Privacy Policy of Playbrush

Privacy Policy of Playbrush

Lies die Datenschutzbestimmungen auf Deutsch: www.playbrush.com/datenschutz

  1. WHAT IS THE SCOPE OF THIS PRIVACY POLICY

1.1. This Privacy Policy applies to the collection, administration and transfer of personal data of a user by

Playbrush GmbH, Alserbachstrasse 2/9, 1090 Vienna, Austria („Playbrush Austria“), as well as

Playbrush Ltd, 103c Camley Street, N1C 4PF, London, United Kingdom, („Playbrush UK“).

 

Playbrush Austria and Playbrush UK are collectively referred to as “Playbrush”.

 

1.2. This Privacy Policy applies to the collection, storage, administration, processing and transfer of personal data of users by Playbrush UK and/or Playbrush Austria in the course of

a) the purchase of Playbrush products through a Playbrush website under the domain www.playbrush.com and its subdomains (hereinafter collectively the “Playbrush Website”);
b) the registration of a user for one of Playbrush’s subscription services;
c) the use of one of Playbrush Mobile Applications; and
d) the use of the Playbrush Website, only in the form of data collection through Cookies (see section 8. below).

 

No personal data is collected by Playbrush at the occasion of a user (i) purchasing a physical Playbrush product through a retailer (i.e. other than through the Playbrush webshop), whether in an online or brick-and-mortar store. However, in order to use a Playbrush product in combination with a Playbrush Mobile Application, registration is mandatory.

 

The Playbrush Mobile Applications encompass all games made available by Playbrush in in mobile app shops, in particular the games

 

  • UTOOTHIA
  • UTOOTHIA SKY
  • UTOOTHIA MAGIC
  • UTOOTHIA PAINT
  • UTOOTHIA DANCE
  • PLAYBRUSH

 

(these, along with future mobile app releases by Playbrush, collectively the “Playbrush Mobile Applications”),

 

as well as all Playbrush Web-applications, including

 

  • the Playbrush Dashboard, which allows parents to monitor the Brushing Data of their children – for details on how the Playbrush Dashboard works, please see https://www.playbrush.com/terms.

 

1.3. Playbrush has implemented appropriate technical and organisational measures to ensure that all data processing is performed in accordance with applicable data protection legislation, and that all user data is protected against breaches, loss or manipulation. Please note that users are themselves responsible for the adequate security and protection of their log-in data (username and password).

 

1.4. Any person providing his or her consent to this Privacy Policy represents that he/she is at least 16 years of age. Playbrush reserves the right to verify the user’s age at registration or at any time thereafter. In case one or more of the users using a Playbrush Mobile Application are children under the age of 16, the registering user hereby represents that he/she is the holder of parental responsibility for these children and provide his consent to the use of all personal data as set forth in this Privacy Policy for these children as well.

 

  1. WHAT KIND OF PERSONAL DATA IS COLLECTED BY PLAYBRUSH

 

Personal data is data that may by itself or in connection with other data be attributed to a particular person. Depending on a user’s actions, Playbrush collects the following personal information, either automatically or as submitted by users:

(a) Purchase of Playbrush products on the Playbrush Website

In the course of a user’s purchase process of a Playbrush product on the Playbrush Website, users submit the following personal data to Playbrush Austria:

  • First and last name
  • Billing address
  • Delivery address
  • Email address
  • Phone number

This personal information is saved by Playbrush in combination with the specification of the product purchased. It is exclusively used for the fulfillment of the specific order, i.e. shipping of the ordered Playbrush products to the client.

Moreover, in the course of a purchase, the user will also be prompted to provide his payment details via third party payment providers such as Stripe, Braintree, PayPal, Klarna; however, this data is not provided to Playbrush. Rather, the user is forwarded to the respective third party payment providers to effect such payment. This data and the authorization to take recurring payment will be stored by the respective payment providers for the purpose of fulfilling the order, but will not be made accessible to Playbrush.

(b) Use of a Playbrush Mobile Application

In the course a user’s registration for the use of a Mobile Application, Playbrush UK is collecting the following personal data as submitted by the user, which is attributable to the specific registered user:

  • Selected Username (note that under one subscription, multiple usernames may be selected, one for each player profile)
  • Selected password
  • Billing address
  • Phone number (optional)
  • Indicated Email-address (will not be verified)

In addition, upon registration Playbrush UK is collecting the following personal data in connection with the specific registered user:

  • Country the request is made from (from region set on the device used, to determine language)
  • Hardware Identification Number of the Playbrush device used (through Bluetooth)

(c) Use of the Playbrush device

Finally, when using a physical Playbrush device, Playbrush UK is collecting the following non-personal data, irrespective of whether the user is registered or not:

  • Duration of every brushing
  • Time and frequency of brushing
  • Method of brushing(direction and speed)
  • Pressure (for electric toothbrush product only)

(hereinafter and above collectively “Brushing Data”)

 

NOTE: Only when used in connection with a Playbrush Mobile Application, the Brushing Data is attributed to the selected username.

(d) Use of Playbrush Website

Whenever a user uses the Playbrush Website – this includes a mere visit of the website without making a purchase or other interaction – the following data is collected through the Cookies and Plugins:

  • IP-address (non-anonymized)
  • Browser information
  • Browsing information, including the duration of each visit to the Playbrush Website and each sub-site, cursor movements, keystrokes
  • Country
  • Device used
  • Previous domain visited
  • Time spent on each site
  • Log-in status of social networks (Google, Facebook)

 

  1. INFORMATION ON PLAYBRUSH USE OF DATA THAT DOES NOT REQUIRE CONSENT

 

Playbrush cannot carry out all of its data processing on its own. For the purpose of performing contract obligations with its users, Playbrush is using the services of trusted third parties. These partners of Playbrush have implemented appropriate technical and organizational measures to ensure the protection of your data.

The following cases of data usage and transfer are not subject to a user’s consent under applicable data protection legislation, either because they are required for the performance of contracts only or because they involve only anonymized, non-personal data. Nonetheless, for reasons of transparency, we hereby inform about how this data is used:

  • Contract performance: Playbrush itself will use the Email address submitted to send out an order confirmation and for possible subsequent coordination/complaints regarding the order itself and the shipping process.
  • Website: The Playbrush Website is hosted at
    • AMAZON WEB SERVICES, Ireland/USA
  • Data storage: All of the personal data collected by Playbrush is stored securely at servers of the following companies:
    • AMAZON WEB SERVICES, Ireland/USA
    • M LAB, USA
  • Purchases: For the purpose of effecting a purchase on the Playbrush Website, personal data is stored with the host of the Playbrush Webshop:
    • SHOPIFY, Canada
  • Shipping: To ship the ordered products, Playbrush will provide the name, physical address and phone number to the following logistics company:
    • SUXESS LOGISTICS, Hungary
    • Note that SUXESS LOGISTICS may be required to pass this personal data on to another shipping company delivering the products.
  • Payment: Playbrush does not receive any data on payment details in the course of a purchase. Rather, the user is forwarded to a third party effecting such payment. For the purpose of effecting payment, the user will him-/herself submit its payment details to:
    • STRIPE, USA
    • KLARNA, Sweden
    • PAYPAL/BRAINTREE, USA
  • Billing: For billing purposes, Playbrush will provide the name, Email address and billing address to either of the following:
    • BILLOMAT, Germany
    • XERO, New Zealand
  • Recurring payments: In case users choose not just a one-time purchase, but a subscription for a periodic delivery of tooth brushing products, the personal data is provided to the following entities to store the data and effectuate recurring payments and recurring shipments:
    • RECHARGE, USA
    • AMAZON WEB SERVICES, Ireland/USA
    • PAYPAL/BRAINTREE, USA
  • Support: In case a user posts a question or comment in the Q&A/Help & Support section on the Playbrush Website, the specific question and user data (Email address, Name, Username) is provided to the following companies, who assist Playbrush to provide user feedback:
    • FRESHDESK, USA
    • SNAPENGAGE, USA
  • Research & Statistics: We provide non-personal, anonymized Brushing Data to our partner UNILEVER, France. Before providing this Brushing Data to Unilever, Playbrush ensures that it is anonymized and cannot be traced to a specific username or to a person in any way. Unilever uses this Brushing Data to for statistics and research to evaluate how toothbrush products are used, but not for any personalized marketing or profiling purposes.

 

  1. CONSENT TO DATA COLLECTION, PROCESSING AND TRANSFER

Depending on the user’s actions, the user grants his/her consent to the collection, processing, and transfer of personal data by Playbrush as follows:

In the course of registering for the use of the Playbrush Mobile Applications, the user’s consent to Playbrush’s data use is required. By ticking the checkbox “I agree with the terms and conditions and with the privacy policy” when first using a Playbrush app downloaded from the user’s mobile app store, the user consents to the collection, processing and transfer of the respective user’s personal data by Playbrush as follows:

(a) Processing of data by Playbrush

 

Use of data by Purpose Personal Data involved

PLAYBRUSH AUSTRIA

and

PLAYBRUSH UK

–        Technical support to users;

–        Prevention and discovery of fraud;

–        Storage for the purpose of comparing data collected through the mobile Playbrush applications relating to tooth brushing performance with data of other users by graphic representation under the respective selected alias name;

–        Analysis of the collected Brushing Data relating to tooth brushing performance for the development of personalized advice for the respective user to enhance performance, which is provided to the user in the course of the respective mobile Playbrush application or within the Playbrush Dashboard application;

–        Analysis of the collected Brushing Data relating to tooth brushing performance by aggregating it with other users’ data for the research of tooth brushing behavior and improvement possibilities in general;

–        Storage of Brushing Data for the purpose of in-app advertisement: based on the tooth brushing performance (frequency, duration, accuracy), users receive reminders within the respective Playbrush Mobile Application to use their Playbrush or download further games;

–        Storage of Brushing Data relating to tooth brushing performance and aggregation of this data from multiple Playbrush Mobile Applications of a respective user to make it accessible and graphically represent it to the respective user (or in case of minors to his legal representative) on the web application Playbrush Dashboard. Through this application, parents are given the opportunity to view the accumulated data of their children on the Playbrush.com Platform, to attribute them to the user profiles and compare them. Thereby the data is graphically represented and feedback about the tooth brushing performance is provided. Game profiles in Playbrush Dashboard are always attributed to the profiles of the respective children (only by use of the selected alias-name). The data is only made accessible to the respective user (or in case of minors to his legal representative) and not to third parties. The Brushing Data is always saved with a game profile in one of the respective mobile Playbrush applications in connection with the Hardware Identification Number of the Playbrush device, so it is clearly attributable.

Customer Email, Name, Username, Encrypted Password, Browser, Platform, Language, IP Address, Brushing Data.
 
Transfer of data Purpose Personal Data involved

From PLAYBRUSH AUSTRIA

to

PLAYBRUSH UK

 

And

 

From PLAYBRUSH UK

to

PLAYBRUSH AUSTRIA

As set forth in section 2., some personal data is collected by PLAYBRUSH AUSTRIA (in particular data provided through the Playbrush Website) and some data is collected by PLAYBRUSH UK. For the processing of this data for the purposes listed in this table above, the user provides his consent that this data is shared between PLAYBRUSH AUSTRIA and PLAYBRUSH UK to the extent necessary to provide services to users. Customer Email, Name, Username, Encrypted Password, Browser, Platform, Language, IP Address, Brushing Data.

 

(b) Purchase of Playbrush products on the Playbrush Website

In the course of a user’s purchase process of a Playbrush product on the Playbrush Website, users are required to accept the Playbrush Terms & Conditions and this Privacy Policy. Thus, by ticking the checkbox “I agree with the terms and conditions and with the privacy policy”, a user consents to the collection, processing and transfer of the respective user’s personal data as follows:

 

Transfer of data to: Purpose: Personal Data involved
ZAPIER, USA Does not store data, but used to transfer data to MAILCHIMP Email address, Name, Username
MAILCHIMP, USA For initial onboarding emails, to help user activate the Playbrush Email address, Name, Username
REFERRAL CANDY, USA

Referral Candy is a tool that emails existing customers and offers them rewards for onboarding new customers.

By accepting this Privacy Policy, users also provide their consent to receive Emails offering them further rewards by Playbrush through Referral Candy. Users have the right to withdraw this consent at any time – independent from their use of other services by Playbrush. To withdraw, please Email [email protected]

Email address, Name, Username

(c) Order of Newsletter

In case a user subscribes for the Playbrush Newsletter by entering his/her Email address and clicking “SIGN UP” on the Playbrush Website, the user consents to the collection, processing and transfer of the respective user’s personal data as follows:

Transfer of data to: Purpose: Personal Data involved
ZAPIER USA Does not store data, but used to transfer data to MAILCHIMP Email address, Name, Username
MAILCHIMP USA MAILCHIMP is used to distribute the Playbrush newsletter to subscribers Email address, Name, Username

 

(d) Registration for a Playbrush Mobile Application

In the course of registering for a Playbrush Mobile Application, the user’s consent to this Privacy Policy is required. By ticking the checkbox “I agree with the terms and conditions and with the privacy policy” when first using a Playbrush app downloaded from the user’s mobile app store, the user consents to the collection, processing and transfer of the respective user’s personal data as follows:

 

Transfer of data to: Purpose: Personal Data involved
MAILCHIMP, USA

For initial onboarding emails, to help user activate the Playbrush; to send weekly updates on results analyzed from Brushing Data and upsell offers. By accepting this Privacy Policy, users also provide their consent to receive Emails by Playbrush through Mailchimp:

(a)   on a weekly basis with a summary of the duration and frequency of the Brushing Data and offering them further rewards on their Brushing Data; and

(b)   for users without a subscription, Emails containing offers to enlist for a subscription.

Users have the right to withdraw this consent at any time – independent from their use of other services by Playbrush. To withdraw, please Email [email protected]

Email address, Name, Username

(e) Transfer to Playbrush Partners

By ticking the checkbox “I agree with the terms and conditions and with the privacy policy” when first using a Playbrush app downloaded from the user’s mobile app store, the user consents to the collection, processing and transfer of the respective user’s personal data to Playbrush’s commercial partners as follows:

 

Transfer of data to: Purpose: Personal Data involved
UNILEVER, France

Unilever will contact users via Email to inform them about new oral care products from Signal / Mentadent C and other Unilever brands.

 

By accepting this Privacy Policy, users also provide their consent to receive Emails from UNILEVER containing information about new oral care products from Signal and other Unilever brands. Users have the right to withdraw this consent at any time – independent from their use of other services by Playbrush. To withdraw, please Email [email protected] or directly to Unilever

Email address, actual name

 

(f) Application for Insurance

In case a user explicitly requests dental insurance services by UNIQA, Austria, on the Playbrush Website, the user consents to the collection, processing and transfer of the respective user’s personal data as follows:

Transfer of data to: Purpose: Personal Data involved
B Surance, Austria B Surance is an insurance broker and works as an intermediary for the purpose of collecting and passing this personal data on to UNIQA, Austria, who will then use it to contact the users regarding their request for insurance and draft an insurance offer. Email address, Name, Child Name and Date of Birth, Username, Residence Country

 

(g) Use of Playbrush Website

In case a user uses the Playbrush Website – this includes a mere visit of the website without making a purchase or other interaction – the user consents to the collection (including through Cookies and Plugins, as set forth in section 7. below), processing and transfer of the respective user’s personal data as follows:

Transfer of data to:

Purpose:

Personal Data involved

FACEBOOK, USA

To analyse the user behaviour and to send specialized offers via the Facebook networks.

IP Address, location, device, sites visited

GOOGLE ANALYTICS; USA

To analyse the user behaviour for the internal analysis to improve our products and the website experience.

IP Address, location, device, sites visited

GOOGLE ADWORDS, USA

To analyse the user behaviour and to send specialized offers via the Google networks, including Google platforms such as YouTube.

IP Address, location, device, sites visited

HOTJAR, USA

To better understand our users’ needs and to optimize this service and experience

 

Users can opt-out from the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link: (https://www.hotjar.com/legal/compliance/opt-out ).

Data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website)

CartHook; USA

If a user initiates a purchase, provides his Email address, and follows the checkout process, but does not finish the purchase, Playbrush, through CartHook, sends them follow up emails

Email address

Abandonment Protector / ChiliApps, USA

If a user initiates a purchase, provides his Email address, and follows the checkout process, but does not finish the purchase, Playbrush, through Abandonment Protector / ChiliApps, sends them follow up emails

Email address

Semrush; USA

To analyse the user behaviour for the internal analysis to improve our products and the website experience.

IP Address, location, device, sites visited

 

(h) Transfer of data to third countries

Playbrush processes your data in countries where the EU Commission has established an adequate level of data protection. For recipients of data based in countries where the EU Commission has not established an adequate level of data protection, such as recipients based in the USA as set forth in this section 4., Playbrush has ensured an adequate level of data protection by providing for appropriate safeguards, in particular, by entering into agreements with the recipients of personal data based on so called EU standard contractual clauses issued by the European Commission pursuant to Art. 46 para. 2 GDPR.

  1. USER RIGHTS

You have the following rights in connection with the processing of your personal data. Any of the following rights may be exercised by sending a specific Email outlining your request from the Email-address registered with your username to [email protected].

5.1 You have the right to information about the personal data stored by Playbrush. This means that you may have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

5.2 You may have the right to obtain a copy of the personal data undergoing processing.

5.3 You have the right to have incorrect personal data corrected. This means that you may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

5.4 You have the right to fully or partially withdraw the consent granted to Playbrush’s data use under this Privacy Policy at any time or to request a restriction on the processing of your personal data. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. If requested, we will stop processing or transferring the data as outlined in this Privacy Policy. If such partial or full withdrawal makes it impossible or impractical for Playbrush to perform its services to you, Playbrush reserves the right to terminate the contract relationship, provided your payments already made are adequately refunded.

5.5 You have the right to have your personal data deleted. If requested by the user, all personal data relating to the user will be terminally deleted.

5.6 You have the right to data portability, i.e. to receive the data concerning you in a structured, commonly used and machine-readable format and have Playbrush transmit this data to another controller.

5.7 You also have the right to lodge a complaint with the competent data protection supervisory authority, in particular in the EU Member State of your habitual residence or of an alleged infringement of data protection legislation

  1. HOW LONG DOES PLAYBRUSH STORE THE PERSONAL DATA COLLECTED?

All personal data collected by Playbrush will be stored only as long as required to perform the contract with users as set forth in section 3. above or for the purposes set forth in section 4., but in no case longer than 5 years, unless a longer storage is required by law (e.g. 7 years for tax and auditing purposes for billing data).

  1. PLUGINS AND WIDGETS FOR SOCIAL MEDIA

7.1. The Playbrush.com Platform as well as the mobile Playbrush applications may include social media plugins, such as (i) Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA; or (ii) Twitter, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, (iii) Instagram, or (iv) Google +, 1600 Amphitheatre Parkway, Mountain View, CA 94043.

7.2. Such plugins can recognize a user’s IP address and the page visited on the Playbrush.com platform, and, possibly, store cookies, so that the services offered by Playbrush work properly. Social media plugins and widgets are hosted either by third party providers or directly by us. By using these functions not personal data is transferred to Playbrush. Your interactions with these plugins are subject to this privacy policy or the privacy policy of any third party that offers such feature. Playbrush is not responsible for the use of, or guidelines regarding the use of, personal data by third party providers.

7.3. Users may recognize the respective plugins, e.g., by the respective logo or other respective characteristic typical for the respective social media-platform on our pages. You can find an overview of Facebook-plugins here: http://developers.facebook.com/docs/plugins/. You can find an overview of Twitter-plugins here: https://dev.twitter.com/web/overview. You can find an overview of Instagram-plugins here: https://instagram.com/developer/. You can find an overview of Google+-plugins here: https://developers.google.com/+/web/.

7.4. If a user interacts with the plugins, e. g. by clicking on the Facebook “Like-Button” or entering a comment, while being logged in to such user’s Social Media-account on Facebook, Twitter, or Instagram a user links the contents of the Playbrush pages to her respective social media-profile. Thereby, Facebook/Twitter/Instagram/Google+ can associate a user’s visit of the Playbrush page with such user’s social media-account. Playbrush as the provider of the Playbrush.com platform does not have any knowledge of the content of the transmitted data or its usage by Facebook, Twitter, Instagram or Google+. Users can find more information on that issue in the privacy policy of the respective social media-platform:

Facebook: http://www.facebook.com/about/privacy/

Twitter: https://twitter.com/privacy

Instagram: https://instagram.com/about/legal/privacy/?hl=en

Google+ http://www.google.com/intl/en/policies/privacy/:

7.5. If users do not want to have the respective social media-platform associate their visits on our site with their social media-account, users must log out from their social media-account.

  1. COOKIES

8.1. Several areas of the Playbrush website use ‘cookies’ ─ small text files that are placed on the user’s computer and stored by the browser. They are used by Playbrush to provide a more user-friendly, effective and secure service. Cookies also enable Playbrush to identify a user’s browser and offer services to such user. Some Cookies may contain any personally identifiable information or permit any conclusions on personal data.

8.2. You can prevent the installation of cookies by entering the corresponding settings in your browser software. However, please note that in this case you may not be able to use the complete range of functions of the Playbrush.com platform to its full extent.

  1. GOOGLE ANALYTICS

9.1. The Playbrush.com platform uses Google Analytics, a web analysis service by Google Inc. (“Google”). Google Analytics uses ‘cookies’ (see Section 8, above). The information about your visit collected by the cookies, including your full IP address (not anonymized), is usually transferred to a Google server in the USA and saved there. Google will use the information collected on behalf of the website operator to evaluate your use of the Playbrush.com platform, to compile reports about your activities within the Playbrush.com platform, and to provide further services to Playbrush related to use of the Playbrush.com platform and Internet use. Google will under no circumstances associate the IP address transmitted by your browser within the operations of Google Analytics with other Google data.

9.2. You can prevent the data related to your use of the Playbrush.com platform, including your IP address, generated by the cookies from being recorded by Google and Google’s processing of this data by downloading and installing the browser plugin from the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

9.3. Furthermore, you can prevent the future data capture by setting an Opt Out-Cookie via the following link: https://tools.google.com/dlpage/gaoptout/ Further information regarding terms of use and privacy provisions may be found on the websites http://www.google.com/analytics/terms/us.html and https://www.google.de/intl/en/policies/.

9.4. The Playbrush.com platform uses Google DoubleClick for Publishers (“DFP”). DFP uses Cookies to provide the user with user-relevant advertisements – further information may be found at https://support.google.com/dfp_premium/answer/2839090?hl=en.

The user may disable the DFP’s cookie placement and the placement of user-relevant advertisements via the website: http://www.google.com/ads/preferences.

9.5. Playbrush.com uses retargeting technology of Google Inc. This technology allows us to show users, who visited our website, adverts on websites of the Google Partner Network. We do this by analyzing user behavior from data collected by our cookies. This information is anonymous, with no personal information being stored.

  1. CHANGES TO PRIVACY POLICY

10.1. Playbrush reserves the right to amend this Privacy Policy from time to time for a number of reasons including, without limitation, for commercial reasons, to comply with applicable law or regulations, or for customer service-reasons. At any time, the then-current version of this Privacy Policy is available for viewing on the Playbrush.com platform.

10.2. Changes to this Privacy Policy require the consent of the respective user. If Playbrush intends to implement such changes to this Privacy Policy, Playbrush will give the user as much prior notice of such changes as possible. Such notice shall be made (i) via email to the email address the user previously supplied, (ii) on the relevant pages of the Playbrush.com platform, or (iii) on any other device through which the user accesses the Playbrush services. We may invite the user to accept the new Privacy Policy by clicking “yes” or “I accept”, checking a “tick box” or any other similar method of confirmation.

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Contact

Our friendly support team look forward to hearing from you
[email protected]