Last updated: December 06, 2023

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of personal information when You use our products and tells You about Your privacy rights and how the Law protects You.

The legal purpose of this Policy is to ensure the proper legal procedure for personal data processing, provide care and ensure compliance with best global and local practices, all the applicable Law and customer expectations.

We use Your personal data to provide and improve the Product. By using the Product, You agree to collection and use of personal information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is Capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Developer or Data Operator (referred to as either "We", "Us" or "Our" in this Agreement) refers to: Seneka Inc., the incorporated software developer located at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, U.S.

You - the individual accessing or using the Product (if aged 13 (Thirteen) and above), or the representative on behalf of which an individual aged below 13 (Thirteen) is accessing or using the Product. You can be referred to as Data Subject or as You.

Product means the software provided by the Developer to You, namely Savvy KID App.

Data Controller, for the purposes of GDPR, refers to the Developer as the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Personal Data is any information that relates to an identified or identifiable individual.

Usage Data refers to data collected automatically, either generated by the use of the Product or from the Product infrastructure itself (for example, the duration of a visit or the hardware used for connection).

Device means any device that can access the Product such as a computer, a phone or a digital tablet.

Account means a unique credential profile created for You by Facebook to access the Product or parts of the Product’s functionality.

Country refers to The United States of America, where the Developer does business in.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Third-party service refers to any website, application or technology through which You can log in or create an Account to use the Product, arrange a payment or get any other function provided by a third-party.

The Legal Basis

When Does this Policy Apply?

• when You access, install and use the Product;

• when We are fulfilling our obligations to You, set in our agreements and contracts concluded with You, for example in EULA or Terms of Use;

• when We are processing requests, notices, complaints, inquiries, messages sent by You.

The Legal Basis for Processing Personal Data

• Your informed consent to the processing of personal data;

• Our agreements and contracts with You;

• Applicable laws and legal acts adopted on their basis governing information relations and information technologies;

• European Union’s General Data Protection Regulation (GDPR (EU) 2016/679) and legal acts adopted on its basis, only in the event Our legal relationship with You falls under the exterritorial criteria of it (see https://gdpr.eu/ for detailed information about GDPR).

How We Collect and Use Personal Data

Types of Data Collected

Personal Data Requested Directly from You

While using Our Product, We may ask You to provide Us with certain personally identifiable information that can be used to serve, contact or identify You. Such personally identifiable information may include:

• Your full name.

• Email.

• Phone number.

• Name(s), gender(s) and age(s) of the child/children.

Personal Data Requested from Your Apple Account

Our Product exists and functions within the Apple ecosystem, therefore We may ask You to provide Us with certain permissions to access certain personally identifiable information stored in Your account(s) / profile(s). Such personally identifiable information may include:

• First and last name and profile picture to help recognize and address You.

• Gender to help address and describe You.

• Country and language You chose in your Apple account’s language and region settings to be able to better greet You.

• Time zone to know when to best service You.

• Apple ID.

• Birthday.

• Address.

• Phone number.

• Current city.

Usage Data

Usage Data is collected automatically when using the Product.

When You access the Product by or through a Device, We may collect certain information automatically, including, but not limited to, the type of device You use, Your device unique ID, the IP address of Your device, Your operating system, the type of Internet browser You use, unique device identifiers and diagnostic data. We may also collect information that Your hardware sends whenever You visit our site or when You access the Product by or through a Device.

Information from Third-Party Services

We provide You with the option to log in through the following Third-party services, in the event You have personally linked these services to Your copy of Product:

• Apple. Privacy policy: https://www.apple.com/legal/privacy.

Device Location

While using Our Product, in order to provide features of Our Product, We may collect, with Your prior permission:

• Information regarding Device location;

We use this information to provide features of Our Product, to improve and customize Our Product. The information may be uploaded to the Developer's servers or it may be simply stored on Your Device.

You can enable or disable access to this information at any time, through Your Device settings.

No Special or Sensitive Categories of Personal Data

We do not collect or process data related to special (vulnerable/sensitive) categories of personal data including data on racial and national origin, political and religious views, self-identity, health, fitness, medical data, biometric data etc.

Use of Your Personal Data

The Developer may use Personal Data for the following purposes:

• To provide and maintain the Product, including to monitor the usage of the Product.

• To manage Your Account: to manage Your registration as a user of the Product. The Personal Data You provide can give You access to different functionalities of the Product that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the contract for the products, items or services You have purchased or of any other contract with Us.

• To contact You: To contact You by email, telephone calls, SMS, web messenger, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. The limitations of such activities and Our measures to prevent undesired messaging are set in this Policy.

• To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information. The limitations of such activities and Our measures to prevent undesired messaging are set in this Policy.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Product users is among the assets transferred.

• For analytical purposes: We may use Your information for research, analytics and development purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Product, products, services, marketing and Your experience.

We May Share Your Personal Information in The Following Situations

• For business transfers: We may share or transfer Your personal information in connection with any merger, sale of Developer assets, investiture, financing, or acquisition of all or a portion of Our business to another legal entity in which Personal Data held by Us about our Product users is among the assets transferred.

• With Affiliates: We may share Your information with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy and the Law. Affiliates include subsidiaries, joint venture partners or other companies that We control, that control Us or that are under common control with Us.

• With consent: We may disclose Your personal information for any other purpose with Your consent.

What Actions Do We take on Your Personal Data?

Processing of personal data is any action (operation) or a set of actions (operations) with personal data performed with the use of automation tools or without their use. When processing personal data, We will carry out the following actions: collection; recording; systematization; accumulation; storage; clarification (update, change); extraction; usage; transmission (distribution, provision, access); depersonalization; blocking; deletion; destruction.

We may process personal information in the determined above ways (operations) both in automated systems and without using automation tools.

Updating, Correcting, Blocking and Deleting Personal Data. How to Revoke Consent and/or Request Data Deletion?

You’re free to do that at any time by contacting us at info@seneka.life; please refer to this Privacy Policy, as well as our Terms of Service, to understand how we treat information you provide to us after you have stopped using our Product.

Account termination may result in destruction of any content associated with your account, so keep that in mind before you decide to terminate your account. If you have deleted your account by mistake, contact us - we will try to help, but unfortunately, we can’t promise that we can recover or restore anything.

Provisions of this Policy that, by their nature, should survive termination, shall survive termination.

Retention of Your Personal Data

The Developer will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with the applicable Law), resolve disputes, and enforce our legal agreements and policies.

The Developer will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Product, or We are legally obligated to retain this data for longer time periods.

In the event that You withdraw consent allowing processing of personal data or the expiration of such consent, Data Operator has the right to block this data from further editing and retain it in the archived form for 5 (Five) years.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Developer's operating office and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Developer will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data.

Disclosure of Your Personal Data

Business Transactions

If the Developer is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances the Developer may be obliged to disclose Your Personal Data if required to do so by the Law or in response to valid and lawful requests by public authorities (e.g., a court or a government agency).

Other Legal Requirements

The Developer may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation;

• Protect and defend the rights or property of the Developer;

• Prevent or investigate possible wrongdoing in connection with the Product;

• Protect the personal safety of You or the public;

• Protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Data Operator takes all necessary measures to protect Your personal data from unauthorized, accidental or illegal destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing.

By default, personal information is processed by automatic equipment without anyone having access to it. If such access is required, Data Operator provides access to Your personal data only to those persons who need this information to ensure the Purpose of processing. To protect and ensure the confidentiality of data, such persons must undertake to comply with internal legal rules and procedures, state legislation, technical and organizational security measures in relation to the processing of personal information.

Both in the processing of personal data without the use of automation tools, and in automated processing, sufficient security of the place where the processing of personal data takes place is ensured.

The disclosure of the information provided by You can be made only in accordance with the current legislation at the request of the court, law enforcement agencies, and in other cases stipulated by the legislation.

We do not verify the accuracy of the information provided by You, and proceed from the fact that You in accordance with the principle of good faith provide reliable and sufficient information, take care of the timeliness of making changes to previously provided information, update the information when You feel the need to.

About Representatives

You have the right to allow, restrict or prohibit the processing of personal data of third parties only on the basis of a representation established by the Law (for example, parents and guardians) or by a transaction of rights (for example, a power of attorney), which give You the right to give consent to the processing of personal information of a third party and bear other rights and obligations in the interests of a third party. If You do not have the right to give such consent or if You have lost the right to give such permissions, then please refrain from data transferring or stop data transferring (and delete previously transferred data), respectively, and in the event of relevant claims, You undertake to independently resolve the contradictions and release Us from such claims.

Access to Your Personal Data by Third-party Services

Some Third-party services We use will have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity in accordance with their Privacy Policies, linked here. We will do our best to provide that any entity that will have access to Your Personal Data will provide the same or equal protection of Your data as stated in this Privacy Policy.

Automated Analytics

We may use technologies provided by third-parties to monitor and analyze the use of the Product.

• Google Firebase

  Google Firebase is a service offered by Google Inc (1600 Amphitheatre Parkway, Mountain View, CA 94043, U.S.) that tracks and reports Product traffic. It uses the data collected to track and monitor the use of our Product. This data is shared with Google Inc.

  Their Privacy Policy can be viewed at https://policies.google.com/privacy.

• Adapty

  Adapty is a service offered by Adapty Tech Inc (2093 Philadelphia Pike #9181 Claymont, DE 19703, U.S.) that tracks and reports Product traffic. It uses the data collected to track and monitor the use of our Product. This data is shared with Adapty Tech Inc.

  Their Privacy Policy can be viewed at https://adapty.io/policy.

• Amplitude

  Amplitude is a service offered by Amplitude Inc (201 3rd Street, Suite 200, San Francisco, CA 94103, U.S.) that tracks and reports Product traffic. It uses the data collected to track and monitor the use of our Product. This data is shared with Adapty Tech Inc.

  Their Privacy Policy can be viewed at https://amplitude.com/privacy.

Payments

We may provide paid functions and/or services within the Product. In that case, We may use third-party services for payment processing (e.g., payment processors).

We will not store or collect Your payment details. That information is provided directly to Our third-party payment processor whose use of Your personal information is governed by their Privacy Policy.

• Apple Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy.

• Stripe Their Privacy Policy can be viewed at https://stripe.com/privacy.

When You use Our Product to pay for a function and/or service via bank transfer, We may ask You to provide additional information to perform this transaction and to verify Your identity.

EU General Data Protection Regulation

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under GDPR under the following conditions:

• Informed consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Developer is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Developer.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Developer.

Your Rights under the GDPR

You have these rights under this Privacy Policy and by the Law if You are within the EU:

• the right to be informed;

• the right of access;

• the right to rectification;

• the right to erasure;

• the right to restrict processing;

• the right to data portability;

• the right to object;

• the rights related to automated decision making (including profiling).

Exercising Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Union (EU), please contact Your local data protection authority.

Children's Privacy

Our Product is for many audiences and is not intended primarily for kids. We use reasonable efforts to ensure that before We collect any personal information from a child, the child's parent receives notice of and consents to our personal information practices.

We may ask You to verify Your date of birth before collecting any personal information from You. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information. We will ask for Your birthdate and parental/guardian contact information only for the purpose of complying with these legal procedures.

Information Collected from Children’s Device

The Developer may collect and store persistent identifiers such as cookies or IP addresses from children’s device without parental consent for the purposes of supporting the internal operation of the Product and complying with the legal procedure.

We may collect and store any other personal information about children if this information is submitted by the parent/guardian of the child, or by the child over the age of 13.

The Developer may collect and store the following types of personal information about a child when submitted by the parent/guardian of the child, or by the child over the age of 13:

• First and/or last name

• Date of birth

• Email address

• Parent's or guardian's name

• Parent's or guardian's email address

• Gender(s)

For further details on the information We might collect, You can refer to the "Types of Data Collected" section of this Privacy Policy. We follow our standard Privacy Policy for the processing of personal information collected from and about children.

Parental Access

A parent or a guardian who has already given the Developer permission to collect and use his child's personal information can, at any time:

• review, correct or delete the child's personal information;

• discontinue further collection or use of the child's personal information.

To make such a request, You can write to Us using the contact information provided in this Privacy Policy.

Notifications and Communication

We May:

• send You messages by email, telephone calls, SMS, web messenger, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;

• provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information;

  hereinafter referred to as "Notifications".

You Have the Right to Revoke Your Consent to Receive the Notifications

• by clicking on the “Unsubscribe” link at the bottom of the Notification;

• by sending a revocation Notification to Our email.

We stop sending the Notifications not earlier than 24 hours after the performance of these actions.

We Can Use the Notifications For:

• informing You about the operation of the Product;

• informing You about changes in legal documents;

• sending messages and mailings of informational character to You;

• sending messages and mailings of an advertising nature to You.

You May:

• send any digital messages, notifications, statements and documents (including messages that represent responses to prior Notifications) to Our email address specified in this Policy;

• send any documents in paper form to Our location address specified in this Policy.

Links to Other Resources

Our Product may contain links to websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for content, functions, privacy policies or practices of any third-party sites, applications or services.

Changes to Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page, unless otherwise provided by the new edition of the Policy. Expired ineffective editions are available in the archive. If We consider the changes very important, We may also let You know via email and/or a prominent notice within Our Product, prior to the change becoming effective.

By continuing to access or use the Product after any revisions become effective, You agree to be bound by the revised terms. If You do not agree to the new terms, You are no longer authorized to use the Product.

Governing Law and Legal Force

For legal purposes both expression of consent with this Policy and execution of this Policy shall be always considered happening at the Developer’s location, and the law applicable to Our legal relationship with You shall be always the law of the U.S., regardless of where You are located or where the equipment used by You or Us resides. All disputes and disagreements are resolved at the location of the Developer. The exception is when the legal relationship falls under the exterritorial criteria of GDPR. In such case, the law applicable to Our legal relationship with You shall consist jointly of the law of the U.S. and the rules of GDPR, including the rules of solving disputes and disagreements between the participants of personal data processing.

This Policy is effective at the moment You expresses informed consent to its terms and conditions and is valid indefinitely. The indefinite validity of the document itself does not in any way mean the indefiniteness/absence of restrictions on the period for processing personal data. Unilateral termination of this Policy by the sole will of one of its parties is not allowed.

Contact Us

SENEKA INC.

• By email: info@seneka.life

• By visiting this page on our website: seneka.life

• By mail: 16192 Coastal Highway, Lewes, Delaware 19958, U.S.