Privacy Policy for KeepOn App

Last Updated: 7 January 2025

1. Introduction

Welcome to KeepOn, a mobile application developed by InsularCode Ltd. that helps guardians monitor children and elderly dependents by providing real-time updates on their safety, location, and device status. This Privacy Policy outlines how we collect, use, disclose, and protect your information in compliance with the legal requirements of the United States (including the Children's Online Privacy Protection Act (COPPA)) and Europe (in accordance with the General Data Protection Regulation (GDPR)).

By using KeepOn, you agree to the collection and use of your data as described in this Privacy Policy. If you do not agree, please do not use the app.

2. Data Collected

We collect the following types of data depending on whether the device is being used by a guardian or a dependent:

• From Guardian Devices:
  • Email address (mandatory)
  • Password
  • Phone number (optional)
• From Dependent Devices:
  • Location data (background and real-time): Used to notify guardians when dependents enter or exit predefined locations.
  • Battery status: Used to alert guardians about low battery levels on dependent devices.
  • Installed apps: Used to manage which apps can be blocked based on parameters such as location, battery status or time on screen.
  • Web Activity: Details of websites visited by the dependent device for web filtering purposes.
  • Messaging Data: Captured text from messaging apps for safety alert purposes.

In addition, the dependent's name and location labels (e.g., "Home," "School") are set by the guardian during the pairing process.

3. Legal Basis for Processing

We process your personal data based on your consent, as provided during the account creation process. By agreeing to this Privacy Policy and the associated terms, you consent to the collection, processing, and use of your personal data as described herein. You have the right to withdraw your consent at any time, and such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

4. Purpose of Data Collection

We collect and process data for the following purposes:

• Providing core functionality of the KeepOn app.
• Monitoring dependent device battery levels and location.
• Blocking apps based on predefined rules (e.g., low battery, excessive screen time).
• Web Filtering: Notifying the guardian when the dependent navigates to websites containing content such as pornography, drugs, violence, and other harmful topics.
• Safety Alerts: Analyzing text on messaging apps and alerting the guardian if the content relates to sex talk, love talk, bullying, suicide, or similar concerning topics.
• Push Notifications: Sending relevant notifications (e.g., when a dependent enters or leaves a location or their battery is low) via Firebase, using location labels rather than precise coordinates.
• Complying with legal obligations.
• Enhancing app performance and user experience.

5. Data Sharing and Processing

We do not share your data with third parties for marketing, analytics, or advertising purposes. However, we use Firebase for push notifications, and the content of notifications (e.g., dependent’s name, battery level, and location labels) is shared with Firebase only for delivering these alerts.

6. Data Retention

We only retain the latest 25 records per dependent device. Older records are automatically deleted when new ones are added. If the guardian chooses to delete the dependent device from the app, all data associated with the dependent is permanently deleted. After the retention period, all personal data is securely deleted or anonymized.

7. User Rights (GDPR and CCPA Compliance)

As a user, you have the right to:

• Access: your personal data.
• Update: or correct your personal data (such as updating the dependent’s name).
• Delete: your data (e.g., by removing the dependent’s device from the app).
• Restrict: or object to the processing of your data.
• Data portability: Request a copy of your data in a machine-readable format.
• Withdraw consent: You have the right to withdraw your consent for data processing at any time. You can do this through the My Profile Page by clicking on Privacy Center and unchecking the consent checkboxes. By withdrawing consent, KeepOn will no longer process the personal data of the dependent's device, and the accounts of both the dependent and guardian will be permanently deleted.

To exercise these rights, please visit the "My Profile" page in the Support section of the app or contact us at support@keepon-app.com.

8. Security Measures

We take data protection seriously and have implemented the following security measures:

• Data is transmitted securely between the dependent’s device, the server, and the guardian’s device using a secured Web API with HTTPS.
• JWT authentication is used to ensure that only authorized users can access data.
• Guardian devices are protected with biometric authentication (e.g., fingerprint) or a PIN for accessing the app.

9. Children’s Privacy

We comply with the Children's Online Privacy Protection Act (COPPA) in the U.S. and GDPR in Europe. Guardians must confirm they are 18 years of age or older during account creation and consent to the collection of their dependent’s data by checking appropriate boxes during the account creation process. The app may collect information from children under the age of 13 (in the U.S.) or 16 (in Europe) when the guardian installs the app on their dependent’s device. Guardians must pair their device with the dependent’s device and manage their data accordingly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will notify you via the app or email of any significant changes. Please review the policy periodically to stay informed about how we are protecting your data.

11. Contact Information

If you have any questions or concerns regarding this Privacy Policy or wish to exercise your rights, please contact us at:

Email: support@keepon-app.com

Company: InsularCode Ltd.

12. Data Transfers

If your data is transferred outside the European Union or the European Economic Area, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable laws.

13. Data Breach Notification

In the event of a data breach that may affect your personal data, we will notify you without undue delay and in accordance with applicable laws.

14. Cookies and Tracking Technologies

If we use cookies or similar technologies, we will inform you about the types of cookies used, their purpose, and how you can manage your cookie preferences.

15. User Responsibilities

As a user of the KeepOn app, you are responsible for maintaining the confidentiality of your account information, including your email address, password, and any biometric data used for authentication. You agree to:

• Secure Your Account: Ensure that your password is strong and not easily guessable. Do not share your account credentials with anyone.
• Notify Us of Unauthorized Use: Immediately inform us if you suspect any unauthorized access or use of your account. We will take steps to investigate and address any reported issues.
• Log Out After Use: Always log out of your account when using shared or public devices to prevent unauthorized access.
• Keep Your Device Secure: Use device security measures (e.g., screen locks, biometric authentication) to prevent unauthorized access to your personal information and account.

We are not responsible for any unauthorized access to your account resulting from your failure to maintain the confidentiality of your account information.

16. Right to File a Complaint

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority.

17. Effective Date and Review Cycle

This Privacy Policy is effective as of 7 January 2025. We will review and update this policy regularly to ensure compliance with legal requirements.