This policy also describes what personal information we collect from California employees of VTech, California applicants for employment, the California beneficiaries of employees, and California representatives of our business partners.
"Personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, is linked to, or could reasonably be linked, directly or indirectly, to a particular identified or identifiable individual or household. It does not include de-identified or aggregate data or data that is publicly available.
“Sensitive personal information” means personal information that applicable privacy laws determine to be more sensitive and therefore warranting more protection. Sensitive personal information is defined as information that reveals: (a) an individual’s Social Security, driver’s license, passport, or other state identification number; (b) an individual’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) an individual’s precise geolocation; (d) an individual’s racial or ethnic origin, religious or philosophical beliefs, mental or physical health condition or diagnosis, medical treatment or diagnosis, sex life or sexual orientation, citizenship or immigration status, or union membership; (e) the contents of an individual’s mail, email, or text messages, unless the business is the intended recipient of the communication; (f) biometric or genetic information for purposes of uniquely identifying a an individual; or (g) information collected from a known child.
Except for certain areas of our Sites that are limited to our retail dealers and distributors or the Service, you need not "sign-in" or register to browse our Sites. However, some information, such as your Internet protocol (IP) address, may be collected as part of your browsing activities by cookies or similar technology, as described below.
In fulfilling any inquiry or transaction ordered by you, we may rely on affiliates or other companies to perform functions on our behalf. These functions may include order fulfillment, package delivery, postal and email delivery, customer service, data collection, storage, data analysis, and credit processing. We may also use affiliates or other companies to perform marketing on our behalf, such as sending you information about products or services we think you may be interested in. The entities we contract for these purposes have limited access to your PI to perform these functions on our behalf and may not use it for other purposes.
Registration Data: We also provide customers with the opportunity to register their VTech products and give us additional information about themselves, including information about recent purchases and certain demographic data. We refer to this as "Registration Data." Providing Registration Data is optional, and we do not require that you give us this information to complete a purchase, receive warranty services or browse our Sites.
If you choose to provide Registration Data, we may use it, alone or in conjunction with other information, to identify other products or services that we think you may be interested in purchasing and to send you information about those other products or services. If you do not wish to receive these marketing messages from us, you can so indicate by filling the “opt-out” box located on the Contact Us page. If you did not opt-out, you may receive from us periodic marketing emails regarding products or services that we think may be of interest to you. You may also opt-out of receiving these marketing emails by clicking the "Unsubscribe" link at the bottom of the email received. It may take us up to 10 days to complete this process, as permitted by law. If you opt-out, you will still continue to receive non-marketing emails from VTech related to your use of the VTech sites and services.
Cookies and Similar Technologies: Some of the pages on our Sites and Services use "cookies" to help us better service visitors to our Sites and users of our Services. Cookies are brief text files transmitted by a website to the hard drive of your computer when you click on a page. Should you return to the page at a later time, your computer will transmit the text message back to the website server to permit the server to recall previous visits to our Sites or Services or to keep track of a transaction in progress. You may set your browser to reject cookies by changing the settings on your browser. Doing this, however, could diminish your use of our Sites or Services by preventing the use of certain features including the purchasing process. Cookies are not linked to Registration Data.
Do Not Track Signals: Our systems do not currently recognize or respond to browser “Do Not Track” signals.
Web Site Data Collection: To the best of our knowledge, other businesses, which do not have contractual obligation with us, may not, collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when a consumer uses our Sites and Services.
Automated Decision-Making Tools: We use automated decision-making tools or processes in order to prevent misuse of our websites and to prevent fraud when you purchase via our website. This may lead to a refusal of the transaction. Should you not agree with this refusal, please contact our customer service department.
Account Data: If you activate the Services, as part of your account creation for the Web Apps or Mobile Apps, we will ask you to provide certain PI, including your name, physical address, email address, and telephone number (“Account Data”). VTech does not itself collect or obtain your credit card information. To complete the payment or purchase process (for example, for cloud recording subscriptions), you will be directed to a third-party payment site, such as Braintree. For more information on Braintree’s privacy practices, please see their privacy policies, available at https://www.braintreepayments.com/legal/braintree-privacy-policy. Third party payment sites, such as Braintree, have limited access to your PI to perform these functions on our behalf and may not use it for other purposes.
Usage Data: Our Services are designed to allow you to connect certain compatible devices (for example, our monitors and sensors) to the Services. Once the Services are enabled, your use of the Services with a connected device will automatically report certain Usage Data to our servers. This information is collected automatically when you interact with our Services. Such Usage Data may include configuration, technical, and/or set-up information about the connected device; information about the user, including wireless network and/or Bluetooth information; mobile device information; temperature sensors, flood sensors, motion sensors, or other environmental data; Internet Protocol (IP) address; cookie information; and information about the device’s operating system and type of browser. The exact type of information collected from each product will vary depending on the product type.
If video and audio recording devices are used as part of the Services, your use of the Services may also generate additional Usage Data, such as audio and/or video streaming and recording, other audio and/or video content, and images and/or snapshots. This video, audio, and image content will be transmitted to the servers of VTech or its service providers. Nevertheless, this video, audio, and image content will not be stored.
Customization Information: Your use of the Services will also generate a third type of data (“Customization Information”) that will be used to customize your user experience, and may include information such as patterns of your use of the services.
We will use your Transactional, Registration, and Other Data collected through your use of our Sites for the following purposes:
We will use your Account, Usage, and Customization Data collected through your use of our Services for the following purposes:
We will also use your Account, Usage, and Customization Data which has been specified to be used for marketing and promotion at the time of collection:
We do not share or sell any of the information collected from you in relation to our Sites and Services with third parties in exchange for money for their independent marketing or promotional purposes. VTech may, however, disclose your information to service providers and to third parties in the following circumstances:
The security of your personal information is important to VTech, and VTech is committed to handling your information carefully. We use Transport Layer Security Technology ("TLS") to encrypt the PI and Registration Data you transmit to us through our Sites and Services. Further, to ensure that your PI and Registration Data are secure, we store it in a database with restricted access.
VTech also protects your personal information by requiring users of our Sites and Services to verify their identities with unique login information before they can access or edit their account information or settings. If you select and establish an account with us in connection with your use of Sites or Services, you are responsible for keeping that login information confidential. Do not share your login information with anyone else.
We recommend that you review and understand the privacy policies of the websites you visit, whether you visit those websites directly or through a link from a page on the Web Services. VTech does not have access to or control over information collected by third-party websites.
Nonetheless, we seek to protect the integrity of our Web Services and the links placed upon them and therefore we request feedback not only for our own Web Services, but also for websites we link to as well (including if a specific link does not work).
We do not sell products for purchase by children. All of our products (including products intended to be used by children) are intended to be purchased by adults. If you are under 18 years old and you want to buy something on our website, you must have an adult buy it for you. We have not designed our website to encourage transactions with, or to obtain information from, children. VTech respects the sensitive nature of children's privacy online. Therefore, if we learn that a user is under 13 years of age, we will promptly delete any information collected from that user, and if we learn that a user under 18 years old made a purchase through our Sites without adult involvement, the order will not be processed.
In the preceding 12 months, we collected for a business purpose the following categories of personal information about you. We retain this information only for as long as is reasonably necessary to fulfill the purposes for which it was collected unless a longer retention period is required by law. We determine how long to retain each category of personal information based on (1) the amount, nature and sensitivity of the information; (2) the manner in which the information is necessary to fulfill the purposes for which it was collected; and (3) the amount of time required to properly delete or otherwise cease retention of the information in accordance with data security laws and regulations.
We collect this personal information from the following categories of sources:
We collect and disclose this personal information for the following business or commercial purposes:
In the preceding 12 months, we collected for a business purpose the following categories of sensitive personal information (these categories do not include information that is publicly available). We retain this information only for as long as is reasonably necessary to fulfill the purposes for which it was collected unless a longer retention period is required by law. We determine how long to retain each category of personal information based on (1) the amount, nature and the sensitivity of the information; (2) the manner in which the information is necessary to fulfill the purposes for which it was collected; and (3) the amount of time required to properly delete or otherwise cease retention of the information in accordance with data security laws and regulations.
We collect this sensitive personal information from the following categories of sources:
We collect, use and disclose this sensitive personal information for the following purposes:
We do not use or disclose sensitive personal information for any purpose other than those described above or otherwise specified and permitted by law, including the California Consumer Privacy Act (as amended by the California Privacy Rights Act) and regulations issued thereunder.
Should VTech at any time collect sensitive personal information in our interactions with you, we will provide you clear notice of the type of data we collect, what it is used for, and we will obtain your consent before collecting this data.
For the purposes of this Section and Section7, “sell” means disclosure of personal information to a third-party for monetary or other valuable consideration. “Share” means disclosure of personal information to a third-party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. “Cross-context behavioral advertising” means the targeting of advertising to a person based on the person’s personal information obtained from the person’s activity across businesses, distinctly-branded websites, applications, or services, other than VTech’s. “Targeted advertising” means displaying advertisements to a person where the advertisement is selected based on personal information obtained from that person’s activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests, but does not include advertisements based on activities within VTech’s own websites or online applications or in response to a person’s request for information or feedback, or processing personal information solely for measuring or reporting advertising performance, reach, or frequency. “Profiling” means any form of automated processing performed on personal information to evaluate, analyze, or predict personal aspects related to an identified or identifiable natural person's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. "Decisions that produce legal or similarly significant effects concerning the consumer" means decisions that result in the provision or denial of financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, health care services or access to essential goods or services or basic necessities, such as food and water.
VTech does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
In the preceding 12 months, we have not knowingly disclosed personal information to third parties in exchange for money. However, we have disclosed personal information to third parties for the purpose of web analytics, and this disclosure may constitute a “sale” under the broad meaning of some state laws and the definition above. In addition, we have “shared” and processed personal information for “targeted advertising” within the meaning of those terms provided above. However, we have not knowingly sold, shared, or processed for targeted advertising the personal information of minors under 16 years of age. Accordingly, we permit residents of the U.S. to “opt-out” of the “sale,” “sharing,” and processing of personal information for “targeted advertising,” as set forth in Section 7 below.
In the preceding 12 months, we disclosed for the business purposes described above (to the extent only as necessary) the following categories of personal information to the following categories of third parties.
We have disclosed these categories of personal information for the purposes described above.
We will not discriminate against a person because the person exercised a personal information request (as described below), including, but not limited to, by:
However, we may offer a person a different price or rate or provide a different level or quality or selection of goods or services if the offer is related to the person’s voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program and the difference is reasonably related to the value provided to us by that person’s personal information. In addition, we may offer financial incentives, including payments as compensation, for the collection of personal information, the sale or sharing of Personal information, or the retention of personal information. We will provide notice of the material terms of a financial incentive program before a person enrolls, and will enter a person into such a program only if the person gives us prior opt-in consent, which may be revoked by the person at any time.
We will not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature. We currently do not offer any financial incentive programs.
The purpose of this Section is to inform you of your privacy options. Some states provide these options to their residents as a right, but we want to provide all of our customers and users and others from whom we collect personal information these opportunities to better control how VTech interacts with their personal information. VTech reserves the right to discontinue this policy at any time, and at its sole discretion, and to limit these privacy options to only those residents of those jurisdictions with privacy laws affording the applicable rights.
You may request that we confirm whether we process your personal information and that we disclose to you the following information:
Please note that all requested information includes information from a 12-month period preceding our receipt of your request. You may request information beyond this 12-month period, and we will provide the information as long as it is not impossible or involve a disproportionate effort for us to do so. The request for information beyond the 12-month period applies only to information collected on or after January 1, 2022.
You may submit a request to know by calling our toll-free number at 1 866 277 9032 or submitting a request at “Contact Us” or “Personal Information Request Form”. Such a request may be referred to as a “request to know”. In the request, please specify whether you are seeking information about categories of personal information and/or specific pieces of personal information. We will verify your identity before complying with any such request. We will require you to provide personal information in order to verify your identity, such as your name, email address, and/or telephone number. For requests to know specific pieces of information that we have collected, we may also ask for information about a product you purchased, and we may ask you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
You may request that we delete any personal information about you, and that we notify any service provider, contractor, or third-party to delete your personal information from its records. Such a request may be referred to as a “request to delete.” However, your personal information may not be deleted under certain circumstances allowed by law, including (but not limited to) where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with us, or to otherwise perform a contract between us and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; to comply with a legal obligation; or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided that specific data.
You may request the deletion of such person information by calling our toll-free number at 1 866 277 9032 or submitting a r0equest at “Contact Us” or “Personal Information Request Form”. In the request, please specify that you are requesting the deletion of personal information. Before deleting such personal information, we will verify your identity. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number.
You may request that we correct any inaccurate personal information about you. You may request the correction of such personal information by calling our toll-free number at 1 866 277 9032 or submitting a request at “Contact Us” or “Personal Information Request Form”. In the request, please specify that you are requesting a correction of personal information. Before correcting such personal information, we will verify your identity. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number.
You may direct us not to do the following:
You may also opt-out of targeted advertising by clicking “Cookie Control” button at the bottom left-hand corner of our website and selecting “DISABLE ALL” cookies. Or, if your browser supports it, you can turn on the Global Privacy Control (GPC) for that particular browser. Please note that we respect GPC for cookies on our website and will automatically opt you out of all but “Cookies essential to the operation of the site” when a GPC setting is detected. Please visit globalprivacycontrol.org for more information.
Should we deny your personal information request, you may appeal the denial within 60 days from receipt of our decision on your request. You may submit an appeal by calling our toll-free number at 1 866 277 9032 or submitting a request at “Contact Us” or “Personal Information Request Form”.
If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General of your state (or the Minister of Justice for Canadian provinces) to submit a complaint or express your concerns.
You may use an authorized agent to submit personal information requests, including through the use of a technology including, but not limited to, an Internet link or a browser setting, browser extension or global device setting, indicating your intent to opt out of certain processing of personal information. An authorized agent may submit a request to know, to delete, to correct, or to opt-out, or may submit an appeal, by calling our toll-free number at 1 866 277 9032 or submitting a request at “Contact Us” or “Personal Information Request Form”.
To use an authorized agent, you must provide the agent with signed permission, and the authorized agent must include proof of signed permission from the person on whose behalf the agent is submitting the request. In addition, you may be required to verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to applicable state law (though the agent will be required to submit proof of such power of attorney) or requests made by an opt-out preference signal.
If we make material changes, we will notify you by e-mail if you have registered an account with us prior to the changes becoming effective, as well as inform you of any choices you may have with respect to these changes.
If you choose to visit the Web Services, your visit and any dispute over privacy are subject to this Policy and the relevant Terms and Conditions for that service. This Policy shall be governed and construed in accordance with the laws of the State of Oregon, excluding its conflicts of law rules. Any dispute arising out of or relating to this Policy or information VTech receives through the Web Services will be subject to the dispute resolution procedures and provisions set forth in our Terms and Conditions.
If any provision of this Policy is held to be unlawful, void or unenforceable for any reason, then that provision will be deemed to be deleted from this Policy and that deletion will not affect in any way the remaining provisions in this Policy.
VTech will not be liable in any way for its failure or delay to comply with this Policy if that performance becomes commercially impracticable as a result of any existing or future law, rule or regulation, whether valid or invalid, or any cause beyond VTech's reasonable control, including war, mobilization, insurrection, accident, natural disaster, explosion, rebellion, civil commotion, riot, act of an extremist, terrorist or public enemy, sabotage, labor dispute, lockout, strike, explosion, fire, flood, storm, accident, drought, power failure, inability to obtain suitable and sufficient energy, labor or material, delay of carriers or embargo. VTech also is not responsible for harm, damage, or injury caused by the actions of others.
This Policy constitutes your entire understanding related to information about you received in connection with your use of the Web Services, and it supersedes any prior agreements or understandings about that topic not incorporated in this Policy. If more than one version of this Policy applies to any dispute related to that information or the Web Services, the latest version of this Policy will control.
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