Tangible Play, Inc.
Effective Date: May 30, 2018
The Osmo Website is provided for use in managing our Apps, which are available on iTunes and downloadable to your iOS device. The Website is intended for adults only and does not allow game play.
The Apps downloaded to your iOS device all allow game play (the “Osmo Play Experience”) and are intended for families and users of all ages.
If you are accessing the Service from within the European Union (EU) or are an EU citizen, please review the Lawful Bases for Processing Personal Data and Individual Rights sections below for more information on your how your personal data will be processed and the rights you have regarding this processing.
The Website is intended for adults, teachers, and parents to allow them to manage the Osmo Play Experience and gives adults the ability to deliver additional content to the Osmo Play Experience. This Website does not provide access to the Osmo Play Experience and does not contain content intended for online Website play.
When you use the Website, you may provide and we may collect Personal Information about you through our Website when you visit or order from our Website, such as your email address, physical address, phone number or credit card information. Other information you may affirmatively provide to us is generally maintained along with Personal Information. You can choose not to provide any information that is affirmatively requested of you. However, this may limit your ability to use the Website.
User-generated content in you create on the Service may include Personal Information.
In addition to collecting information on the Website, we may collect information from you when you communicate with us over the phone or via e-mail. This information may include Personal Information. This information may be matched with and stored in connection with Personal Information provided or collected in connection with the Website.
Log file information is automatically reported by your browser each time you access a web page on our Website. When you access the Website, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.
We may use mobile analytics software and various backend systems to analyze certain information regarding your use of the Website such as email address, pageviews, advertisements clicked on, and transaction related information.
In general, we will store Website tracking information in an anonymous aggregated form; however, we or our third-party tracking partners may store certain information, such as pageviews, in a manner that can be associated to specific users.
We do not collect information about your location from your mobile device, but we do log your IP address, which can be used to approximate location. We use IP addresses only for activities necessary to maintain or analyze the Service; perform network communications; authenticate users or personalize content; protect the security or integrity of the user and the Service; ensure legal or regulatory compliance; or fulfill a request of a user.
We use or may use information we collect for a variety of purposes, including:
Tangible Play will not rent or sell your Personal Information to others, nor will we share your Personal Information with independent third parties for marketing purposes. To operate the Service, however, we may share your Personal Information with our agents, representatives and contractors so they can provide us with support services and other features. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
Below are categories of recipients of your personal data and some examples of the third-parties in that category. If you would like more information on any of these categories or specific recipients, please contact us at [email protected]:
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Website.
We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of our products, services, assets and/or businesses. Your information, such as email addresses, and other user information related to the Service, may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.
If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:
Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contact for Individual Rights Requests section. Some examples of our legitimate interests and the data being processed include:
Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in the Individual Rights section below.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected].
We primarily store data about you, including personal information, on servers located and operated within the United States. If you reside outside of the United States, in order to provide and operate the Service, we may send and store your personal information (also commonly referred to as personal data) outside of the country where you reside or are located, to the United States. Therefore, our collection and use of your personal information is subject to the United States’ laws related to privacy and use of personal data and information.
Whenever we share personal information originating in the EU with an entity outside of the EU, we will do so on the basis of the EU standard contractual clauses or the Privacy Shield Frameworks.
Tangible Play is certified under the EU-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the United States, respectively. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. For more information on the EU-U.S. Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website at: https://www.privacyshield.gov/welcome.
You may, of course, decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page on the Website or contacting us at [email protected]. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. To update, correct, or delete any other personal information, please see the Individual Rights section below for more information.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by using the account management tools on our website at https://my.playosmo.com or sending your request to us by email at firstname.lastname@example.org.
Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.
Tangible Play also makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe.
You have the right to access and update any personal data that we have collected. Some personal data, such as the account holder’s name and email address can be found and updated using the account management tools on our website at https://my.playosmo.com. For any personal data beyond this, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before modifying any personal data.
You also have the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section. We may request more information to confirm your identity before deleting any personal data.
Using the “Delete Account” function on https://my.playosmo.com WILL NOT automatically remove all of your personal data from our system. You must submit a request using the below information if you wish to delete all personal data from our system.
After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems, for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.
You have the right to restrict how we process your personal data in certain circumstances. In some ways, this is an alternative to requesting the erasure of your data. Rather than requesting we erase all of your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it.
You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data.
You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.
If any request made under this section is manifestly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.
Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.
195 Page Mill, #105
Palo Alto, CA 94306
If you are located in the European Union, you can contact Osmo’s Data Protection Officer at [email protected]. If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.
Tangible Play may retain users’ data for the following purposes:
We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the Service, which may include maintaining this information beyond when you cease using the Service.
Tangible Play takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information.
If you create an account to use the Website, you may be asked to choose a password for your account, which can be used to access information associated with your account (including Personal Information). You should choose a password that is not easy to guess, and does not use words that you would find in a dictionary. Do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and we will attribute activities that occur using your account information (e.g., through the use of your password) to you. If you suspect that your password has been compromised, contact us immediately at [email protected].
We may send you, or you may elect to sign up to receive, emails from us. To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavor to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message. We reserve the right to send you service announcements or similar administrative messages, without offering you the opportunity to opt out of receiving them.
We may send you communications within an App regarding recommendations for other Tangible Play Apps. You may opt out of such communications by visiting your account at https://my.playosmo.com/, then visiting Profiles, then selecting Games, and finally choosing “Disable Recommended Games” within the Recommendations section. We reserve the right to send you service announcements or similar administrative messages within an App, without offering you the opportunity to opt out of receiving them.
Tangible Play makes commercially reasonable efforts to ensure its Apps and the Osmo Play Experience comply with the Children’s Online Privacy Protection Act (“COPPA”). While inside the Osmo Play Experience, all play is locally stored, and no Personal Information is collected or solicited from a child user. The Osmo Play Experience contains no external links to third party websites or services.
The Osmo Play Experience is available by downloading one or all of our Apps to your iOS device. The Osmo Play Experience is directed at users of all ages, including children. We encourage parents and teachers to supervise their child or student’s use of the Apps and supervise the overall Osmo Play Experience. Simply downloading any Osmo App to your iOS device does not trigger the collection of any personally identifiable information. We collect only a unique device identifier (a 40-character long mathematical code, called a “hex value”). This device identifier only allows Tangible Play to send necessary administrative updates to your tablet (such as software updates and administrative messages). No Personal Information is collected by Osmo through the App download process or during the Osmo Play Experience. We may collect analytics data (which does not contain Personal Information) from your use of the Service in order to offer and develop the Service, and we may collect information such as age and nickname from you as part of your use of the Apps and the Service and the creation of your user profile.
Certain features within our Apps, that are outside the Osmo Play Experience, (such as the email sharing feature within Masterpiece for Osmo) may allow children users to input Personal Information such as a friend’s email address, or may otherwise process or record a child’s activities within the app, such as the pattern of their drawing or other creations. In addition, users may request that drawings, word albums and other user creations (together, the “User Creations”) made in our Apps be shared to the broader community of users via the myOsmo section on our Website. These features are designed so that no Personal Information is uploaded back to or stored on our web servers unless consented to by the parent or teacher account holder, or in such a manner that is otherwise exempt from or compliant with COPPA. We review all User Creation submissions to ensure no obvious Personal Information is included before any User Creations are made available publicly.
If you are under 16 years of age, then please do not use or access the Website at any time or in any manner. If we learn that personally identifiable information has been provided to us and/or collected on the Website from persons under 16 years of age and without verifiable parental consent, such as through a support request, we take the appropriate steps to delete or hash this information in a secure manner. If you are a parent and discover that your child under 16 years of age has obtained an account on the Website, then you may alert us at [email protected] and request that we delete that child’s personally identifiable information from our systems. A parent or teacher can visit his or her account online at any time to delete any information and/or the account.
Osmo Apps – including Words, Tangram, Newton, Masterpiece, Numbers, Hot Wheels™ MindRacers, Monster, Pizza Co., Coding Awbie, and Coding Jam- are certified by the kidSAFE Seal Program. The kidSAFE Seal Program is an independent safety certification service and seal-of-approval program designed exclusively for children-friendly websites and technologies, including kid-targeted game sites, educational services, virtual worlds, social networks, mobile apps, tablet devices, and other similar interactive services and technologies. Click on the seal or go to www.kidsafeseal.com for more information.
Users who are California residents may request and obtain from us once a year, free of charge, certain information about the personally identifiable information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If, and when, applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to [email protected]. As noted above, we do not share your Personal Information with independent third-party companies for their marketing purposes.
Additionally, we comply with California SB 1177 and do not:
If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by email at [email protected].
You may also contact us below:
Tangible Play, 195 Page Mill Road, #105, Palo Alto, CA 94306, USA. Phone: +1 408-676-6411