as “cookies” or “pixel tags”) to understand how you use our Properties and Services, including ones offered by Third Party Service Providers. These technologies are used in order to maintain, provide and improve our Properties and/or Services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of and “remember” our Users’ preferences and authenticated sessions, (ii) secure our Website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Properties, (iv) create and monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/).

 

Learn more about your choices and how to opt-out of tracking technologies: Cookie Policy

13. Direct marketing

You hereby agree that we may use your contact details provided during the filling of a contact form or during the registration process for the purpose of informing you regarding our products and services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending us written notice by email to the following address: support@giantleap.tech or by pressing the “Unsubscribe” link in the email.

 

Please note that the Company may also contact you with important information regarding our Properties. For example, we may notify you (through any of the means available to us) of changes or updates to our Properties, technical issues, or service maintenance, etc. You will not be able to opt-out of receiving such service messages.

 

14. Changes to the Privacy Policy

The terms of this Privacy Policy are an integral part of the GiantLeap App and Properties and will govern the use of the same and any information collected in the scope of such use. GiantLeap reserves the right to change this Privacy Policy at any time and in its sole discretion, so please re-visit this page frequently. We will provide notice of substantial changes to this Privacy Policy on the homepage of our Website or the landing page of the GiantLeap App, and/or we will send you an email regarding such changes to the email address that you may have provided to us. Such substantial changes will take effect seven (7) days after such notice was provided on our Properties or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Properties, the GiantLeap App or the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

 

15. General Information

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

 

This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

 

16. Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email to: privacy@giantleap.tech and we will make an effort to reply within a reasonable timeframe.

 

By contacting GiantLeap, and accessing the GiantLeap App and Properties, you warrant and agree that you are free to do so and that you are not providing GiantLeap with information which violates any third party intellectual or privacy rights.