Privacy Statement
Ninja Focus, Inc. values the privacy of its users. We are committed to protecting your privacy though compliance with this policy. Our aim is to create a safe and secure environment for our users. This Privacy Statement (“Privacy Statement”) informs you about our policies and practices regarding the collection and use of your information and lets you know about options that you have to control or restrict the availability and use of your information.
1) About Us. We are Ninja Focus, Inc. (“Ninja Focus”, “us”, “we” or “our”), a Delaware corporation.
2) Our Services. Ninja Focus provides a mobile application to promote mindfulness among children. We deliver mindfulness tools to users (“Users,” “you,” “your”) via the Ninja Focus app, which can be found on Apple’s App Store or Google Play store for Android and through other platforms and media through which we may make the services, content and functionality available, including any related websites (collectively, the “Services”).
3) Purpose of Privacy Statement. This Privacy Statement informs you of Ninja Focus’s policies and practices regarding the collection and use of information you submit to us or which we collect about you through our Services. We will only use your information or share your information in the ways we describe in this Privacy Statement. The Privacy Statement also outlines options that you have to control or restrict the availability and use of your information. By using the Services you acknowledge and agree that:
(i) your information will be processed as described in this Privacy Policy; and
(ii) you consent to have your information transferred to us and our facilities in the United States or elsewhere, including those of third parties as described in this Privacy Policy.
We are committed to protecting the privacy of children who use our sites and applications. This Privacy Statement explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Statement. This Statement is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.
4) Privacy Statement Changes. Ninja Focus reserves the right to change this Privacy Statement from time to time. We will usually inform you of any changes by posting the updated Privacy Statement through the mobile applications and through other platforms and media through which we may make the services available. If we make any material changes to our Privacy Statement, we will post a notification through the mobile application and/or, if you are registered, notify you via your preferred means of contact for such notices (e-mail or text message) and/or by asking you to review the changes to the Privacy Statement the next time you access the Services. Your continued use of the Services after the changes are communicated will indicate your consent to our use of your information consistent with this Privacy Statement, including those changes.
5) Terms. Important terms that we use in this Privacy Statement are “Personal Information”, “Non-Identifying Information” and “Log Data.” To explain what we mean by these terms:
6) “Personal Information” is information about you that can be used to contact or identify you, such as, name, address, e-mail address. It also may include financial information and certain health-related information that you may provide.
7) “Non-Identifying Information” means information that does not permit the identification of an individual person, such as, hobbies and habits. Some Non-Identifying Information could be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified.
8) “Usage Details” is derived by our servers automatically as you interact with the Services, which record information that your browser or mobile device sends whenever you interact with the Service. Log Data is a form of Non-Identifying Information.
9) Purpose of Collecting Information. We want to give Users the best experience possible. We collect information to provide and manage the Services, to deliver to our Users a personalized experience, and to improve our Services, features and content. To access the website or the Services, you may be required to create a user account, including user ID and password, and input certain Personal Information, including your email address. In general, you can browse the website and “opt-out” from providing us with any Personal Information. Once you agree to provide us with Personal Information, you are no longer anonymous to us. If you choose to use and/or purchase certain Services we may require you to provide contact and identity information, billing information, and other Personal Information as indicated on the forms throughout the Site. Where possible, we indicate which fields are required and which are optional. You always have the option to not provide information by choosing not to use or purchase a particular service.
10) Information Collected.
i. Personal Information. When you create an account, we may collect your Personal Information. If you choose to view content that may be available through a subscription (“Subscription Services”), we will also collect credit card or other payment information and your billing address through our third party processors as described further below.
ii. Non-Identifying Information. We also collect some Non-Identifying Information about a user’s feelings as they navigate through our Services to enhance certain functionalities on the Services. For example, when a user first describes their mental, physical and emotional status as they enter the Services, Ninja Focus will use this information to improve its recommendations to the user and enhance certain modules, including, but not limited to, the “The Gift of Compassion”, “Power of Imagination”, “Garden of Happiness”, and “ABC’s of Gratitude”. We also track the content and time a user is meditating for the purposes of improving your experience and tracking a user’s progress.
iii. Usage Details. When a user interacts with the Services, our servers automatically record Log Data that the user’s mobile device or browser sends. This Log Data may include information such as the user’s mobile device identifier, computer’s IP (Internet Protocol) address and browser type, operating system, and other analytics that help us deliver and monitor the effectiveness of our Services.
iv. Parental Controls and Waiver. Ninja Focus incorporates parental controls in the process for creating a Ninja Focus account or changing any settings on your child’s account. Ninja Focus may enable features that we update from time to time, including, chat, social media sharing, etc. When registering, we will ask whether the parent would like to opt-in to the “parental controls” option. Parents have the option to opt-in or they may skip this process by pressing the “skip” button. If you choose to skip the button, you consent that you have waived your right to utilize the parental controls feature until you re-enable the parental controls feature again. You consent that by opting out of the parental controls feature, you will not be able to restrict your child’s access to Ninja Focus’s content. Opting in to the parental controls feature will be available at all times.
v. Contacting Us. If you leave us feedback or write to us directly, we will collect the information that is contained in your feedback or comment form, which may include your e-mail address or other information that you may submit to us.
11) Information Collected from Children. Children can access many parts of the mobile application and its content and use many of its features without providing us with Personal Information.
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.
We enable registered users to activate or control certain features of the Ninja Focus application with their voice on speech-based products (e.g., Amazon Alexa, Google Home, Siri, etc.) to promote mindfulness practices among children. Use of the Voice Activated Commands results in the temporary collection and recording of a voice audio file. We only use the audio files generated from the Voice Activated Commands to execute those instructions and do not make other uses of the audio files. We delete the associated audio files after executing the requested action in accordance with this Privacy Statement. Some content or applications on Ninja Focus are served by third-parties and application providers. If you would like to learn more about these third-parties and application providers, please visit their privacy statements to learn more about how your information is protected.
12) Protecting Child Users. Different practices apply to Users under the age of 13 (“Child Users”), as required by the Children’s Online Privacy Protection Act (“COPPA”). There will be no opportunity for a Child User to submit Personal Information on Ninja Focus to create an account except in limited circumstances consistent with this Privacy Statement. Parents and legal guardians are required to create a Ninja Focus account on behalf of their children under the age of 13. Certain Non-Identifying Information may be collected from a Child User solely to enable Ninja Focus to deliver the Services and personalize the Services for the Child User.
In general, if you are under the age of 13, it is a good idea to talk to and ask your parent(s) or guardian(s) for permission before using or playing on the Service. If you do not get such permission, you should not use our Service. Parents should contact Ninja Focus immediately if they have any concerns regarding the Service. Please see the Contact Information section below for further details.
If you (not a Child User) wish to purchase a subscription, only information and data for the purchaser shall be stored in accordance with this Privacy Statement, and the purchase shall not result in the storage of additional data about the Child User. Any further collection of information from or communications with the Child User beyond what is described in this Privacy Statement will be subject to advance parental consent under COPPA. If you have any further questions about how information from a Child User is collected or used, please contact us at privacy@ninjafocus.com.
i. Information relating to your use of or interaction with third party plug-ins. Social media plugins include links to Google, Facebook or Twitter. When you use these features, certain information from your social media accounts may be accessed by or shared with Ninja Focus, and likewise, certain information about your use of Ninja Focus may be posted to your profile on those platforms.
ii. Push Notifications. Your child may be able to receive push notifications to receive reminders for incorporating mindfulness practices into their life, such as, reminders for your child to brush their teeth, meditate, or exercise. Push notifications will not be used for advertising purposes.
We ensure that your child’s receipt of push notifications will be COPPA-compliant. To ensure compliance, Ninja Focus takes the following measures:
a) We do not combine any other personal data collected from the child with the push notification, e.g. Ninja Focus will not personalize the message by including the child’s name, for example, even if that name was collected in compliance with COPPA.
b) At the point of requesting the push notification permission (or before), Ninja Focus will obtain the parent’s email address. Ninja Focus will then provide the parent with notice that the child has enabled notifications and give the parent a way to opt out. This is called Direct Notice.
c) Ninja Focus will only send push notifications containing information about the Ninja Focus app and that is relevant to the child’s activities in the Ninja Focus app. For example, a notification that new content is available. Ninja Focus will not send any marketing messages about other products.
13) Tracking Methods. We may collect information through the mobile application about your individual device. The purpose of this collection is:
(i) to deliver content requested by the Users or to recommend content we think may be of interest;
(ii) to optimize the Services for the particular mobile device; and
(iii) to gather analytics and data about the way the Services are used through the mobile applications.
14) Internal Use. We only use Personal Information for internal use. We use Personal Information in some cases in conjunction with Non-Identifying Information to recommend and deliver to the User content and features we think the user will enjoy, based on their age, habits, hobbies, and other information that will improve the Ninja Focus user experience. Log Data is used to track and report to a user on their progress, monitor and analyze use of the Services, to analyze usage patterns, to optimize their access to our Services, and to control the load on our servers so that we can serve users better. We may also combine Personal Information with Non-Identifying Information and Log Data and aggregate it with information collected from other Users to improve the quality and performance of our Services and to analyze how our Services are used. We may use your contact information to remind you about the Services and new options that we may make available and to inform you about changes to our Services.
15) Information Shared with Third Parties.
We do not share your information with third parties except for limited circumstances such as:
- Sharing financial information with payment processors;
- Transferring information in the event of a business transfer;
- Compliance with laws and law enforcement; or
- Social media sharing
i) Payment Processors. If you sign up through Ninja Focus for a Subscription Service or purchase premium content, third party payment processors (e.g., Stripe, PayPal, Google Play, App Store, Amazon, Microsoft Store) may have access to your Personal Information for the sole purpose of processing transactions and renewals. Any such payment processors will be bound to maintain all such Personal Information in a secure environment, keep its confidentiality and not use or disclose such information for any purpose other than to validate purchases and operate Subscription Services. If you purchased content or signed up for Subscription Services through an app store, you should refer to that store’s terms for information on how it maintains personal financial information.
ii) Business Transfers. If Ninja Focus or the assets of Ninja Focus are acquired by another company, we may transfer your information in connection with that acquisition or sale and the acquiring company will possess the information (including your Personal Information) collected by us and it will assume the rights and obligations described in this Privacy Statement.
iii) Compliance with Laws and Law Enforcement. We may access and disclose your Personal Information to government or law enforcement officials or private parties if we believe in good faith that such disclosure is necessary to comply with applicable laws, to respond to valid legal process such as a search warrant, subpoena, statute, or court order, to protect the property and rights of Ninja Focus or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
16) Unsubscribing and Deleting Information. You may access, update and edit certain Personal Information that is in your account. When you receive messages from us by your chosen method of communication (whether e-mail or text or by push notification), you may indicate a preference to stop receiving further communications from us by electing to “unsubscribe” and you may turn off notifications on your mobile device. We may, however, still send you administrative messages regarding the Services. You may contact us privacy@ninjafocus.com with a request that we delete your Personal Information from our database or remove other information that you no longer wish to include as part of the Services. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Child Users may not add Personal Information to their account and will only receive administrative messages that affect their use of the Services. If a child between the ages of 13 and 18 wishes to erase or delete any information that he or she has included or shared via the Services, please contact us at privacy@ninjafocus.com and we will promptly comply.
At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.
You can review, change, or delete your child’s personal information by:
1.) Logging into your child’s account and visiting his or her account profile page; OR
2.) Sending us an email at privacy@ninjafocus.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
17) Information Retention. Unless there is a specific legal or regulatory requirement for us to keep information, we will retain it for no longer than is reasonably necessary for the purposes for which the data was collected or for which it is to be further processed. The retention period is also subject to provision
18) Information Storage. Ninja Focus is located in the United States. Accordingly, Personal Information we collect may be transferred to and stored in our servers or those of third parties that act on our behalf (such as hosting providers) in the United States. By using the Services you agree to such collection, transfer and storage to other territories where the information may have been collected.
19) Securing Information. We follow generally accepted industry standards to protect Personal Information, including your email address, submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
20) Assess/Correct Child’s Information. You should be aware that while we take industry standard administrative, physical and technological measures to maintain the security of your Personal Information, we are not able to fully eliminate all security risks or potential breaches.
We value you and your child’s privacy. We want Ninja Focus to be a safe place to promote mindfulness for children. If you have any questions regarding privacy, please do not hesitate to contact us at privacy@ninjafocus.com.
21) California Privacy Rights. California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@ninjafocus.com.