1. IMPORTANT INFORMATION AND WHO WE ARE
While Robin and the Services may relate to children, we do not collect data relating to children without your request to do so. All data on our will be encrypted and stored via high security standards.
CONTROLLER & CONTACT DETAILS
Full name of legal entity: Expper Technologies, Inc.
Email address: [email protected]
Postal address: 326 Mira Loma Ave, Glendale, California, 91204
If you are subject to the GDPR and/or UK Data Protection Act 2018, you may also contact your local data protection authority within the European Economic Area for unresolved complaints (for example, the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach your local data protection authority so please contact us in the first instance.
It is important that the legal data we hold about you is accurate and current. Please keep us informed if your legal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). References herein to your personal data or personal data shall mean, as relevant, the personal data of Client Users, including children. Besides your legal data, we are not collecting, using, storing and transferring any kinds of personal data about you and your Client Users, including children, that we have grouped together as follows:
We acknowledge that children Client Users may interact with Robin and share personal data about themselves, such as their first name, last name, date of birth, gender, preferences, and other personal data, however, all data is removed during or after interaction.
In the case of our other Services, we do not collect or solicit personal data from or direct or target interest-based advertising to anyone. If you are under 13, please do not send any data about yourself to us, including your name, address, or email address. If we learn that we have collected any kind of personal data, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child, please contact us.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If we need to collect personal data by law or under the terms of a contract we have made with you, and you fail to provide that data when requested, we may not be able to perform the contract we already have or are in the process of entering into with you (for example, to provide you with Robin and the Services). In this case, we may have to cancel a Service with you, but we will make sure to provide you with notice if this occurs.
3. HOW WE USE YOUR DATA
We will only use your legal data when the law allows us to. Most often, we will only use your legal data in the following circumstances: where we need to perform the contract we are about to enter or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; where we need to comply with a legal obligation. We process your data for the following purposes:
To provide Robin and the Services.
To perform the contract, we process data necessary to:
Verify and confirm payments; At our discretion, provide and deliver products, services, and any other information you reasonably request; Send you Robin- or Services-related communications, such as when updates are available, and of changes to any products or services we offer or provide through Robin or the Services; Fulfill any other purpose for which you provide the information; Carry out our obligations and enforce our rights arising from any contracts entered into between Company and Client, including for billing and collection.
To keep Robin and the Services safe and fair.
Analyze and monitor use of Robin and the Services and their social features; Take action against fraudulent or misbehaving users.
MARKETING & PROMOTIONAL OFFERS FROM US
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Sensory, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from or through us and you have not opted out of receiving that marketing.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. Except as explicitly provided hereunder, we do not sell your personal data. In addition, we may disclose personal information that we collect or you provide:
To our subsidiaries; To a buyer, investor, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Expper’s assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Expper about Robin and the Services users is among the assets transferred; With your consent; To comply with any court order, law, or legal process, including to respond to any government or regulatory request, including in order to combat fraud and illegal activity; To enforce our rights arising from any contracts entered into between you and us; and If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Expper, our customers, users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
We have put in place appropriate security measures to prevent your legal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected legal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we do our best to protect your legal information, we cannot guarantee the security of your network which can be used for Robin and the Services. Any transmission of information is at your own risk.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We retain your data for as long as your account is active or you are otherwise accessing and using Robin and the Services or as needed to provide you with Robin or the Services. Note that if you ask us to remove your legal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us, the DPO, at the contact information provided above.
What We May Need From You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know.
Your Legal Rights. You have the right to:
Opt-out of marketing emails and other direct marketing. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful, but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims. You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.