Last Updated: January 28, 2021
We take reasonable steps to protect user privacy consistent with the guidelines set forth in this Policy and with applicable U.S. state and federal laws. WE TAKE PRECAUTIONS IN AN EFFORT TO PROTECT YOUR INFORMATION AGAINST SECURITY BREACHES. HOWEVER, THIS IS NOT A GUARANTEE THAT SUCH INFORMATION MAY NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF SUCH FIREWALLS AND SECURE SOFTWARE. BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THESE RISKS.
In this Policy, “user” or “you” means any non-Learner individual using the Service. “Learner” means a child using the Service. This Policy forms part of and is incorporated into our Terms of Service published at https://getgoally.com/terms-of-service/ (the “Terms of Service”).
BY ACCESSING OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS POLICY AND OUR TERMS OF SERVICE.
What Information Do We Collect?
- Personal Information in the Services: We may collect certain information that relates to and/or identifies you in connection with your use of the Service, as set forth below. We do not collect Personal Information from children or Learners; we collect information about Learners from persons authorized to share such information, either the parent/ guardian or a clinician or teacher who has obtained legally-valid consent. We will obtain any legally required consent before collecting Personal Information from a Learner.
- When you register on the Service, we may collect personal information such as your name and email address, password, the Learner’s diagnosis, the Learner’s name and birthday, clinic and school name, address, and other similar information. You may also choose to All of the foregoing is “Registration Information”.
- If you pay for the Service, a third-party processor will collect your Payment Information.
- If you provide your email or communicate with us by email but do not otherwise register to use the App, we will collect your email address for marketing and update purposes.
- You or a Collaborator may upload videos into the Service to model behaviors for a Learner, or track a Learner’s behavior through text, video, or pictures (all “Your Content”).
- If you choose to enable location tracking on the App, we will collect the geolocation of the device on which the App is installed (“Location Information”).
All of the information described in this Section 2 is collectively “Personal Information.” If you contact Goally through the App and disclose additional personal information, we will also collect and store that communication.
- User Data: We also collect “User Data”, which means all data other than Personal Information that Service users provide regarding or related to their use of or access to the Service that is not paired with their identity, such as routines, behaviors, goals, or rewards.
- Web Tracking Information and Cookies: The Site may use web tracking technologies such as cookies, pixel tags and beacons in order to operate the Site efficiently and to collect data related to usage of the Site. Such collected data (“Web Tracking Information”) may include the address of other websites you have visited, the type of browser you are using, your Internet Protocol (IP) address, device model, device ID and other unique device identifiers, what pages in the Site you visit and what links you clicked on, and whether you opened email communications we send to you. We may also use web tracking technologies that are placed in web pages on the Site or in email communications to collect information about actions that users take when they interact with the Site or such email communications. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. We use this information not to identify individual users, but to analyze trends, administer the Site, track users’ movements around the Site, and gather demographic information about our user base as a whole which provides us with the ability to determine aggregate information about our user base and usage patterns.
- How Do We Use the Information We Collect?
- Generally: Generally, we will use and store your Personal Information and User Data for the purpose of delivering the App and to analyze and enhance the operation of the Service. We may also use your Personal Information and User Data for the internal operational and administrative purposes of the Service. you make a person a Collaborator for a given Learner, that Collaborator will be able to see all your Personal Information except for Payment Information.
- Registration Information: Specifically, we use Registration Information to create an account for you on the App and to contact you about the Service. We may also share Registration Information with the Learner’s Collaborators if you invite them. We store Registration Information and do not share it with third parties except those service providers that make it possible to provide the Service.
- Payment Information: A third-party processor will collect and process your Payment Information; we do not store or process your Payment Information.
- Chat Information, Your Content, Learner Information, and Location Information: We use this information to provide you the ability to talk to your Learner and Collaborators, to help your Learner use the App, to track your Learner’s progress on their in the educational or clinical goals, and to physically track your Learner by your request. We share this information with your Collaborators who have access to the Learner’s
- Web Tracking Information: We use Web Tracking Information to administer the Site and to understand how well the Services are working, to store your user preferences, and to develop statistical information on usage of the Services. This allows us to determine which features visitors like best to help us improve the Service, to personalize your user experience, and to measure overall effectiveness. We also use Web Tracking Information to deliver advertising for the Service off the Site, for which we have implemented the following:
- Remarketing with Google AdSense; and
- Demographics and Interests Reporting.
Further, we, along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
- Aggregated and De-Identified Information: We will also create statistical, aggregated and/or de-identified data from Personal Information, User Data, and Web Tracking Information for analytical and commercial purposes. We are the sole owner of this aggregated or de-identified information. Aggregated and/or de-identified information is derived from Personal Information and User Data but in its aggregated and/or de-identified form it does not duplicate or reveal any User Data or relate to or identify any individual. We use this data to understand our customer base and to develop, improve and market our services, and for any other legally-permissible purpose.
- Legal Exception: Notwithstanding the above, we may store and use Personal Information and User Data to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.
- Promotional Communications: If you register and provide your email address along with the applicable consent, we may send you administrative and promotional emails.
- Account Closure: If any of your Personal Information appears to be incorrect, please contact us and let us know. If you delete or close your account, we will delete any Personal Information associated with your account, but other information you submitted that is not associated with you personally may not be deleted.
What Information Do We Disclose to Third Parties?
- Personal Information and User Data: We will not disclose your Personal Information or User Data to third parties except as follows:
- To third-party contractors engaged to provide services on our behalf (“Contractors”), such as analysis of data and usage of the Service, hosting and operating the Service, providing marketing or support and maintenance services for the Service, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us.
- If your Learner has a clinician or teacher and you want to share your or your Learner’s Personal Information with him or her, we will share your Personal Information with that Collaborator as you direct.
- When we otherwise have your consent in advance to share the information.
- Web Tracking Information: We may disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.
- Aggregated and De-Identified Information: We may disclose aggregated and/or de-identified data that does not contain Personal Information or User Data to any third parties, such as Contractors, potential customers, business partners, marketers, and funding sources, in order to describe our business and operations.
- Network Operators: Use of the Service may involve use of the services of third-party telecommunications carriers. Such carriers are not our contractors, and any information that a carrier collects in connection with your use of the Service is not “Personal Information” and is not subject to this Policy. We are not responsible for the acts or omissions of telecommunications carriers.
- Under certain circumstances, Goally may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- Finally, we may disclose your Personal Information in the good faith belief that such action is necessary to:
- comply with a legal obligation;
- protect and defend the rights or property of Goally;
- prevent or investigate possible wrongdoing in connection with the Service;
- protect the personal safety of users of the Service or the public; or
- protect against legal liability.
- Privacy Settings, Opt-Out
If you would like your Personal Information permanently removed from our Service, please contact us at [email protected] or follow the prompts on the Service or App.
We will promptly fulfill requests to delete Personal Information unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).
Your removal from our mailing list or database will not remove data you have submitted to us or records of past use of the Service, nor delete information stored in our data backups and archives. Such data will be maintained and/or deleted in the ordinary course of Goally’s business.
If you wish to opt out of promotional emails (but would not like to have your information permanently removed from our database), you may do so by following the “unsubscribe” instructions in the email, or by modifying your account settings. All users receive administrative emails; you cannot opt out of them while you remain registered on the Service.
You can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt-Out Browser add on.
- Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this Policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our reasonable security procedures. For example, we store all Personal Information and User Data using an industry-leading cloud service provider. We only store a Learner’s name on any device; all other Personal Information is stored off the device. We encrypt all Personal Information in transit and at rest.
- Links: The Goally App or Site may contain links to other websites. Goally is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave the Service and review the privacy statements of each third-party website. This Policy applies solely to information collected by the Service. We encourage our users to read the privacy policies of these other websites before proceeding to use them.
- Minors: Goally does collects and maintains personally identifiable information from persons under 18 years of age. Consistent with the Children’s Online Privacy Protection Act (COPPA) and other relevant child protection laws, we take extra precautions to protect the privacy of our child users. Because this is a service specifically for young children, purchase of this service is explicity permission to collect this information.
- Users from outside the United States: Goally and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Service, you consent to the use and disclosure of information in accordance with this Policy and subject to such laws.
- Reporting of Abuse: As detailed in our Terms of Service, if we detect any content or behavior in the Media that suggests abuse or harm to children, we will report such instances to the appropriate authorities in accordance with legal obligations and our commitment to child safety.