Interactive Media Publishing
Effective Date: September 1, 2014
Last Updated: October 1, 2017
Most of the websites operated by IMP are websites intended for grown-ups (parents, educators, developers, etc.) to learn about and/or purchase our products and services. These websites (which we refer to as our “General-Audience Sites”) include, but are not limited to, our main website and our e-commerce site at www-exploringrobots.com and our teachers’ and student course sites at RobotCourse.com and Ed4Tech.com. We do not knowingly solicit or collect Personal Information (defined below) from children under the age of 13 (“Children Users”) on these General-Audience Sites.
The robots sold on our website developed by other Manufacturers and Software Developers (Dash & Dot, Ozobot, Boe-Bot, Cubelets, Cue, Scribbler, etc.), and their corresponding mobile applications, (together, our “Child-Directed Products”) are generally intended to be used and enjoyed by children, students, and teenagers of all ages. The Apps for these robots are provided by their manufacturers who employ special measures when collecting or processing information through their Child-Directed Products and generally avoid or limit the collection of Personal Information through these products. For more details on our practices related to children, please see the section on Children’s Privacy below.
· “App” means any software application, including, but not limited to, Android and/or iPad and/or iPhone software applications provided by IMP or any software application that IMP resells from a manufacturer or software development company.
· “Browsing Information” means information about your use of the Service, or your computer’s (or other access device, such as an iPad or smartphone) interaction with the Service. Browsing Information also includes certain of the information described in the “Information Collected Automatically” section below. This information is linked to a device identifier, such as the Internet Protocol (IP) address of your computer or device. Some robots include a product identifier, and through the App your robot transmits information to the manufacturer that they may use to provide services, assist you in troubleshooting, and improve the products, services, Website and App. In general, IMP does not use Browsing Information to identify you, but such information may be paired with Personal Information, or with other information that together, could be used to identify you. Additionally, third parties, such as analytics companies and advertising service providers may access, collect, store, and use Browsing Information, and they may use it to identify you.
· “Personal Information” means information that directly identifies you, or that can directly identify you, such as your full name, physical address (home, mailing, shipping, and/or billing address), e-mail address, phone number, and/or credit card information. In the case of Children Users, Personal Information may also include the child’s precise geo-location, school name/address, a photo, video, or audio file that contains the child’s image or voice, and/or a persistent identifier (such as an IP Address or device ID) when such information is not used for internal support purposes.
· “Product Use Information” means information related to use of one of our products, such as robot name, activities coded, or similar information. Product Use Information is linked to the product identification number of your robot.
· “User Content” means any content that you personally create or produce and upload to our Service, such as a comment, message, photo, video, voice recording, artwork, software code or program, or other similar content. User Content may (in some cases) contain Personal Information if Personal Information is provided within the User Content.
· “Website” or “Site” means any websites, web pages, and any subpages (including mobile websites, web pages and subpages) under IMP’s control, whether partial or otherwise. This includes but is not necessarily limited to the General-Audience Sites listed above, and any subpages of these websites.
INFORMATION WE COLLECT
Personal Information We Affirmatively Collect From You
We may collect Personal Information from you, such as first and last name, phone number, email address, physical address, school information, and/or credit card information, when you: (i) register for an account on our Service, (ii) sign up for our newsletter, (iii) make a purchase or order on our General-Audience Sites, (iv) include Personal Information in User Content that you upload to our Service, or (v) set up or enable certain features for your child/student on the Child-Directed Products we resell. Other profile information you may affirmatively provide to us about you or a child or student (such as birthdate, age, gender, username, password, etc.) may be collected and maintained together with your Personal Information. You can choose not to provide any information that is requested of you by us. However, this may limit your ability to use or access the Service.
Additionally, if a friend refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send the friend’s message unless you otherwise affirmatively provide information to us.
In addition to collecting information on the Service, we may collect information from you when you communicate with us over the phone, including via text messages or via e-mail. This information may include Personal Information. This information may be matched with, and stored in connection with Personal Information provided or collected in connection with your registration for or use of the Service.
We also may now or in the future receive Personal Information about you from third parties. For example, if you access our Service or Site through a third-party connection or log-in, including social networking services such as Facebook where you have a registered account, that third party may pass certain information about your use of its service to IMP. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the IMP Service or Site.
Please note that the third party functionalities described above are not made available to Children Users. For more details on our data collection practices for Children Users, please see the section on Children’s Privacy below.
Information Collected Automatically
Log file information is automatically reported by your browser each time you access a web page on our Service. When you access the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your IP Address, web request, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.
We may use certain third party services including, but not limited to, Google Analytics, to help us understand your use of the Service. These services collect information about your use of and the performance of the App, the Site, and/or robots and also collect information sent by your browser as part of a web page request, including cookies and your IP Address.
In general, we will store tracking information in an anonymous aggregated form, however, we or our third party tracking partners may store certain information, such as pageviews, in a manner that can be associated to specific devices.
Third Party Ad Networks
On our Child-Directed Products, IMP does not show behaviorally-targeted or retargeted ads to Children Users or track Children Users for targeted advertising purposes.
Some web browsers may automatically transmit "do-not-track" signals to the websites which users visit. IMP does not currently process or respond to such automated “do not track” signals or other transmissions that indicate a request to automatically disable online tracking of users who visit or use our Service.
HOW WE USE YOUR INFORMATION
We use or may use Personal Information and Browsing Information for a variety of purposes, including:
· To operate the Service, monitor the effectiveness of the Service, to improve the content of the Service, and layout and design.
· To help provide you with a smooth, efficient user experience.
· For billing, identification and authentication, and fraud prevention.
· To respond to any inquiries or requests received from you.
· To monitor, analyze and describe usage patterns and performance of the Service, including aggregate metrics such as total number of visitors, traffic, and demographic patterns.
· To contact you and deliver administrative notices and communications relevant to your use of the Service, such as security or support and maintenance advisories.
· To conduct system administration and system troubleshooting and to diagnose or fix technology problems.
· To comply with legal requirements and process (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service).
· To send promotional communications and/or newsletters to you and for other marketing purposes of IMP or partners.
· In connection with an unusual business transaction, such as the bankruptcy or liquidation of, sale of, purchase of, or merger with our business or another business.
· For distribution to third-party service providers that provide services to IMP and partners of IMP.
HOW WE SHARE YOUR INFORMATION
Personal Information: Except as set forth below, IMP will not rent or sell your Personal Information to others, or share it with independent third parties for their separate marketing-related purposes. To operate the Service, however, we may share your Personal Information with our agents, representatives and contractors so they can provide us with support services and other features and fulfill your orders. We require these third parties not to use your Personal Information for any other purpose. We may store Personal Information in locations outside the direct control of IMP (for instance, on servers or databases co-located with hosting providers).
Browsing Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for our Service. Non-personally identifiable information may be stored indefinitely.
STORAGE AND PROCESSING
YOUR CHOICES ABOUT RECEIVING MARKETING MESSAGES
IMP offers parents, teachers, and other adults the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications or you may also elect to receive marketing communications and other special offers from us via email. To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavor to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message. You may also access and manage your preferences from your account, when available, or by contacting us directly at the contact information below. We reserve the right to send you service announcements or similar administrative messages, without offering you the opportunity to opt out of receiving them.
HOW WE PROTECT YOUR INFORMATION; SECURITY AND PASSWORDS
IMP takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and "perfect security" does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information.
If you create an account to use the Service, you may be asked to choose a password for your account, which can be used to access information associated with your account (including Personal Information). You should choose a password that is not easy to guess, and does not use words that you would find in a dictionary. Do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and we will attribute activities that occur using your account information (e.g., through the use of your password) to you. If you suspect that your password has been compromised contact us immediately at using the contact information below.
HOW YOU CAN UPDATE YOUR INFORMATION
IMP believes strongly in giving you the ability to access and update or correct your Personal Information. You may update your Personal Information by logging into your account on IMP’s Website, when available, or by contacting us directly using the contact information below.
We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, please consult this simple one-page informational guide from the kidSAFE Seal Program: https://www.kidsafeseal.com/knowaboutcoppa.html.
Please note that while the Child-Focused Products offered by us (or by the Manufacturers and Developers whose products we resell) are aimed to be usable by children, students, and young teenagers, that only parents, legal guardians, or other adults are allowed to make purchases on our General-Audience Sites or within the Child-Focused Products.
To set up your robot, a parent or guardian should download the corresponding App and assist with account creation (if applicable). As part of the account creation, we may ask a parent/guardian to provide an email address, account password, and limited profile information (username, birthdate, gender, etc.) about the child using the robot. This information is used to customize the robot experience for the child and to keep the parent informed of the child’s activities.
In compliance with COPPA, the parent's email address may be used to notify and obtain verifiable consent from a parent before activating an account or enabling certain data collecting features for their child (such as chat messaging between the child and robot). The parent account information may also be used for account management purposes (e.g., profile updates, password reset, login for another IMP Website, etc.) and to communicate with the parent about new products, features, newsletters, and special promotions and events. Product Use Information is used only to support our internal operations.
In some instances, IMP may collect a limited amount of personal information from a parent or child (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a child (e.g., email alerts, push notifications). For these types of activities, IMP may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of personal information prior to collection or immediately after use, parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.).
IMP does not currently offer any features on our Child-Directed Products that would allow Children Users to publicly post or share Personal Information with other users via the web. Some features on our Child-Directed Products may allow the storage of information (including Personal Information) locally on an App or robot device, without the uploading of such information to the web or IMP servers. Parents are still advised to remove any such information from their robot device, should they choose to sell, donate, or gift their device to someone else.
On our Child-Directed Products, we may collect and process Product Use Information and Browsing Information from Children Users, but only for purposes of supporting our internal operations, such as to help us:
· Maintain or analyze the functioning of our Child-Directed Products;
· Perform network communications; and
· Authenticate users of, or personalize the content on, our Child-Directed Products.
On our Child-Directed Products, we do not use Product Use Information or Browsing Information for behavioral or re-targeted advertising purposes or to allow third parties to track the activity of Children Users for such purposes.
With proper authentication, a parent or legal guardian always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by IMP. Please keep in mind that a request to delete such information may limit the child’s access to all or a portion of the Service. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us using the contact information below. We urge parents to monitor their children’s use of all digital media.
LINKS TO OTHER WEB SITES
CALIFORNIA PRIVACY RIGHTS
Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information below.
VISITORS RESIDING OUTSIDE THE UNITED STATES
If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian, as applicable and legally required.