Effective Date: 5-18-2023

Latest Update: 08-04-2023

Introduction

We at Yeti My Friend, Inc. (“we,” “us,” or “Yeti My Friend”) value your privacy. In this Privacy Policy, we provide you with detailed information about our collection, use, maintenance, and disclosure of Personal Data (as defined below) when you use our website (the “Site”) or our mobile application (the “App”) (collectively, the Site and the App are referred to as the “Services”). This Privacy Policy applies to any information that can be used to identify a person (“Personal Data”) that Yeti My Friend may collect from you when you use, access, or otherwise interact with our Services.

The App and Services are designed to teach critical thinking and character-building skills to elementary and primary school children (each, a “Learner”) through interactive storytelling. If you are a parent or guardian of a Learner (“Guardian”) that creates a user account (“User Account”) through the App or visits our Site, we may collect certain Personal Data about you and about your Learner.

In the United States, the App, Site, and Services may be used by teachers, school administrators, or other school personnel (“Educators”) as part of an educational program or materials offered through a school, school district, or other similar educational institution (“School”). Our collection of any Personal Data pertaining to Educators and/or Learners on behalf of an Educator or School will be governed by our contract with the School and any other applicable privacy laws. In the event of a conflict between this Privacy Policy and our contract with the School, the contract with the School will govern as to Personal Data collected under that contract. If you have any questions or concerns about how we collect and use Learner Personal Data pursuant to our contract with a School or would like to exercise any rights you may have with respect to that Personal Data, you should contact the School directly.

If you are a resident of the United Kingdom (“UK”), please see the addendum titled “UK GDPR Addendum to the Yeti My Friend Privacy Policy” (the “Addendum”) at the end of this Privacy Policy. This Addendum may contain additional terms that apply to you.

IF YOU DO NOT AGREE WITH ANYTHING DESCRIBED IN THIS PRIVACY POLICY OR THE ADDENDUM, DO NOT DOWNLOAD THE APP, PERMIT A LEARNER TO DOWNLOAD THE APP, LOG IN TO OR PERMIT A LEARNER TO USE THE APP, OR USE OR PERMIT A LEARNER TO USE THE SERVICES.

If you have any questions related to how we use and disclose Personal Data, please contact us at:

Yeti My Friend, Inc.

privacy@yetimyfriend.com

When any user clicks on the privacy support email address, the user is asked whether they are under the age of 13. If the user is under the age of 13, the App will require the user’s Guardian to satisfy a security protocol. 

Note regarding third-party sites: Our Services contain links to other sites not operated by Yeti My Friend. If you click a third-party link, you will go to that third party’s site. We have no control over how any third party uses your Personal Data. We strongly advise you to review the privacy policy(ies) of every site you visit. Yeti My Friend has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Privacy Policy does not apply to your use of or access to any third-party sites or services.

Privacy Policy Updates

Please note that we occasionally update this Privacy Policy. If we make any material modifications to this Privacy Policy, we will send any new versions of this Privacy Policy to the email address you provided when creating a User Account, conspicuously post this Privacy Policy in the Services, and/or otherwise communicate any new versions of this Privacy Policy to you through your User Account. Any changes to this Privacy Policy will be effective immediately upon posting.

Deletion

If you are a Guardian and no longer agree to the collection, use and disclosure of a Learner’s Personal Data, as described in this Privacy Policy, you can request deletion of Personal Data and/or your User Account (or the User Account you created on behalf of a Learner) by (i) selecting the delete account option within the settings of your User Account, or (ii) sending a deletion request to support@yetimyfriend.com with the following information: 

• Your name;

• Your login email address; and

• A statement that you are requesting account deletion.

Deletion of User Accounts created by an Educator or School are governed by our contract with that School. If you have any questions about the deletion of User Accounts on behalf of your School, please reach out to your School directly. 

Collection and Use of Personal Data

How Does Yeti My Friend Collect Personal Data and What Personal Data Do We Collect?

Directly from you or on your behalf. We collect Personal Data that you provide directly to us. Personal Data is required to use certain features of our Services. We will collect Personal Data that you provide to us through the Service features, contact forms on the Site, and in your communications with us in the following ways:

Registration and Account Data: From Guardians, we collect your and your Learner’s name and email address, as well as your Learner’s grade level, a username, and your relationship to the Learner. If you are an Educator, we collect your name, email, and the grade level you teach from you or the applicable School. We use this information primarily for creating User Accounts, customizing the user experience, and contacting you relating to our Services and your User Account.

User-Generated Information: Yeti My Friend may collect information provided to us by the Learner about the Learner’s education and personal experiences input on the App. User-generated information is only used to (i) customize the user’s experience provided by the Services, and (ii) improve the Services and create additional functionality.

Feedback: When you provide comments or feedback about our Services or our content ("Feedback"), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify a person. Feedback will be used without attribution or compensation to you.

Through automated means.

If you are under 13 years of age: We will not collect any Personal Data from you unless and until we have received consent from your Guardian to do so. Specifically, this means that we will not collect any IP addresses assigned to the computers and other devices you use (or proxy server); your internet service provider and/or mobile carrier; device ID number; browser type; operating system Site pages visited; websites you access before and after visiting the Site, system configuration information, date/time stamps associated with your usage; and data related to how and when you use the Site. This may prevent you from using some or all of the features of the App or the Services.

If you are older than 13 or Guardian consent has been provided: While we do not collect Personal Data automatically, we may tie automatically collected information to Personal Data about you that has previously been provided to us. We may use common information-gathering tools and similar technologies to automatically collect information about you from your computer system or mobile device as you navigate and use the Site, including via the use of cookies, web beacons, pixel tags and other tracking technologies (collectively "Cookies"). A cookie is a small text file that our Site may save onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons/pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Most browsers automatically accept Cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.

The Cookies on our Sites may collect information such as: IP addresses assigned to the computers and other devices you use (or proxy server); your internet service provider and/or mobile carrier; device ID number; browser type; operating system Site pages visited; websites you access before and after visiting the Site, system configuration information, date/time stamps associated with your usage; and data related to how and when you use the Site.

A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a site that has implemented a persistent Cookie, the persistent Cookie is renewed, and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.

How does Yeti My Friend Use Personal Data?

In addition to the uses described elsewhere in this Privacy Policy, Yeti My Friend uses Personal Data for the following purposes:

• To manage, analyze and provide the functionality of the App, Site, and Services to you, as well as to troubleshoot problems and address security issues;

• To transact business with you;

• To inform our marketing strategies;

• To inform our business strategies and analyze our current and prospective customer base;

• To respond to requests from government authorities, and to comply with applicable state and federal law, including cooperation with judicial proceedings and court orders;

• To protect our legal rights and interests and to seek business and legal advice;

• To manage and improve our operations and the App, Site, and Services, including through development of additional functionality; and

• To evaluate the quality of the Services you and/or Your Learner receive and improve your and/or your Learner’s user experience.

To Whom Does Yeti My Friend Disclose Personal Data?

In addition to disclosures of Personal Data described elsewhere in this Privacy Policy, we may disclose Personal Data to the following categories of individuals/entities:

Business Partners and Vendors: We disclose Personal Data to our partners, service providers, and other individuals/entities who help run our business, provide marketing, administrative or technical functions for our business, and help us provide communications to you (“Business Partners”). Specifically, we may employ third-party companies and individuals to store Personal Data, facilitate the App, Site, and/or our Services, develop and/or provide the App, Site, and/or Services on our behalf, perform Service-related functions, help with our sales and marketing efforts, and/or assist us in analyzing how our Services are used.

Our Advisors: We may disclose Personal Data to third parties that provide advisory services to Yeti My Friend, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”).

Third Parties Pursuant to Business Transfers: We may disclose Personal Data to a subsequent owner if the Site or App are sold to a third party, or in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Yeti My Friend corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), including with respect to any due diligence performed related to the foregoing.

Government and Law Enforcement Authorities: We may disclose Personal Data to (i) respond to legal and governmental requests and comply with legal processes or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or the Terms of Use; or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with our legal rights or any other party's legal rights.

How Long Does Yeti My Friend Retain Personal Data?

Yeti My Friend retains Personal Data for as long as is reasonably necessary to fulfill the purpose for which the Personal Data was collected.

Children’s Data

What Happens to Personal Data Submitted by Children?

Yeti My Friend will not require a Learner or any other child to disclose more information than is reasonably necessary to access and use the App and/or Services. Except in limited circumstances permitted under applicable law, Yeti My Friend does not knowingly collect Personal Information from children under the age of 13 without first securing verifiable consent from the child’s parent or guardian. If access to the Services is provided by a School, we rely on the School to obtain appropriate consent from an appropriate parent or guardian. If Yeti My Friend learns that Personal Data has been collected from or about a Learner or child under the age of 13 on our Service without the consent required by applicable law, Yeti My Friend will take appropriate steps to delete this information.

If you discover that a Learner under the age of 13 has a registered User Account without appropriate consent, please contact us at privacy@yetimyfriend.com and we will make commercially reasonable efforts to delete such Personal Data.

How Do Guardians Give Consent?

When a user accesses the App prior to creating an account, the user is asked whether they are under the age of 13. If the user is under the age of 13, the App will require the child to enter their Guardian’s email address for the purpose of obtaining Guardian consent for the child to access or use the App or the Services. We will then send a direct notice to the child’s Guardian via email that includes instructions on how to provide consent to Yeti My Friend. If the user accessing the App indicates that they are a Guardian for a Learner under the age of 13 and provides their email address, we will send an email direct notice to that Guardian that includes instructions on how to provide consent to Yeti My Friend. If the Guardian consents, we will send a consent confirmation email to that Guardian within a reasonable time period and the Guardian will be prompted to create a User Account on behalf of their Learner. If the Guardian does not consent, we will not collect Personal Data from their child, and the App and Services may not be available to that child. If we do not receive a response from the Guardian to the first notice we send after a reasonable time period, we will consider the request as rejected and we will (i) not collect Personal Data from the child, in which case the App and Services may not be available to that child, and (ii) make commercially reasonable efforts to delete the Guardian’s email address as provided by the child.

Additionally, when a Learner attempts to access links to external videos, the Learner is asked whether they are under the age of 13. If the Learner is under the age of 13, the App will require the Guardian to grant the Learner access to the external video.

What Rights Do Guardians Have Concerning Learner Personal Data?

You may have certain rights relating to the Personal Data of a Learner if they are under the age of 13 pursuant to the Children’s Online Privacy Protection Act (“COPPA”) and other applicable data protection and privacy laws. If you are a Guardian, these rights include the right to:

• Access and review Personal Data about the Learner that is held by Yeti My Friend;

• Erase/delete the Learner’s Personal Data, to the extent required by applicable data protection and privacy laws and to the extent technologically feasible;

• Be informed regarding and/or receive communications related to the processing of the Learner’s Personal Data;

• Restrict the processing of the Learner’s Personal Data to the extent required by law;

• Object to the further processing of the Learner’s Personal Data.

Where the processing of a Learner’s Personal Data is based on Guardian consent, a Guardian has the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at privacy@yetimyfriend.com. 

Will Yeti My Friend Disclose Personal Data Collected From Learners?

If we receive verifiable parental consent from the Guardian of a Learner under 13 years old, we will disclose that Learner’s Personal Data only in a manner consistent with, and as described throughout, the rest of this Policy. When we request a Guardian consent, you have the option of consenting to our collection and use of the Learner’s Personal Data without consenting to the disclosure of the Learner’s Personal Data subject to any exceptions permitted by applicable law.

Website Operators

The following operators may collect or maintain Personal Data through the App, Site, or Services: IESOFT Technologies, Firebase, FlutterFlow, and Google Cloud.

Please direct your inquiries about any operator's privacy practices and use of a Learner’s Personal Data to:

Yeti My Friend, Inc.

Email: privacy@yetimyfriend.com

Safeguarding Personal Data

Yeti My Friend understands the importance of data security. We use a combination of technical and administrative security controls with the goal of (i) maintaining the security and integrity of Personal Data; (ii) protecting against any threats or hazards to the security or integrity of Personal Data; and (iii) protecting against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.

However, no method of transmission of data over the Internet, or any other method of electronic storage or transmission, is 100% secure. THEREFORE, WE DO NOT GUARANTEE OR WARRANT THAT OUR CONTROLS WILL PREVENT UNAUTHORIZED ACCESS TO OR PROTECT THE SECURITY OR INTEGRITY OF PERSONAL DATA IN ALL SITUATIONS. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS THAT MAY COMPROMISE THE SECURITY OF PERSONAL DATA AT ANY TIME.

Advertising, Marketing, Tracking and Other Communications

Can You Opt Out of Receiving Communications from Yeti My Friend?

We may send you communications, such as emails, using the contact information we have on file for you, and we may use third parties to provide these communications. You may opt-out of marketing emails from us by clicking “unsubscribe” in the email, however, this does not opt you out of non-marketing emails, such as emails about your User Account or your use of the Services.

Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. YETI MY FRIEND DOES NOT CURRENTLY PARTICIPATE IN ANY DNT FRAMEWORKS THAT WOULD ALLOW YETI MY FRIEND TO RESPOND TO SIGNALS OR OTHER MECHANISMS REGARDING THE COLLECTION OF PERSONAL DATA.

UK GDPR Addendum to the Yeti My Friend Privacy Policy

This UK GDPR Addendum to the Yeti My Friend Privacy Policy (“Addendum”) is for residents of the United Kingdom (“UK”) and supplements the information contained in the main body of the Yeti My Friend, Inc. Privacy Policy (the “Privacy Policy”). This Addendum applies solely to UK residents who use the Yeti My Friend App, Site, and/or Services covered by the Data Protection Act 2018 (“DPA 2018”) and the UK General Data Protection Regulation (“UK GDPR”). In the event of a conflict between this Addendum and the remainder of this Privacy Policy, this Addendum shall control for those persons located in the UK.

Definitions

Capitalized terms in this Section have the same definitions as set forth in the UK GDPR. The definitions of "Personal Data" and "Processing" are set forth below for your convenience: 

"Personal Data" means any information relating to an identified or identifiable natural person (each, a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Legal Basis for Processing

Does Yeti My Friend Have a Legal Basis for Processing?

When Yeti My Friend Processes Personal Data, it has a legal basis for doing so pursuant to the UK GDPR. Yeti My Friend will only Process Personal Data if: (i) it has received express opt-in consent from a Guardian for such Processing, (ii) the Processing is necessary for performance of a contract, (iii) the Processing is necessary for a legal obligation to which Yeti My Friend is subject, (iv) the Processing is necessary to protect the vital interests of the Data Subject, (v) the Processing is necessary for a task carried out in the public interest, or (vi) if Yeti My Friend or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the Data Subject.

We have set out in the table below the reasons why we Process Personal Data, the associated legal basis for Yeti My Friend’s Processing of such Personal Data, and the type of Personal Data. If Yeti My Friend is required to Process any Personal Data for reasons (iii), (iv) or (v), those reasons may not be known to Yeti My Friend today and therefore may not be listed below.’