Privacy Policy – App

Privacy Policy

Updated September 9, 2020.

1. Overview

At Grom Social, Inc., we are dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Privacy Policy covers the use of information collected by Grom Social related to your use of our website www.gromsocial.com and our mobile Grom Social applications.

To help ensure a rewarding experience for our visitors, we are providing you with this Privacy Policy that describes the information practices of the website and our mobile Grom Social App, including how we collect, use, and disclose personal information.

Although we acknowledge that no place is completely safe and no online safety measure will work all of the time, we are committed to providing a fun, entertaining, and safe website and mobile application for our users. We are dedicated to safeguarding personal information collected on the website and the mobile app. We work hard to ensure that our Privacy Policy and our information practices adhere to the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) and the General Data Protection Regulation (GDPR).

Grom Social is designed specifically for children under the age of 16. We are dedicated to protecting their privacy and handling any personal information we obtain with care and respect. COPPA requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 16 years of age. COPPA also requires that we obtain the consent of parents and guardians of children under 16 years of age prior to allowing them to use certain features of our website and mobile app. Below, we explain how we do that for these children. Also, when we use the term “parent” below, we mean to include legal guardians. When we use the terms “personal information,” “personally identifiable information,” or “personal data,” we mean information that can specifically identify you or your child.

Our Commitment to Children’s Online Safety Education

Grom Social is very committed to helping kids learn about proper netiquette and how to protect their privacy. Parents also have the ability to monitor their child’s activity on Grom Social by using the Parent Portal. Should a parent see child-generated content in any area of the app that they deem to be personally identifiable information (PII), they can request removal of the content by contacting us at support@gromdevelopers.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

As required by General Data Protection Regulation (GDPR), the following identifies the data controller and data protection officer.

  • Data Controller: Grom Social Inc
  • Data Protection Officer: Dan Putnam
  • Address: 2060 NW Boca Raton Blvd Suite 6 Boca Raton, FL 33431
  • Email: support@gromdevelopers.com

The FAQ section on our website is updated periodically with common questions and information, but if you have questions or concerns regarding this Privacy Policy, please email us anytime at support@gromdevelopers.com. To learn more about COPPA, you may consult this simple, one-page informational guide from the kidSAFE Seal Program www.kidsafeseal.com/knowaboutcoppa.html

2. THE INFORMATION WE COLLECT

There are two different methods of collecting data in the Grom Social App. The first is data entered by the user, and the second is data that is automatically obtained public information made available by visiting our website and/or downloading our mobile app.

Children must be registered members to access certain areas of the Grom Social Mobile App.

Automatically collected data

  • (1) Internet Protocol (IP) Address – this is a number identifier associated with your computer/device. We use this to verify your host or network interface and location by country origin only.
  • (2) Third-Party Advertisers/Analytics – Please refer to our third-party privacy policies listed below to see what information they collect.

 

Requested information at time of registration sign up for children ages under 16:

  • (1) Date of Birth (required): to clarify the age of the person interested in membership.
  • (2) Username/“Grom Name” (required): The name the child uses to log into the Grom Social Mobile App and the name that will be visible to other Grom Social members once registration is complete.
  • (3) Parent email address (not-required): The parent email address is used to contact and inform the parent about the child’s wish to participate in Grom Social, provides parents info to monitor and control their child’s account with the MamaBear Parenting App, and provides parents access to remove their email and child’s account from our system.
  • (4) Password (required): This is secret and only known by the user.

3.DATA SECURITY PRACTICES

Grom Social operates with collecting as little personal information as possible about your child. Even though we only collect limited personal information this information is kept behind firewall and SSL encryption. With this safety infrastructure in place, we still follow data security practices to make sure this data is secure.
Guidelines for Administration and IT teams

  • Each user/employee with access is background checked and signs a confidentiality agreement before obtaining their required access.
  • Each user shall be identified by a unique user ID so that individuals can be held accountable for their actions.
  • The use of shared identities is permitted only where they are suitable, such as training accounts or service accounts.
  • Each user shall read this data security policy and the logon and logoff guidelines, and sign a statement that they understand the conditions of access.
  • Records of user access may be used to provide evidence for security incident investigations.
  • Access shall be granted based on the principle of least privilege, which means that each program and user will be granted the fewest privileges necessary to complete their tasks.

Network Access

  • All employees and contractors shall be given network access in accordance with business access control procedures and the least-privilege principle.
  • Segregation of networks shall be implemented as recommended by the company’s network security research. Network administrators shall group together information services, users and information systems as appropriate

User Responsibilities
a. All users must lock their screens whenever they leave their desks to reduce the risk of unauthorized access.

b. All users must keep their workplace clear of any sensitive or confidential information when they leave.

c. All users must keep their passwords confidential and not share them.

Application and Information Access
a. All company staff and contractors shall be granted access to the data and applications required for their job roles.

  • All company staff and contractors shall access sensitive data and systems only if there is a business need to do so and they have approval from higher management.
  • Sensitive systems shall be physically or logically isolated in order to restrict access to authorized personnel only.

Access to Confidential, Restricted information

  • Access to data classified as ‘Confidential’ or ‘Restricted’ shall be limited to authorized persons whose job responsibilities require it, as determined by the Data Security Policy or higher management.
  • The responsibility to implement access restrictions lies with the IT Security department.

4. THE REGISTRATION PROCESS

Once the initial sign up process is completed, the child is granted access to their Grom Account with limited access. Once the parents email is supplied, the parent is emailed for email verification. Parent emails will be stored for 10 days from the day email is sent; however, if parental email verification is not provided within 10 days of the email being sent, the Parent email will be deleted from our system. Children will have the opportunity to resubmit the parent email again. The Parent will have the ability to delete the account by email. Non-Parent-Approved Grom members have limited access to app features as noted below.

During the registration process, we will collect and store certain information from you and your child. As described in this Privacy Policy, we only directly collect PII from members who have completed and verified accounts through this process. PII is kept private and is not shared publicly or with third parties except as described in this Privacy Policy.

5. ACCOUNT TYPES

There are FOUR account types on Grom Social App. Depending on your age and verifiable parental consent, each account type has specific limitations to access within the app. Below are the descriptions of each account type.

Privacy Policy - App 1

Grom Guest

This is a user who downloads the app but is not registered as a user. Grom Guest users will be allowed to watch streaming Grom TV content and will not be allowed to enter any data or interact with any Grom users or data. When Grom Guest users try to access these features, they will be prompted to register an account or sign in to an account.

Privacy Policy - App 2

Non-Parent-Approved Grom

A Non-Parent-Approved Grom is a child under the age of 16 who has registered on the Grom Social App, but parent approval process using our secure in-app payment method has not been completed by the parent. The Non-Parent-Approved Grom features will be limited as shown below in the Feature List Grid.

Privacy Policy - App 3

Parent-Approved Grom

As a parent you can choose to approve a child to become a Parent-Approved Grom, and are required to activate and/or approve their child’s account by verifiable parental consent. As required and approved by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) parents may provide verifiable parental consent using the secure one-time $1 in-app purchase for parent approval.

Privacy Policy - App 4

Grom Adult

Grom Adults CANNOT interact with ANY Grom accounts. A Grom Adult is someone over the age of 16 who is not a parent and is a registered member of the Site with limited access to the Site’s features as noted below in the features Grid. If you wish to register as a Grom Adult, you will be required to agree to the Site’s Privacy Policy and Terms and Conditions by activating your account.

6. FEATURE LIST

Grom Social users will be able to participate in the following activities depending on their Account Profile Type. However, once a parent or legal guardian has activated/approved their child’s Grom account, they will receive the information to access, monitor, and control their child’s Grom account from the MamaBear App.

Features:

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Add Real NameUsers can add their real name. This will not be seen by the public but will be used for search results when searching for a user in the app. Privacy Policy - App 9 Privacy Policy - App 10 Privacy Policy - App 9 Privacy Policy - App 9
Add SchoolUsers can add the school that they attend. This will help them to connect with other kids from their school. Privacy Policy - App 9 Privacy Policy - App 10 Privacy Policy - App 9 Privacy Policy - App 9
Follow Users

Users can follow other users and have users follow them. This lets users see all the public/private friend video posts that their friends post.

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Accept User Follow Request

Users can request to follow your child, and your child has the option to accept or deny their request.

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Like Content

Users can show they like something they find in the app by liking it.

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Stream Grom TV Shows

Stream full-length TV shows that are all curated and collected according to age-appropriate content and age-appropriate Internet safety messaging.

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Add Comments

Users can type comments on any public content that allows comments.

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Share Content

All the content in the app can be shared through Direct Message / Chat.

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Record Public 15 Second Video Post

Users can record videos from their phone for 15 seconds and save them for the public or solely their friends to view.

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Record Private 15 Second Video Post

Users can record videos from their phone for 15 seconds and save them, but these will not be viewable by any other users.

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Direct Message / Chat with Users

Users can participate in Direct Message / Chats with other Grom Users.

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Direct Message / Chat with Helpers

Users can participate in Direct Message / Chats with our Grom Helpers staff for support, advise, and Internet safety tips.

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Send Doodle

Users can create Doodle drawings and send them in Direct Message / Chat.

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Send Photo

User can send a photo from their phone in Direct Message / Chat.

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Add Description to Video Post

Users can add a description to their video post.

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Turn Off Funny Face Mask*

Users can turn off the Funny Face Safety Feature. This feature applies a mask to the user’s face, covering it to hide their identity in their video post.

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