Privacy Policy

SafeToNet (hereafter, “we”, “us”, “our”) is committed to respecting and protecting your privacy and values its relationship with you. We will be clear and transparent about the information we are collecting from you and what we will do with that information.

Please note that our privacy policy which is designed to be read by children, is available here.

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy sets out the basis on which we will process any personal data we collect from you that you provide to us when we contact you, when you visit our website at www.safetonet.com or when you use our mobile application ("SafeToNet App").

www.safetonet.com and the SafeToNet App (together, the "SafeToNet Services") are operated by SafeToNet Limited. We are registered in England and Wales under company number 08733316 and have our registered office at 40 Caversham Road Reading RG1 7BT United Kingdom.

We advise you to read this privacy policy carefully together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using your data. This privacy policy supplements the other policies and notices and does not override them.

Changes to this Privacy Policy and your duty to inform us of changes

This version of the Privacy Policy was last updated in December 2018. Historic versions of this policy can be obtained by contacting us.

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

It is important that the personal data we hold about you is accurate and current otherwise, for example, the SafeToNet Services may not work effectively. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our website and the SafeToNet App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. Data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. Personal data does not include data where the identity has been removed (anonymous data).

In order to use the SafeToNet Services, you may be required to provide certain information including but not limited to your name, contact details, payment details, information about your dependants and family members as well as information related to applications and mobile devices used when using the SafeToNet Services.

We may collect, use, store and transfer different kinds of personal data about you or your dependants which we have grouped together as follows:

Identity Data includes first name, last name, date of birth and gender.
Contact Data includes email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions as well as information about the operating system, platform and other technology on the devices you use to access the SafeToNet Services.
Profile Data includes your username and password, preferences and feedback responses.
Usage Data includes information about how you use our SafeToNet Services and data gathered through the operation of the SafeToNet Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Additional Information that you choose to share with us which may be considered personal data.

We collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may collect Special Categories of Personal Data about your dependant whilst providing the SafeToNet Services (this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We will only process Special Categories of Personal Data where we have your consent to do so and only for the purposes described when we asked for your consent and in this privacy policy. You will be asked to provide this consent when installing the SafeToNet Services on your device. Where the SafeToNet Services are installed onto your device and you are at least 13 years of age, your consent will be required for SafeToNet to process Special Categories of Personal Data. Where the SafeToNet Services are installed onto your device and you have reached the respective age of consent in your country of residence, your consent will be required for SafeToNet to process Special Categories of Personal Data. Where you are below the respective age of consent in your country of residence, your parent or guardian will be asked to provide their consent on your behalf. You can withdraw your consent by contacting us (see below).

Information about your device use

The nature of the SafeToNet Services is that, with your express consent, we collect and automatically analyse information about the applications running on, and communications sent from, a mobile device. This may include the mobile device of a child.

What happens if you fail to provide us with personal data?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

order our services;
create an account on our website or SafeToNet App;
request marketing to be sent to you; or
give us some feedback.

Automated technologies or interactions. As you interact with our SafeToNet Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive Technical Data from analytics providers such as Google which is based outside the EU.

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.

Where we use your personal data, we make sure that the usage complies with law and the law allows us to use personal data for a variety of reasons. These include:

where we need to perform the contract we are about to enter into or have entered into with you;
where we have obtained your consent (you can withdraw your consent by contacting us, see below);
where we need to comply with our legal or regulatory obligations;
where we need to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
where it is necessary for our legitimate interests, or those of a third party (and your interests and fundamental rights do not override those interests) including
allowing us to effectively and efficiently manage and administer the operation of our business; and
maintain compliance with internal policies and procedures.

4. Purposes for which we process your data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal ground we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and SafeToNet advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about new SafeToNet goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop/improve our products/services and grow our business)
To operate the SafeToNet App	(a) Technical (b) Usage (c) Profile	Performance of a contract with you
To provide the optional Digital Safety Indicator feature which generates automatic decisions including profiling (discussed below)	(a) Usage	Consent
To process special categories of personal data when processing keyboard outputs	(a) Usage	Consent

4.1 Profiling and automated decision-making

The optional Digital Safety Indicator feature available on the SafeToNet App uses automatic decision-making, including profiling, to indicate the device holder's digital safety. SafeToNet software analyses how a device is used, including the nature of the language typed on the keyboard, to generate the digital safety indicator representation. To ensure that the indicator is as accurate as possible, SafeToNet uses a number of mathematical and statistical measures that for ensure, for example, that the safety indicator ignores one off indicators. This safety indicator is shared with the relevant parent or guardian of the child using the Digital Safety Indicator feature, but the data analysed to provide the indication is never shared. The Digital Safety Indicator feature can either be switched on or off at any time by a parent or guardian or child which stops data being processed in this way. The rights listed in paragraph 9 below can be exercised at any time.

SafeToNet use the language typed on the keyboard by the child to provide the digital indicator but this language is never shared with a parent or guardian. Language typed onto the keyboard is anonymised because SafeToNet remove any data (like UDID / IMEI numbers) which could otherwise associate a device with an individual.

4.2 Marketing

You will receive marketing communications from us, if you have requested information from us or purchased services from us and where you have opted-in to receiving that marketing. We do not send marketing communications to children.

You can opt-out of receiving marketing messages at any time by following the opt-out links on any marketing message sent to you by us or by contacting us to inform us of your preferences using the details provided in paragraphs 9 and 10 below.

4.3 App and User Tracking

Based on your consent, we use the following analysis technologies to generate statistics on the use of the app, to optimize the user experience and to analyze user behavior:

Firebase SDK from Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Mixpanel SDK from Mixpanel Inc, 405 Howard St, Floor 2, San Francisco, CA 94105, USA

4.3.1 How it works

Based on online identifiers (including cookie identifiers), IP addresses, device identifiers, and customer-assigned identifiers, we record user behavior, which consists primarily of events occurring in our app and user properties. Events include, for example, the opening of individual pages or the selection of menu items; user properties include, for example, devices used or version numbers used.

On the SafeToNet website, other services may be used on a consensual basis:

Google Tag Manager from Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Faceboook pixel from Facebook Inc, 1601 S. California Ave Palo Alto, CA 94304, USA
By merging app and web information, we can create statistics on user behavior across different devices.

4.3.2 How to change your consent

You have the possibility to change your decision to collect usage data using the above mentioned services and technologies at any time.

App: You can enable or disable the modules in the app settings.
Website: You can view and change the current status of your cookie consent here.

After deactivation, no data is collected in the context of the respective user tracking.

5. Disclosure of your information

We may share your personal information with third parties, including those set out below or any other third parties notified to you, for the purposes set out in paragraph 3 above:

professional advisers including lawyers, bankers, auditors and insurers;
regulators and other authorities who require reporting of processing activities in certain circumstances;
third party agents/suppliers or contractors in connection with the processing of your personal information for the purposes described in this privacy policy. These third parties may include, for example, customer service providers, payment processors and IT service providers; and
fraud prevention agencies.

We do not allow our third-party service providers and advisors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and strict confidentiality obligations.

6. International transfers

Some of our data processors are based outside the European Economic Area ("EEA") so their processing of your personal data may involve the transfer of your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements and that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
where applicable, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We follow strict security measures and procedures to protect your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

However, please remember that the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you or any applicable regulator of a breach where we are legally required to do so.

We have installed secure-server software which encrypts all Personal Data. The encryption process takes the characters entered on the website and the SafeToNet App and converts them into bits of code that are then securely transmitted over the Internet. This is done using Secure Socket Layer certificates. As a result, if you provide us with any personal or financial details, no information will be transferred unencrypted.

As a condition of employment, SafeToNet employees are required to follow all applicable laws and regulations, including in relation to data protection law.

When you contact a SafeToNet employee in relation to your SafeToNet account, you may be asked for your personal information. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your personal information.

8. Data retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

SafeToNet shall store the following personal data relating to a parent or child:

name;
date of birth;
gender;
telephone number;
email address;
child's school name and school post code; and
geographical location.

This data will be promptly deleted from the live SafeToNet server by SafeToNet upon termination of a SafeToNet account or where deletion is requested by you (please see paragraph 9 for your right to erasure). This personal data is then deleted from the SafeToNet automatic backup system 12 months following the date of the account termination or request.

Any data which is retained for a period longer than 12 months, which for example may include keyboard outputs, is anonymised.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your Rights

Under the data protection laws, you have certain rights regarding your personal data, which include:

Right of information:

You have the right to receive certain information about our data collection and data processing activities.

Right to access:

This is commonly known as Subject Access Request and enables you to request and receive a copy of the personal data we hold about you.

Right to rectification:

You have a right to ask for modification or completion of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to object:

You can object to, or request that we restrict, our processing of your personal data in certain circumstances. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Right to withdraw consent at any time:

You can withdraw previously given consent for the processing of your personal data for the relevant purpose at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or any processing not based on your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the relevant purpose.

Right to be forgotten (right to erasure):

You can ask us to delete or remove your personal data at any time. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Where this right is exercised, we will delete your personal data from our live servers. Your personal data will then be deleted from our back-up systems 12 months after the request for erasure but your data will not be used by SafeToNet during that 12 month period, Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to data portability:

You can request a transfer of your personal data to a third party in an electronically usable (machine-readable) format. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request to restrict processing:

You may ask to restrict our processing of your personal data

(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right not to be subject to automated decision making:

You have the right not to be subject to automated decision-making (including profiling) which has legal or other significant effects on you.

Right to complain:

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country. In the UK, the Information Commissioner's Office (ICO), is the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

10. Contact us

If you want to exercise any of these rights, you can contact us via our data protection officer (DPO) at dpo@safetonet.com or send a request by post to

SafeToNet Limited,
40 Caversham Road Reading RG1 7BT United Kingdom

Telephone number: +44 203 950 3047.

Our DPO is also responsible for responding to any questions you may have in relation to this Privacy Policy.

We do not charge a fee if you exercise one of the above rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.