Siren Group AG ("Siren", "we" or "us") operates websites (“Sites”) under the business name and trade-marks "ChildSafe Kit" and “Kids Safety Kit.” The Sites include www.thechildsafetykit.com, www.childsafetykit.ca, and www.kidssafetynetwork.com. Working with insurance companies (“Insurance Providers”), Siren offers users a free ChildSafe Kit on the Sites. After collecting basic personal information from users on the Sites, Siren passes the information to the Insurance Providers, who then deliver the free Kits to the users and, at the same time, may offer their own products and services (“Insurance Offers”).
We care about your privacy. We want you to feel secure and confident when using our Sites. As such, we will outline below the standards which we will apply when collecting, using and disclosing any of your personal information.
Much of the information that we may collect, use or disclose in the course of offering products and services (“Services”) to you will be information that we require in order to fulfill those offers. Except for basic account information, such as your name, email address, physical address and telephone numbers, we will rarely collect, use or disclose "Personal Information" as such term may be legally defined or understood in common or industry usage. Nonetheless, we intend to respect and protect the personal information which you provide us, including any sensitive or confidential personal information, in the course of our relationship.
"Personal Information" when used herein means information about an identifiable individual but does not include contact information about a person in their business capacity, such as the name, title, business address, or telephone number of an employee of an organization, except as otherwise may be specified in law. See a more specific definition of Personal Information under California’s “Consumer Privacy Act of 2018” (“CCPA”), discussed below.
A. Purposes for Collection and Use of Personal Information
Siren may collect and use Personal Information from you for the following purposes:
(i) to provide you, via email and other media, with information about our Services, including discounts, offers, promotions, and occasional third-party product and service offerings;
(ii) to enable you to access and use our Services and to receive the free ChildSafe Kit and Insurance Offers from the Insurance Providers;
(iii) to conduct research, analysis and surveys and to review aggregated non-identifying data to improve our Services;
(iv) to provide non-aggregated, non-personally identifiable information to us and to advertisers in order to enable us to offer Services directly to you;
(v) to show you ads of Services on websites like Facebook, Google and others that Siren may deem relevant;
(vi) in order to transfer data to a third party for backup purposes;
(vii) to perform backups, restore data from backups, or to perform service on our servers or system;
(viii) to provide you with support;
(ix) to collect non-identifying and aggregated usage information and transaction volumes in order to understand
usage patterns and improve the system design and prompt users with suggestions on ways to improve their own use of the system; and
(x) where required to comply with a statutory requirement, valid court order, warrant, or other valid law enforcement purpose.
Siren will not collect, use or disclose your Personal Information for any purpose other than those listed here, without prior notice to you and your consent. We may transfer Personal Information to third parties who are contractually engaged by us to perform certain functions, including the Insurance Providers and the parties that host and maintain the servers upon which the Personal Information is stored and processed. We will make every reasonable effort to ensure that the standards of such parties for governing security and confidentiality of Personal Information are at least as rigorous as our own standards.
B. Disclosure where Required by Law
C. Privacy Principles
Siren is responsible for maintaining and protecting Personal Information about you in our care or control.
II. Identifying Purposes
You have a right to know how your information will be used. (See CCPA below for specific rights in California.) We will explain why we need your information before or when we collect it, if the purpose is not already clear. We have set out the purposes for which we may use your Personal Information in section A above.
Siren will only collect, use and disclose your Personal Information with your knowledge and consent, except where permitted or as required by law. Except as otherwise set out herein, Siren will not rent, sell, or otherwise distribute your Personal Information without your permission.
At any time a user may prevent future secondary use of your information (i.e., disclosing or sharing with other parties) by "opting out" when Siren collects your information or by contacting us via the contact form here. (See CCPA below for specific opt-out rights in California.) Except as may be the case under the CCPA or other laws, opting out only applies to the secondary purposes, because we may still need access to your Personal Information to contact you regarding your usability of our Services, or to alert you to important revisions or updates concerning our Services.
IV. Limiting Collection
Siren will only collect Personal Information for the purposes we've identified or for the primary uses as we have described above. We will always strive to do this fairly and legally.
V. Limiting Use, Disclosure, and Retention
Siren will not use or disclose your Personal Information other than for the purposes for which it was collected, with the exception of receiving your consent or as permitted or required by law. When providing information in response to a legal inquiry or order, we will verify its validity and only disclose information that is legally required.
Siren will keep Personal Information only as long as necessary for the identified purposes or as required by law. Siren will follow internally set guidelines and use care in the disposal, destruction, or de-identification of Personal Information to prevent unauthorized parties from gaining access to Personal Information.
Siren will keep your Personal Information as accurate, complete and up-to-date as necessary for the identified purposes for which it was collected. We encourage you to let us know if your contact information changes.
We protect Personal Information in our possession and control by using industry standard security safeguards including:
- encryption and passwords;
- employee confidentiality agreements;
- restricted office access.
Our servers are protected by a firewall and are only accessible by authorized users using a password.
We reserve the right to change this policy. If any changes affect your rights, we will immediately notify you. You may access an up to date version of this policy at any time by contacting us via the contact form here.
IX. Individual Access
Subject to exceptions as permitted by law and subject to your written request, Siren will inform you of the existence, use and disclosure of your Personal Information and give you access to that information. You have the right to challenge the accuracy and completeness of your information and have it amended as appropriate. (See CCPA below regarding this right in California.)
X. Challenging Compliance
D. Correcting and updating your information
You may at any time correct or update any Personal Information which you have provided to us by contacting us via the contact form here. (See CCPA below regarding this right in California.)
E. Siren may monitor system usage
Siren has access to and may obtain information relating to the webpages which you view, the number of times you view them, the time and date of use, your IP address and cookie information. We may also have access to aggregate information such as number of associated users, number of transactions. We may use our access to such aggregate information to for the purposes of billing, monitoring server and software performance, improving our Services, and for other internal purposes.
Except as set out herein, Siren will never access the details of any user entered and stored in the Siren system. Siren will never access system usage history for a specific identifiable user, except where granted permission by the user to assist with resolution of a system issue or error.
F. Security of your Personal Information
The internet is not in itself a secure environment. Users should only enter Personal Information within a secure environment. This means that the user's browser must support the encryption security used in connection with Siren Servers.
G. Siren will give you access to your data at any time
On request, Siren will provide you with a summary of your Personal Information. You may request corrections to or deletion of your Personal Information at any time by contacting us via the form here. (See CCPA below regarding your right to these requests in California).
H. Your browser stores only enough information to keep you logged in
I. You can opt-out of any email communications
Siren may send promotions, surveys and regular customer newsletters to registered users via email. We may also send special advertising messages that we believe are relevant to our users. We may also from time to time send you a request to complete a survey to determine your level of satisfaction with our Services and to seek suggestions as to how we may improve our system.
Our email communications will contain clear and obvious instructions describing how the user can opt to be removed from the mailing list. You also may opt out at any time on this page. Siren will remove any user upon request.
K. Public Forums
Information which you post on any public forum, including a product discussion forum, chat room, blog or bulletin board, may be seen by the public. Third parties may be able to contact you using or through such forums. We take no responsibility and accept no liability relating to this contact.
L. California Privacy Law
I. Right to Request Information about Your Personal Information
Free of charge, you have the right to request for the last 12 months, and receive within 45 days (and in any event no more than 90 days):
(1) The categories of personal information we have collected about you;
(2) The categories of sources from which the personal information is collected;
(3) The business or commercial purpose for collecting or selling your personal information;
(4) The categories of third parties with whom we share your personal information;
(5) The specific pieces of personal information we have collected about you.
We must provide this information to you in a readily useable format that allows you to easily send the information to and between other entities, thus allowing you to “port” or move your personal information from us to another company offering similar services.
Under the CCPA, “Personal Information” includes, but is not limited to, identifiers such as a real name, alias, postal address, unique personal identifier (including cookies), online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. It does not include de-identified information or aggregate consumer information.
In the last 12 months, we have collected these categories of personal information from consumers:
- first name, last name, email, phone number and mailing address.
In the last 12 months, we have not sold any categories of personal information about consumers.
In the last 12 months, we have disclosed these categories of personal information about consumers for a business purpose:
- first name, last name, email, phone number and mailing address.
II. Right to Request Deletion of Your Personal Data
Free of charge, you have the right to request deletion of your Personal Information that we have collected from you. We shall comply with that request by deleting all of your Personal Information from our records and directing any service providers to delete your Personal Information from their records.
Some exceptions do exist to our duty to delete your Personal Information at your request. These are when your Personal Information may be needed to:
(1) Complete a transaction for which your Personal Information was collected, provide a good or service that you requested, or that we could reasonably anticipate within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
(3) Debug to identify and repair errors that impair existing intended functionality;
(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that follows applicable ethics and privacy laws, when our deletion of your Personal Information is likely to prevent or seriously impair the achievement of such research, if you have provided informed consent;
(7) To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
(8) Comply with a legal obligation;
(9) Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
III. Right to Disclosure of Categories of Personal Information Sold
Free of charge, you have the right to request for the last 12 months, and receive within 45 days later, the following information about the sale of your Personal Information:
(1) The categories of Personal Information that we have collected about you;
(2) The categories of Personal Information that we sold about you, the categories of third parties that we sold your Personal Information to, and the category or categories of your Personal Information that each third party purchased from us;
(3) The categories of your Personal Information that we disclosed about you for a business purpose;
(4) If we have not sold your Personal Information, disclosure of that fact.
IV. Right to Request that Personal Data Not be Sold
Free of charge, you have the right to opt out of the sale of your Personal Information. “Sale” means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating” your Personal Information by us to another business or a third party “for monetary or other valuable consideration.”
To make it easy for you to exercise your opt out rights, pursuant to the CCPA, we provide a link on the homepages of the Sites, titled “Do Not Sell My Personal Information”, to enable you to opt out of the sale of your Personal Information.
If and after you have directed that we not sell your Personal Information, we are prohibited from selling it until and unless you later expressly authorize us to sell your Personal Information.
The CCPA prohibits the sale of Personal Information of consumers under 16 years of age without express approval from the minor (between ages 13 and 16) or the minor’s parent or guardian (if under 13 years of age). Siren’s Sites do not knowingly collect from minors, much less sell, Personal Information of individuals under the age of 18 (see “Children’s Privacy” below). Siren may collect certain Personal Information about minors from their parent or guardian customers of Siren, solely for the purpose, and only as needed, to fulfill the Services that the Sites offer.
V. Right to Receive Equal Service and Pricing, Even if Exercising Your Privacy Rights
Pursuant to the CCPA, we cannot and will not discriminate against or penalize you for exercising your privacy rights. We will not:
(1) Charge different prices for our service;
(2) Provide a different level or quality of service to you;
(3) Suggest that you receive a different price for, or a different level or quality of, our service.
Provided, however, the CCPA does not prohibit differences in prices, levels or quality of service offered to users if the difference is reasonably related to the value provided to the consumer by the consumer’s data.
VI. How to Make Requests Regarding Your Personal Information
To request information about your Personal Information, to delete your Personal Information, to direct us not to sell your Personal Information, or for disclosure of the types of your Personal Information that we may sell, contact us at:
1. any of the Sites
M. Children's Privacy
Although the Sites are general audience sites, we restrict the use of our Services to individuals age 18 and above. We do not knowingly collect personal information from children under the age of 18. The only personal information we knowingly collect about minors is that which is received from their parent or guardian users of the Sites, and is collected and used solely for the purpose, and only as needed, of enabling us to fulfill the Services we offer. No information should be submitted through the Sites by individuals under eighteen 18 years of age. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
N. This policy may be updated from time to time
O. Changes of control or transfers of business
P. Contacting Siren