Net Nanny Privacy Policy

CW Acquisition Corp (“we”, “our” or “us”) is the provider of www.netnanny.com (the “Site”), the Net Nanny applications, and the services, features, content or other applications we offer (collectively with the Site, the “Net Nanny Services”).  We respect your privacy and will be clear and transparent about the information we are collecting from you and its purpose.

A child friendly privacy policy in plain English will be available soon.

1. Introduction

Who We Are:

Content Watch is a US based company that owns, develops, maintains and supports the product known as Net Nanny. The online services associated with the Net Nanny product and service are hosted within a US based cloud environment of Amazon Web Services.

What does this Privacy Policy Cover?

This Privacy Policy covers the treatment (collection, use and disclosure) of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Net Nanny Services.

Third Parties

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ.

We encourage you to read the privacy notice of all Third Party Services you use.

Your Role:

It is important that the personal data we hold on you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us. When you use the Net Nanny Services, you are consenting to the processing of personal data as described in this Privacy Policy.

2. What Information We Collect

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Account Information

When you create an Account, you will provide information that could be Personal Information, such as

• your first name and last name (Identity)
• email address and telephone number (Contact)
• username and password (Profile)

Location Information

Some of the Net Nanny Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”).  To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services. This information can come from a variety of sources depending on the client you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

Technical Information

Technical Information is collected automatically through the interaction with the Net Nanny Services and includes

• IP address
• browser and plug-ins
• operating system

We may collect some device-specific information if you access the Net Nanny Services using a mobile device.  It may include but is not limited to:

• phone number
• unique device identifiers
• network information
• hardware model

Usage Information

This includes how you use the Net Nanny Services and data gathered through the operation of the Net Nanny Services.

Marketing and Communications Information

This includes your preferences in receiving marketing communications from us. You may unsubscribe from these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Aggregated Information

We collect statistical or demographic information about how both unregistered and registered users, collectively, use the Net Nanny Services. This information might include, but is not limited to, for example, session information, Account settings, and parental controls activities.  Some of this information may be derived from Personal Information but it is not considered Personal Information, as it cannot be used to identify you.

3. How We Collect Personal Information

We receive information about you from various sources.

Direct Interaction

This includes Personal Information you provide when you

• register for the Net Nanny Services;
• contact us;
• provide feedback; or
• request information

Automated Technologies

This includes Personal Information you provide through your interaction with the Net Nanny Services (your “Account”). Please see our Cookie Policy for more details.

Other Sources

This includes publicly available information or information provided by third party services (e.g. Analytics or Identity providers).

4. Purposes for the Processing of Personal Information

We will only process your Personal Information where we have a legal basis to do so. The legal basis will depend on the reasons we have collected your Personal Information and need to use it for.

Please see the table below for the specific purposes that we have identified, the legal basis and what our legitimate interests are where appropriate:

Please contact us if you need more details about the above description.

Profiling and Automated decision-making

By default, the Net Nanny Services do not use profiling or automated decision making. Net Nanny lets parents create a profile for each protected user. This has custom settings for content filtering, screen time settings, apps and location tracking. This profile includes a created name and avatar that is associated with profile. The settings determine content, apps and device usage rule for each user and the settings are applied to all devices where the Net Nanny software is installed.

Marketing

We will not send you marketing communications unless you have requested such information or have opted in to receive promotional offers. We do not send any kind of promotional communications to children.

You may opt out from receiving marketing communications through your Account settings.

Tracking

We may serve advertisements, and also allow third parties to serve advertisements through the Net Nanny Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies including “ad networks.”  Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. To support and enhance the Net Nanny Services, we use online identifiers (including cookie identifiers), IP addresses, device identifiers, and customer-assigned identifiers to record and analyze user behavior.

We do not provide Personal Information to any ad networks for use outside of the Net Nanny Services and we do not advertise to children.

App

The Net Nanny apps use a variety of tracking technologies to customize the user experience and understand App usage for future improvements and enhancements. These technologies include Firebase, Braze, AppFlyer and Aptitude. The modules are used for in-app functionality and enhanced user experience and cannot be disabled.

Website

Our website uses various technologies to track usage and provide a customized user experience while managing your account and shopping on the website. For additional information about the cookies we use, please see ourCookie Policy.

5. Disclosure of Personal Information

We may share your Personal Information with third parties and for various purposes as shown below:

Third Parties may include:

• Suppliers and Providers including IT Services, Customer Support, Payment Processors
• Professional Advisors including lawyers, bankers, auditors, insurers, agents
• Regulators and authorities including auditors, fraud preventions, public bodies

Purposes may include:

• Necessity to performing the contract with you
• Legal and regulatory obligations and proceedings
• Legitimate interests including
  1. Operation of our business
  2. Compliance with internal policies and procedures

By default, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers for the purposes stated in this Privacy Policy.

6. Data Storage

Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed within the United States. By using the Net Nanny Services, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy.

Non-U.S. Users:  Please be advised that your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal data may be less stringent than the laws in your country.  If you have concerns about our processing of your personal data, please do not use the Net Nanny Services.

7. Data Security

While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.

When you use the Net Nanny Services, your Personal Information is securely encrypted in transit and at rest. We have also put in place security measures and access control mechanisms to ensure that your information is prevented from loss and only accessed in an authorized manner.

We store and process information by using latest industry-standard techniques. However, we cannot guarantee or warrant that such techniques will provide complete security of your Personal Information.  Any transmission is at your own risk.

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

8. Data Retention

As stated above we only collect Personal Information that is needed for the purposes specified in this Privacy Policy and we only retain Personal Information for as long as it is necessary,

Net Nanny stores the following Personal Information:

• Name
• email address
• telephone number
• unique device ID
• geographical location
• IP address

Upon termination of the contract personal data is deleted from live systems within 30 days and from the backup systems after 12 months following the date of the account termination or request.

Any data which is retained for a period longer than 12 months, which for example may usage information, is anonymized. We may use this anonymized information for research or statistical purposes indefinitely without further notice to you, as it can no longer be associated with you.

9. Your Rights

You have certain rights that you can exercise in relation with your Personal Information:

Right of information:

You have the right to receive certain information about our data collection and data processing activities.

Right to access:

This is commonly known as Subject Access Request and enables you to request and receive a copy of the personal data we hold about you.

Right to rectification:

You have a right to ask for modification or completion of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to object:

You can object to, or request that we restrict, our processing of your personal data in certain circumstances. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Right to withdraw consent at any time:

You can withdraw previously given consent for the processing of your personal data for the relevant purpose at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or any processing not based on your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the relevant purpose.

Right to be forgotten (right to erasure):

You can ask us to delete or remove your personal data at any time. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Where this right is exercised, we will delete your personal data from our live servers. Your personal data will then be deleted from our back-up systems 12 months after the request for erasure but your data will not be used by Net Nanny during that 12 month period, Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to data portability:

You can request a transfer of your personal data to a third party in an electronically usable (machine-readable) format. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request to restrict processing:

You may ask to restrict our processing of your personal data

• if you want us to establish the data's accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right not to be subject to automated decision making:

You have the right not to be subject to automated decision-making (including profiling) which has legal or other significant effects on you.

Right to complain:

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

10. Contact us

If you want to exercise any of these rights have any questions or concerns regarding privacy using the Net Nanny Services, please send us a detailed message to legal@netnanny.com. We will make every effort to resolve your concerns.

You can also send a written request by post to

CW Acquisition Corp, 1055 Westlakes Drive, Suite 301, Berwyn, PA 19312

We do not charge a fee if you exercise one of the above rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.