FarFaria Privacy Policy

Effective as of May 25, 2018

  1. Introduction
  2. About this Policy
  3. Your rights and your preferences: Giving you choice and control
  4. How do we collect your personal data?
  5. What personal data do we collect from you?
  6. What do we use your personal data for?
  7. Sharing your personal data
  8. Data retention and deletion
  9. Transfer to other countries
  10. Links
  11. Keeping your data safe
  12. Children
  13. Changes to this Privacy Policy
  14. How to contact us

1 Introduction

Thank you for choosing FarFaria!

FarFaria, owned by Intuary, Inc. (“Intuary”), was created to expand children’s knowledge and imagination through reading. Our mission is to provide you and your family with the best possible story time experience. To do this, we collect certain information about your reading habits and FarFaria usage.

We want you to know that your privacy and the security of your personal data is a high priority to us. Furthermore, we want to ensure that you understand how and why we gather, store, share and use your personal data. We also want to explain the controls and choices you have regarding personal data collection.

In addition to covering the above, this Privacy Policy (“Policy”) also provides you with information on how to contact us should you have any questions or concerns.

2 About this Policy

This Policy sets out the essential details relating to your personal data relationship with Intuary. The Policy applies to all FarFaria services and any associated services (referred to as the ‘FarFaria Service’).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless otherwise stated, new or additional services will be subject to this Policy.

The aim of this Policy is to:

  1. Ensure that you understand what personal data we collect, the reasons why we collect and use it, and with whom it is shared;
  2. Explain how we use the personal data we collect to give you a great experience when you are using the FarFaria Service; and
  3. Explain your rights and choices in relation to the personal data we collect and process, and how we protect your privacy.

We hope this helps you understand our privacy commitments to you. For information on how to contact us with any questions or concerns, please see the ‘How to Contact Us’ Section 14 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the FarFaria Service.

3 Your rights and your preferences: Giving you choice and control

You may be aware that a European Union law called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:

  • Right of Access - the right to be informed of and request access to the personal data we process about you;
  • Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • Right to Erasure - the right to request that we delete your personal data;
  • Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
  • Right to Object -
    • the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
    • the right to object to your personal data being processed for direct marketing purposes;
  • Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
  • Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you receive from the FarFaria Service (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).

If you would like to exercise any of the rights described above or have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer by email at [email protected] We will respond to your request within a reasonable period of time upon verification of your identity. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with your local Data Protection Authority.

4 How do we collect your personal data?

We collect your personal data in the following ways:

  1. When you sign up for the FarFaria Service - when you sign up for the FarFaria Service, we collect certain personal data so you can use the FarFaria Service such as your email address and name.
  2. When you submit your email address – when you provide your email address to the FarFaria website, app, or any other Intuary product.
  3. Through your use of the FarFaria Service - when you use the FarFaria Service, we collect personal data about your use of the FarFaria Service, such as what books you have completed.
  4. From third parties - we will receive personal data about you and your activity from third parties, including partners we work with in order to provide you with the FarFaria Service (please see ‘Sharing your personal data’ Section 7 below). We will use this personal data either where you have provided your consent to the third party or to Intuary or where the FarFaria Service has a legitimate interest to use the personal data in order to provide you with the FarFaria Service.

We use anonymized and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the FarFaria Service, and developing new features and functionality within the FarFaria Service.

5 What personal data do we collect from you?

We have set out in the tables below the categories of personal data we collect and use about you:

Personal data collected when you sign up for the FarFaria Service
Categories of personal data Description of category
Account Registration Data

This is the personal data that is provided by you or collected by us This is the personal data that is collected to enable you to sign up for and use the FarFaria Service. This includes your email address, first name, and last name.

Some of the personal data we will ask you to provide is required in order to create your account.

The exact personal data we will collect depends on the type of FarFaria Service plan you sign up for and whether or not you use a Third Party Service (as defined in the Terms and Conditions of Use, such as the Apple App Store) to sign up and use the FarFaria Service. If you use a Third Party Service to create an account, we will receive personal data via that Third Party Service but only when you have consented to that Third Party Service sharing your personal data with us.

Personal data collected through your use of the FarFaria Service
Categories of personal data Description of category
FarFaria Service Usage Data

This is the personal data that is collected about you when you are using the FarFaria Service - this may include:

  • Information about your type of FarFaria Service plan.
  • Information about your interactions with the FarFaria Service which includes the date and time of any requests you make, books you have consumed, books you add to your Favorites, and your interactions with other FarFaria users. This also may include details of your use of Third Party Applications and advertising you receive.
  • Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the FarFaria Service, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and FarFaria application version.
  • Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the FarFaria Service to you.
Personal data collected with your permission that enables us to provide you with additional features/functionality
Categories of personal data Description of category
Voluntary Mobile Data

In addition to the mobile data we collect to provide you with the FarFaria Service (outlined above), you also have the option to give us your consent to collect additional personal data from your mobile device to provide you with features/functionality that will enhance your FarFaria Service experience.

We will not access any of the personal data listed below without first obtaining your consent:

  • Your photos - If you give us permission to access your photos or camera, the FarFaria app will only access images that you captured with the camera within the FarFaria app and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll.
Payment Data

We may collect such personal data if you purchase any of our Paid Subscriptions or Lifetime Access (as defined in the Terms and Conditions of Use) or make other purchases through the FarFaria Service. The exact personal data collected will vary depending on the payment method (e.g. direct via your mobile phone carrier or by invoice) but will include information such as:

  • Name;
  • Date of birth;
  • Credit or debit card type, expiration date, and certain digits of your card number;
  • Mobile phone number; and
  • Details of your transaction history.
Contests, Surveys and Sweepstakes Data

This personal data is used to allow you to sign up and participate in these types of promotions. The exact personal data collected will vary depending on the promotion.

Marketing Data

This personal data is used to enable Intuary and our partners / service providers to send you marketing communications either:

  • Via email;
  • Whilst using the FarFaria Service.

6 What do we use your personal data for?

When you use or interact with the FarFaria Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:

Description of why the FarFaria Service processes your personal data (‘processing purpose’) Legal Basis for the processing purpose Categories of personal data used by the FarFaria Service for the processing purpose

To provide, personalize, and improve your experience with the FarFaria Service and other services and products provided by Intuary, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of the FarFaria Service (including for third party products and services).

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data

To understand how you access and use the FarFaria Service to ensure technical functionality of the FarFaria Service, develop new products and services, and analyze your use of the FarFaria Service, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the FarFaria Service.

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data

To communicate with you for FarFaria Service-related purposes.

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data

To process payment, to prevent or detect fraud including fraudulent payments and fraudulent use of the FarFaria Service.

  • Performance of a Contract
  • Compliance with legal obligations
  • Legitimate Interest
  • Payment Data
  • Account Registration Data

To communicate with you, either directly or through one of our partners, for:

  • marketing,
  • research,
  • participation in contests, surveys and sweepstakes,
  • promotional purposes,

via emails, notifications, or other messages, consistent with any permissions you may have communicated to us (e.g., through your Account Settings page).

  • Consent
  • Legitimate Interest
  • Contests, Surveys and Sweepstakes Data
  • Marketing Data

If you require further information about the balancing test that Intuary has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 14 ‘How to contact us’ for further details on how to contact us.

7 Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the FarFaria Service.

Personal data you may choose to share

The following personal data will only be shared with the categories of recipients outlined in the table below if:

  • you choose to make use of a specific FarFaria Service feature where sharing of particular personal data is required for the proper use of the FarFaria Service feature; or
  • you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the FarFaria Service.
Categories of Recipients Reason for sharing

Third Party Applications you connect to your FarFaria Account

If you connect your FarFaria account to a Third Party Application, such as, for example, social media, Intuary may share your Service Usage Data so you can connect to your FarFaria account.

Learn more about how to manage notifications, your publicly available information, and what you share with others in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.

Information we may share

Categories of Recipients Reason for sharing

Service Providers and Others

We use technical service providers which may operate the technical infrastructure that we need to provide the FarFaria Service, in particular providers which host, store, manage, and maintain the FarFaria application, its content and the data we process.
We use technical service providers to help us communicate with you, as described in Section 6 of this Policy.
We use marketing and advertising partners to show you more tailored content, or to help us understand your use of the FarFaria Service, to provide you with a better service. We also may share personal data with certain marketing and advertising partners to send you promotional communications about the FarFaria Service.

FarFaria Partners

If you access the FarFaria Service through an offer that you received or purchased from a third party, we share personal data with that third party about your use of the FarFaria Service, such as whether and to what extent you have used the offer, activated a FarFaria account, or actively used the FarFaria Service.
Depending on how you purchase any of our Paid Subscriptions or Lifetime Access (e.g. through a third party service), we share your FarFaria username or other Account Registration Data as necessary to enable your account.
We also share your personal data in a pseudonymised format with marketing partners who help us with promotional efforts and with advertisers that allow us to offer a free service.

Academic Researchers

We may share your personal data for activities such as statistical analysis and academic study but only in a pseudonymised format.

Other Intuary Products

We may share your personal data within Intuary to carry out our daily business operations and to enable us to maintain and provide the FarFaria Service to you.

Law Enforcement and Data Protection Authorities

We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.

We will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

Purchasers of our business

We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, FarFaria will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different Privacy Policy.

8 Data retention and deletion

We keep your personal data only as long as necessary to provide you with the FarFaria Service and for legitimate and essential business purposes, such as maintaining the performance of the FarFaria Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the FarFaria Service. For example, we keep your Favorites list, reading history, and account information.

If you request, we will delete or make anonymous your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
  • Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

9 Transfer to other countries

Intuary shares your personal data globally in order to carry out the activities specified in this Policy. Intuary may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.

Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in a country outside of the European Union and Switzerland. In such instances Intuary shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU Commission.

For further details of the security measures we use to protect your personal data, please see the ‘Keeping your data safe’ Section 11 of this Policy.

10 Links

We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the FarFaria Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

11 Keeping your personal data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, and to limit access to your computer, device, and browser.

12 Children

The FarFaria Service is directed to children under the age of 13 years. Intuary makes every effort to ensure that the FarFaria Service and other services and products provided by Intuary, comply with the Children's Online Privacy Protection Act (COPPA).

We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please use the FarFaria Service under the supervision of your parent or legal guardian, but do not provide any personal data to us.

If you are a parent or guardian of a child under the Age Limit and become aware that your child has provided personal data to Intuary, please contact us by sending an email to [email protected], and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.

If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the FarFaria account for that child.

13 Changes to this Privacy Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the FarFaria Service or by sending you an email. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.

14 How to contact us

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by sending an email to [email protected] or by writing to us at the following address:

Intuary, Inc.
5696 Diamond Heights Blvd, San Francisco, CA 94131
USA

We hope you enjoy FarFaria!
© Intuary, Inc.