- FiLIP is since late-2016 part of SMARTCOM SAS. With headquarters in Sophia Antipolis, France and Alpharetta (GA), USA. All data is safely hosted by Amazon Web Services (‘AWS’) within two (2) regions: North Virginia (us-east-1) and Ireland (eu-west-1).
- FiLIP provides a service to help primary caregivers to communicate with, monitor, track and locate their children. This is data-driven service.
- This service will automatically collect the physical location from the device at all times when activated. FiLIP also receives data about device and application usage..
- FiLIP will use this information to provide the location-based services and to contact the parents/guardians regarding the service and other information.
Last updated: June, 2018 – GDPR/COPPA Compliance
Personal information collected through the FiLIP App: Through the FiLIP App we may collect your name, email address, date of birth, billing information and other personal information, as well as that of the child who will use the Device associated. We do not collect personal information from you unless you voluntarily provide it to us.
Location-based information collected through the FiLIP Service: FiLIP’s paired Family Wearable Devices automatically and constantly collects information about the physical location of the Device when it is activated. This information is acquired through numerous methods, including GPS, cell towers and wi-fi hotspots, which are enhanced over time as we follow the Device, collect more information and improve our tracking. You may not disable location-based data collection from the Device. We may also collect such location-based information through your use of the FiLIP App.
Non-personal or aggregate information that we collect: We automatically collect non-personal information from your use of the FiLIP Service, such as IP host address, device-specific identifiers, computer or smartphone configurations, pages viewed, time and usage habits on the FiLIP Service and similar data. It is possible at times when collecting non-personal information through automatic means that we may unintentionally collect or receive personal information that is mixed in with the non-personal information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If we do inadvertently collect personal information, we will not intentionally use such personal information as if we had collected it with your consent. We may also aggregate demographic information collected from our users (such as the number of users in a particular State) in a manner which does not identify any one individual.
Therefore, we may use your information to:
- respond to your inquiries or requests;
- send you information about the FiLIP Service (such as promotions, maintenance or security information);
- send you a limited number of offers for additional products and services that may interest you, but we will not provide your personal information to third parties for them to contact you directly for their own benefit without your consent;
- permit our vendors and subcontractors to perform services, provided they are under an obligation of confidentiality and do not use the information for their own benefit;
- comply with applicable law or legal process;
- provide to a third party for their own use, such as marketing, but only if you have specifically opted-in to such third party sharing (ref. GDPR, COPPA, CPIAPP, etc.);
- investigate suspected fraud, harassment, danger to persons or property or other violations of any law, rule or regulation, or the terms or policies for the FiLIP Service or our business partners;
- share with law enforcement and other parties trying to locate a lost child, including sharing the audio content of emergency calls;
- transfer information in connection with the sale or merger or change of control of FiLIP or the division responsible for the services with which your information is associated;
- share non-personal or de-identified information with any number of parties, including analytics companies, technology providers, and other business partners; or
- combine it with data from other sources outside of your use of the FiLIP Service, such as data obtained from wi-fi access points within range of your Device.
Auto-deletion of data: We may automatically delete data from a Device or from the FiLIP App in connection with a returned or terminated account or device, or as necessary to protect against unauthorized access to the data.
Security: The security of your information is very important to us. We use reasonable efforts internally at FiLIP to protect it from unauthorized access. However, due to the inherent open nature of the Internet and wireless communications, we cannot guarantee that your personal information will be completely free from unauthorized access by third parties, such when transferred over or through systems not within our exclusive control. Your use of our FiLIP Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personal information. For more information on protecting your privacy, please visit www.ftc.gov/privacy for US customers For EU, please visit www.eugdpr.org.
Personal information from children: While some ofFiLIP’s associated Family Wearable Devices (“Device”) are designed to be worn by a child, our customer is the applicable parent/guardian or other adult over 18 years of age who has enabled the FiLIP Service. By providing the Device to a child, you represent and warrant to FiLIP that you are authorized by such child’s parent or guardian to enable and permit FiLIP to operate the FiLIP Service and collect and use the information from the child as stated herein.
Data retention: We may retain your information for as long as we feel that there is a business need or benefit to do so. This will include retaining location-based information.
Data Access: FiLIP Data collected through use of the Device and/or the FiLIP App, including location information, frequency of use and emergency contact information is generally not available to customers for their own, direct access. Please contact firstname.lastname@example.org for specific questions about access to any collected data.
Other services: As a convenience to you, Network Providers may provide links to third party services from within our FiLIP Service. We are not responsible for the privacy practices or content of these third party services and such links should not be construed as an endorsement of any such third party services. When you link away from our FiLIP Service, you do so at your own risk.
If you no longer want any data collected by FiLIP from the Device, then you will need to deactivate the service.