Privacy Policy

Welcome to SmartDaddy’s Privacy Policy, which explains how we collect, store, protect and share your personal information and with whom we share it. While you use the SmartDaddy app and our digital and services, we collect some information about you. This Policy applies to our Parent App and Child App. If you are using the web-based version of our Services, please refer to our Privacy Policy posted on the website.

The SmartDaddy app is a parental control application which has two apps, one for parent(s) and another one for child(ren). Whilst downloading the app and registering for the services we are the Controller of the personal data you supply to us when downloading the app and registering for the services. However, whilst you are using our services and the features of the services (including but not limited to SMS tracking, call tracking, contacts, web history, apps history, screen time, screen capture, SOS functions) you are the Data Controller and we become the Data Processor. For further details, please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

SmartDaddy LLP
NOORAYINGANAKATH, 25/9 8, FIRDOUS MANZILPUNNATHIRUTHI, THRIKKAVU,
PONNANI MALAPPURAM, KERALA,
INDIA -679577

E-mail address: support@smartdaddy.app
Web: www.smartdaddy.app

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

• Content data
• Contract data
• Meta/communication data
• Usage data

• Interested parties
• Communication partners
• Customers
• Users

• Provision of the app and user experience
• Contact requests and communication
• Security measures
• Provision of contractual services and customer service
• PAdministration and response to enquiries

In the following, we inform you about the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. If more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject’s request.
• Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

However, you must understand that no web site or Internet transmission is completely secure. Therefore, we can never guarantee that unauthorised access, hacking, data loss and other incidents can be completely excluded.

The data protection laws in your country may give you the following rights:

• Right to information: what personal data a company processes and why (this notice).
• Right of access: You can request information about data collected.
• Right to rectification: If data collected is not correct, you can ask for it to be corrected.
• Right to erasure: Under certain circumstances, you can request the erasure of your data.
• Right to restriction of processing: In certain circumstances, you can request the further processing of your data, but the data will remain stored.
• Right to data portability: You can have the data collected about you transferred to another provider in a machine-readable format.
• Rights in relation to automated case-by-case decisions, including profiling: This includes several rights where data is processed solely by automated means and this has a legal or significant impact on an individual. In these circumstances, you have, among other things, the right to human intervention in the decision-making process.

If you wish to exercise any of the rights listed above, you can contact us by email at support@smartdaddy.app. For your protection and the protection of all our users, we may need to request certain information from you to help us confirm your identity before we can respond to the above requests.

If you feel that we have not resolved your concern, you have the right to make a complaint at any time. You can also contact your local data protection supervisory authority.

Our APP can be downloaded from the APP stores “Google Playstore” and “Apple App Store”. Downloading our APP may require prior registration with the respective APP store and installation of the APP store software.

APP installation via the Google Playstore
You can use the Google service ” Google Play” of Google Inc, (“Google”) to install our APP.

As far as we are aware, Google collects and processes the following data;

• License check,
• network access,
• network connection,
• WLAN connections,
• location information,

It cannot be ruled out that Google also transmits the information to a server in a third country. We cannot influence which personal data Google processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Google as the operator of the Google Play Store. You can find more detailed information in Google’s privacy policy, which you can access here: https://policies.google.com/privacy.

APP installation via the Apple App Store
You can use the Apple service “App Store” a service of Apple Inc, to install our app.

As far as we are aware, Apple collects and processes the following data;

• device identifiers,
• IP addresses,
• location information,

It cannot be excluded that Apple also transmits the information to a server in a third country. This could in particular be Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store. You can find more detailed information in Apple’s privacy policy, which you can access here: https://www.apple.com/legal/privacy/.

When you install the SmartDaddy app and create an account, we collect some or all of the following information about you.

• Parent App:
  • Parent’s Name, Email and Password for authentication.
  • Child’s Name, Dob (optional) and gender (optional)
• Child App:
  • Parent’s email and password is collected during the sign in process.

Once you have registered, you can review and change this information at any time. It is your responsibility to ensure that your account details are kept up to date. The information we collect helps us improve the app and verify our users.

If you contact us, we will receive your email address and may store your IP address and the information you give us so that we can process your request. We store correspondence with you, including complaints we receive from you about other users (and complaints about you we receive from other users) for 6 years after your account is deleted.

When using the SmartDaddy app, you will receive so-called push messages from us, even if you are not currently using the SmartDaddy app. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your end device.

We collect information from and about the device(s) you use to access our APP, including hardware and software information such as IP address, device ID and type, device-specific and app settings and properties, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both randomly generated numbers, information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope and compass.

In order to use the Parental control features of the Child App we request access or permission to certain functions from your mobile device (Photos, Videos, Camera. Location, and Push notifications) as well as Call history, SMS history, Contacts history, web history, app usage, location and screen shots. The legal basis for data processing is the provision of contractual or pre-contractual measures. You can your permissions at any time via Settings (iOS) or Settings Menu (Android). For further details, please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

User information is, of course, mainly shared with other users with your consent. We also share some user information with service providers and partners who help us operate the Services, and in some cases with legal authorities. Please note that this does not apply to any data provided by you or your child when using Parental Control services. For further details, please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

a) With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer support, marketing, advertising, payment processing, and security measures.

We may also share information with partners who distribute our services and assist us with advertising. For example, we may share limited information about you in hashed, non-human readable form with advertising partners.

We follow a rigorous vetting process before engaging a service provider or working with a partner. All our service providers and partners should commit to strict confidentiality.

b) For corporate transactions
We may transfer your information if we are involved in whole or in part in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

c) When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/legal investigation or other legal requirement; (ii) to assist in the prevention or detection of crime (in each case, subject to applicable law); or (iii) to protect the safety of any person.

d) To enforce legal rights
We may also disclose information: (i) if disclosure would reduce our liability in actual or threatened litigation; (ii) if necessary to protect our legal rights and the legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activities, suspected fraud or other misconduct.

e) With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make clear why we want to share the information.

We may use and share non-personal information such as device information, general demographic information, general behavioural information, geolocation in de-identified form, and personal information in hashed, non-human readable form in the above circumstances. We may also share this information with third parties (including, without limitation, advertisers) to develop and deliver targeted advertisements on our Services and on third party websites or applications and to analyse and report on the advertisements you see. We may combine this data with additional non-personal data or personal data in hashed, non-human readable form collected from other sources.

The App uses the Firebase tool, which is part of the Firebase platform of Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, to obtain statistics on how the App is used, in particular active user numbers, session length, stability rating and storage time. Answers logs the use of the app, and we evaluate user behaviour and user activity in general, i.e., not on a personal basis.

For this purpose, the following data is transferred to the Analytics Engine: name and AppStore ID, build version, individual device installation key (e.g. IDFA [iOS], Advertising ID, and Android ID), timestamp, device model, device name, device operating system name and version numbers, the language and country settings of the device (iOS), the number of CPU cores on the device (iOS), whether a device has the status “jailbreak” (iOS) or “root ” (Android), app lifecycle events (iOS) and app activities (Android);

The legal basis for this data processing is our legitimate interest. The data collected via Google will be deleted after 6 months at the latest. You can select in the settings under data services whether or not you want to send data to Google.

Advertisers and third parties also may collect information about your activity on our app, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our app and on third-party sites and applications. You can opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. You may also be able to choose to control targeted advertising on other websites and platforms that you visit. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your devices.

You can stop the collection of information by the SmartDaddy app by uninstalling it using the standard uninstall procedure for your device. When you uninstall the app from your mobile device, the unique identifier associated with your device will still be stored. If you reinstall the SmartDaddy App on the same mobile device, we may again associate that identifier with your previous transactions and activities.

Unless a more specific retention period is stated within this privacy policy, we will retain your personal data until the purpose for processing it no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

Among other things, tools from companies based in the USA are integrated in our app. If these tools are active, your personal data may be transferred to the US servers of the respective companies. We would like to point out that the USA is not a safe third country in the sense of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g., intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.

Databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your user account or contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

You are not obliged to provide us with personal data. However, depending on the individual case, the provision of certain personal data may be necessary for the provision of the above services. If you do not provide us with this personal data, we may not be able to provide the service.

This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes.

Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.