Services Designed for Children Aged 13 and Under (COPPA Compliance)
Publicista’s Services include apps specifically designed for children aged 13 and under.
These include “ABC Baby Babble”, and any other Publicista apps marketed in the “Kids” section of mobile app stores.
These apps fully comply with the US Children’s Online Privacy Protection Act of 1998.
As of March 2017, the full text of this act can be found at:
Specifically, our apps do not knowingly collect ANY personal information on children aged 13 and under. If we learn that we have inadvertently gathered personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records.
All Other Services
- what information we collect, how we collect it, and why;
- how we use that information and with whom we share it;
- how you can access and update that information;
- the choices you can make about how we collect, use, and share your information; and
- how we protect the information we store about you
Information We Collect and How We Collect It
- Information We Collect Automatically
- Information From Social Networks (like Facebook)
If you use Publicista’s apps or access any of our other Services on a social network such as Facebook, we automatically receive certain information about you from the social network, depending upon the Publicista app you’re using, the social network, and your friends’ and your privacy settings on that social network.
For example, Publicista automatically may collect and store some or all of the following information provided by the social network:
- your first and last name;
- your profile picture or its URL;
- your social network ID number, which is linked to publicly-available information like your name and profile photo;
- public data for your friends (including their social network ID numbers);
- the login e-mail you provided to that social network when you registered with it;
- the location of the devices you use to access our Services;
- your gender;
- your exact age and/or age range;
- other publicly-available information on the social network; and/or
- any other information that you or the social networks share with us.
Cookies and Tracking Technologies
We and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as:
- cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;
- web beacons, which inform us if a page was visited or an e-mail was opened;
- tracking pixels, which we or or our advertising partners use to provide more efficient and effective advertisements; and
- local shared objects, also known as flash cookies, which help us reduce fraud, store your app preferences, and improve load times.
We and our service providers use these technologies to collect and analyze certain kinds of technical information, including:
- IP addresses;
- the type of computer or mobile device you are using;
- your operating system version;
- your mobile device’s identifiers, such as your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
- your browser types;
- your browser language;
- the website you visited before or after visiting our Services;
- platform type;
- whether or not some of Publicista’s other apps are installed on your device;
- the number of clicks on a page or feature;
- domain names;
- landing pages;
- pages viewed and the order of those pages;
- the amount of time spent on particular pages; and
- app state and the date and time of activity on our websites or apps.
We may connect this information with your social network ID (where available) or Publicista user ID.
- Information from Your Mobile Device
If you use Publicista apps or access our other Services on your mobile device, in addition to your device identifiers, we may also automatically collect:
- the name you have associated with your device;
- your telephone number;
- your country;
- your specific geolocation; and
- information about Publicista apps you have on your device.
- Information About You That You Share With Us Directly
- Account and Profile Information
Some apps or parts of our Services may use a registration or account set-up process where you may be asked to give us some or all of the following information:
- your age or birthday;
- your first and last names;
- your e-mail address;
- a password; and
- other information so we can authenticate you or so we can improve our services.
We may also let you create a user profile, separate from your social networking site profile, that other Publicista users can see. Your user profile may include information you provide such as:
- a profile photo;
- a username(s);
- your gender;
- biographic details (like your age or age range); and
- approximate location that you provide.
If you create a user profile, we may automatically collect:
- links to your profiles on various social network;
- details about the apps you use; and
- a Publicista user ID number that is created by Publicista and used to identify your profile.
Certain information in your Publicista user profile will be publicly accessible on Publicista’s websites that offer direct access to Publicista apps, including:
- The Publicista user ID;
- Your first and last names; and
- Your user profile picture.
Your Publicista user ID number used to identify your account and user profile will appear in the URL of your profile page. It will only allow access to information you make public in your settings.
- Information about your contacts
We may give you the ability to import your address book contacts, including names, e-mail addresses, and social media handles, if available, or manually enter them so that you can find your contacts on Publicista and invite them to user our apps or to other of our Services. You are responsible for obtaining your contacts’ permission when you choose to provide their contact information to us. We may receive information about you from other Publicista users who import or manually share their contacts. We use and may store any or all of this contact information to enable you and your contacts to connect through all of our Services. If you want to remove the contacts stored in our apps or Services, follow the instructions provided in the particular app or Service to request that we remove them from our systems for that app or Service. If you have provided us your contacts in multiple apps or Services and want to remove those contacts from all apps and Services, you will need to take this step in each app or Service. If you need to enter a password to allow us to access your address book, we will not store that password.
- Information You Generate Using Our Communications Features
Our Services may allow you to communicate or share information with Publicista and with other Publicista users. These features include:
- user forums, message boards and chat function;
- the ability to post public comments to other users’ profiles;
- private messaging;
- the ability to send invitations to other users, either directly on our websites or to their e-mail accounts; and/or
- photo or drawing sharing.
You acknowledge and expressly agree that we may access in real-time, record and/or store of these communications, comments, photos, and drawings on our servers. We may use these communications to protect the safety and well-being of our users and Publicista’s rights and property in connection with our Services; to conduct research; to operate, improve, and personalize our Services and our users’ experiences, including through analytics; and to manage and deliver contextual advertising.
- Payment Information
If you make a purchase in our Services, such as a license to use in-app virtual currency or virtual items in a app you use, our third party payment processor will collect the billing and financial information to process your charges. This information may include your postal address, e-mail address, and financial information, like credit card numbers. Publicista does not collect or store your financial information. However, Publicista’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order. We may also obtain the non-financial billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a app you user on a social network or that you downloaded on your mobile device.
Please note that purchases of third party credits or currencies may also be subject to those parties’ policies.
- Customer Support Correspondence
When you contact our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your app use or activity on our Services, and your Publicista user and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support.
- Information We Receive from Other Sources
We may collect or receive information about you from other sources like third party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.
How We Use the Information We Collect
We primarily use the information we collect and store to improve the app experience for our users, but there are other uses as well,including:
- to operate, improve and optimize our Services and our users’ experiences;
- to create user accounts or profiles and to enable you to use our apps;
- to find and recommend other Publicista users to you;
- to personalize our Services for you;
- to enable users to communicate with each other;
- to provide technical support and respond to user inquiries;
- to protect the safety and well-being of our users;
- to protect Publicista’s rights and property in connection with our Services;
- to prevent fraud or potentially illegal activities;
- to enforce our Terms of Service;
- to manage and deliver contextual and behavioral advertising;
- to notify users of in-app updates, new products or promotional offers;
- to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes we may have with you or other users, and to enforce our agreements with third parties; and
- to conduct research.
If you provide your e-mail address to Publicista, we will use it to respond to customer support inquiries, informed you about in-app activity, including comments from friends and in-app status updates and upgrades. Some messages, such as invitations to friends to user a app, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages (e.g. text messages) (“Promotional Communications”) directly or in partnership with other parties, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages.
How We Share Your Information
We will share your information (which may include personal information) with third parties or allow third parties to collect this information from our Services in the following circumstances:
- Aggregated or Non-Personal Information
We may disclose or publish aggregated information, which is information about you and other users collectively that is not intended to specifically identify you, (for example, users between the ages of 29 and 34 who live in Berlin) and other non-personal information about our users for industry analysis, demographic profiling, marketing, analytics, and advertising, and other business purposes.
- Friends and Other Publicista Users
The Services allow you to interact with other users. In most Publicista apps, if you user through a social network or register through a social network (for example, Facebook Connect), your friends will see your name, profile photo and your app activity. In some Publicista apps, other users, including those who are not your social network friends, will be able to see your app activity and profile, which may include your name or user name and your profile photo, and communicate with you within our Services. In certain cases, your profile photo, can reveal your social network ID or Publicista user ID, and access to a social network ID or Publicista user ID may allow others to view the public information associated with your related social network profile or Publicista account. Other users may be able to send you app requests or friend requests through the related social network’s or Publicista’s features.
- Third Party Advertising and Analytics
We allow advertising on our Services so we can continue to offer many of our Services for free.
To our best knowledge, we do not share personal information with third party advertisers for their direct marketing purposes unless you provide your consent.
When advertisers or ad networks place ads in our Services, they may collect or we may share with them and with analytics providers the following types of information from our Services:
- performance data (like the number of clicks on an advertisement);
- aggregated and/or de-identified information about you and other users collectively that is not intended to specifically identify you (for example, users between the ages of 29 and 34 who live in Berlin);
- certain technical information (such as, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID);
- your social network ID; and
- other contextual data about your app user (such as, your level and session duration).
This information may be used to:
- measure the effectiveness of advertising,
- show you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or
- conduct analytics to improve your experience (such as Google Analytics which analyzes traffic and user activity).
Advertisers or advertising networks may collect this information by using one of more tracking technologies like browser cookies and web beacons.
Please note, if you click on a third party advertisement, you may no longer be on a site hosted by Publicista or the social network through which you are using Publicista’s apps.
- Safety, Security and Compliance with Law
Your information, the contents of all of your online communications in our Services, and the communications between You and Publicista may be accessed and monitored as needed to provide our Service and may be disclosed:
- when we have a good faith belief that we must disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
- to comply with any applicable laws or regulations;
- where, in our sole discretion, we believe that the Service is being used to commit a crime, including in order to report criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and
- to protect the rights or property of Publicista and other applicable third parties, including to enforce our Terms of Service.
- Offer Walls
Publicista apps or their purchase pages may use an “offer wall” that is hosted by an offer wall provider. An offer wall permits third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by Publicista. These offers may be shown to you based on certain technical information, like your geographic area or de-identified demographic information. If you click on one of these offers, you will no longer be on a site hosted by Publicista or the social network through which you are usering Publicista’s apps. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your social network ID or Publicista user ID, will be shared with the offer wall provider.
- Third Party Service Providers
We may share information we collect with our third party service providers that perform services on our behalf, including, but not limited to, payment processing, e-mail delivery, hosting services, and customer service.
- Sale or Merger
How to Access, Update and Manage Your Information
- Information We Receive From a Social Network Where You Use Our Apps or From Your Mobile Device
To manage the information Publicista receives about you from a social network, like Facebook, where you user our apps, you will need to follow that social network’s instructions in order to update your information and change your privacy settings.
To review and update information associated with your Publicista app profile in certain apps, visit the “settings” page in that app. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.”
- Accessing and Updating Your Information Held by Publicista
If you want to review, delete, or change the information Publicista has about you or have additional questions, e-mail us at firstname.lastname@example.org. We will respond to your request within ninety days. Please note, Publicista may not be able to provide change or delete certain of your information or provide the ability for you to review such information.
- Stopping Use of Your Information
If you no longer want Publicista to use of your information, you may send an e-mail to email@example.com. Place “Delete My Account” in the subject line and include your first name, last name, e-mail address and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within ninety days. If you make such a request, you may longer be able to user such app or use our Services. We may request additional information from you to authenticate that you are the owner of the account. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.
- Opting Out of Geolocation
If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device’s settings for the relevant application or the “settings” page for the relevant app.
- Opting Out of Promotional Emails from Publicista
If you want to stop receiving promotional e-mails from Publicista, click on the “unsubscribe” link in any promotional email from Publicista. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than thirty business days.
- Opting Out of Other Communications
When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.
- Opting Out of Third Party Tailored Advertising
If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you may visit the following websites:
- Network Advertising Initiative Consumer Opt-Out Pageor the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
- Your Online Choices UK website for EU-based advertising.
These opt-out tools are provided by third parties, not Publicista. Publicista does not control or operate these tools or the choices that advertisers and others provide through these tools.
In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” In additition, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Publicista. Publicista does not control or operate these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive advertisements from third parties within Publicista’s apps even if you opt-out of tailored advertising but they will not be based on your activity across unrelated web sites or apps.
- Opting Out of Cookie Tracking
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
If you disable cookies, you may lose some of the features and functionality of our Services because Publicista cookies are necessary to track and enhance your app activities.
California Online Privacy Protection Act Notice
At this time, there is no general agreement on how companies like Publicista should interpret Do Not Track signals. Publicista does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. You can learn more about Do Not Track here.
Privacy Policies of Linked Third Party Services and Advertisers
Our websites and apps may contain advertisements from third parties, which are companies other than Publicista that may link to their own websites, online services or mobile applications. We are not responsible for the privacy practices or the content of these third parties. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.
Transfer of Information to Other Countries
How Long We Keep Your Information
How long we retain your information depends on why we collected it and how we use it. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.
Security of Your Information
If you have an account registered directly with Publicista, your profile information is protected by the password you use to access your Publicista account. It is important that you protect and maintain your Publicista account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Publicista account, the Service allows you to request that instructions be sent to you that explain how to reset your password. If you access our Services through a social network and your social network account is hacked, this may lead to someone using your Publicista apps without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well. We urge you to log out of your Publicista account and any social network account you have used to access our Services after you use it.
When you sign into your Publicista account or enter payment information, we or our third party payment processor use secure socket layer technology (“SSL”) to encrypt the transmission of that information.
While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. Although we strive to protect your personal information, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us at firstname.lastname@example.org.