A. TYPES OF INFORMATION WE COLLECT AND HOW WE USE INFORMATION
We collect several types of information through the Services:
General information collection
Personal information is information about you that can be used by itself, or combined with other information, to personally identify you (“Personal Information”). We collect this information directly from you when you provide it to us and by other means.
When you purchase an Anki product from our website, you provide us with your name, email, phone number, shipping and billing addresses, credit card information, and other information you affirmatively provide. When you register to receive Anki news we collect your age and email address.
If you choose to purchase an Anki product as a gift and send it to a third party, we will ask you for friend or family member's name and shipping information. We do not use the shipping information for any secondary purpose.
We do not collect more Personal Information than is reasonably necessary to participate in the Services or improve the Services.
Specific to the Services
Sign-up for an Account (Account Information)
When you sign up for an Anki account (an "Account"), we may collect Personal Information and other information such as your name, driver name (please do not use your real name), email address, birthdate, password, address and billing information (“Account Information”). If a child under the age of 13 registers for an Account, the email address of his or her parent/legal guardian is collected instead. When you create an Anki account, you can store your address and other billing information to make purchases.
What do we use this data for?
When you sign-up for an Account, we use your Account Information to create this Account and to maintain and manage it for you. For example, your driver name will be displayed to other Anki users you play with. We also use your Personal Information to backup stats, track progress on multiple devices and reserve a unique driver name. We collect your address and other billing information to facilitate current or future purchases.
We collect gameplay data such as game scores, game achievements, game performance, and your usage of various game features. We also automatically record information such as how often you use the Services, the events that occur within the Services and usage and performance data.
In addition, we may collect your device make and model, randomized device ID, vehicle ID, Geolocation Data (as defined below), operating system version and language your device is set to, as well as other device-related information like the battery level and the disk usage (collectively, “Analytics Data”). This Analytics Data is not connected to your name but stored under an anonymized unique ID.
This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
What do we use this data for?
Analytics Data is used by us to enable usage of the Services, enhance your gameplay experience, and help improve our products and services. For example, it enables us to develop new features, to analyze crashes or to fix bugs that occurred within the Services and to develop new products and services.
We may also use Analytics Data, either alone or combined with other data and information, to create aggregated, anonymized data (“Aggregate Data”), which does not identify you personally. We may freely use and share this Aggregate Data, for example, by posting it on publicly-accessible web sites such as Facebook and sharing it with hardware manufacturers, developers, platform hosts and marketing partners.
If you are a user in Germany, you can opt-out at any time from the collection of Analytics Data. For further information on how to opt-out please see Section E below.
Cozmo facial recognition data
If you use Cozmo, it may collect data that allows it to recognize certain users’ facial features. Cozmo does this by sending a picture of the faces it sees with its built-in camera to the Cozmo application via Wi-Fi which then translates the picture into binary encoded facial features that are not recognizable by a person (“Facial Recognition Data”). Once this translation occurs, the Facial Recognition Data is sent back to the Cozmo unit and stored there for comparison to other faces it sees in the future. We also may collect a player name (e.g., first name) which can be associated with the faces that Cozmo recognizes (“Player Name Information”).
What do we use this data for?
Facial Recognition Data and Player Name Information are used by Anki to allow Cozmo to identify faces to enable personalized usage of Cozmo and enhance your gameplay experience, such as to greet you by your first name. It is not shared with any third parties, and Facial Recognition Data and Player Name Information are stored only on the Cozmo unit. The information is not uploaded back to Anki’s web servers.
- Other features of the Services
Some features of the Services may provide you with options to share your information via text messaging, email, or social applications you have on your mobile device. For example, the Services may allow you to share your race results with your friends. You may have the ability to save images to your device in our sharing of results feature. If you wish to do so, you will receive a notification indicating that the Services would like to access your photos which you may allow or deny. We only allow you to save the image you create within the Services to your device and we do not access other photos that you may have saved to your device.
With your devices' IP addresses we obtain zip-code level geographic information (which is not connected to your name but instead stored under an anonymized unique ID) (“Geolocation Data”). If you are a user in Germany, you may opt-out from us collecting Geolocation Data by visiting the setting sections of our application (see also Section E below).
If you opt-in to receive push notifications, we may send you notifications regarding service updates and other relevant messages. You may opt-out of receiving these at any time by going to the phone settings and turning them off.
Our applications may also request permission to use Bluetooth on your device. The applications use Bluetooth to communicate with Anki vehicles and other in-game devices during gameplay. You can turn on / off Bluetooth at the device level.
Automatically as you navigate through the Site: log files, cookies and other technologies
When you visit the Services, certain information is or can be automatically recorded and stored in log files. Generally, we use this information in an aggregated and anonymized way. If we need to combine this type of information with Personal Information, we treat it as Personal Information. Automatically collected information includes:
- Statistical or technical information such as your computer or device's Internet Protocol address, operating system and browser type, time and date, and how you navigate through and interact with the Services.
Emails and other communications and your choices
If you have provided us with your contact information, we may use this information to communicate with you about your order or Account, or to address your questions.
If you have, or, in case of a child under the age of 13, his or her parent/legal guardian has, given us consent by providing us your contact information, we may from time to time, subject to your marketing preferences, send you education, marketing, product support, and research emails. Our third-party mail service provider provides us with anonymized and aggregated demographic information about the respondents to our emails. You can unsubscribe from our marketing and research emails by following the instructions included in them. In addition, 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.
We may also ask you to participate in surveys. These surveys are purely optional and help us improve our products and provide aggregate information, which we think may interest our registered users and visitors. If you choose to participate in an Anki survey, any information you provide to us, including Personal Information, will be linked with your Account in our system and to any Personal Information contained therein. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.
We have a presence on various social media platforms, such as Facebook, Twitter, and YouTube. We receive from them anonymized and aggregated demographic and use information related to our presence on the respective social media platform when you choose to visit us on those sites or to communicate with us.
From time to time, we may conduct contests and sweepstakes on our social media channels or in cooperation with other partners. If you choose to participate in such contests and sweepstakes, we may collect information from you, as described in the terms of the respective contest or sweepstakes.
In addition, we may, from time to time, offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take on the Services with other media, and vice versa. The use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides these features. These features may also collect your IP address, which page you are visiting and may set a cookie to enable the features to function properly. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these features.
B. HOW WE USE THIS INFORMATION
- Provide and deliver products and services you request
- Allow us to internally operate and maintain the Services (such as for the purposes of fixing malfunctions, testing our security systems, etc.)
- Allow you to participate in interactive features on the Services
- Personalize your experience and customize content, marketing, and recommendations
- Respond to requests that you make, provide you with customer service, send you press releases, general informative announcements, and promotional information about us or our products, and to fulfil any other purpose for which you provide it
- Assist those who help us in designing and operating the Services or help us analyze collected data
- Analyze, use and learn about the interests of our users in the aggregate to better understand your interests and needs, or to aid us in serving you better
- Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
- Protect, investigate, and deter against fraudulent, unauthorized, illegal activity, or violations of our policies
- Notify you about changes to the Services or any products or services we offer or provide though it
- In any other way we may describe when you provide the information for any other purpose with your consent or the consent of a parent or legal guardian
- We may use Cookie Information to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
C. SHARING YOUR INFORMATION
We may share your Personal Information as follows:
- With third parties that support our business, such as to process payments, to provide accounting services or to store and/or process information collected through the Services, and who are bound by contractual obligations to keep Personal Information confidential and adequately protected and use it only for the purposes for which we disclose it to them. Personal Information is shared with third parties only in the ways that are described in this privacy statement. You can opt-out from the transfer of data to selected third parties on our third party operator site.
- With a parent company, subsidiaries, joint ventures, or other companies under common control with us, provided the data is adequately protected. 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 (subject to your consent, where required by applicable law).
- To fulfill the purpose for which you provide it (for example, if you consent to us posting to a third party account on your behalf), for any other purpose disclosed by us when you provide the information, or otherwise with your consent or, in case of a child, the consent of a parent or legal guardian.
We may also freely disclose Aggregate Data to third parties. This may be done for a variety of reasons, such as for research and development, product improvements, and other related business purposes.
D. TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES; PRIVACY SHIELD CERTIFICATION
The Services are hosted and operated in the United States and are subject to United States law. By using the Services, you acknowledge and agree that any Personal Information that you provide to Anki is being provided to Anki solely in the United States and will be hosted on United States servers.
Anki, Inc (and its subsidiary companies Anki Canada Ltd, Anki UK Limited, Anki Germany GmbH) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Anki, Inc is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List [https://www.privacyshield.gov/list]
Anki, Inc is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Anki, Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Anki, Inc is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Anki, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Anki, Inc complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Anki, Inc has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Anki, Inc’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
E. ACCESSING YOUR INFORMATION; YOUR OPT OUT RIGHTS
- Accessing your information
Upon request Anki, Inc will provide you with information about whether we hold any of your personal information. You may modify or update your Personal Information, request deletion of certain Personal Information or your Account or request a copy of the Personal Information that we hold about you by emailing us at firstname.lastname@example.org or by contacting us as described in Section J. We will use commercially reasonable efforts to respond to all access requests within 30 days. We may not accommodate a request to access information where such a request is unreasonable under applicable law and we will not change information if we believe the change would violate any applicable law or legal requirement or cause the information to be incorrect.
In case you request to delete Personal Information, you may no longer be able to use all features and functions of our services.
- We will retain your
information for as long as your Account is active or as necessary to
provide you services. We may also be required to keep some of your
Personal Information for legal reasons, for instance to comply with
statutory retention periods or for tax purposes. In addition, we
will continue to retain and use Aggregate Data.
Right to opt-out
We offer certain choices about how we communicate with you and what information we obtain about you and your child. You may opt-out of receiving any emails from Anki at any time. For example, you can click "unsubscribe" at the bottom of our marketing emails to stop receiving them.
If a child signs up for an Account, his or her parent or legal guardian will be provided with notice via email and the parent/legal guardian must approve the Account before it is activated, or, we may choose to obtain verifiable consent of the parent/legal guardian via other acceptable methods. If no consent is received within 14 days after sign-up, the child's Account will be deleted.
The Personal Information collected and stored from the child (with permission of the parents/legal guardians) may include a username (e.g., driver name), Account password, parent’s/legal guardian's email address, and age/date of birth (as noted above). We may also collect and link to the child’s Account the information we store within the analytics software.
We will only collect such Personal Information from children as is reasonably necessary to provide the features and services of the Services. When applicable, parents/legal guardians have the right to consent to Anki's collection and use of Personal Information from the child without also consenting to its disclosure to independent third parties.
If a parent or legal guardian becomes aware that his or her child has provided us with information without the parent's/legal guardian's consent or the parent/legal guardian wishes to revoke his/her prior consent, the parent/legal guardian should contact us at email@example.com or as mentioned in Section J. We will delete such information from our files within a reasonable time. The parent/legal guardian may also contact us to review, modify, delete, or stop Anki’s continued use or collection of their child’s Personal Information.
Alternatively, a parent or legal guardian may contact us by sending a letter to:
55 2nd St
San Francisco, CA 94105
If we change this privacy statement in a way that expands the collection, use or disclosure of children's Personal Information to which a parent/legal guardian has previously consented, the parent/legal guardian will be notified and we will be required to obtain the parent's/legal guardian's additional consent.
We will notify the parent/legal guardian when important information changes, like e.g. when password changes, purchases or other settings changes are made to Accounts from children under the age of 13.
We encourage parents to talk with their children about communicating with strangers and disclosing personal information online.
We are concerned about safeguarding the confidentiality of your Personal Information. We use reasonable industry standard practices to protect the confidentiality, integrity, and availability of your data. All information you provide to us is secured using industry standard procedures. Any payment transactions will be encrypted in transit using SSL. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. While Anki strives to protect your Personal Information and privacy, we cannot guarantee the security of any information you disclose online. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org
H. YOUR CALIFORNIA PRIVACY RIGHTS
UNDER CALIFORNIA CIVIL CODE SECTIONS 1798.83-1798.84, CALIFORNIA RESIDENTS ARE ENTITLED TO ASK US FOR A NOTICE IDENTIFYING THE CATEGORIES OF PERSONAL INFORMATION WHICH WE SHARE WITH OUR AFFILIATES AND/OR THIRD PARTIES FOR MARKETING PURPOSES AND PROVIDING CONTACT INFORMATION FOR SUCH AFFILIATES AND/OR THIRD PARTIES. IF YOU ARE A CALIFORNIA RESIDENT AND WOULD LIKE A COPY OF THIS NOTICE, PLEASE SUBMIT A WRITTEN REQUEST TO: email@example.com OR Anki, Inc., 55 2nd St., San Francisco, CA 94105.
I. LINKS TO THIRD PARTIES
J. HOW TO CONTACT US
If you have any questions regarding privacy while using the Services, or if you have questions about our practices, please contact us via email at firstname.lastname@example.org You can also send a letter to
55 2nd Street
San Francisco, CA 94105
Anki.com, the Anki DRIVE mobile app, the Anki OVERDRIVE mobile app and Cozmo are certified by the kidSAFE Seal Program. The kidSAFE Seal Program is an independent safety certification service and seal-of-approval program designed exclusively for children-friendly websites and technologies, including kid-targeted game sites, educational services, virtual worlds, social networks, mobile apps, tablet devices, and other similar interactive services and technologies. Click on the seal or go to www.kidsafeseal.com for more information.