PRIVACY POLICY

This is the privacy policy (“Privacy Policy”) that governs how we, Alerteenz Ltd. (“Bosco” “Boscoapp”, “we”, “our” or “us”), use Personal Information (defined below) that we collect, receive and store about individuals in connection with the use of Bosco app application and any other service that we operate (“application”, “service”). This Privacy Policy supplements the Terms of Use of Bosco (the "Terms"), available on https://www.boscoapp.com/terms-of-use

The intended user is the parent or legal guardians of children who, in this policy, will be referred to as "You",“Your” or “user”.

The data controller is Alerteenz Ltd. and its affiliated companies with registered address at Hacharuv 8, Riphon, Israel. Privacy-related questions can be directed to privacy@boscoapp.com. Please note that Israel is a country whose level of data protection has been declared by the Spanish Data Protection Agency as adequate (Commission Decision 2011/61/EU of 31 January 2011). You can contact the designated EU representative of Boscoapp by reaching privacy@boscoapp.com

Boscoapp has appointed an EU representative in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of Personal Data (the “GDPR”).

We do not ourselves host the application. All hosting is done by third party service providers that we engage, with whom we have entered into the relevant processor agreement in accordance with the GDPR. This means that data You provide us or that we collect from You (including any Personal Information, as defined below), as further described in this Privacy Policy, is hosted with such third-party service providers on servers that they own or control. We process the information under arrangements aimed at providing an adequate level of data protection, which includes EU decisions recognizing the adequacy of those countries and Standard Contractual Clauses. In case it is necessary to transfer personal data to countries which provide e a lesser degree of data protection than the laws of Your own country, we will subscribe Standard Contractual Clauses with them or any other appropriate safeguard as established in GDPR.Y

1. Introduction. We have implemented this Privacy Policy because Your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices You can make about the way Your Personal Information is collected and used in connection with the application. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a mobile number, an email address, location data, a home or other physical address, or other contact information.

2. Consent and Modification. You are not legally obligated to provide us Personal Information, and You hereby confirm that providing us Personal Information is at Your own free will. By using the Application, You consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If You do not agree to this Privacy Policy, please do not access or otherwise use the Application. We reserve the right, at our discretion and for legitimate reasons, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Application, and Your continued use of the Application thereafter means that You accept those changes.

3. What Personal Information We Collect and how We collect It. We do not currently require You to provide Personal Information in order to have access to general information available on the Application. But, we do receive and/or collect Personal Information from You in the following ways:

3.1 Account. In order to use certain services that we offer via the Application, You may be required to create an account (“Account”), by one of the following methods (for types of Accounts in the application please see the Terms):

(a) You may create an account by completing a form on the Application. If You create an Account You will be required to provide us with certain information, such as (but not limited to) Your name, email address, Your mobile phone number as well as a password that You will use for Your Account.

(b) You may also choose to create an Account by logging in with Your Facebook account which You may do by clicking on a Facebook ‘connect’ or ‘sign-in’ button that we may display on the Application (“Facebook Account”). Doing so will enable You to link Your Bosco Account and Your Facebook Account. If You choose this option, then You will be required to approve the connection as well as the types of information (which may include Personal Information) that we may obtain from Facebook, including Your name, Facebook identification (ID) number, Your profile picture, Your gender, age range, locale and time zone, and e-mail address. You may disable or withdraw certain Permissions in the settings section of Your Facebook Account (on Facebook), but doing so may cause certain features of the Application to become unavailable to You. In addition to the use of data described here, we may also use such data as described in Sections 4 (The Way We Use Personal Information) and 5 (Use of Anonymous Information) below. YOU ACKNOWLEDGE AND AGREE THAT WE MAY KEEP DATA WE OBTAIN FROM FACEBOOK AS DESCRIBED ABOVE EVEN AFTER WE CEASE USING THE FACEBOOK PLATFORM OR OFFER FACEBOOK FUNCTIONALITY SUCH AS FACEBOOK CONNECT OR LOGIN ON THE APPLICATION.

Regardless of whether You create an Account through a form on the Application or by using Your Facebook Account, You may also choose to provide additional Personal Information as part of the Account registration process and in connection with Your ongoing use of Your Account.

We may send You a text message to Your mobile phone or an e-mail to the e-mail address You submit to confirm Your registration. If You choose not to create an Account, You may not be able to access or use certain features of the Application.

(c) You may also choose to create an Account by logging in with Your Google account which You may do by clicking on a Google or ‘sign-in’ button that we may display on the Application (“Google Account”). Doing so will enable You to link Your Bosco Account and Your Google Account. If You choose this option, then You will be required to approve the connection as well as the types of information (which may include Personal Information) that we may obtain from Google, including but not limited to Your name, Your profile picture, Your gender, age range, locale and time zone, and e-mail address. You may disable or withdraw certain Permissions in the settings section of Your Google Account (on Google), but doing so may cause certain features of the Application to become unavailable to You. In addition to the use of data described here, we may also use such data as described in Sections ‎4 (The Way We Use Personal Information) and 5 (Use of Anonymous Information) below. YOU ACKNOWLEDGE AND AGREE THAT WE MAY KEEP DATA WE OBTAIN FROM GOOGLE AS DESCRIBED ABOVE EVEN AFTER WE CEASE USING THE GOOGLE PLATFORM OR OFFER GOOLGE FUNCTIONALITY SUCH AS GOOGLE CONNECT OR LOGIN ON THE APPLICATION.

Regardless of whether You create an Account through a form on the Application or by using Your Google Account, You may also choose to provide additional Personal Information as part of the Account registration process and in connection with Your ongoing use of Your Account.

3.2 Add child device. In order to add a monitored child device, You may be required to provide certain information, such as the name of the child, birthdate, gender, phone number and e-mail address. You may also provide additional information such as a profile picture for the Child. This information is voluntarily provided by You.

As stated in the Terms, by creating an account, You expressly authorize us to track Your child’s activity and use it to send you Notifications and reports in relation to your child’s activity. It is Your responsibility to inform your child of Your registration with Boscoapp and the fact that Your child’s mobile usage is being monitored through us. By providing personal information about a child, You represent and warrant that You are the legal guardian of such child, and that You are not prohibited by law from providing such information to us.

3.3 ‘Contact Us’ Information. If You send us a “Contact Us” request, whether by submitting an online form that we make available or by sending an email to an email address that we display, You may be required to provide us with certain information such as Your name and email address.

3.4 Invite Friends Service. The Application may enable You to invite Your friends to use our Application by sending them an invitation email or message through a third-party service such as Facebook or X. If You send an invitation to a friend, we may obtain Your e-mail address or the username for Your third-party service account. In the event that You provide us with information from third parties (see section 3.4), You represent and warrant that You have the consent of such third parties to provide us with such personal data.

Y4. The Way We Use Personal Information. If You submit or we collect Personal Information through the Application, then we may use such Personal Information in the following ways within our Services, via any applicable communication channel, including e-mail, SMS, etc.:

4.1 We will use location data to enable to locate the monitor phone, whether the Application is in use or not.

4.2 We will use Your Personal Information to provide and improve our Application, to contact You in connection with the Application and certain programs or offerings that You may have registered for, and to identify and authenticate Your access to the parts of the Application that You are authorized to access. If we have Your explicit consent to do so, we will use Your Personal Information to send You marketing/advertisement communications that we believe may be of interest to You.

4.3 We may use Your designated email address to: (i) send You updates or news regarding the Application and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change Your password).

4.4 If You choose to send Your friend an invitation email or message, we will use the contact information that You provide, or make available, to automatically send Your friend a message by the method You have chosen with the invitation or the shared content (as applicable). Your name and email address may be included in the message.

4.5 We may transfer Your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries. We require that these parties agree to process such information in compliance with our Privacy Policy.

4.6 We may share Your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Application to You and other users. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information.

4.7 We may disclose Your Personal Information or any information You submitted via the Application it is necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Bosco, our users, yourself or the public.

4.8 We will collect User's and children device installed application usage data, and use it to analyze user's social activity. Collected data will not be shared with any other parties.

5. Use of Anonymous Information. We may use Anonymous or de-identified Information (as defined below) or disclose it to third party service providers in order to improve our Application and enhance Your experience with the Application. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners. “Anonymous Information” means information which does not enable identification of an individual user, such as user-level information about the use of our Application. You acknowledge and agree that even if You request that we delete personal information obtained from Facebook/Google in connection with Your Facebook/Google Account, we may nevertheless retain Anonymous Information which was based on that information and use such information as described in this Section ‎5.

This Anonymous Information is not considered Personal Information and therefore the GDPR does not apply to it.

6. Legal basis for processing Your data

We are the data controller with respect to the personal data collected and processed within the scope of the service provided via the Application. Only we collect and maintain Personal Information through the Application. In this capacity, we process Your personal data pursuant to the following:

Your informed consent to this Policy. Note that You may withdraw Your consent at any time, without affecting the lawfulness of data processing we carried out based on Your consent before such withdrawal.

As necessary for the performance of the Terms which are a contract that You and the Company have entered for the provision of the Service.

7. Data protection rights

Under the terms established in the personal data protection regulations in force at any given time, and in accordance with the applicable legislation, You may at any time revoke the authorisation granted for the processing of Your personal data, as well as exercise Your rights of access, rectification, cancellation, opposition, the right to limit the processing of Your personal data and the right to portability. If You wish to exercise any of these rights, contact us at: privacy@boscoapp.com. When handling these requests, we may ask for additional information to confirm Your identity and Your request.

You also have the right to lodge a complaint with the competent supervisory authority. In the case of Spain, this is the Spanish Data Protection Agency.

8. Opting Out. You may choose not to receive future promotional, advertising, or other Application-related emails from us by selecting an unsubscribe link at the bottom of each email that we send. Please note that even if You opt out of receiving the foregoing emails, we may still send You a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate Your use of the Application.

9. Choice. At all times, You may choose whether or not to provide or disclose Personal Information. If You choose not to provide mandatory Personal Information, You may still visit parts of the Application, but You may be unable to access certain options, programs, offers, and services that involve our interaction with You.

10. Access/Accuracy. To the extent that You do provide us with Personal Information, we wish to maintain accurate Personal Information. If You would like to delete or correct any of Your other Personal Information that we may be storing, You may use the tools that we may make available on the Application or You may submit an access request by sending an email to privacy@boscoapp.com. Your email should include adequate details of Your request.

11. Children’s Privacy. We do not target or sell products, programs or services to minors. Minors under 18 years old cannot create and account or submit personally identifiable information. If a parent or guardian becomes aware that their child has created and account or provided Boscoapp with Personal Information or that we have otherwise inadvertently collected this information, contact us at contact@boscoapp.com so that we may delete the information from our servers.

The user of the Application is the parent or legal guardian, but not the child. The Personal Information collected from children is extracted from their use of the App, not as users. This information is analysed and deleted immediately after creating a report for You, in accordance with the Terms. Bosco only stores metadata, in no case data that identifies (or may identify) children.

12. Security. The security of Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use reasonable acceptable means to protect Your Personal Information, we cannot guarantee its absolute security or confidentiality. If You have any questions about security on the Service, You can contact us at contact@boscoapp.com.

13. Data retention

We retain the personal data we collect from the User for as long as needed in order to provide the Service to You. We then either delete from our systems or anonymize it, so long as we are not otherwise legally required to retain the data or require it in order to establish, exercise or defend against legal claims, in this case, such data shall be kept appropriately blocked

If You withdraw Your consent to us processing You and Your child’s information, we will erase the information from our systems so long as we are not otherwise required to retain the data or need it in order to establish, exercise or defend against legal claims, in this case, such data shall be kept appropriately blocked

14. Commercial operations. In the event that we are acquired by or merge with a third party entity, or in the event of bankruptcy or a comparable event, we may disclose Your information, provided that this is necessary for the successful completion of the transaction and ensures, where appropriate, continuity in the provision of services.

15. Commitment. We are committed to protecting Your privacy. Protecting Your privacy online is an evolving area, and we are constantly evolving our Service to meet these demands. If You have any comments or questions regarding our Privacy Policy, or Your Personal Information that we may be storing and using, including any concern You may have regarding the violation of Your privacy please contact us at privacy@boscoapp.com.

Last updated: April 2024