Privacy Policy

Early Reader’s Book- App - Privacy Policy for Users in India

M/s. Data Processing Forms Private Limited, its subsidiaries and affiliates (“Company” or “we” ) respects the privacy of the users (“User” or “you”) of the mobile applications we distribute (“Apps”) and are committed to protect Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps.

IMPORTANT – We operate Apps for all ages:

Apps distributed within our developer account under the brand “Early Reader’s Book” that do not include an age-gate and are intended for general audiences (“Early Reader’s Book Apps”), which are subject to our Early Reader’s Book Privacy Policy (defined below).

Apps that include an age-gate and are not primarily directed at children but may appeal to them. Users of such Apps who indicate they are under the age of sixteen (16) are subject to our Children Privacy Policy, and Users of such Apps who indicate they are over the age of sixteen (16) are subject to our Early Reader’s Book Privacy Policy.

By “Children Privacy Policy” we refer to our privacy practices and principles described in Chapters A and C below. By “Early Reader’s Book Policy” we mean our privacy practices and principles described in Chapters B and C below.

Note that the “Children Privacy Policy” (Chapter A below) and the “Early Reader’s Book Policy” (Chapter B below), and each together with Chapter C detailed below, shall be referred to collectively as “this Privacy Policy”.

Capitalized terms not defined in this Privacy Policy shall have the meaning given to them in our Apps terms of use.

If you are a child, please ensure that your legal guardian has reviewed this Privacy Policy.

Chapter A: Children Privacy Policy

This Children Privacy Policy is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding children using our Children Apps and Users who indicate at an age-gate in our Apps that they are under 16. For the purposes of Chapter A, the term “Children Apps” will include the age-gated section of Apps accessible only to Users indicating they are under 16, and “children” will include Users indicating at an age-gate that they are under 16.

We do not knowingly collect any personal information from children other than as expressly specified in Sections 2.2 and 2.3 below.

We hereby prohibit children from actively and directly providing us with any personal information other than as specified in Section 2.3 below. If you are a legal guardian of a child and believe your child has provided us with any personal information, please contact us at admin@earlyreaderbook.com (email) and we will delete such information from our servers.

We may collect and maintain the information described in Section 2, directly or through certain products or services, solely for providing support for our internal operations as permitted under applicable laws and rules (described in greater detail below).

Third party providers of certain products or services, such as advertising providers, tracking services, analytics services etc. (“Third Parties”) may passively collect and maintain information about Users. Some of these Third Parties act on our behalf under our instructions. Others act independently as controllers of personal information in their own right. Such Third Parties are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider (such as Apple or Google) in performance of their services.

Any question about Third Parties’ privacy practices and policies should be directed to our Privacy Policy Administrator by e-mail to:admin@earlyreaderbook.com. We will forward your inquiry to the applicable Third Party and make an effort to provide you with such Third Party’s response within a reasonable timeframe.

2. Online Use

The current version of the software is available for access only for online use.

There are three types of data and information which may be collected from Users of our Children Apps:

2.1 Non-personal Information: We and our Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such children Non-personal Information, we and the Third Parties are not aware of the identity of the User from whom children Non-personal Information has been collected. Children Non-personal Information collected by us or our Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Children Apps, User’s gameplay (e.g. level reached, frequency and time spent in the Children App and in each level, game progress, fail rate, mini game(s) played, tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Children Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), our other installed Apps, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 16), and geo-location – only at a country level.

2.2 Children’ Persistent Device Identifier and No Other children personal identifiable information: We and our Third Parties may passively collect a persistent device identifier from children, such as randomly generated User ID and IP address (“Children Persistent Device Identifier”). This is processed for the limited purposes of supporting the internal operations of the Children Apps. In the case of IP addresses, we retain the data for error logs and for statutory compliances, in the event that we governmental authorities call upon the same to be furnished for the purpose of security and governance. We do not collect and do not permit Third Parties to collect from children any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about children.

We do not link any additional personally identifiable information to the Children Persistent Device Identifier, even from other services.

We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data or any sensitive device data concerning children.

Purpose of the collection: The information described above is collected and processed solely for the purpose of supporting our internal operations. This means the following:

• providing and improving Children Apps as well as ensuring proper functioning of the Apps and services;
• maintaining or analyzing the functioning of Children Apps and services;
• Enhancing User experience
• performing network communications;
• protecting the security or integrity of Users, Children Apps and services;
• ensuring legal or regulatory compliance;
• fulfilling a User’s request under Section 2.3.

The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.

How is the Information about our Users of Children Apps being collected? The Non-personal Information and Children Persistent Device Identifier are collected by us or our Third Parties through the Users’ use of Children Apps, including through Third Parties’ SDKs embedded in our Children Apps. Non-personal Information and the Children Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within the Children Apps, such as “cookies-like technology” and local storage (see Section 18 below for further details on Cookies and Local Storage).

If Third Parties collect Non-personal Information, Children Persistent Device Identifier and/or any other information directly from children, such collection and processing is governed by such Third Parties’ privacy policies and not by this Privacy Policy. However, all Third Parties are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider in performance of their services.

In addition to the processing of information described in this policy, some of our Apps may also access Personal and Non-personal Information but without Early Reader’s Book carrying out any processing. In these cases, the Apps may access the information but it is not transmitted outside of your device and Early Reader’s Book does not collect or use it in any way. An App may access information in this way in order to provide functionality necessary for particular features of an App.

2. Sharing Children information with third parties

We may share the Children Persistent Device Identifier only in limited cases, including the following:

• to satisfy any applicable law, regulation, legal process, summons, notices by the judiciary or governmental request;
• to enforce this Children Privacy Policy or the Terms of Use, including investigation of potential violations thereof;
• to detect, prevent, or otherwise address fraud, security or technical issues;
• to protect the rights, property, or personal safety of the Company, its Users, suppliers, licensors, and/or licensees, or the general public;
• when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or
• pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or the User of Children Apps may have requested from the Company.

To clarify, we may transfer and disclose Children Non-personal Information to third parties at its discretion.

3. Advertising

These Third Parties ad networks are carefully selected to ensure compliance with applicable privacy laws, this Privacy Policy and Platform Providers’ rules, policies and guidelines. Note that if the User of Children Apps clicks on any of these ads, the User will leave our Children Apps and go to the advertisers’ site which the User selected, and the advertisers may use cookies and other tracking technologies to collect Non-personal Information and/or children personally identifiable information. We recommend that children and their legal guardians review the terms of use and privacy policies of these advertisers. Their privacy policy, not ours, will apply to any of those interactions. We may also promote Children Apps in Third Parties’ applications and platforms.

In addition, we may advertise our other Apps within Children Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random Apps.

4. Additional Terms and Conditions

See further terms and conditions which also apply to Users of Children Apps in Chapter C below: “Terms and Conditions Common to Both Children Privacy Policy and Early Reader’s Book Privacy Policy”.

Chapter B: Early Reader’s Book Apps Privacy Policy This Early Reader’s Book is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding Users of our Early Reader’s Book Apps and Users. For the purposes of Chapter B, the term “Early Reader’s Book Apps” will include the age-gated section of Children Apps accessible only to Users indicating they are above the age of 16.

5. Which information may be processed from Users of our Early Reader’s Book App?

There are two types of information which may be processed about Users of our Early Reader’s Book App

5.1 Non-personal Information. Non-identifiable and anonymous information (“Non-personal Information”) may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). We and our Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to us and/or our Third Parties through use by Users of the Early Reader’s Book Apps. For details of the categories of data constituting Non-personal Information please refer to Section 2.1 above.

5.2 Personal Information. Individually identifiable information (“Personal Information”). This information may identify an individual and/or may be of a private and/or sensitive nature.

In addition, we may collect and/or process, directly or through Third Parties, the following Personal Information:

the User’s e-mail address which may be collected within the framework of the “Ask a Question” type of feature which may be available on the Apps;

the User’s persistent device identifier such as advertising identifier (IDFA, Advertising ID), randomly generated User ID and IP address. In the case of IP addresses, we retain the data for error logs and for statutory compliances, in the event that we governmental authorities call upon the same to be furnished for the purpose of security and governance. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable Platform Provider’s rules, policies and guidelines.

In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below Section 17.

To clarify, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Users.

In addition to the processing of information described in this policy, some of our Apps may also access Personal and Non-personal Information but without Early Reader’s Book carrying out any processing. In these cases, the Apps may access the information but it is not transmitted outside of your device and Early Reader’s Book does not collect or use it in any way. An App may access information in this way in order to provide functionality necessary for particular features of an App.

6. How is the Information about Our Users collected?

6.1 Non-personal Information may be collected through your use of the Early Reader’s Book Apps. In other words, when you are using Early Reader’s Book App, we and our Third Parties are aware of it and may gather information relating to such usage, through the Early Reader’s Book Apps, APIs or SDK embedded in our Early Reader’s Book Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the Early Reader’s Book Apps, such as “cookies” and local storage (see Section 16 below for further details with respect to Cookies and Local Storage).

6.2 Personal Information which you provide us directly and/or through Third Parties via your installation and/or use of the Early Reader’s Book Apps or your behavior to ads inside such Apps. This information is collected via the Early Reader’s Book Apps or such Third Parties’ APIs or SDKs embedded in our Early Reader’s Book Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the Early Reader’s Book Apps, such as “cookies” and local storage (see Section 16 below for further details about Cookies and Local Storage).

6.3 We collect Personal Information which you provide us voluntarily. We collect Information which the User voluntary provides us through the Early Reader’s Book Apps “Ask a Question” type of feature.

7. What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:

• Use it for statistical, analytical and research or business intelligence purposes (e.g., to track trends within our Early Reader’s Book Apps, for reports and for public relations purposes); and for customization, development and improvement of our Early Reader’s Book Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on behavior and preferences shown by Users usage within the Early Reader’s Book Apps).
• Measure traffic and usage on the Early Reader’s Book Apps.
• Promote our Apps.

Personal Information is collected in order to:

• Improve the Early Reader’s Book Apps.
• Provide the Users with personalized content and information
• Enable certain features, such as frequency capping etc.
• Provide Users with updated information regarding our products and services
• Authentication purposes including to verify clicks and/or installs, verify User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.
• Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the User (i.e. behavioral ads).
• Any other purpose explained at the time of collection.

8. Sharing Information with other third parties

In addition to the sharing of Personal Information with Third Parties described in sections 6-8, we may share Personal Information in the following cases:

• to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
• to enforce this Privacy Policy and/or the TOU and other of our terms or policies, including investigation of potential violations of such policies;
• to detect, prevent, or otherwise address fraud, security or technical issues;
• to respond to claims that any content published on the Early Reader’s Book App violates any right of a third-party;
• to protect the rights, property or personal safety of the Company, its Users, suppliers, licensors, licensees or the general public;
• when the Company undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case your Personal Information may also be disclosed, transferred and/or assigned;
• pursuant to your explicit approval prior to the disclosure;
• as part of a competition, receiving rewards or otherwise interact with our social media channels..

For clarity, we may transfer and disclose Non-personal Information to third parties at our discretion.

9. Additional Terms and Conditions

See further terms and conditions which also apply to Users of the Early Reader’s Book App in Chapter C below: “Terms and Conditions Common to both Children Privacy Policy and Early Reader’s Book Privacy Policy”.