Privacy Policy - To help you understand how we handle your data and personal information

Welcome to the Oyoty service, which is owned and operated by Privately SA, 109-110, Batiment I, EPFL Park Scientific, 1015, Lausanne, Switzerland (collectively referred to as “Privately,” “we,” “us” or “our”).

Oyoty is a smart virtual assistant that educates and guides children when they start using smartphones and social media. This self-help tool is meant to build a child’s understanding of online privacy and responsible online behavior and to give them a way to manage issues that might arise.

Oyoty uses the latest advances in computer vision/ machine learning to spot private or inappropriate content children might post on Social networks, and provide them upfront ways to manage these spotted issues. On the basis of the context of the spotted problem Oyoty serves educational content created by experts to children that helps them understand the problem. Oyoty empowers children to be private and safe as they start to experiment in social media with emphasis on education rather than prohibition. At the same time Oyoty provides progress reviews to parents and offers guidance to deal with issues. The mobile application installed on the child’s smartphone, the parental web dashboard, the emails sent and the push notifications are collectively referred to as the “Service”.

In order to provide parents and children with the Service and improve and facilitate its functionality, we gather a minimal amount of personal information from our usersparents and children using the service. This Privacy Policy explains how we collect, use, share and protect this information in relation to the Service.

1. Our collection and use of personal information

As with most online services, personal information is required in order to set up your account and use our Service. We collect only personal information required to meet the needs of the service or as aggregated statistics to improve our Services. Currently, we collect the following information: Provided by users

Provided by users

Analytics Information

Meta Data

2. Sharing of the information we collect

We do not sell or rent user’s personal information to third parties. However in response to a subpoena, an official inquiry, any legal requirements, or any summon from law enforcement, we might be obliged to share this information.

We may share part of this information with technology providers, such as providers of cloud-based services, that help us provide the Service to users (“Service Providers”). Our Service Providers will be given access to user information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

We may remove parts of data that can identify users and share such data with other parties. We may also combine this information with other information in a way that it is no longer associated with an individual and share that aggregated information.

However, the content that children shares on social networks is never shared with other parties.

3. Information shared within the family

Oyoty will highlight to parents issues that were not addressed by their children. In doing so, Oyoty will share the problematic content with the parent. Any content and report highlighted and collected by Oyoty is only shared among the members of the family- children and their parent.

4. How we store your information

User information collected through the Service will be stored and processed in Switzerland and the European Union. Privately is committed to handle all personal data of its users as per the EU General Data Protection Regulation and Swiss Federal Data Protection Act. Currently, we rely on some non-EU based web services (Google, Mixpanel, Twitter, Mailjet and UrbanAirship), which might also have access to part of user information. However none of these services get access to the content or images that have been shared by the children. By using our Service You expressly agrees to such handling of your data.

All passwords handled by the system are encrypted and all communication between various subsystems is also encrypted.

Oyoty may transfer information that we collect about user, including personal information across borders and from their country or jurisdiction to other countries or jurisdictions around the world. We follow both the Swiss Data protection laws the European Data Protection Regulation. If the user is located outside Switzerland and the European Union with laws governing data collection and use that may differ, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as their jurisdiction. However such transfer will be done only in line with the rules of the EU/Switzerland pertaining to such transfer request.

If the users remove images from Social media through Oyoty, our service does not keep any copies of the removed content.

If user deletes their account- all information about users associated with the account will be immediately deleted. All records will be deleted from our servers within 6 months unless required to be retained for legal reasons.

By registering for and using the Service you consent and hereby agree to the transfer of information and the use and disclosure of information about you as described in this Privacy Policy.

We use commercially reasonable safeguards to help keep the information collected through our Service secure and take reasonable steps (such as requesting a strong password) to verify your identity before granting you access to your account. However, Oyoty cannot ensure the security of any information you transmit to Oyoty or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Please do your part to help us. You are responsible for maintaining the secrecy of your password and account information.

5. Children’s privacy

As Oyoty expects its users to be under 16, we requires parents to consent for their child’s use of its service as well as children to accept its terms of use. In order to execute the service, our machine learning algorithms must parse through the content on the social network feeds of the child to identify inappropriate content. This information is then shared back to children and parents and deletion of inappropriate content is facilitated. Oyoty thus helps children remove private content that they might have inadvertently posted on social networks.

We will not retain any personal information of the child beyond the remit and time that the child uses the service. At any time the parent can delete the profile of the child and all the information related to this account. If you believe that we might have any information from or about a child under 13, please contact our support at support@privately.eu.

6. Other web sites and services

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you go from our Service to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including any that may have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your user content. If you are using a third-party website or service and you allow them to access your user content you do so at your own risk.

7. Changes to our privacy policy

Oyoty may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Privately app or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.

8. Contact us

If you have any questions or concerns about this Privacy Policy, please contact our support at support@privately.eu.

You benefit from a right to access, modify, rectify or have rectified, oppose and have deleted your personal data that you have communicated to Oyoty (to the extent you have not communicated such personal data beyond our Service, e.g. on Facebook outside of the perimeters of Oyoty, over which we do not exercise control), without prejudice to any legal obligation for such treatment of data, and without prejudice to article 3 above and specific rules in our Terms of Use. To exercise such rights, please contact our support at support@privately.eu.

This Privacy Policy and our collection and use of your information pursuant to this Privacy Policy shall be governed by and construed in accordance with the substantive laws in force in the Canton of Vaud, Switzerland.