Parents and Children Privacy Notice

Last updated: August 2022

We at Universal Grammar Ltd. ("UG Labs", "us", "we", or "our") recognize and respect the importance of maintaining the privacy of Children using our AI-based voice recognition toy or mobile app "Product" and parents or guardians using the accompanying "Parent App". This Privacy Notice describes the types of information we collect from you when you use the Parent App and information we collect from your Child when he or she uses the Product. This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at ("Terms"). "You" means a parent or guardian of a child using the Product.

"Personal Data" means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data we collect when we provide the Services to you and your Child.

Our collection and use of Personal Data about your Child is subject to your consent. We will not collect or use any of your Child's Personal Data if you have not provided such consent.

1. Personal Data We Collect 

1.1 In order to provide you with the Services, you will be required to provide certain Personal Data about yourself and your Child as follows:

1.1.1 You will be required to provide your name and email address, which we will use in order to identify you and allow you to use the Parent App and Services.

1.1.2 You will be required to provide your Child's age, and, if you wish to provide it, his/her gender and a nickname for your Child.

1.2 Throughout the course of your Child's use of the Product, we will automatically record your Child's voice interactions with the Product in the form of Voice Recordings. Voice Recordings will be associated with certain device identifiers but will not be associated with the Child's name or other direct identifying details.

1.3 You are under no legal obligation to provide us with any of the Personal Data listed above. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we may not be able to provide you or your Child with the Services. 

2. How We Use Your Personal Data

2.1 General. We and any of our trusted third-party subcontractors and service providers use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you and your Child with the Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, algorithms, and Services; (4) to review the usage and operations of the Product, Parent App, and Services; (5) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); and/or (6) to prevent fraud, protect the security of our Product, Parent App, and Services, and address any problems with the Product, Parent App, and Services. 

3. Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

3.1 Service Providers and Subcontractors.
We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: (1) help us provide you with the Services and (2) aid in their understanding of how users are using our Services.

Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis.

3.2 International Transfers.
By accepting this Privacy Notice, you acknowledge and agree that we may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data). All of our subcontractors and service providers will be subject to non-disclosure and non-use obligations. 

3.3 Business Transfers.
Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

3.4 Law Enforcement Related Disclosure.
We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority. 

3.5 Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements. 

4. Security

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

5. Your Rights

Subject to applicable law, you may request to see any Personal Data that we have collected about your Child and may request to have this Personal Data deleted. You can also refuse to permit further collection or use of your Child's Personal Data. You can submit such requests by emailing us at . 

6. Data Retention

Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above, including further improvement and development of our Product and Services. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. 

7. Third-Party Applications and Services

All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies. 

8. Communications

We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your Child's account. 

9. Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on the Parent App. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice through the Parent App or via email. 

10. Comments and Questions

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please don't hesitate to contact us. Our company's name is Universal Grammar Ltd. We are incorporated in the State of Israel and our company number is 516425246. Our registered address is Nissim Aloni 4, Tel Aviv – Yafo, Israel 6291918. Our address is .