We are committed to protecting the privacy of all our users. The Privacy Act (1988) (Cth) (Privacy Act) and the Australian Privacy Principles (Privacy Principles) set out in Schedule 1 of the Privacy Act, govern the collection, storage, use, and disclosure of information by which individuals may be identified. Further, we comply with EU General Data Protection Regulation 2016/679 (GDPR), and the US Children’s Online Privacy Protection Act 1998 (COPPA).
Our Services are designed for the whole family, including young children with parent supervision. As such, the protection of children’s privacy is of the upmost importance at WEYO.
Our Services do not collect or store personal information about children under the age of 13. The App does allow your children to create images and videos of themselves with Sesame Street or The Wiggles (Children’s Content). Children’s Content is only ever saved locally on your device and is only accessible within the App’s viewing page. For the avoidance of doubt, no Children’s Content is ever saved or copied onto WEYO’s or any third party’s servers.
Children’s Content created in the App can only be saved locally to a device after a ‘parent gate’ is completed. A Parent Gate is a question or task that prompts children under the age of 13 to have a parent or guardian help them advance to the next page. Successful completion of a Parent Gate leads to a ‘Just for Grown Ups’ page where you can choose subscribe to our premium service, allowing you to save any of the videos the child has created to the device’s camera roll.
In order to create the videos, the Parent Gate has a prompt for the App to access your camera, microphone or camera roll. Note that refusing access to camera or microphone could affect our ability to provide the App in a functional form.
Our Services automatically collect anonymous usage data for the purpose of providing and improving the Services for our users. If there was any instance where such automatically collected information could cumulatively be used to personally identify a child, we would then ask for a parent or guardian’s email address in order to obtain parental consent to collect and use such information in line with COPPA requirements. Email addresses collected for this purpose would only be used to seek consent, and are not stored or used for any other reason without your permission.
If you have any questions or concerns about your child’s privacy through the use of our Services, we encourage you to contact our privacy officer at [email protected] for more information about our privacy policies and practices.
What Information Do We Collect
‘Usage Information’ means anonymous aggregate data that is automatically collected through your use of the Services. This includes information that identifies your device, your operating system, your IP address and dates and times that you access and use the Services. This information is used to aid us in resolving any technical issues that may arise, or for statistical analysis to help us to improve the Services to the benefit of all users.
How Do We Collect Your Information
Personal Information is collected directly from you when you:
- subscribe to our premium service
- provide your email to opt in to our mailing list; or
- contact us via email or otherwise to raise a question or concern about the Services.
It is your choice to provide Personal Information to us. Wherever it is lawful and practicable, you have the option not to identify yourself when interacting with us. Please be aware that it may be necessary for us to collect your Personal Information to enable us to provide the Services to you. As such, if you do not wish to provide your Personal Information, we may not be able to provide the Services to you in a fully operational form.
Our App utilises TrueDepth API to map the faces of users to create the effect of wearing masks within the App. Note that face-maps or any other data utilised by TrueDepth API is not collected, processed or stored by WEYO at any time.
We collect anonymous Usage Data on our Website through Google Analytics and Facebook Ad Analytics, which utilises cookies, pixel tags and other tracking technologies (collectively Cookies). Cookies are small packets of data that are downloaded onto your device when you access a website. Cookies hold specific information that helps a website ‘remember’ your actions and preferences over time. These are the types of Cookies that we may use to operate our Services:
Strictly Necessary Cookies – these Cookies are essential to making sure the Services work correctly, and record information that allows you to move around the Services and navigate their features.
Performance Cookies – these Cookies collect information about how you use the Services, such as how often you access the Services and if you encounter any errors.
Functionality Cookies – these Cookies allow our Services to remember the choices you make to provide a more personalised experience.
Cookies can stay on your device temporarily (Session Cookies) or until you manually delete them (Persistent Cookies).
If you have any questions about how we collect usage data, please email your enquiry to us at [email protected].
How Do We Use Your Personal Data
Legimate purposes that you agree WEYO may use your Personal Data for include but are not limited to the following:
- to respond to requests submitted by you;
- to ensure technical functioning of the Services;
- to contact you via email to provide you with information about the Services, only where you have opted in to receiving such communication and until you withdraw such consents by altering your account settings or by emailing WEYO at [email protected]
For the avoidance of doubt, we will only use your Personal Data for purposes that you would reasonably expect WEYO to use your Personal Data for in connection with operating and providing the Services to you, or where we are required by law to collect your Personal Data. We will not sell, rent, or licence your email address or any of your Personal Data unless we have otherwise obtained your express consent to do so.
We recognise your right under the Spam Act 2003 (Cth) and the GDPR to opt out from direct marketing, and as such these consents can be modified at any time by emailing us at [email protected], or by clicking ‘unsubscribe’ on any direct marketing communications.
Who Do We Disclose Your Personal Data To
You agree and consent to WEYO disclosing your Personal Data to:
- other entities in WEYO’s corporate group structure;
- the Australian Broadcasting Corporation and other service providers with whom WEYO has entered into an agreement with to help WEYO provide the Services, including marketing agencies, financial service providers and technical support;
- certain third parties (IP rights holders, authorities, police, regulators) if WEYO is required to do so by law.
You can withdraw your consent for us to share your Personal Data with third parties at any time by emailing us at [email protected], but please note that withdrawal of such consents may affect your ability to access and use the Services.
What are your rights to your Personal Data
In accordance with the GDPR, we acknowledge the right of EU citizens to:
- have their data erased that is no longer being used for a legitimate purpose;
- request a copy of all Personal Data held about you by WEYO in a readable format; and
- request restricted processing of your Personal Data whilst any complaints or concerns are being resolved.
To erase, request or restrict processing of your Personal Data, please email us at [email protected].
Accessing, Reviewing and Changing your Personal Information
WEYO cannot modify your Personal Information. You can modify your own information by emailing us at [email protected]. You acknowledge that it is your responsibility to maintain the truth, accuracy, and completeness of your information and your failure to do so may inhibit our ability to provide the Services. You acknowledge and agree that you remain solely responsible for maintaining the truth, accuracy, and completeness of your information at all times, and we shall have no liability to you or any third party arising from your failure to do the same.
WEYO protects your Personal Data through technical security measures i.e. firewalls, encryption that limit the risk of loss, disclosure, unauthorised access and modification. No security measures are, however, 100% secure so we cannot guarantee the security of your information or data at any time. To the extent permitted by law, we accept no liability for any breach of security, or direct hacking of our security measures, or any unintentional disclosure, loss or misuse of any information or data or for the actions of any third parties that may obtain any information or data.
Notwithstanding the above, we acknowledge our obligation to report any data breach that is likely to risk the rights and freedoms of natural persons to the Australian Information Commissioner and, where our data breach involves the information of EU citizens, report to the European Data Protection Supervisor. We will also inform you, where possible, if your data has been breached in the circumstance where it poses a risk of serious harm or your rights and freedoms.
We may, in the course of providing the Services to you, disclose Personal Data to overseas countries that are deemed by the EU Commission as having an ‘adequate’ level of Personal Data protection. Where we transfer data to a third party in a country where no adequacy decision has been made, we warrant that such third parties in those countries are bound under contract to meet the requirements of the Privacy Act, Privacy Principles and GDPR.