Elephant Global Privacy Policy

Welcome to Elephant!  When you use our app, we collect and process information about you and what you’re doing on YouTube.  This is mainly so that your Admin (this is the person that looks after your account, e.g. a caregiver, school or workplace) can watch out for you, and make sure that you don’t see content that isn’t suitable for you.

This privacy policy explains what we collect, why we collect it, and what we do with it, but you should be aware that:

• basically, anything you do on Elephant can be seen by your Admin. Elephant can also see this information, but we don’t match it to your username or other identifiers, and we keep it encrypted.
• if you’re an Admin, any feedback you give about content on Elephant can be seen by other Admins, and may be used as part of our Elephant engine.

You can click through to see more information below.

1. Who we are
2. Changes to this Privacy Policy
3. The information we collect
4. How we collect information
5. How we use and share information
6. How long we keep information for
7. Your rights

1. WHO WE ARE

We are Elephant Global Limited.  Our address is C/- Monteck Carter, Unit 5, 15 Accent Drive, East Tamaki, Auckland, 2013 , New Zealand.

2. CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review and will provide notice of changes to this privacy policy on our website, and by email or notification in the app to our registered Admins and users.

This version was last updated on 29^th September 2020.  Historic versions can be obtained by contacting us on the details below.

3. THE INFORMATION WE COLLECT

In this privacy policy “personal information” means any information about an identifiable individual, or (in other words) any information that identifies you.  When you use or subscribe to Elephant, we’ll collect, hold, use and disclose your personal information as described in this privacy policy.

The types of personal information we collect about you are:

• Account holder information: Where you are the account holder (i.e. the person that sets up your herd’s Elephant subscription), we collect your name, email address, mobile number, date of birth, country of residence, and subscription/payment records.  You’ll also be taken to our payment provider’s website to provide payment information (but we don’t actually receive your card details – you give these directly to the payment provider).
• User information: If you are an Elephant user (but not the account holder), we collect your username (this is assigned to you by your Admin, and might be your real name or something else), and your date of birth.  We also record whether you have been appointed an Admin for the account.
• Profile information: If you choose to upload a profile picture or answer profile questions about your preferences and interests, then we will collect that information.
• Technical information: For everyone that uses Elephant, we collect technical data about your device, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device type and other technology on the device you use.
• Social media information: Information about the social media or video streaming platform you access with Elephant, including the platform name, your username and subscription type (for example, if you are a YouTube premium subscriber), and authorisation to connect your social media account to Elephant (where relevant).
• Usage information: We record how you use Elephant, and what content you view and search for while using Elephant. This includes time on app, your interactions with Elephant, potentially your location and what application, tools, browser or webpage you are using with Elephant.  We also record any reactions or feedback you put into Elephant about content, and (if you are an Admin) the settings you have selected for your users (and any changes to those settings).
• Marketing and communications information: including your preferences in receiving marketing from us and your communication preferences.

Sometimes providing information to us is optional.  For example, it’s up to you whether you upload a profile photo or not.  However, sometimes if you choose not to enter personal information, then that may mean you can’t get the most out of Elephant’s services.  For example, the more you tell us about viewing preferences and interests, the better Elephant’s content filtering and recommendations will be.

4. HOW WE COLLECT INFORMATION

We get your personal information in different ways:

• Sometimes we get your personal information because you put it into the Elephant app yourself.
• If you contact us directly, by phone, email or post, then we collect information from that communication.
• Admins on your account might enter information about you. For example, your Admin will choose your username and your date of birth.  They might also set up account preferences for you based on information they know about you.

5. HOW WE USE AND SHARE INFORMATION

We will use your personal information to:

• provide the Elephant service. This includes filtering the content you view while using Elephant, so that you don’t see certain types of content (based on the preferences that you and your Admin have chosen), letting your Admin see the content you have watched and searched for, sending requests for viewing content, collecting your feedback and reactions about the content you see, and telling your Admins about concerning or inappropriate content or searching;
• administer your account, and comply with our legal, regulatory, tax and/or accounting requirements;
• test and improve the services and products that we provide, e.g. if you are involved in a beta testing program;
• contact you about the service and your subscription (where you are an Admin or a user), and if you consent, to email you for marketing purposes;
• carry out marketing and product analysis; and
• assist with queries, requests or complaints, or reports of inappropriate user-created content or feedback.

The list below explains how we share your personal information:

• if you are a user, all of the information we hold about you (such as what content you have watched, what you have searched for, and how you have reacted to content) can be seen by your Admin.
• if you are involved in checking or moderating content on Elephant, we may share your de-identified feedback with other users using Elephant;
• we may share information about you with our service providers and suppliers where it’s needed for us to be able to use your personal information (as set out above) – this will be on a de-identified basis wherever possible;
• potential purchasers of our business; and
• anyone who we need to share information with by reason of law or to address any complaints you make to a third party or regulator (such as the Privacy Commissioner).

In some cases, we may also need to disclose your personal information to third parties outside of New Zealand, but we will always make sure that reasonable safeguards are in place to keep your personal information safe, and protected by comparable standards to New Zealand privacy law.   Elephant currently stores all of its data on AWS servers in the USA and Asia Pacific (Sydney) Region, Australia.

6. HOW LONG WE KEEP INFORMATION FOR

We will only keep your personal information for as long as we need it, and are legally allowed to use it.  If you unsubscribe to Elephant, all content feedback that you and your users have provided will be kept on a de-identified collated basis within Elephant’s library.  Your payment details will be deleted immediately after unsubscribing, user search and viewing history will be deleted within 6 months, and the remainder of your account information (including user and Admin information) will be kept for 12 months after unsubscribing (to make re-subscribing easy for you).   We will de-identify and aggregate information wherever we reasonably can.  For example, when we store usage information about you, we try to keep it in a way that is not directly associated with your username.

If you would like us to delete your information permanently outside the timeframes explained above, please contact us on the details below.

7. YOUR RIGHTS

You have rights to see and request the correction of any personal information we hold about you.  If you want to exercise these rights or to ask us questions about this privacy policy, please contact us using the following details:

Email address: info@designimpact.net.nz

Postal address: Joanne Lottering, Design Impact Ltd / Elephant Global Ltd, 99 Walter Strevens Drive, Takanini 2112, Auckland, New Zealand.

This privacy policy is governed by New Zealand law.  For more information about privacy issues in New Zealand and protecting your privacy, visit the New Zealand Privacy Commissioner’s website.