App Privacy Policy

Privacy is SelfieCop's #1 priority. This includes the privacy of parents, children and third-parties. Nothing is more important to us.


This page contains the Privacy Policy for the SelfieCop Parent-App, Parent-App & related services. (To read the Privacy Policy for our website & related services, go to our Web Privacy Policy.)

(Oct. 6th 2015) Important notice: SelfieCop 'Safe Harbor' transfers to USA

Following the European Court of Justice ruling that invalidates Safe Harbor data transfers to the US, SelfieCop has started a process to ensure all data can in future be stored within the EU. We expect this change to be ready by early-mid 2016.

In the meantime, if you do not wish your data to be transferred to the USA, please do not use the SelfieCop service.

(Find out more about Safe Harbor from European Commission & Wikipedia.)

We have made special effort to make this policy easy to read. Please take time to go through it. It will help you to understand:

  • How our apps & services work.
  • The information we collect when you use our apps.
  • What we do with your information.
  • Your own privacy-related responsibilities.

To get going, you should first read the important note below about "consent". It explains how you indicate to us that you consent to this Privacy Policy.

We want you to understand this policy & use our service in the best way possible. If you have any questions, contact Shane on Twitter or via email.

Important: How you consent to this Privacy Policy

When installing the Parent-App and Parent-App you will see text that reads:
"I read & agree with SelfieCop's Terms of Use & Privacy Policy". Alongside is a check-box.

If you 'tick' the check-box, you are indicating your consent for SelfieCop Limited to process information in the manner described in this document and that you will comply with your own responsibilities.

For example, by consenting to this policy you agree that SelfieCop can do the following with you & your child's information:

  1. Collect & combine information in order to provide the SelfieCop service to you, e.g. by storing your email addresses.
  2. Collect & combine information in order to improve the SelfieCop service, e.g. by analysing the type of device you and other people use.
  3. Transfer some information to certified service providers, e.g. storing files in a safe location.
  4. Transfer & store information in the USA.

A full description of everything we do with your information is below. Please read it carefully.

If you do not agree with this policy, DO NOT tick the check-box.

SelfieCop Privacy Policy

Version 1.0 | Effective 1st September 2015

  1. Introduction
  2. Scope
  3. Information we collect about you
  4. Information we collect about your child
  5. How we use information
  6. Where we store information
  7. How we share your child's information
  8. How we protect information
  9. How to access, update, correct and/or object to the use of your information
  10. When we delete information
  11. Third-parties' information (clarification)
  12. Privacy-related obligations
  13. Limitation of liability
  14. Changes to this Privacy Policy (notifications)
  15. Contact

1. Introduction

In order to function as intended, the SelfieCop Service must collect, combine, use, store and disclose some parts of a Child's personal information. In particular, this includes a Child's photographs or videos.

It is our intention that the identity of an individual Child should not be easily established by anyone with access to the limited information we collect and process.

To that end, we have implemented measures that ensure information is dealt with confidentially and securely. For example, no-one at SelfieCop can view a Child's photos or videos. This is because all photos or videos are encrypted and we do not have access to the decryption keys.

However, in some limited situations, the information we collect or process could lead to the identification of an individual Child. (Full detail of all information we store or process is provided below.)

As a result, your consent (as the Child's Parent) is required in order for this Service to operate.

Your consent is provided by checking the Box "I read & agree with SelfieCop's Terms of Use and Privacy Policy" in the Parent-App and Child-App. By checking the Box you indicate that you consent to:

  1. The processing of you and your Child's information as described in this document.
  2. That you will comply with, are accountable for and are liable for the Privacy Related Obligations mentioned in Paragraph 12 of this Privacy Policy.

Terms and meanings

The meaning of certain expressions is important in order to understand this Privacy Policy and SelfieCop's Service. This includes:

To find out more about the meaning of each term, click on the links.

2. Scope

This Privacy Policy applies to the SelfieCop Service provided through the installation and use of:

  • The Parent-App, on the Parent's device; and
  • The Child-App, on the Child's device.

This Privacy Policy describes:

  • How we collect and use information that identifies (or may be used to identify) you and/or your Child (personal data); and
  • The Privacy Related Obligations that you (the Parent) shall comply with and agree with in order to install and use the SelfieCop Service.

3. Information we collect about you

In order to use the SelfieCop Service you must download and install the Child-App & Parent-App. You install the Child-App onto your Child's device. You install the Parent-App onto your (the Parent's) own device.

During installation and set-up, the SelfieCop Service collects certain information about you (the Parent) and your Child, as described below.

3.1a What information is collected?

In order to install the Apps, Parents are required to provide the following information during set-up:

  • An email address.
  • A password (to protect access to each App).
  • Confirmation of the following:
    • (i) That you are the Parent/Legal Guardian of the Child (Parent-Child relationship).
    • (ii) Your Child's age.
    • (iii) That you believe using the SelfieCop Service is in your Child's best interest.
    • (iv) That you will only install the SelfieCop Service on a device owned or operated by your Child (device monitoring restriction).
    • (v) That you will only use the SelfieCop Service to link to a device owned or operated by your Child (image viewing restrictions).
    • (vi) That in the event your Child's refuses consent to install the SelfieCop Service, you will indicate your intention to override that refusal and accept responsibility for doing so (if applicable).
    • (vii) That you accept the Terms of Use and Privacy Policy of the SelfieCop Service.

3.1b Why is this information collected?

The information in the paragraph above is necessary to provide the SelfieCop Service. The SelfieCop Service aims to:

  • Deter your Child from unsafe behaviour.
  • Teach your Child that every photo taken may be seen by someone else.
  • Allow you (the Parent) to check/validate (if you so choose) that your Child is using the camera safely and to comply with SelfieCop's legal obligations.

3.1c Is collecting this information mandatory?

Yes. Without it the installation of the Apps cannot be completed.

3.2a What information is collected?

SelfieCop also collects information from the device upon which the Parent-App is installed, i.e. the Parent's device:

  • Device brand name & model.
  • Version of the operating system.
  • Date and time of installation of the Parent-App.

3.2b Why is this information collected?

This data is used for customer support, data security and for the development of the SelfieCop Service.

For example, this information allows us to understand how many types of device SelfieCop must support (business analysis purposes) and to help track performance on different devices (information about products and services).

3.2c Is collecting this information mandatory?

Yes. Without it SelfieCop won't be able to provide you with the best service. If you don't want to provide us such data, you won't be able to use the service.

Important note about how encryption keys are used by the SelfieCop Service

SelfieCop relies on "symmetric" encryption to work. An encryption key (called a "secret key" in the App) is automatically generated by the Parent-App during set-up.

For the SelfieCop Service to work, the encryption key generated by the Parent-App must also be manually input into the Child-App. This is the last step of set-up and ensures both Apps are in "symmetry" regarding encryption.

The Child-App can then encrypt photos/videos and the Parent-App decrypt photos/videos using the same key.

Important: Encryption keys are secret and must only be shared the Child-App you wish to link to. Never disclose an encryption key to anyone or write it down. You do not need to remember your encryption key. A new key can be generated at any time.

Note: A new encryption key may be generated on the Parent-App at any time. However, whenever a new key is generated, the old key is immediately deleted. This could cause the Parent-App and Child-App to go "out-of-symmetry". As such, the new key must also immediately be input to any Child-App the Parent-App is linked to.

4. Information we collect about your Child

In order to use SelfieCop Service you must download and install the Child-App onto your Child's device. During installation and set-up, the SelfieCop Service collects certain information about your Child, as described below.

4.1a What information is collected?

In order to install the Apps, the SelfieCop Service collects confirmation of your Child's "acceptance" or "refusal" of consent to use the SelfieCop Service.

As noted above, in the event your Child's refuses consent to use the SelfieCop Service, SelfieCop will also record (if applicable) your intention to "override" that refusal.

4.1b Why is this information collected?

This is referred to as the "Child's voice" and is used to record your Child's consent (or refusal) to use the SelfieCop Service.

4.1c Is collecting this information mandatory?

Yes. This information is necessary to provide you the Service.

4.2a What information is collected?

In order to function as intended, the SelfieCop Service routinely collects and processes information as follows:

  • Copies, reduces and encrypts an image of each photo and video that your Child's captures via his/her device's built-in camera (these encrypted files are then processed accordingly).
  • Collects and records the date and time each encrypted file is stored on your Child's device.
  • Creates a link to each encrypted file on your Child's device.

4.2b Why is this information collected?

This is used to deliver the core SelfieCop Service. This is in order to:

  • Deter the Child from unsafe camera behaviour.
  • Teach the Child that every photo taken may be seen by someone else.
  • Allow the Parent to check/validate (if they so choose) that their Child is using their device's built-in camera safely and to comply with SelfieCop's legal obligations.

4.2c Is collecting this information mandatory?

Yes. This information is necessary to provide you the Service. Without it, the Service does not work.

4.3a What information is collected?

From the device upon which the Child-App has been installed, SelfieCop also collects and uses the following information:

  • Device brand name & model.
  • Version of the operating system.
  • Date and time of installation of the Child-App.
  • List of the names of all other Apps running on the device
  • A record every 10 minutes that SelfieCop Child-App is "live"

4.3b Why is this information collected?

This data is combined with (i) the date and time an encrypted file is stored and (ii) the link to the encrypted file mentioned in the paragraph above, and used for:

  • Development of the SelfieCop Service, including for analytics and to provide information about SelfieCop products and services.
  • Customer support, e.g. for identification.

In addition, knowing which other Apps your Child has installed allows SelfieCop to:

  • Steer development for maximum coverage and ensure the Child-App functions as intended, and
  • More accurately inform prospective users (adults) about which services the Child-App is compatible with.

Knowing the date & time each Child-App is installed allows SelfieCop to:

  • Determine the total number of Apps installed, measure sales performance and estimate the overall life-time of customers.

Retaining a record that SelfieCop Child-App is "live" every 10 minutes allows SelfieCop to:

  • Alert the Parent via email whenever the Child-App stops working unexpectedly (is not "live")
  • In such an instance, a record of the last signal is retained, until the next successful signal is received.

4.3c Is collecting this information mandatory?

Yes. Without it SelfieCop won't be able to provide you the best service. If you don't want to provide us such data, you won't be able to use the service.

Note: SelfieCop does NOT contact children for marketing purposes.

Important note about how phone numbers are used by SelfieCop Service

During set-up you (the Parent) must send at least one SMS message from your device to your Child's device. This is in order to assist set-up and create a valid link between devices (as described below).

To this end, the SelfieCop Service requires you (the Parent) to insert your Child's phone number into the Parent-App. The Child's phone number is used to:

  • i. (Optional) Send an SMS from the Parent's device to the Child's device with a link to download the SelfieCop Child-App. (Note: The number is not recorded by the SelfieCop Central Customer Database, but is temporarily stored in the Parent-App.) This SMS has the same risks as sending a normal SMS, which you Consent to by accepting the present document.
  • ii. (Mandatory) Send an SMS from the Parent's device to the Child's device, with a SelfieCop temporary Parent-App Identity Code. This code enables a "verified link" to be made between the Parent's device and the Child's device. (Note: The number is not recorded by the SelfieCop Central Customer Database, but is stored in the Parent-App.) If the SMS is not sent the Service cannot be provided. This has the same risks as sending a normal SMS, which you Consent to accept by accepting the present document.

As noted, when sending the SelfieCop temporary Parent-App Identity Code, the source number (Parent's number) is recorded by the SelfieCop Child-App on the Child's device. In addition, the destination number (Child's number) is recorded by the SelfieCop Parent-App on the Parent's device.

The phone numbers are recorded in order to allow the Parent and Child to visually validate that the correct link has been created. (As noted, neither number is recorded by the SelfieCop Central Customer Database.)

5. How we use information

SelfieCop does not use your Child's information to identify him/her or monitor his/her habits.
In addition, we do not monitor your (the Parent's) habits.

SelfieCop uses Parents' information in order to:

  • Set up the SelfieCop Child-App and Parent-App.
  • Communicate with Parents.
  • Provide product information to the Parent (in accordance with the Parent's consent).

SelfieCop uses information provided to it by Parents about their Child in order to provide the Service. That is, to:

  • Deter the Child from unsafe behaviour.
  • Teach the Child that every photo/video he/she captures may be seen by someone else.
  • Allow Parents to check/validate (if they so choose) that their Child is using their device's built-in camera safely.

SelfieCop uses the information it collects from the devices upon which Parent-App and Child-App are installed in order to:

  • Provide the SelfieCop Service (for identification and customer support).
  • Develop and improve the SelfieCop Service, including for analytics and to provide information about SelfieCop's products and services.

SelfieCop uses photos and videos copied from the Child's device in order to:

  • Make them available to the Parent so that the Parent can use that information to protect the Child's best interests. That is, by checking/validating (if they so choose) that their Child is using their device's built-in camera safely.

SelfieCop uses the record that the Child-App is live in order to:

  • Warn parents if the SelfieCop Service has stopped working unexpectedly, e.g. if Child's device is turned "off", if the Child has uninstalled the App, etc.

NOTE: The Parent's primary duty when using SelfieCop is to consider the best interest of their Child. Parents are encouraged to speak with their Child about safe camera usage and to regularly review the need for the SelfieCop Service.

6. Where we store information

SelfieCop transfers, stores and further processes you and your Child's information in the United States of America, at the data centres operated by our host-provider Liquid Web.

Liquid Web agree to co-operate and comply with the EU and/or Swiss Data Protection Authorities & Law.

7. How we share you and your Child's information

SelfieCop does NOT share your Child's personal data with third parties. The only exception is when we provide information to:

  • Certified Partners to provide support for the internal and external operations of the SelfieCop Service we provide you, including for the development of the service, analytics and to provide information about SelfieCop products and services.
  • Government officials or otherwise as required by our legal obligations.

SelfieCop shares your (the Parent's) personal data only to:

  • Certified Partners to provide support for the internal and external operations of the SelfieCop Service we provide you, including for the development of the service, analytics and to provide information about SelfieCop products and services.
  • Government officials or otherwise as required by our legal obligations.

NOTE: A Certified Partner is an entity that has to comply with strong and rigid security measures (technical security measures and organisational measures). We require that Certified Partners:

  • Keep you and your Child's personal information secure and confidential.
  • Use it only on our behalf.

With the exception of the above SelfieCop does NOT sell, rent, give, disclose or make available by any other way you or your Child's personal data.

Regarding information that does NOT identify you or your Child (anonymized data) SelfieCop may disclose it to third parties for analytics, marketing, research and other purposes.

8. How we protect information

SelfieCop has taken administrative, technical, physical and procedural security measures, including encrypting your information during transmission, to protect you and your Child's personal information.

Namely, SelfieCop staff cannot view the visual information of the photos or videos processed by the SelfieCop Service, since it cannot access the associated encryption keys.

Additionally, only Authorised Persons have access to personal data/information; whilst Certified Partners may be granted access only for a period required to complete specific tasks, e.g. development, analytics.

All processing takes place subject to a contract between SelfieCop and Certified Partners that specifies, namely, the following:

  • The conditions under which the data may be processed including the processing only under SelfieCop's behalf.
  • The security conditions attaching to the processing of the data
  • That the data be deleted or returned upon completion or termination of the contract.

SelfieCop takes reasonable steps to ensure compliance by Certified Partners with the best international standards applicable.

9. Accessing, updating, correcting and objecting to the use of information

You have the right to contact us to update, correct and request removal of inaccurate personal data we have about you or your Child.

You can review some of personal information you have provided us and make any reasonable desired changes by visiting the Child-App's or the Parent-App's Settings.

You also have the right to access to your personal data we hold about you or your Child.

To request it, please write to us at:

SelfieCop Limited
38 The Waterside
Charlotte Quay
Dublin
D04 EP22
Ireland

Please send us the following information together with your letter:

  • Proof of identity
  • Information that may help us locate your data, such as device brand name & model
  • 6.35 euros

We will respond within 40 days.

You can refuse to allow any further collection or use of your of your Child's personal data. You can also request us to delete you or your Child's personal data.

10. When we delete information

Parent's email, parent's device number and password

Parent's email, parent's device number and password are deleted from the SelfieCop central customer database 6-months after the last recorded usage of an app or 6-months after service cancellation. (On the device this data is deleted when the user uninstalls SelfieCop.)

Encrypted image files

Encrypted image files are deleted from each step of the SelfieCop Service as they are processed. This includes:

  • Encrypted image files are deleted from the Child-App after being uploaded to SelfieCop central storage infrastructure.
  • Encrypted image files are deleted from the SelfieCop central storage infrastructure after transfer to the Parent-App. (Note: If a Parent-App does not request download of encrypted files within 40 days, they are automatically deleted.)
  • Encrypted image files are deleted from the Parent-App after each has been displayed.

Device brand name & model, version of Android, date and time of installation of the App, list of the names of other Apps running on the Child's device

This data is anonymised for individual records 6-months after the last recorded usage of an App, or 6-months after service cancellation.

Unique Identity Code

Unique Identity Code has different data retention periods depending on the purpose for which it is used:

  • The Unique Identity Code used for identification purposes of the Apps is never deleted. This is so a permanent record (count) of each installation may be retained. It is not deleted so as to ensure that no duplication of records ever occurs.
  • The Unique Identity Code is deleted from the Parent's device and the Child's device when the SelfieCop Parent-App or Child-App is uninstalled.

Temporary Parent-App Identity Code

In order to initiate the process of creating a link between a Parent's device and Child's device, a temporary Parent-App Identity Code is sent from the Parent's device to the Child's device via SMS.

The temporary Parent-App Identity Code is then visible in plain-text format in the list of SMS messages on both the Parent and Child's device. When received by the Child's device and recognised by the Child-App, the code is uploaded to the SelfieCop Central Customer Database for processing.

After processing the temporary Parent-App Identity Code is deleted from the SelfieCop Central Customer Database when a link between the Parent-App and a Child-App is created.

The temporary Parent-App Identity Code must be manually deleted from the list of SMS messages on both the Parent and Child's device by the Parent.

Record that SelfieCop Child-App is "live"

All data is deleted 6-months after the last recorded usage of an App.

Individual data may be stored for longer than 10 minutes in instances of a record not being successful, i.e. if it appears a Child's device is not "live". In this event, the time/date of the last record is stored until a new record is received. When a new record is received, stored data is deleted.

A list of encrypted files created (time & date)

In the Child-App, this data is deleted 6-months after the last recorded usage of the App, or 6-months after cancellation of the service.

On SelfieCop's central customer database, this data is deleted a maximum of 40-days after entry (if no request is made by the Parent-App to download this data).

Encryption keys

A new encryption key may be generated on the Parent-App at any time. Whenever a new key is generated, the old key is immediately deleted from the Parent-App. To permanently delete all keys, uninstall the App.

To delete an encryption key from a Child-App, the Parent may:

  • Enter a new key.
  • Delete any existing "link" to a Parent-App.
  • Uninstall the Child-App.

Note: Encryption keys are not stored at the SelfieCop central customer database.

11. Third-parties' information (clarification)

It is important to note that the SelfieCop Service may process images that contain personal data of your Child, your Child's friends and/or of Third Parties.

For example, when your Child takes a photo of a friend (who is identifiable by his/her face or a tattoo) that photo will be sent to the Parent-App through the SelfieCop infrastructure.

SelfieCop is not able to identify, avoid or block those situations. Neither is it able to obtain your Child's friend's consent or (friend's parent's consent) to process your Child's friend's personal data.

To minimize the risk of processing Third Parties' personal data, SelfieCop has included "privacy-by-design" principles in this Service. For example, this includes:

  • SelfieCop encrypts all photos and videos.
  • SelfieCop does not have access to encryption keys and cannot view any photos and videos.
  • SelfieCop only allows Parents to view decrypted photos and video after entering a password that only the Parent should know.
  • Decrypted photos and videos are displayed for a maximum of 5 seconds on a Parent-App before being deleted.

12. Privacy related obligations

Protection of your Child's personal data and Third Parties' personal information is not only in SelfieCop's hands, but also in the hands of Parents who use the SelfieCop Service.

As such, and for the protection of your Child and Third Parties we created the following Privacy Related Obligations.

By accepting the present document, you consent, accept and agree to be solely responsible, accountable and liable for the following privacy related obligations:

  • To use the SelfieCop Service only if you are the Parent/Legal Guardian of the Child upon whose device you intend to install the Child-App (Parent-Child relationship).
  • To use the SelfieCop Service only to ensure the Child's best interest and only in accordance with the law.
  • To inform the Child (or any person that uses the device on which the Child-App is installed) prior to the completion of installation of the Child-App:
    • What SelfieCop Service is.
    • How SelfieCop Service works.
    • What the SelfieCop Service is for.
  • To inform the Child (or any person that uses the device on which the Child-App is installed) that she/he shall inform any person (Third Party) whose picture is being captured by the device on which the Child-App is installed, that the SelfieCop Service is installed and, therefore, the person's recorded image will be seen by the Parent.
  • To inform the Child (or any person that uses device on which the Child-App is installed) that he/she shall act accordingly with the person's decision whether to be photographed or recorded, or not.
  • To protect the password provided by the Parent to use the SelfieCop Service against unauthorised access to, alteration, disclosure or destruction and against all other unlawful forms of use.
  • To protect the encryption keys ("secret codes") to use the SelfieCop Service against unauthorised access to, alteration, disclosure or destruction and against all other unlawful forms of use.
  • To delete from your device and your child's device any SMS messages used to share a temporary Parent-App Identity Code from the Parent-App to the Child-App.

Note: if a Parent receives an image that gives him cause of concern and copies it or forwards it to anyone, the Parent could be guilty of a Criminal Offence under child protection laws. Parents should report images of concern to the relevant law enforcement authorities.

13. Limitation of liability

By providing Consent, you are solely responsible for all liability that results with respect to any unpermitted or illegal use of the SelfieCop Service by any person that uses the device on which the Child-App or the Parent-App is installed, including yourself.

To the fullest extent allowed by applicable law, SelfieCop disclaims all warranties of every nature relating to privacy or the right to the protection of personal data of Third Parties, the Child, the Parent and/or any possible user of SelfieCop Service, without limitation, including implied warranties, providing the SelfieCop Service as it is.

SelfieCop shall not be liable to you or any Third Party, or any nature or legal person for any damages of any kind that arise out of or related to the SelfieCop Service, even if SelfieCop has been advised of the possibility of such damages.

14. Changes to this notice (notifications)

You Consent, agree and recognize SelfieCop's right to determine the form and means of providing notifications to you, and you agree to receive legal notices electronically if SelfieCop so chooses.

SelfieCop may revise this Privacy Policy from time to time and the most current version will always be posted on our website at www.selfiecop.com.

If a revision is material we may notify you (at our sole discretion) and we will post a prominent notice on our website at www.selfiecop.com prior to the change becoming effective.

If the change would have the effect of introducing a purpose for the use of your personal data, which is inconsistent with this notice, and where required by applicable law, SelfieCop will either notify you or provide you with an opportunity to opt-out from such use.

By continuing to use SelfieCop Service after revisions become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the new terms, please stop using SelfieCop Service.

15. Contact

If you have any questions, please contact us:

SelfieCop Limited
38 The Waterside
Charlotte Quay
Dublin
D04 EP22
Ireland

Email: team&selfiecop.com

Terms and meanings

"SelfieCop Service"

The scope of the "SelfieCop Service" is defined in our Terms of Use.

"Parent" or "you"

A "Parent" or "you" is the user of the SelfieCop Service that has confirmed themselves to SelfieCop to be the father, mother or legal guardian of the Child (minor) who Consents to use the SelfieCop Service in support of the Child's best interest.

"Child"

The "Child" is the person (considered a minor under the applicable law) who requires the use of the SelfieCop Service to ensure her/his best interest and for whom the "Parent" has confirmed themselves to be the father, mother or legal guardian thereof.

"Third-Party"

A "Third Party" is any person, other than the Parent and/or the Child, whose personal data is captured by the device on which the Child-App is installed (e.g. a person whose identifiable face appears in a photo or video taken by the device upon which the Child-App is installed).

"Personal data" or "personal information" or "information"

Any information relating to an identified or identifiable individual, such as faces, names, phone number, email, address, etc.

"Certified Partner"

An entity that has to comply with strong and rigid security measures (technical security measures and organisational measures). We require that a "Certified Partner" (i) keep your personal information secure and confidential and (ii) use it only on our behalf.

"Child-App"

The "Child-App" is defined in our Terms of Use.

"Parent-App"

The "Parent-App" is defined in our Terms of Use.