Privacy Policy for Space For Kidz

Effective Date: 2023-06-01

1. Introduction

Welcome to Space For Kidz (the "App"). This App is published by Prime Studios LLC ("Publisher," "we," "us," or "our") and is owned by the City of Kent ("Owner"). We are dedicated to protecting the privacy of all users, especially children. This Privacy Policy outlines our practices concerning the collection, use, and disclosure of information through the App. This policy is designed to comply with the Google Play Store's requirements, including those pertaining to children's privacy, such as the Children's Online Privacy Protection Act (COPPA) in the United States and the General Data Protection Regulation (GDPR) in Europe.

Please read this Privacy Policy carefully. By downloading, accessing, or using the App, you agree to the terms of this Privacy Policy. If you are a parent or guardian, you provide your consent to our privacy practices on behalf of your child by allowing them to use the App.

2. Information We Collect

We aim to collect as little personal information as reasonably necessary to provide and improve the App. The information we may collect includes:

2.1. Information Your Child May Provide

The App is designed so that children do not typically need to provide personal information to use its core features. We do not knowingly collect personal information that your Child directly provides within the App, such as full name or email address, unless it is for a specific feature clearly explained at the point of collection and, where required by law, with verifiable parental consent.

2.2. Information Collected Automatically

To enable the augmented reality (AR) features and ensure the App functions correctly, certain information may be collected automatically:

• Camera Access: The App requires access to your device's camera to provide its augmented reality experiences. The camera images are processed in real-time on your device to overlay digital content onto the real world. We do not store the camera images or videos on our servers or share them with third parties, except as may be processed by essential third-party SDKs (like Unity) as described below for the functioning of AR features. The camera is only active when the AR features of the App are in use.
• Device Information (via Unity): The App is developed using the Unity software. Unity may collect certain device information automatically, such as device type, operating system, IP address, and other technical information necessary for providing and improving their services and for the App to function. We encourage you to review Unity's privacy policy (linked in Section 5).
• Usage Data (via Unity): Unity may collect anonymized or aggregated data about how the App is used, such as features accessed and crash reports, to help us and Unity improve the App and the Unity engine.
• Advertising ID: The App does not collect or transmit the Android Advertising ID (AAID) or any other persistent identifiers for our own advertising purposes. However, third-party SDKs like Unity might collect such identifiers as per their own privacy policies; please review their policies for details on their data collection and use for advertising, if any.

Important Note on Identifiers for Children: For users known to be children, any persistent identifiers collected (e.g., by Unity) should, according to applicable laws like COPPA, only be used to support the internal operations of the App (e.g., providing app functionality, maintaining security, performing analytics to improve the app, and ensuring legal compliance). We do not use such identifiers for behavioral advertising targeted at children.

3. How We Use Collected Information

The information we collect is used for the following purposes:

• To Provide and Maintain the App: Ensuring the App functions correctly, delivering its content, and providing the augmented reality features.
• To Improve the App: Analyzing usage data (often via tools provided by Unity) to understand user needs, enhance user experience, and develop new features.
• Personalization (Limited): To personalize the App experience (e.g., remembering game progress or settings locally on the device). This personalization is not based on tracking children across apps or services.
• Customer Support: To respond to user inquiries, troubleshoot problems, and provide assistance.
• Security and Legal Compliance: To protect the safety and security of our users and the App, to enforce our terms, and to comply with legal obligations.

4. How We Share Information

We do not sell personal information, especially information from children. We may share information collected through the App only in the following limited circumstances:

• Service Providers (including Unity): We use the Unity engine to develop and run the App. As such, Unity Technologies and its affiliates may collect and process data as described in their privacy policy (see Section 5). This is essential for the App's functionality, including its AR features. We do not share camera images or videos collected by the App for AR with other third parties. Other service providers (e.g., for cloud hosting, if applicable, though not currently used for data storage from this app) would be contractually obligated to protect information and use it only for the services they provide to us.
• Legal Requirements: We may disclose information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend our rights or property, protect the personal safety of users or the public, or protect against legal liability.
• Business Transfers: If Prime Studios LLC is involved in a merger, acquisition, or sale of all or a portion of its assets, user information may be transferred as part of that transaction. We will provide notice before personal information is transferred and becomes subject to a different privacy policy.
• Owner (City of Kent): Aggregated or anonymized usage data (e.g., from Unity Analytics, if configured) that does not personally identify any individual child may be shared with the City of Kent for purposes of evaluating the App's effectiveness and understanding user engagement.

5. Third-Party Services and SDKs

The App is developed using the Unity software and may utilize Unity's services (e.g., for AR functionality, analytics, diagnostics). Unity Technologies and its affiliates may collect data from users of the App as described in their privacy policy.

• Unity Technologies: The App uses the Unity game engine. Unity may collect device information, usage data, IP address, and other information as outlined in their privacy policy. This data is used by Unity to provide and improve their services, and by us to understand app usage and performance.
  • You can review Unity's Privacy Policy here: https://unity.com/legal/privacy-policy

We encourage you to review the privacy policies of these third parties. We are not responsible for the data collection and use practices of third parties like Unity, but we rely on their services for the App to function.

6. Advertising

The App does not contain any third-party advertising placed by Prime Studios LLC. Unity's services, as a third-party SDK, might have their own advertising practices if certain Unity services are enabled; please refer to Unity's privacy policy for details.

7. Data Security

We take reasonable measures to protect the integrity and security of the App itself. Camera data for AR is processed on the device and not stored by us. For data collected and processed by Unity, please refer to Unity's privacy policy for their security measures. While we strive to protect user information, no method of transmission over the internet or method of electronic storage is 100% secure.

8. Data Retention and Deletion

Prime Studios LLC does not directly store personal information or device data from users of this App, other than what might be processed ephemerally on the device for AR. Data collected by Unity is subject to Unity's data retention policies. Please refer to Unity's privacy policy for information on how long they retain data and how you might request deletion of data they hold.

If you have concerns about data collected by Unity, we recommend contacting Unity directly as per their privacy policy.

9. Children's Privacy (Specific Disclosures)

The App "Space For Kidz" is designed for children. Our practices are guided by the Children's Online Privacy Protection Act (COPPA), GDPR, and other applicable children's privacy laws and regulations.

• We require camera access solely for the AR features, and this data is processed on the device. We do not store these images or videos.
• We do not knowingly collect personal information from children beyond what is necessary for the app's functionality (e.g., camera access for AR, data collected by essential SDKs like Unity) without verifiable parental consent, unless permitted by law.
• We do not condition a child's participation in an activity on the child disclosing more personal information than is reasonably necessary to participate in that activity.
• Parents/guardians have rights regarding their child's personal information, as detailed in Section 11.
• If we discover we have inadvertently collected personal information from a child in a manner inconsistent with legal requirements, we will promptly delete the information we control.

10. Links to Other Sites or Apps

The App does not contain links to other websites or apps, other than potentially to Unity's privacy policy as referenced herein.

11. Parental Rights and Controls

As a parent or guardian, you have rights regarding your child's personal information. While Prime Studios LLC does not directly collect or store extensive personal data from this app, data is processed by Unity.

• Access to Camera: You can control the App's access to the camera through your device's permission settings. Disabling camera access will prevent the AR features from working.
• Data Collected by Unity: For information collected by Unity and to exercise your rights regarding that data (such as access, review, or deletion), you should consult Unity's Privacy Policy and follow their procedures for making such requests.
• Contact Us: If you have any questions or concerns about our privacy practices or how they relate to your child's use of the App, please contact us using the details in Section 13.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App's features, or applicable laws (including changes to Unity's policies). If we make material changes, we will provide notice through the App or by other means (such as by posting a notice on our website or in the app store listing) before the change becomes effective. We encourage you to review this Privacy Policy periodically for any updates.

Your continued use of the App after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact the Publisher:

For matters specifically related to the ownership of the App, the Owner is the City of Kent. Privacy-related inquiries concerning the app's operation should be directed to Prime Studios LLC.

14. App Publisher and Owner Information

This App, "Space For Kidz," is published by:

Prime Studios LLC

The owner of the App is:

City of Kent