Stop, Breathe & Think Kids Privacy Policy

STOP, BREATHE & THINK KIDS PRIVACY POLICY Stop, Breathe & Think respects the privacy of all of its users. We believe that the regular practice of mindfulness and compassion is the key to emotional wellness and that this concept applies equally to children. Our intention is to create a safe and secure environment for all of our users and in particular our child users under the age of 13 (“Child Users”), for whom we have created special protections. This Privacy Policy (“Privacy Policy”) informs you about our policies and practices regarding the collection and use of your information and lets you know about options that you have to control or restrict the availability and use of your information.

1. ABOUT US We are Stop, Breathe & Think, PBC (“SBT”, “us”, “we” or “our), a public benefit corporation registered under the laws of the state of Delaware in the United States with its principal office address at 11111 Santa Monica Boulevard, Suite 1700, Los Angeles, CA, 90025, USA, (424) 901-5114.

2. ABOUT OUR SERVICES Stop, Breathe & Think provides easy tools and inspiring content to help improve your mental wellness, every day. SBT’s mobile application for children is known as Stop, Breathe & Think Kids or “SBT Kids”. We deliver to Child Users and their parents or supervising adults accessing the Services on their own behalf or on behalf of their Child User (“Parent Users”) (together, “Users” “you”, “your”) stories, games and meditation and mental wellness activities via the SBT Kids mobile application, the SBT Kids website (currently located at http://www.stopbreathethink.com/kids), and through any other platform or media through which we may make such services available (the “Services”).

3. ABOUT THIS PRIVACY POLICY This Privacy Policy informs you of SBT’s policies and practices regarding the collection and use of information Users submit to us or which we collect about you through our Services. We will only use your information or share your information in the ways we describe in this Privacy Policy. The Privacy Policy also outlines options that you have to control or restrict the availability and use of your information. Wherever you reside or from whichever country you submit your information, Parent Users consent to our use of your information, consistent with this Privacy Policy, in the United States and in other territories where SBT provides its Services.

4. CHANGES TO THIS PRIVACY POLICY SBT reserves the right to change this Privacy Policy from time to time. We will usually inform you of any changes by posting the updated Privacy Policy through mobile applications and on the SBT website. If we make any material changes to our Privacy Policy, we will post a notification to Parent Users through the mobile applications and on the SBT website and, if Parent Users have registered, notify the Parent User via the preferred means of contact for such notices (e-mail or text message) and/or by asking Parent Users to review the changes to the Privacy Policy the next time either the Child User or the Parent User accesses the Services. Your continued use of the Services after the changes are communicated will indicate the Parent User’s consent to our use of the Parent User’s and the Child User’s information consistent with this Privacy Policy, including those changes.

5. WHY DO WE COLLECT INFORMATION? We want to give Users the best experience possible. We collect information to manage the Services, to deliver to our users a personalized experience, and to improve our Services, features, and content. We do not collect any information from Child Users beyond what is necessary to provide them access to the Services, as outlined below.

6. SOME TERMS WE USE IN THIS PRIVACY POLICY Important terms that we use in this Privacy Policy are “Personal Information”, Non-Identifying Information” and “Log Data”. To explain what we mean by these terms:a. “Personal Information” is information about the User that can be used to contact or identify the User, such as a full name, street address, e-mail address or mobile number. It may also include financial information that is provided in connection with a subscription. We do not collect Personal Information directly from Child Users and will only directly collect information through their Parent Users.b. “Non-Identifying Information” means information that may be specific to a person but does not permit the identification of an individual person, such as other information that Parent Users provide as part of the Child User’s and Parent User’s use of the Services. For example, we ask Parent Users to create a user name for their Child Users. c. “Log Data” is derived by our servers automatically as the Child User or Parent User interacts with the Services, which record information that the User’s browser or mobile device sends whenever they interact with the Service. Log Data is a form of Non-Identifying Information.

7. WHAT INFORMATION DO WE COLLECT, AND HOW DO WE USE IT?

1. Personal Information. SBT Kids does not currently require Users to set up an account or to input any Personal Information, except that in the course of obtaining parental consent for Child Users, we collect and maintain a Parent User e-mail address. We may collect names and e-mail addresses from Parent Users who correspond with us or sign up for newsletters. We will not retain any Personal Information about a Child User, and Parent Users should not include such information in any correspondence. If Parent Users need to refer to a Child User account, they should only refer to the user name of the Child User so that we may distinguish between the Parent User’s children. If a Parent User chooses to authorize their Child Users to view content that may be available through a subscription (“Subscription Services”) or purchase premium content, we will also collect credit card or other payment information from the Parent along with the Parent User’s billing address.

2. Non-Identifying Information. We collect some Non-Identifying Information about the User as they navigate through our Services. For example, when the Child User selects images that reflect their moods and emotions as they enter the Services, the Child User is explicitly sending information, which SBT will use to improve its recommendations to the Child User. We also track the content and time for each activity by the Child User for the purposes of knowing which activities are being used and also for measuring the progress of our Child Users, which allows them to earn stickers. We will then associate the stickers with a Child User’s account.

3. Log Data. When a user interacts with the Services, our servers automatically record Log Data that the User’s mobile device or browser sends. This Log Data may include information such as the mobile device identifier, the computer’s IP (Internet Protocol) address and browser type, the operating system, and other generalized analytics that help us deliver and monitor the effectiveness of our Services. Log Data is used to track a User’s progress, monitor, and analyze the use of the Services, to analyze usage patterns, to optimize access to our Services, and to control the load on our servers so that we can serve you better.

4. Child Users. We will not use Log Data or any Non-Identifying information to contact a Child User directly. Any required communications with the Child User will be directed to the Parent User. If you have any further questions about how information from a Child User is collected or used, or if you need to make any changes to a Child User account, please contact us at support@stopbreathethink.com.

5. Retention and Storage of Information. Unless there is a specific legal or regulatory requirement for us to keep the information, we will retain it for no longer than is reasonably necessary for the purposes for which the data was collected or for which it is to be further processed. SBT is located in the United States. Accordingly, the information we collect may be transferred to and stored on our servers or those of third parties that act on our behalf (such as hosting providers) in the United States or other countries outside of the European Economic Area. If a Parent User is located within Europe, then by reviewing this Privacy Policy and using the Services the Parent User is approving the collection, transfer, and storage of the Parent’s and the Child’s information outside of the European Economic Area or other territories where the information may have been collected.

6. Security. We have protected Personal Information with industry-standard administrative, physical and technological measures to maintain the security of Personal Information, however, we are not able to fully eliminate all security risks or potential breaches. We have developed protocols and notification processes that will be followed in accordance with applicable law in the unlikely event of a security breach.

8. HOW CAN I REVIEW OR EDIT MY INFORMATION OR UNSUBSCRIBE FROM COMMUNICATIONS?
Parent Users may access, update and edit certain Personal Information that is in their account. Child Users cannot access the information in their account but can view their stickers and may be able to view their history. When a Parent User receives messages from us, the Parent User may indicate a preference to stop receiving further communications from us by electing to “unsubscribe”. We may, however, still send the Parent User administrative messages regarding the Services and we will message the Parent User for any communications concerning their Child User. Parent Users may contact us at support@stopbreathethink.com with a request to review their child’s information, to request that we delete such information, or to request that we not further collect or use such information. We may retain an archived copy of your records as required by law or for legitimate business purposes.

9. WHEN DO WE SHARE INFORMATION WITH OTHERS, AND WITH WHOM? We do not disclose information collected from Child Users to third parties, other than in the limited circumstances described below.

1. Payment Processors. If a Parent User signs up through SBT Kids for a Subscription Service or to purchase premium content, a third-party app store or payment processor may receive access to the Parent User’s Personal Information in the form of payment information (credit card and address) for the sole purpose of processing transactions and renewals. Any such payment processors will be bound to maintain all such Personal Information in a secure environment, keep it confidential and not use or disclose such information for any purpose other than to validate purchases and assist us in operating the Subscription Services. If the Parent User has purchased content or signed up for Subscription Services through an app store, the Parent User should refer to that store’s terms for information on how it maintains personal financial information for all purchases including the SBT Kids Subscription Services.

2. Other Service Providers. We may employ third party companies and individuals to help us deliver our Services, to perform maintenance and research services, or to assist us in analyzing how our Services are used (such as infrastructure providers, database management, web or mobile analytics and improvement of the Services’ features). These third parties will receive access to your information only to perform these tasks on our behalf and are contractually obligated not to disclose or use the information for any other purpose.

3. Aggregate and Non-Identifying Information. We may disclose to third parties information that does not include Personal Information but may include certain aggregated Non-Identifying Information and Log Data for the purposes of industry analysis, research and other purposes relating to our Services. Any aggregated information shared in these contexts will not contain or be connected with your Personal Information.

4. Business Transfers. If SBT or the assets of SBT are acquired by another company, we may transfer your information in connection with that acquisition or sale and the acquiring company will possess the information (including your Personal Information) collected by us and it will assume the rights and obligations described in this Privacy Policy.

5. Compliance with Laws and Law Enforcement. We may access and disclose your information to government or law enforcement officials or private parties if we believe in good faith that such disclosure is necessary to comply with applicable laws, to respond to valid legal process such as a search warrant, subpoena, statute, or court order, to protect the property and rights of SBT or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

10. WHAT POLICIES APPLY TO THIRD-PARTY SERVICES AND APPLICATIONS? The Services may contain links or integrations to third-party applications, websites or services. We have no control over, do not review, and cannot be responsible for these outside services or their content. This Privacy Policy does not govern your visits to these other services, and your access is entirely at your own risk. These other services and applications may set their own cookies on users, collect data, or solicit personal information. You should refer to any privacy policies on such services and applications to understand how your information may be collected and used, and should choose appropriate settings for sharing your personal information before proceeding to any integration with a third-party service or application. Effective Date: October 21st, 2019