Effective date: 5th October 2014
Last Updated: 19th September 2019
This Privacy and Cookies Statement explains how personal information is collected, used, and disclosed by SoapBox Labs Limited, an Irish company (“we”, “us”, “our”) in connection with your use of the speech recognition applications and associated services (collectively the “Services”) of SoapBox Labs.
We respect your right to privacy and your freedom to control and monitor your children’s online activities. This Privacy and Cookies Statement together with any terms and conditions of use for the Services (“Terms”) and any other documents which they refer to sets out the basis on which any personal data we collect from you and from any children who use our Services will be processed by us. Note that children are defined as under the age of 18 in the US, or 16 in the EU (unless the Member State has made provision for a lower age limit, but no lower than 13).
There are two different ways that our Services can be accessed:
Our services apply a “data protection by default” and “data protection by design” approach in keeping with the principle of minimizing the processing of personal data to the extent necessary to provide the Services and to further develop and enhance our services. Accordingly, Soapbox will not take any steps to re-identify or de-anonymize any voice data or otherwise associate the voice data with personally identifiable information and does not authorize, instruct, or encourage any third party to do so.
For Direct Access, we rely on consent from an individual with parental authority as the legal basis for processing data where the data subject is a child. We have our own clear parental consent mechanisms and verification processes in place and you can withdraw your consent as outlined below. For Indirect Access, we require any third parties using our services to ensure that the relevant parental consents are in place before they send any voice data to our services. We process de-identified voice data for the legitimate interest purposes of improving the Services as outlined in this statement. Your rights and the mechanisms for objecting to this type of processing of data are clearly outlined below.
SoapBox Labs comply with the Children’s Online Privacy Protection Act (COPPA). COPPA is a U.S. law created to protect the privacy of children under 13. As such, we have established COPPA compliant privacy practices and adhere to the strict information collection, use and disclosure requirements set forth by the Act.
If you have questions or concerns about our privacy practices, please contact us at firstname.lastname@example.org
If you are in the European Union, please note that our Data Protection Officer (DPO) can be contacted at email@example.com
If you are in the European Union and have further concerns after you have contacted us, you can lodge a complaint with the Irish Data Protection Commission directly at firstname.lastname@example.org.
By using the Services or permitting your child to use the Services, you signify acceptance of this Privacy and Cookies Statement. If you do not agree with or you are not comfortable with any aspect of the Privacy and Cookies Statement, you should discontinue use of the Services.
Where you are accessing our services through a third party, the voice data passed to us is de-identified voice data and no other data relating to the identity of the child is received by our system. Depending on the terms and conditions agreed with the third party provider, this voice data may be retained in our system after processing for the sole purpose of improving the services. In other cases, the data is deleted immediately after processing. You should check with the third party to clarify the basis on which the voice data is passed to our system to assess whether or not it is retained post-processing.
We collect Recordings from children which are captured when children interact with the Services depending upon the particular application being used. We may use, store, process and transcribe Recordings in order to provide and maintain the Services, to perform, test or improve our own/proprietary speech recognition technology and artificial intelligence algorithms, or for other research and development and data analysis purposes. Additionally, these recordings may be listened to by human ears for the specific purpose of generating transcriptions or labelling data. We do not share the recordings, or any data generated by the recordings, with any third parties for any purpose other than those described above.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). By submitting your personal data or permitting your child to use the Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy and Cookies Statement, typically through the use of EU-approved “model contract clauses” or ensuring our third party vendors are certified under the EU-US Privacy Shield.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password or username which enables you to access certain parts of our Services, you are responsible for keeping this password or username confidential. We ask you not to share this information with anyone. You can request deletion of this data at any time by emailing us at email@example.com, from the email address provided upon initial registration.
We will delete personally identifiable information after expiry of an appropriate retention period (typically a number of years after our contact with you has terminated). However we will retain de-identified data indefinitely for product development purposes unless you have chosen to withdraw your consent or delete your data as outlined below.
We use information held about you:
We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of SoapBox Labs, its subsidiaries and its group companies, our users, or others.
We may disclose aggregated or anonymised data if:
If you are accessing our services directly, we may collect information about your computer or other device including, where available, device and browser type for system administration and analytical purposes. This is statistical data about how you use our Services.
For the same reason, we may obtain information about your general usage of the Services by using a cookie or similar software which is stored on the memory of your computer or device. This software contains information that is transferred to your computer or device’s memory. Cookies help us to improve our Services and to deliver a better and more personalised service. We may use Web beacons or similar technology in connection with the Services. Web beacons are small, invisible graphic images that may be used in the Services or in emails relating to our Services to collect certain information and monitor user activity on the Services.
You may refuse to accept cookies by activating the settings on your browser or device which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Services.
You have the right to request a copy of your personal data which is held by us about you or your child. If you are accessing our service directly, you should contact us about this data – if you are accessing our services indirectly, you should also contact the third party provider. You also have the right to access your or your child’s personal data, have changed any inaccuracies in the details we hold, the right to object to the use of personal data, the right to block any specific uses of personal data in certain circumstances, the right to data portability and the right to request deletion of personal data, by means of a request in writing setting out as much detail as possible to firstname.lastname@example.org Where your data has been deleted or de-identified by us it will not be possible to act on your request.
Questions, comments and requests regarding this Privacy and Cookies Statement are welcomed and should be addressed to SoapBox Labs with its registered office at Floor 3, The Boat House, Bishop Street, Dublin 8, Ireland or email@example.com