Last Revised: 11 April, 2017
What Information Do We Collect?
Active Collection: When the Companion Apps are downloaded, we collect a parental email and password in connection with obtaining parental consent and creating a parent account. Parents may also provide additional information, when they set up the Barbie Products or through the parent account, such as indicating their child’s birthday, what holidays to remember, and other conversation options that are used to improve the conversational experience.
Voice recordings: When children or other users talk with Hello Barbie by pressing and holding the “Talk” button, interact with Barbie Hello Dreamhouse after saying the Gate Phrase, or record their voice to customize the sounds in a room, we may capture voice recordings. These voice recordings are considered personal information under the Children’s Online Privacy Protection Act (“COPPA”). We cannot prevent children from providing additional personal information when they interact with the Barbie Products, and such information may be captured in the voice recordings. However, it is our policy to delete such personal information where we become aware of it and we contractually require our service providers to do the same.
Passive Collection: When the Companion Apps or speech processing services are being used, some information is also automatically collected. For example, we may automatically collect certain information when you use the Companion Apps or the Speech Processing services, such as device model and name, operating system and version, the browser type, mobile network information, preferred language, time zone, and activity on the Companion Apps. We may also automatically collect certain logistical information in server logs, including information about how various features of the Companion Apps and speech processing services are used and information about the number, frequency and length of each session. In addition, we may collect IP Address for the purpose of password attempt rate limiting to provide additional security to the user's account, but we do not store or track IP addresses.
If you use our Site, such as to access your parent account, we may also automatically collect certain information through the use of "cookies." Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us analyze and improve our Site and speech processing services, and our other products and services, and the experience of our users. If we link cookies to any personally identifying information, we will treat this information as personal information. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features of the Site or speech processing services.
We may use Web beacons or similar technology in connection with the Site and the speech processing services. Web beacons are small, invisible graphic images that may be used in the Site and the Service or in emails relating to the Site or the speech processing services to collect certain information and monitor user activity on the Site, such as to count visits, understand usage and effectiveness and to tell if an email has been opened and acted upon.
How Do We Use the Personal Information We Collect?
ToyTalk uses parental email to obtain parental consent for your children's use of the speech processing services and to create a parent account, which allows you to access the Parental Settings section of the ToyTalk website. For your convenience, ToyTalk offers a unified parent account so if your children also use or want to use other ToyTalk children’s products or services (including non-Barbie products and services), you may use the same account to manage your children's use of all such products or services, and all information about you and your child obtained from all products and services would be accessed through this account.
ToyTalk may also use the parental email and other information parents provide, or that is automatically collected, through the Companion Apps or the parent account as follows:
We may periodically contact parents to inform them when a voice recording is available under their account. Parents can choose to not receive these notifications via the Settings page on the Site or by following the unsubscribe instructions in those notifications.
We may store and process personal information in the United States and other countries.
Does the speech processing services enable children to make personal information publicly available?
Although parents may share certain voice recordings through their parent account via email, on third-party websites and services, such as Facebook and Twitter, or directly through the Site, we do not knowingly allow children under 13 to share voice recordings or otherwise make any personal information publicly available.
What Information Do We Share With Third Parties?
We may also share aggregated or anonymized information that does not constitute personal information. For example, we may share analytics and other aggregate information about users’ activities on our speech processing services that do not contain any personal information with parties we partner with, such as Mattel.
We will not share voice recordings with Mattel. We may, however, share certain transcripts or other text derived from voice recordings with Mattel, which will be used solely for the purpose of enabling Mattel to assist us in providing quality control and in improving and approving the scripting of the Barbie Products.
As part of providing support for the operations of our speech processing services, service providers may use voice recordings or other personal information they receive from us to provide, maintain, support, test, develop and improve the services and technology being provided to ToyTalk. We may also share transcripts, text or “feature extracted data” (which is data that is created from the voice recordings, but which no longer contain a child’s voice), with service providers or other third parties, which they may use for research and development purposes that are not related to the services they provide us, including developing, testing and improving speech recognition technology and artificial intelligence algorithms not related to the services or technology being provided to ToyTalk. These service providers and other third parties (including Mattel) may not use any voice recordings, feature extracted data, transcripts or any content contained therein to contact or advertise to children.
Links to and Sharing with Other Websites
EU-U.S. Privacy Shield Certification
In connection with ToyTalk’s processing of personal data it receives from the EU (“EU Data”), ToyTalk adheres to the EU-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield website. Please direct any inquiries or complaints regarding our compliance with the Principles to the point of contact listed in the “Contact Us” section below. If ToyTalk does not resolve your complaint, you may submit your complaint free of charge to JAMS, ToyTalk’s designated Privacy Shield dispute resolution provider here: https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. ToyTalk is subject to the investigatory and enforcement powers of the Federal Trade Commission. ToyTalk assumes responsibility for EU Data that it shares with third-party service providers when they process that data on ToyTalk’s behalf unless ToyTalk demonstrates that it was not responsible for the events giving rise to the damage. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
What Steps Do We Take To Protect Your Information Online?
We use reasonable measures and safeguards in an attempt to keep the data we collect secure. For example, we use secure, encrypted communications when transferring all personal information over the web. No voice recordings are stored locally on the Barbie Products, however, your WiFi credentials are stored in an encrypted section of the Barbie Products so that it can connect to the Internet. Please be aware that despite our efforts, no security measures are perfect or impenetrable and there is no method of data transmission that can be guaranteed to protect against any interception or other type of misuse.
What Choices Do You Have Regarding the Use of Your Information?
You may choose to permanently delete your ToyTalk account via ToyTalk's website. We will delete all personal information connected with your account when you close your account in this manner except that cached copies may exist for a certain period of time after the account is deleted.
You may have legal rights of access to and correction of the personal information held by us. For example, under COPPA, parents have the right to review or have deleted any personal information (including voice recordings) collected from their child that are retained by ToyTalk and parents may refuse to permit further collection or use of their child's personal information. You may review and delete voice recordings that are in your parent account via the Settings page when you log in to ToyTalk's website. To review or delete such voice recordings, click on the “Conversation Link.” If you delete voice recordings from your parent account, we will no longer retain those voice recordings in any form. We may periodically delete voice recordings from your parent account, but in such case, we may still have access to those voice recordings for research and development purposes. If you wish to review or have us delete such voice recordings, please email us at firstname.lastname@example.org. If you wish to stop any further collection or use of your child’s personal information, or delete your email address, you must delete your account from the Settings page. We do not, however, have control over any other Third-Party Sites with whom you have shared voice recordings, and you will need to contact them directly regarding any voice recordings you have shared to Third-Party Sites.
For the Service to function, ToyTalk must share voice recordings with our service providers as described in this policy. If you no longer wish for voice recordings to be shared in this manner, you may delete your account as described above, in which case no further information will be shared with third parties.
You may "opt out" of receiving marketing or promotional emails from us by following the unsubscribe instructions in those emails or through the “Settings” page on the Site (under “content update notifications”). Where required by applicable law, we will get your consent prior to sending you such emails.
Questions or Concerns?
Attn: Chief Privacy Office
133 Kearny Street, Suite 400
San Francisco, CA 94108