Wonder Workshop, Inc.
Effective Date: March 11, 2019
Prior Version Updated: October 19, 2017
Most of the websites operated by Wonder Workshop are websites intended for grown-ups (parents, educators, developers, etc.) to learn about and/or purchase our products and services. These websites (which we refer to as our “General-Audience Sites”) include, but are not limited to our:
We do not knowingly solicit or collect Personal Information (defined below) from children under the age of 13 (“Children Users”) on these General-Audience Sites.
The Wonder Workshop robots (Dash & Dot, Cue, etc.), corresponding mobile applications, desktop applications, browser-based educational software and play.makewonder.com website (together, our “Child-Directed Products”) are generally intended to be used and enjoyed by children, students, and teenagers of all ages. For this reason, we employ special measures when collecting or processing information through our Child-Directed Products and generally avoid or limit the collection of Personal Information through these products. For more details on our practices related to children, please see the section on Children’s Privacy below.
- “App” means any Wonder Workshop software application, including, but not limited to, the Wonder Workshop Android, Apple App Store, Microsoft Store, Amazon Appstore and/or software applications.
- “Browsing Information” means information about your use of the Service, or your computer’s (or other access device, such as an iPad, tablet, Chromebook or smartphone) interaction with the Service. Browsing Information also includes certain of the information described in the “Information Collected Automatically” section below. This information is linked to a device identifier, such as the Internet Protocol (IP) address of your computer or device. Your Wonder Workshop robot includes a product identifier, and through the App, your robot transmits information to us that we use to provide our services, assist you in troubleshooting, and improve our products, services, Website, and App. In general, Wonder Workshop does not use Browsing Information to identify you, but such information may be paired with Personal Information, or with other information that together, could be used to identify you. Additionally, third parties, such as analytics companies and advertising service providers may access, collect, store, and use Browsing Information, and they may use it to identify you.
- “Personal Information” means information that directly identifies you, or that can directly identify you, such as:
- your full name
- physical address (home, mailing, shipping, and/or billing address)
- e-mail address
- phone number, and/or
- credit card information In the case of Children Users, Personal Information may also include the child’s precise:
- Precise geolocation
- school name/address
- a photo, video, or audio file that contains the child’s image or voice and/or
- a persistent identifier (such as an IP Address or device ID) when such information is not used for internal support purposes.
- “Product Use Information” means information related to use of one of our products, such as robot name, activities coded, or similar information. Product Use Information is linked to the product identification number of your robot.
- “User Content” means any content that you personally create or produce and upload to our Service, such as a comment, message, photo, video, voice recording, artwork, software code or program, or other similar content. User Content may (in some cases) contain Personal Information if Personal Information is provided within the User Content.
- “Website” or “Site” or “Site” means any websites, web pages, and any subpages (including mobile websites, web pages, and subpages) under Wonder Workshop’s control, whether partial or otherwise. This includes but is not necessarily limited to the General-Audience Sites listed above, the play.makewonder.com website, and any subpages of these websites.
What information do we collect?
Personal Information We Affirmatively Collect From You
We may collect Personal Information from you, such as:
- Payment: credit card, bank account, or other information used in payments
- Contact: email id, phone number, billing, shipping, or mailing address
- Identity: first name, last name, age, username, password
- User Content: text, image, video, or a combination of such media authored by using our service
- Social Media: Personal data when you interact with our ads and related content
- Job Data: Details related to your work history if you apply to Wonder Workshop
- (i) register for an account on our Service
- (ii) sign up for our newsletter
- (iii) make a purchase or order on our General-Audience Sites
- (iv) include Personal Information in User Content that you upload to our Service, or
- (v) set up or enable certain features for your child/student on our Child-Directed Products.
Other profile information you may affirmatively provide to us about you or a child or student such as:
may be collected and maintained together with your Personal Information. You can choose not to provide any information that is requested of you by us. However, this may limit your ability to use or access the Service.
Additionally, if a friend refers you to us by providing us with your e-mail address, the system may send you a message. However, we will use your e-mail address only to send the friend’s message unless you otherwise affirmatively provide information to us.
In addition to collecting information on the Service, we may collect information from you when you communicate with us over the phone, including via text messages or via e-mail. This information may include Personal Information. This information may be matched with and stored in connection with Personal Information provided or collected in connection with your registration for or use of the Service.
We also may now or in the future receive Personal Information about you from third parties. For example, if you access our Service or Site through a third-party connection, Single Sign-On (SSO) or log-in methods such as:
- Facebook SSO
- Google SSO
- Microsoft SSO
where you have a registered account, that third party may pass certain information about your use of its service to Wonder Workshop. This information could include, but is not limited to:
- the user ID associated with your account
- an access token necessary to access that service
- any information that you have permitted the third party to share with us, and
- any information you have made public in connection with that service.
You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Wonder Workshop Service or Site.
For more details on our data collection practices for Children Users, please see the section on Children’s Privacy below.
Information Collected Automatically
We may collect Personal Information from you, such as:
- Product Usage: data related to your use and engagement with our account system, apps, etc
- Such information is automatically transmitted to Wonder Workshop through our App and used to provide product support, improve our products and services, and for similar activities that support our internal operations.
- Robot: diagnostic data of the robot used
- This could include details such as:
- Crash data
- Firmware version
- Language of robot sounds, etc
- Device: Anonymized details related to the device (computer, smartphone, tablet)
- Log file information is automatically reported by your browser each time you access a web page on our Service. When you access the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as:
- your IP Address
- web request,
- browser type
- referring / exit pages and URLs
- number of clicks
- domain names
- landing pages
- pages viewed, and other similar information
- device system language
We may use certain third party services including, but not limited to, Google Analytics, to help us understand your use of the Service. These services collect information about your use of and the performance of the App, the Site, and/or Wonder Workshop’s robots and also collect anonymized information sent by your browser as part of a web page request, including cookies and your IP Address.
In general, we will store tracking information in an anonymous aggregated form, however, we or our third-party tracking partners may store certain information, such as page views, in a manner that can be associated to specific devices.
Third Party Ad Networks
On our Child-Directed Products, Wonder Workshop does not show behaviorally-targeted or retargeted ads to Children Users or track Children Users for targeted advertising purposes.
Some web browsers may automatically transmit “do-not-track” signals to the websites which users visit. Wonder Workshop does not currently process or respond to such automated “do not track” signals or other transmissions that indicate a request to automatically disable online tracking of users who visit or use our Service.
How we use your information?
We use or may use Personal Information and Browsing Information for a variety of purposes, including:
- To operate the Service, monitor the effectiveness of the Service, to improve the content of the Service, and layout and design.
- To monitor, analyze and describe usage patterns and performance of the Service, including aggregate metrics such as the total number of visitors, traffic, and demographic patterns.
- To conduct system administration and system troubleshooting and to diagnose or fix technology problems. To help provide you with a smooth, efficient user experience.
- For billing, identification and authentication, and fraud prevention.
- To respond to any inquiries or requests received from you. To contact you and deliver administrative notices and communications relevant to your use of the Service, such as security or support and maintenance advisories.
- To comply with legal requirements and process (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service).
- In connection with an unusual business transaction, such as the bankruptcy or liquidation of, sale of, purchase of, or merger with our business or another business.
- To send promotional communications and/or newsletters to you and for other marketing purposes of Wonder Workshop or partners. You may access and manage your communication preferences from your account, when available, or by contacting us directly at firstname.lastname@example.org. For distribution to third-party service providers that provide services to Wonder Workshop and partners of Wonder Workshop. We require these third parties not to use your Personal Information for any other purpose.
Personal Information: Except as set forth below, Wonder Workshop will not rent or sell your Personal Information to others, or share it with independent third parties for their separate marketing-related purposes. To operate the Service, however, we may share your Personal Information with our agents, representatives, and contractors so they can provide us with support services and other features and fulfill your orders. We require these third parties not to use your Personal Information for any other purpose. We may store Personal Information in locations outside the direct control of Wonder Workshop (for instance, on servers or databases co-located with hosting providers).
Browsing Information: We may share non-personally identifiable information such as:
- anonymous usage data
- referring/exit pages and URLs
- platform types
- number of clicks, etc.
with interested third parties to help them understand the usage patterns for our Service. Wonder Workshop may store such Non-personally identifiable information for an amount of time determined to be reasonable for internal operations.
Instances where we are required to share your information: Wonder Workshop will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to:
- comply with the law and the reasonable requests of law enforcement;
- to exercise or protect the rights, property, or personal safety of Wonder Workshop, our users or others.
How do we store and process information?
Your information collected through the Service may be stored and processed in the United States or any other country in which Wonder Workshop or its subsidiaries or service providers maintain facilities. Wonder Workshop may transfer information that we collect about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
What are your choices about receiving marketing messages?
Wonder Workshop offers parents, teachers, and other adults the choice of receiving different types of communication and information related to our company, products, and services. You may subscribe to e-newsletters or other publications or you may also elect to receive marketing communications and other special offers from us via email.
To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavor to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message. You may also access and manage your preferences from your account, when available, or by contacting us directly at email@example.com. We reserve the right to send you service announcements or similar administrative messages, without offering you the opportunity to opt out of receiving them.
How we protect your information; security and passwords?
Wonder Workshop takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information.
If you create an account to use the Service, you may be asked to choose a password for your account, which can be used to access information associated with your account (including Personal Information). You should choose a password that is not easy to guess and does not use words that you would find in a dictionary. Do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and we will attribute activities that occur using your account information (e.g., through the use of your password) to you. If you suspect that your password has been compromised contact us immediately at firstname.lastname@example.org.
How you can update your information?
Wonder Workshop believes strongly in giving you the ability to access and update or correct your Personal Information. You may update your Personal Information by logging into your account on Wonder Workshop’s Website, when available, or by contacting us directly at email@example.com.
We take student privacy seriously. As a provider of educational technology and in an effort to support statewide and public school districts, Wonder Workshop has signed state-specific privacy pledges or agreements such as the:
- CA Student Data Privacy Agreement or CSDPA.
- California schools are now part of the CA Student Privacy Alliance. The CSDPA is designed to meet both federal and student data privacy requirements.
- New York State (NYS) Education Law Section 2D
- Connecticut Student Data Privacy Pledge
The above agreements and pledges are executed, at times, with school-specific agreements based on the products and/or services provided.
The Family Educational Rights and Privacy Act (FERPA) is a federal law that prevents Educational Institutions from releasing certain information about your child to vendors such as Wonder Workshop without consent.
We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, please consult this simple one-page informational guide from the kidSAFE Seal Program: http://www.kidsafeseal.com/knowaboutcoppa.html.
Please note that while the Child-Focused Products we offer are aimed to be usable by children, students, and young teenagers, only parents, legal guardians, or other adults are allowed to make purchases on our General-Audience Sites or within our Child-Focused Products.
To set up your Wonder Workshop robot, a parent or guardian should download the corresponding App and assist with account creation (if applicable). As part of the account creation, we may ask a parent/guardian to provide their email address, an account password, and limited profile information (username, birthdate, gender,) about the child using the robot. This information is used to customize the robot experience for the child and to keep the parent or guardian informed of the child’s activities.
In compliance with COPPA, the parent’s email address may be used to notify and obtain verifiable consent from a parent before activating a Wonder Workshop account or enabling certain data collecting features for their child (such as chat messaging between the child and robot). The parent account information may also be used for account management purposes (e.g., profile updates, password reset, login for another Wonder Workshop Website, etc.) and to communicate with the parent about new products, features, newsletters, and special promotions and events. Product Use Information is used only to support our internal operations.
In some instances, Wonder Workshop may collect a limited amount of personal information from a parent or child (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a child (e.g., email alerts, push notifications). For these types of activities, Wonder Workshop may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of personal information prior to collection or immediately after use, parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.).
Wonder Workshop does not currently offer any features on our Child-Directed Products that would allow Children Users to publicly post or share Personal Information with other users via the web. Some features on our Child-Directed Products may allow the storage of information (including Personal Information) locally on our App or robot device, without the uploading of such information to the web or Wonder Workshop servers. Parents are still advised to remove any such information from their robot device, should they choose to sell, donate, or gift their device to someone else.
On our Child-Directed Products, we may collect and process Product Use Information and Browsing Information from Children Users, but only for purposes of supporting our internal operations, such as to help us:
- Maintain or analyze the functioning of our Child-Directed Products;
- Perform network communications; and
- Authenticate users of, or personalize the content on, our Child-Directed Products.
On our Child-Directed Products, we do not use Product Use Information or Browsing Information for behavioral or re-targeted advertising purposes or to allow third parties to track the activity of Children Users for such purposes.
With proper authentication, a parent or legal guardian always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by Wonder Workshop. Please keep in mind that a request to delete such information may limit the child’s access to all or a portion of the Service. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us at firstname.lastname@example.org. We urge parents to monitor their children’s use of all digital media.
Links to other websites
California Privacy Rights
Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to email@example.com.
Visitors residing outside of the US
If you are located in the European Union (EU) please note that laws governing data collection and use that may differ from U.S. law and that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. Whenever we transfer Personal Information originating in the EU to an entity outside of the EU we will take reasonable steps to ensure that your privacy rights continue to be protected, e.g. conclude the EU Standard Contractual Clauses with third parties.
LAWFUL BASES FOR PROCESSING PERSONAL INFORMATION
If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:
- It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Website, and increasing the security of the Website and network infrastructure;
- You have consented to this collection and processing for a specific purpose;
- It is necessary to fulfill our contractual obligations; or
- It is necessary to comply with a legal obligation.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in the Contacts for Individual Rights Requests [insert jumplink] section. Some examples of our legitimate interests and the information being processed include:
- Network and information security (password, IP address, Device ID)
- Customer Support and fraud prevention (name, email address)
- Improving our products and services (hardware information, activity logs)
Where we rely on our legitimate interests to process your Personal Information, you have the right to object. More information on exercising this right can be found in the Individual Rights section below.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at firstname.lastname@example.org.
Wonder Workshop makes certain choices available to you when it comes to your Personal Information. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated on our progress.
Review and update your information: You have the right to access and update any Personal Information that we have collected. Some Personal Information, such as the account holder’s name and email address can be found and updated using the account management tools on our website at https://www.makewonder.com/account/edit. For any Personal Information beyond this, please submit a request using the contact information at the end of this section.
Delete your information: You also the right to have your Personal Information deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all Personal Information about you, please submit a request using the contact information at the end of this section.
We may decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.
Restrict Processing: You have the right to restrict how we process your Personal Information in certain circumstances. Rather than requesting we delete all of your Personal Information, you may request that we limit our uses of your Personal Information to specific purposes.
Data Portability: You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others.
Right to Object: You have the right to object to the processing of your Personal Information for direct marketing purposes or when our processing of your data is based on legitimate interests.
If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.
CONTACT FOR INDIVIDUAL RIGHTS REQUESTS
Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.
Wonder Wordshop, Inc.
Attn: Privacy Manager
1500 Fashion Island Blvd., #200
San Mateo, CA 94404, USA
If you are an EU citizen or reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.
If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian, as applicable and legally required.
How to contact us
If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by writing to us at email@example.com or Privacy Manager, Wonder Workshop, Inc., 1500 Fashion Island Blvd., #200, San Mateo, CA 94404, USA.