Sago Sago (owned and operated by Spin Master Ltd.) is committed to protecting your privacy. While our apps are designed for young kids and parents, the websites we own and operate (www.sagomini.com, www.sagominibox.com, www.tocalifebox.com) are intended for adult use only. We take privacy seriously at Sago Sago and this policy is designed to share the information we collect and how we use it.
Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification
Sago Sago (owned and operated by Spin Master Ltd) is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates Sago Sago has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process.
If you have questions or concerns about our privacy practices, please contact us at (416) 703-6459 or email@example.com. If you have further concerns after you have contacted us, you can contact PRIVO directly by emailing firstname.lastname@example.org.
Information We Collect
We collect the following personal data from parents and grownups:
- Name (screen or nickname)
- Billing address
- Shipping name and address (physical subscriptions only)
- Phone number
- Payment details
- Email address
We collect the following non-personal information when you install and/or use one of our apps:
- Unique device identifier
- IP address
- Browser type and version
- Mobile phone carrier
- Game progress
- Time spent playing
How We Collect and Process Your Information
We collect and process personal data when parents and grownups voluntarily:
- Register for an account with us online
- Subscribe to one of our physical or digital subscriptions
- Pay for one of our services or products
- Complete a customer survey or provide feedback on any of our products
- Subscribe to a newsletter or alert
- Request technical support
When parents and grown-ups create an account in any apps that offer a registration, the same login credentials can be used across all services.
Subscription services may offer different features
We collect and process personal data from parents and grown ups using the following third-party services for functions such as technical support, transactional (i.e., shipping notices) or marketing emails, order management, and payment processing:
- Amazon Web Services (aws.amazon.com/privacy)
- Avalara (avalara.com/us/en/legal/privacy-policy.html)
- Chargebee (chargebee.com/privacy)
- dotDigital (dotdigitalgroup.com/privacy-policy)
- GiftUp (https://help.giftup.com/article/40-privacy-policy)
- Google Maps - Places API (https://policies.google.com/privacy?hl=en)
- Helpscout (helpscout.com/company/legal/privacy)
- SendGrid by Twilio (twilio.com/legal/privacy)
- Shopify (physical subscriptions only) (shopify.com/legal/privacy)
- Stripe (stripe.com/privacy)
We collect and process non-personal data when you:
- Use our websites
- Use our apps
We may receive your non-personal data indirectly from the following third-party analytics providers. These third parties do not share your user data; they are used to support the operation of our apps (respective privacy policies are noted below).
- Mixpanel (mixpanel.com/privacy)
- Unity (unity3d.com/legal/privacy-policy)
- Firebase Crashlytics (policies.google.com/privacy)
We use the following third-party analytics providers in relation to parents only:
- Facebook Analytics (facebook.com/policy.php)
- Google Analytics (policies.google.com/privacy)
- Firebase Analytics (policies.google.com/privacy)
We use Appsflyer (appsflyer.com/privacy-policy) attribution platform to record installs of our apps in relation to the parent experience, as well as to track in-app events in the parent’s section of our apps.
We use OneSignal to send push notifications in the Sago Mini School Parents app (onesignal.com/privacy_policy).
How we Collect and Process Children’s Information in our apps
We collect non-personal data indirectly from the following third-party analytics providers. These third parties do not share your user data; they are used to support the operation of our apps (respective privacy policies are noted below):
- Mixpanel (mixpanel.com/privacy)
- Unity (unity3d.com/legal/privacy-policy)
Some of our apps allow children to create content in our apps that may include images, audio or video. In all apps except Sago Mini School, this content is saved locally to the device and is not saved on a server.
Sago Mini School collects user generated content from children, including drawings and audio recordings, and saves them on our servers to display back to parents in the Sago Mini School Parent’s app. This content is not shared publicly at any time.
The Sago Mini First Words app requests parents optionally provide information about their child’s speech level, diagnosis and if the child attends speech therapy. This information is saved locally to the user’s device and used once to assign appropriate speech exercises. Once the child’s level is set, this information is deleted from the device.
Sago Mini First Words uses TrueDepth camera: During the exercise, we may use ARKit with front-facing TrueDepth camera if your device is compatible. ARKit face anchors are used in order for the face filters to work and move with the user's face. We do not use the TrueDepth camera directly. We use TrueDepth camera only for face tracking and do not collect or store this data. Our usage of TrueDepth camera is limited to iOS ARKit FaceTracking API and due to API limitations, we cannot remove TrueDepth camera usage from Sago Mini First Words.
If a parent purchases the physical subscription box on behalf of a child, they additionally provide:
- Child’s first name
- Month and year of birth
- Information about the child’s interests, if they choose to do so
How We Use Your Information
We use the information we collect to:
- Process your order(s) and manage your account
- Provide technical support
- Understand your use of our sites and apps
- Help us operate, analyze, and improve our sites and services
- Contact you about new services and features
- Send push notifications if consent has been given
- Let you know about specials offers on other products we think you might like
How We Store Your Information
Sago Sago uses generally accepted security measures and safeguards to keep the data it collects secure. We require that the third parties we work with do the same.
These measures and safeguards include:
- Limiting access to the data to those persons who need it to complete their work for Sago Sago
- Using a fire-wall protected environment
- Storing personal information in secure operating environments
Sago Sago cannot and does not guarantee and does not accept liability for unintentional disclosure.
Where We Store Your Information
The information we maintain may be stored both within and outside of the United States and Canada. As part of the services and products we offer and the third-party services we use (e.g., payment processors), the information you provide to us may be transferred to countries outside these areas.
If we transfer your information outside of these areas, we will take appropriate steps to ensure that any personal data relating to you will continue to be adequately protected. By using our sites and services, you consent to such transfer(s) as necessary.
Privacy Policies of Other Websites
Your use of Sago Sago’s sites and services may also be subject to the terms and conditions and privacy policies of other services that Sago Sago doesn’t control. This includes mobile application stores, mobile software platforms, online social media sites, and payment processors.
How to Update or Remove Your Information
Sago Sago keeps your content for as long as necessary to provide its services. If you want to opt out of services, or review or delete you or your child’s information, please contact us at email@example.com.
Notice to California Residents
To make such a request, please send an email to firstname.lastname@example.org.
As you can see, we collect minimal personal data from parents and grownups who wish to provide it, and some non-personal data for internal use only or in conjunction with third parties to help us operate, analyze, and improve our sites and services. In addition, we may disclose your personal or non-personal information to additional parties if we believe we are required to by law, by a judicial proceeding, to protect Sago Sago’s rights and properties, or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose Sago Sago or a user of its services to legal liability.
In addition, Sago Sago may disclose your information in the event of a change or proposed change in the ownership of the company; for example, a sale, a merger, or a bankruptcy.
This policy was last updated November 5, 2021.
How to Contact Us
If you have questions, please contact us at email@example.com.
You can also write to us at:
Sago Sago Toys Inc.
487 Adelaide St. W., Suite 301
Toronto, ON M5V 1T4 CANADA