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PRIVACY POLICY

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Last Update: August 18, 2023

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Nurture Holdings, Inc. ("Nurture," “we,” “us,” or “our”) is committed to protecting the safety and security of our registered users, including parents/legal guardians and children (collectively, "Users"). This privacy policy (this “Policy”) is intended to help you understand how we collect, store, use, and remove the information that you provide to us. This Policy applies to our data privacy practices in connection with our website located at https://www.nurture.is/, our Smart TV app and mobile app, and any other associated applications owned by Nurture (collectively, the “Site”).

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By using or accessing our services and the Site, including any content posted on the Site, you indicate your acceptance of our Terms of Service, including this Policy. If you do not agree to the Terms of Service, you must stop accessing or using the Site, and by not doing so, you will be deemed to have accepted the Terms of Service. Please contact us with any questions or concerns about this Policy at support@nurture.is.

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The date of the latest version of this Policy is set out above. We may update this Policy from time to time; you can always come back here and check for any changes. If there are any material changes to this Policy, Nurture will make an announcement on the Site.

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WHAT PERSONAL INFORMATION WE COLLECT

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Nurture collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“personal information”). Nurture also collects non-personal information that cannot be linked or associated with any individual person or household. When non- personal information is combined with other information so that it does identify an individual person, we treat that combination as personal information. We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:

  • Identifiers such as first name, last name, alias, username or similar unique personal identifier, account name, online identifier, and/or age.

  • Contact Information such as email addresses.

  • Profile Data such as username, password, payments you have made, and/or other details of products and services you have purchased from us in the past, purchase or product preferences, your child's personal interests, your child's dietary preferences, information provided to customer support, information provided to Kira (Nurture's coaching chatbot), posts and comments within the Nurturers community forum, comments on Nurture's blog posts, feedback, and survey responses.

  • Technical Information such as cookies, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site and any other Nurture platforms.

  • Usage Data includes information about how you use the Site, such as statistics regarding the opening and clicking on emails sent by Nurture, and activity on the Site (e.g. your child's use of the Site, such as records of which puzzles have been successfully solved).

  • Marketing and Communications Information such as marketing campaign data, click-throughs, date/time stamps, customer lifetime value, your preferences and consent in receiving marketing from us and our third parties, email communications, and your communication preferences.

  • Audio and Visual Information such as your profile photo or image files attached to posts or comments in the Nurturers community forum.

  • Inference Data including inferences drawn from the personal information identified above.
     

You may agree to the collection and use of your child’s personal information, but disallow disclosure to third parties, unless such disclosure is part of the services provided on the Site. If you’d like to disallow disclosure to third parties, please contact us at support@nurture.is.
 

Financial Data. Please note that any processing of financial data is carried out by the payment provider chosen by the User (e.g. the App Store or Google Play). As such, Nurture does not collect, store or have access to any financial data.
 

If You Do Not Provide Personal Information. Where we need to collect personal information by law, or under the terms of a contract we have with you, and you do not 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 products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
 

Information You Provide To A Third Party. The Site may include links, plug-ins to websites operated by third parties such as Instagram, Twitter, LinkedIn, YouTube, or Substack  (such sites, “Third-Party Site(s)”). Nurture does not control any Third-Party Sites and is not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by its privacy policy. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.
 

HOW WE COLLECT YOUR PERSONAL INFORMATION


Information You Provide To Us

Nurture may collect personal information from you that you voluntarily provide to us in various ways, including, but not limited to:

  • Create an account with us

  • Sign up to receive newsletters

  • Respond to quizzes, surveys or marketing emails

  • Call, email, or otherwise communicate with us and/or third parties contracted by Nurture

  • Otherwise interact with the Site

Users registering individually must give their consent at the time of registration to provide us with their personal information such as their name, age, and email address (or if they are under 13 years of age, or legally a minor in their relevant location, a parent or legal guardian must consent on their behalf and provide the minor's personal information). Alternatively, a parent or legal guardian registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren). Users may withdraw consent at any time by contacting us at support@nurture.is.

Nurture will not require a child to disclose more information than is reasonably necessary to participate in an activity on the Site. Parents or legal guardians may also refuse to allow any further collection or use of a child’s personal information.
 

Information We Collect When You Use Our Services

Automated technologies or interactions. As is true of most websites, we receive and store certain types of personal information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our website and platforms from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
 

Cookies and Tracking Technologies. We and our service providers use cookies, pixels, and other tracking technology to recognize your browser or device and to capture and remember certain information about your activities on our website. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. If you turn off your cookies, some of the features of the website may not function properly.

NURTURE DOES NOT USE COOKIES OR THIRD PARTY PROVIDERS TO ENGAGE IN BEHAVIORAL TARGETING OF ADVERTISEMENTS TO MINORS OTHER THAN AS SPECIFICALLY AUTHORIZED BY A PARENT OR LEGAL GUARDIAN.
 

Information We Collect From Third Parties

We collect personal information from various third parties, including those listed below. The collection, use, and disclosure of personal information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
 

Third Party Service Providers. We collect personal information from service providers including log-in integration providers, website hosting providers, software development providers, email service providers, marketing providers, analytics providers, and social media platforms.

Third Party Advertising Partners. We collect personal information received from third party advertising partners, including partners who host and manage various online advertisements and ad platforms.  This may be combined with the website analytics data described below.
 

Google Analytics for Firebase. Our mobile app and Apple TV app use Google Firebase technology. Firebase is one of various services provided by the Google Cloud Platform, a list of which can be found here: https://firebase.google.com/terms/.
 

In particular, we use Firebase Analytics, which collects so-called “instance IDs”, which are provided with a time stamp, and advertising IDs. Firebase’s instance IDs are unique and thus allow the linking of different events or processes. These data are neither personally identifiable data nor does Nurture make any effort to personalize it afterwards. We process this aggregated data to analyze and optimize usage behavior and app functionality.

In addition to the “Instance ID” described above, Google also uses the advertising ID of the device for Firebase Analytics. In the device settings of your mobile device you can restrict the use of the advertising ID. You can restrict the use of the advertising ID in the device settings of your mobile device as follows:

  • For Android: Settings > Google > Ads >  Disable personalized advertising

  • For iOS: Settings > Privacy > Advertising > No ad tracking
     

For more information about Firebase’s privacy and security, please visit https://firebase.google.com/support/privacy/. Google has joined the EU-US Data Privacy Framework Program, certifying that Google has reliable mechanisms for personal data transfers to the United States from the European Union, United Kingdom, and Switzerland while ensuring data protection that is consistent with EU, UK, and Swiss law: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active. For more information on Google Firebase and privacy, visit https://www.google.com/policies/privacy/ and https://firebase.google.com/.


Unity Analytics. Unity Technologies provides the software engine that powers our software. It collects statistical information to better understand Users’ experiences and interactions with the Site. This information helps us to improve the Site. Unity does not retrieve any personally identifiable information or share any personal information with third parties. All the collected information is anonymized before being sent to Unity Analytics:

“In order to provide analytics for your games, Unity Analytics generates an anonymized user ID for each user in your game. We do not use any of these IDs generated from Child Apps to track users across apps built by other developers or to map users between different services, devices, or browsers on the same computer. In addition to these IDs, Unity Analytics also collects the following personal information from Child App users: IP address, identifiers for advertisers (IDFA is only collected if Unity Ads is also enabled) and device identifiers (IDFV, Android device ID or IMEI if Android device ID is unavailable).
 

Unity’s use of the personal information identified above is limited to providing app-level analytics for the application’s developer and analyzing and reporting anonymized and aggregate-level information about devices, apps and the game industry (for example, the percentage of devices using a certain operating system or the percentage of certain devices by regions). This aggregate-level data contains no personal information. Also, if you’ve enabled Unity Ads in a Child App, Unity may use information about a user collected by Unity Analytics from that Child App to serve contextual advertising within that Child App.” (https://docs.unity3d.com/2020.1/Documentation/Manual/UnityAnalyticsCOPPA.html).
 

For more information on Unity please see the privacy policy here: http://unity3d.com/legal/privacy-policy.

Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
 

HOW WE USE YOUR PERSONAL INFORMATION 
 

Our primary purpose in collecting personal information is to provide you with the products and services that you have ordered or requested with a safe, smooth, efficient, and customized experience.  We may also use your personal information for the following business purposes:

  • To manage purchases and payments including to provide quotes or offers.

  • To send a confirmation notice to the User of the registration; to administer and manage accounts, including password resetting, responding to questions raised by Users, to contact the User about any problems with the User's account or conduct on the Site;

  • To provide you with our newsletter, if you have registered and consented to receiving our newsletter;

  • To provide you with non-promotional updates about the Site, such as upgrades or the rules of the Site;

  • For administrative, planning, product or service development, staff training, quality control and research purposes relating to our products and services;

  • For marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Users may also opt out at any time by following the specific opt out instructions within the communications that we send.
     

The Site does not provide minors with any means to communicate directly with each other. There are no chat rooms connected with the learning resources. Access to, and use of the Nurturers community forum is designed for use by parents/legal guardians and other contributors who are not legally minors. The Site may have additional features in which parents/legal guardians can give their consent, and/or give consent on behalf of a minor, to access, disclose or use their personal information or learning activity information.  
 

WHAT WE WILL NOT DO WITH YOUR PERSONAL INFORMATION
 

Nurture will keep your personal information confidential and not sell or disclose your information to advertisers or any external third parties, unless:

  • we believe, in good faith, that we are required to share your information with a third party such as a regulator or court in order to comply with law, regulation, legal process, court order or subpoena; 

  • to enforce our Terms of Service or the terms of the license granted to access and use the Site;

  • the disclosure is to a third party that acts on our behalf, powers certain aspects of our Sites or processes data on our behalf, such as a distributor of our products and services, the licensor or owner of a product or resource that we distribute, or to a contracted service provider;

  • in connection with any transaction involving our companies or assets, where another party acquires ownership or operation of the Site, in which case that successor organization will be subject to the obligations in this Privacy Policy and any contractual representations we have entered into; or

  • to protect the safety and security of our Users and our Site.
     

HOW WE DISCLOSE YOUR PERSONAL INFORMATION
 

We disclose your personal information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our goods and services and perform any contract we enter into with them or you. We do not retain your personal information for a duration that is longer than reasonably necessary for the disclosed purpose.
 

Information You Instruct Us to Share. You may be presented with an option on our website to have us send certain information to third parties or give them access to it. If you choose to do so, your personal information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
 

User Disclosures.  Some personal information is disclosed as a matter of course as a result of your use of the website.  For example, if you choose to participate in our community forum.  Any personal information shared via any public forum on our Site will become public information.  
 

Service Providers.  We may use third-party service providers to perform certain business services and may disclose personal information to such service providers as needed for them to perform these business services.  Service providers are only allowed to use, disclose or retain the personal information to provide these services and are prohibited from selling personal information.   Business services provided include, but are not limited to, hosting services, communications services, website development services, software development services, accounting and audit services, compliance services, analytics services, and marketing services. If third parties act on our behalf, we require them to hold, use and disclose your personal information in accordance with this Policy, applicable privacy obligations and our contractual obligations. 
 

We use the Google reCAPTCHA tool to protect our website from various types of abusive processing attempts.  In order for this tool to work, reCAPTCHA analyzes various information that it collects from each visitor, which may include the IP address, mouse movements, length of stay, and other information gathered by Google.  By using reCAPTCHA, this data is sent to Google and used to determine whether the visitor is a natural person or an abusive automated program (e.g. bot).  You can find more information about reCAPTCHA at https://www.google.com/recaptcha.  All information captured by the Google reCAPTCHA tool is subject to Google’s Terms and Privacy Policy.
 

Internal Third Parties. We may share personal information with our parent company, subsidiaries, successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your personal information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Nurture who may use the personal information for the purposes described above.

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy.
 

Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
 

Personal Information Sold. We do not sell data to advertisers (whether personal, anonymous or aggregated). We do not use data to engage in targeted advertising to children and we do not create or build personal profiles of minors other than as specifically authorized by a parent or legal guardian. 
 

HOW LONG WE HOLD YOUR INFORMATION
 

  • Retention. We retain the personal information that we collect from and about our Users for as long as it is needed to provide access to the Site or to manage that User's account.
     

We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you (or if you are under 13 or legally a minor in your relevant location, a parent or guardian may request on your behalf) opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.
 

  • Deletion. Users can request that their, or their child’s, personal information be deleted by contacting support@nurture.is.
     

UPDATING AND ACCESSING YOUR PERSONAL INFORMATION
 

  • Users have a right to request a copy of the personal information we hold about them. In particular, parents or legal guardians have the right to review their child’s personal information.

  •  Users can also update their personal information at any time by contacting Nurture.

  • If you wish to receive a copy of this information or to update or correct information held about you, please address your request to support@nurture.is. We will endeavor to deal with your request promptly.
     

KEEPING YOUR PERSONAL INFORMATION SECURE
 

  • Nurture is committed to information security. We will use all reasonable endeavors to keep the personal information we collect and use in a secure environment, and we have implemented appropriate technical, administrative and physical security measures that are designed to protect personal information from unauthorized access, disclosure, use and modification. These measures include the encryption of personal information and the implementation of organizational measures. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods and engage independent third parties to review and audit aspects of our information security. 

  • We use Microsoft Azure, a provider recognized for its leading approach to data security, for Nurture’s data hosting and storage in the U.S. Further information regarding Microsoft Azure’s privacy and security practices, including the latest updates and compliance information, at https://privacy.microsoft.com/en-us/privacystatement.

  • We provide our personnel with training about data security and privacy, and we require all our employees and contractors to comply with this Policy and their obligations of confidentiality. We will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Policy.
     

DATA TRANSFERS, STORAGE AND PROCESSING GLOBALLY
 

  • Users’ personal information is uploaded to and stored on servers that are maintained by third party providers, such as Microsoft Azure, at locations in the United States.

  • As we operate globally, we may on occasion allow your personal information to be accessed in countries other than your own location. We may do this where data is accessed:

    • by our sales, operational or global customer support teams (primarily, although not exclusively, located in the USA, Europe and Asia); or

    • where a copy is sent to the User itself at the User's request.

  • By consenting to the collection and use of their personal information, Users’ consent to their personal information being transferred and stored in this manner.

    • Users in California, please refer to 'SPECIAL INFORMATION FOR USERS IN CALIFORNIA'

    • Users in Canada, please refer to ‘SPECIAL INFORMATION FOR USERS ACROSS CANADA’.  

    • Users in the EU and UK, please refer to ‘SPECIAL INFORMATION FOR USERS IN THE EUROPEAN UNION AND THE UNITED KINGDOM’. 

  • We may record, with your express consent, calls with customers for quality and staff training purposes. If, with your consent, we record a telephone call for this purpose, that recording will be stored in data centers located in US and deleted when no longer required. 
     

ANONYMOUS OR AGGREGATED INFORMATION
 

  • In addition to personal information and results data, Nurture also collects anonymous information about Users and the activities of Users on the Site. Anonymous information is information that is not linked to the name or identity of a user. This information is used for educational performance reporting and analytics and to assist us in enhancing the learning resources. The information remains anonymous at all times.

  • Nurture utilizes third-party providers to power certain elements of the Company’s online marketing and advertising. These service providers collect data about your activities that does not personally or directly identify you when you visit our website or the websites and online services where we display advertisements (i.e. publishers). This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we and these third party service providers collect to serve you more relevant advertisements regarding Nurture resources, referred to as “retargeting”. We collect information about where you saw the ads and what ads you clicked on. This is data that does not personally or directly identify you. We do not engage in this type of marketing or advertising to minors or children.

  • When agreeing to the Terms of Service, Users grant us the right to use this anonymous information for our own purposes, such as the preparation of statistical reports or to improve and change the content of our products.
     

REVISION OF PRIVACY POLICY
 

Nurture reserves the right to change, modify, or revise this Policy in order to comply with any applicable laws, to reflect changes in our processes or for any other reason at any time. Material changes in our Policy will be communicated to Users, but we also encourage our Users to check this Policy periodically to read about any changes, modifications, or revisions. Users may wish to check it each time they submit personal information. You will be deemed to have consented to such variation by your continued use of the Site following any changes being made. 
 

SPECIAL INFORMATION FOR USERS IN CALIFORNIA
 

California residents have the right to receive information that identifies any third party companies or individuals that Nurture has shared your personal information with in the previous calendar year, as well as a description of the categories of personal information disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at the address below.

 

SPECIAL INFORMATION FOR USERS IN THE EUROPEAN UNION AND THE UNITED KINGDOM
 

  • Nurture welcomes the EU GDPR and UK GDPR as essential regulations to affirm our commitment to data protection across the European Union and the United Kingdom. We are committed to ensuring:

    • Personal data is processed fairly, lawfully and in a transparent manner

    • Personal data is collected and processed only for specified and lawful purposes

    • Processed data is adequate, relevant and not excessive

    • Processed data is accurate and, where necessary, kept up to date

    • Personal data is not kept longer than necessary

    • Personal data is processed in accordance with an individual’s rights

    • Personal data is kept secure

    • Personal data is not transferred to countries outside of the EU or the UK without adequate protection

  • The information below should be read in addition to our Privacy Policy, and outlines specific information relevant to certain aspects of our GDPR compliance.

    • Lawfulness of processing: Nurture collects personal information in a number of contexts and for a number of purposes. Please refer to the “WHAT PERSONAL INFORMATION WE COLLECT”, “HOW WE COLLECT YOUR INFORMATION” and “HOW WE USE YOUR PERSONAL INFORMATION” sections of the Privacy Policy. Our processing activities are based either on consent or legitimate interests pursued by Nurture in delivering learning resources for use by parents, legal guardians, and minors which are designed to improve learning outcomes and inspire a love of learning.

    • Is personal information transferred outside of the European Union or the United Kingdom? Yes, Nurture is based outside the EEA and the UK and thus our processing of any EU/UK data will involve a transfer of data outside of the EEA and UK. User data will be uploaded to and stored on our servers located in the US.

 

  • To ensure appropriate safeguards exist in relation to such transfers, Nurture ensures proper data processing agreements, or data processing addendums, as applicable, to cover the transfer of data relevant to EU and UK Users.

 

  • We stay up to date with regulatory developments in the EU and the UK to ensure that appropriate and compliant safeguards are in place for the transfer of any personal information outside of the EU or UK.

 

MORE PRIVACY INFORMATION
 

CONTACT US
 

If you wish to contact us about any privacy questions or concerns you may have, please do contact us at support@nurture.is. We will endeavor to respond to your question as quickly as possible.

If you are not satisfied with the response you receive, you may have the right to contact the regulator responsible for privacy in your home country.

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