Back to site

Levelty privacy policy V 1.0

Date of last revision: October 2022

Introduction.

At levelty we want to be clear and transparent about what information we collect, why we collect it, and how we use that information. Your family's privacy is important to us. This policy will evolve over time as we grow and we will post any changes to this page so please check it from time to time - and don’t worry, if we’re making major changes, we’ll notify you via email, SMS or in-app notifications.

This privacy policy seeks to address any concerns with how your 'Personally Identifiable Information' (PII) may be used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

If you have any questions about your personal information or our privacy policy, please email us at: team@levelty.app

“levelty” means Levelty Inc. The policy applies to the levelty website, levelty.app (the “Website”), the levelty application for a mobile phone or any other device (the “Application”), levelty Services and all related sites, applications, data storage, services and tools regardless of how you access or use them. By requesting, accessing, or otherwise using our services, products, features, functions, technologies, or content offered on the Website, the Application, and all related sites and applications, regardless of how accessed, including by computer, mobile phone, or any other device (collectively “Services or levelty Services”), you accept this Privacy Policy and agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

A “levelty Account” means the service account at levelty, established by the Primary Account holder (the parent or guardian), through which the levelty Services are provided with regard to the Primary Account and Sub-Account(s) (child accounts). The terms “Primary Account,” “Primary Account holder,” “Sub-Account,” and “Sub-Account Cardholder” shall have the same meanings as set forth in the levelty Terms of Service.

Notice to parents/guardians and other Primary Account holders

As a parent or guardian (or other Primary Account holder) who has signed-up with a child to use the levelty service, you are giving us explicit prior verifiable consent to collect, use and share their data in the ways specified in this policy. By providing a set of verified contact details for your child or teen, parents and guardians are explicitly giving their permission for their children to be contacted.

We are reliant on you providing accurate information in order to implement our Privacy Policy and cannot be held responsible if you circumvent age restrictions by providing incorrect date of birth information.

We encourage parents and guardians to explain to their children how their information will be used, as set out in this policy.

1. What personal information do we collect and why?

We may collect PII automatically, when you give it to us directly, or when we receive it from other sources such as our partners (as set forth below) or social media accounts you choose to link to our Services. The PII we collect depends on the context of your interactions with our Services, and the choices you make and may include the following:

The PII we collect depends on the context of your interactions with our Services, and the choices you make and may include the following:

• Contact and identification information such as your name and your child’s name, your phone number, email address, date of birth, personal description, social handles, photographs and other similar contact information;
• Demographic information such as your or your child’s age, gender, nationality, country and other similar demographic information;
• Security information such as passwords, password hints and other similar security information;
• Device and technical information such as IP address, unique device identifiers (such as the IMEI number for phones, the MAC address of the device’s wireless network interface), device functionality (browser type and version, operating system and platform, hardware used, browser plug-in types and versions) and other similar device and technical information;
• Usage information such as the full uniform resource locators (URLs), information about page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), error reports and performance data (ie: details of the software or hardware related to an error, content of files you were using when an error occurred), troubleshooting and help data plus other similar usage information;
• Any other information you directly provide to us when filling out forms, corresponding with us (ie: email, conversations with Member Services by phone or chat sessions), filling out surveys, providing us with feedback and product reviews and other similar information.
• Device and technical information such as IP address, unique device identifiers (such as the IMEI number for phones, the MAC address of the device’s wireless network interface), device functionality (browser type and version, operating system and platform, hardware used, browser plug-in types and versions) and other similar device and technical information;

You have choices about the PII we collect. So, when you are asked to provide us with your PII, you always have the right not to do so. Please note however that if you choose not to provide us with your PII when prompted, you may not be able to use our Services.

2. What do we do with your personal information?

The PII we collect from you is used for the following purposes:

• To provide you with our Services: we use your information to process your account application and authorize your access to our Services, process your payments and provide you with any other Services you request from us;
• To communicate with you: we use your information to share important news relating to our Services. We offer regular emails including newsletters to let you know about our Services. From time to time we may also contact you to ask your views on our Services, to fill out a survey, to send you marketing communications such as special offers and updates that we think will be of interest to you. We may contact you through email, notices posted on our website or app, text messages or push notifications. You may always change your communication preferences in your preference settings at any time and choose to hear a bit less or a bit more from us.
• To conduct research: we use your information to conduct research for the further development and improvement of our Services.
• To help you: we use your information to investigate and resolve complaints and services issues;
• To improve the Services offered on our website and make them more secure: we use your information so we can provide you with the most user-friendly navigation experience we can, and if we think it’s necessary, for security purposes or to investigate possible fraud;
• To comply with legal and/or regulatory requirements; and
• To better understand our business: we use aggregate information to generate statistics about our users or the demographic distribution of visitors to our website. Note that aggregate is information combined from several measurements and doesn’t identify you.

3. How do we protect your and your family’s information?

We know that security is a major concern for many of our customers, and to give you peace of mind we have the most advanced security systems in place as required under both US and the very stringent EU data protection laws.

To protect your and your family’s information we:

• Use secure server software to store your information;
• Encrypt your payment transactions;
• Implement security safeguards designed to protect your personal information such as HTTPS;
• Use full login on our systems;
• Ensure that access to your information is limited to those who need it in order to do their job;
• Ensure that all our employees sign a confidentiality clause as part of their terms of employment;
• Follow tight security procedure, such as maintaining physical, electronic and procedural safeguards to protect your information from unauthorised access;
• Continuously educate and train our employees about the importance of confidentiality and privacy of customer information;
• Continuously monitor our systems for possible vulnerabilities and attacks; and
• Regularly review and update our privacy controls and policy.

If we transfer your information to our servers, or a service provider or agent in another country, we will make sure that we and the service provider or agent agrees to apply the same levels of protection as apply to personal information held and processed in the US and to use your information only for the purpose of providing the service to us. Please know however that although we do our best to protect your PII, we cannot guarantee the security of your information during transmission of information via the internet, as any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to do our best to prevent unauthorised access to your information.

4. Will we pass your or your family’s personal information on to third parties?

First of all, please rest assured that WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES. We also do not pass your or your family’s personal information to third parties for marketing purposes without your permission.

We may however access and disclose your personal information in the following circumstances:

• When the disclosure is requested by you;
• When working with our business partners (e.g., payment services provider, risk and security system providers); our suppliers (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development); and/or our sub-contractors for the performance of any contract we enter into with them or you. For example, companies we have hired to assist in protecting and securing our system and services may need access to personal information to provide those functions. Note that such business partners, suppliers and subcontractors will only have access to your personal information as reasonably necessary to perform these tasks on our behalf and will be obligated to not disclose or use it for other purposes;
• When we sell, merge, or change the control of levelty or in preparation for any of these events, in which case the prospective buyer will have the right to continue to use your personal information, but only in the manner set out in this privacy policy unless you agree otherwise;
• When working with advertising and analytics providers: If we decide to engage advertisers to promote our Services, the advertisers and their advertising networks may require anonymised personal information to serve relevant adverts to you and others. We will not disclose identifiable information about you to advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a subsection of our users.
• Ensure that access to your information is limited to those who need it in order to do their job;
• When required by law, subpoenas, court orders, or other legal process;
• When we have a good faith belief that such disclosure is reasonably necessary to:
  • Investigate, prevent, or take action regarding suspected or actual illegal activities;
  • Enforce our agreement with you;
  • Investigate and defend ourselves against any third-party claims or allegations;
  • Maintain the security and integrity of our Services;
  • Protect the rights and security of levelty user’s, personnel, or others.
• When we are under a legal duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request such as subpoenas and court orders. We will use our best efforts to notify you about such legal demands when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.

5. How long will we retain your personal information?

If you choose to close your account, your personal information will stop being visible on our Services within 24 hours.

We retain your personal information after you have closed your account for the purposes for which it was originally collected, or for which it was further processed. If you want us to delete your personal information completely, you can ask us to do so by writing us on team@levelty.app.

6. How do we protect children’s data (COPPA)?

Protecting the privacy of the data of parents, children and other users of the levelty Services is very important to levelty. We follow the guidelines and rules laid down by COPPA (the Children's Online Privacy Protection Act) and have adopted these policies to keep your children safe.

Please note that there are a few exceptions to these policies as noted below under the heading "Exceptions to Verifiable Parental Consent and Information Collected from Children":

We therefore commit to the following principles regarding how we respect our child users’ personal information:

• We will NOT knowingly collect, use, or distribute personal information from children under the age of 13 without prior verifiable consent from the parent or guardian (Primary Account holder).
• Personal information we collect from children under the age of 13 will be used solely by levelty for internal purposes only and will NOT be sold or otherwise distributed to third parties other than as laid out in this Privacy Policy.
• We will NOT knowingly ask a child under the age of 13 to divulge more information than is needed to use any levelty service.
• We will NOT knowingly keep any new personal information that is inadvertently included in a child's email submission, help inquiry, or other one-time request, if we know that the child is under the age of 13.
• We will NOT knowingly provide any direct link to websites that we feel are unsuitable for children or teens.
• There is currently no place on the levelty application where a child could share any personal information outside of the Primary Account and Sub-Account(s). Should that change, we will advise children under the age of 13 that they MUST obtain permission from their parent or guardian before sharing ANY personal information.
• We will send the following communications to children & teens to make sure that they are able to make the best of the levelty service:
  • levelty push notifications and usage alerts, e.g. on completed tasks, new tasks information etc. These notifications form a major part of the levelty service and we strongly recommend their acceptance, but you may opt-out of receiving these types of communications by turning off push notifications at your or their device level;
  • levelty updates.
• In line with Fair Information Practices, we will take the following responsive action should a data breach occur:
• We will notify you via email within 7 business days;
• We will notify the users via in-site notification within 7 business days.

7. Exceptions to Verifiable Parental Consent and Information Collected from Children

As previously stated in the Privacy Policy, any information collected related to your child will have been provided at sign up or by using the levelty Services, and we will only use their contact information if you have given your consent for your child to receive our newsletter.

In the following instances, we will NOT obtain verifiable parental consent for the collection of a child's personal information:

• Collecting a child's contact information solely to directly respond to the child's request on a one-time basis (for example, to provide assistance with a particular customer service question). We will not use that information to re-contact the child for any other purpose.

8. What are your rights regarding your personal information?

You can ask us what type of personal information we collect about you, the sources from which we collect it, the commercial purpose of the collection, and with whom we share it. You can find answers to these questions in section 3, 4 and 7 of this privacy policy.

You can ask us to view your personal information. You can contact us at any time to ask us to provide you with a copy of the information we hold about you. We will be happy to share it with you free of charge by mail or electronically, unless we are prohibited by law from doing so.

You can ask us to rectify the personal information we hold about you. You can also request us at any time to amend your details if they are deemed to be incorrect i.e. your phone number etc.

You can ask us to delete your personal information. Finally, you can always ask us to delete your personal information.

For all these requests please do not hesitate to write us on team@levelty.app.

9. Can you opt-in or opt-out of receiving marketing offers or updates?

We usually like to send our customers special offers & updates that we think will be of interest to them – special deals for levelty families, product updates etc. You can choose whether you or your child want to receive offers from us and from other companies. Here’s how to let us know your preferences:

• Opting Out - all levelty users: If you would like to opt-out of messages we send you about levelty offers and updates please email us at team@levelty.app or simply click the unsubscribe link in a marketing email that was sent to you.

10. Links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

These third-party websites are not subject to this privacy policy. We strongly recommend that you read the privacy policy of any websites that you visit through us.

11. Cookie policy

Please read this cookie policy (“cookie policy”, "policy") carefully before using [website] website (“website”, "service") operated by Levelty ("us", 'we", "our"). What are cookies? Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers. What types of cookies do we use? Strictly Necessary Cookies These cookies are essential for the website's operation and cannot be turned off in our systems. Typically, they are set only in response to actions you perform that equate to a service request, like setting your privacy settings, logging in, or completing forms. Your browser can be configured to block or alert you about these cookies, but then, certain sections of the site may not function properly. These cookies do not keep any personal identification information.

Performance Cookies

These cookies enable us to track visits and traffic sources to assess and improve our site's performance. They help us to identify which pages are the most and least visited and see how visitors move around the site. The information collected by these cookies is combined and therefore anonymous. If you do not permit these cookies, we will not be informed of your visit to our site and will not be able to monitor its performance.

Functional Cookies

These cookies allow the website to offer improved functionality and personalisation. They may be set by us or by third-party providers whose services we have added to our pages. If you choose not to allow these cookies, some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may use them to create a profile of your interests and show you relevant adverts on other sites. They are based on uniquely identifying your browser and internet device. If you choose not to allow these cookies, you will experience less targeted advertising.

If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. Most browsers will allow you to choose the level of privacy settings you want. This lets you control your cookie settings so that you can:

• See what cookies or other locally stored data you’ve got and delete them on an individual basis;
• Block third party cookies or similar technology;
• Block cookies or similar technology from particular sites;
• Block all cookies or similar technologies from being set; or
• Delete all cookies or similar technologies when you close your browser.

Deleting cookies or similar technologies means that any preference settings you have made on a website will be lost. If you have set your preferences to opt out of cookies, this setting will be lost too, as that information is stored in a cookie. Blocking all cookies or similar technology means functionality on our websites will be lost, as described above.

12. If you have more questions

If you have any more questions about your family’s personal information or our privacy policy, please email us at: team@levelty.app.