Privacy Policy
Sites and apps from MLARAEST OÜ (hereinafter referred to as “BubuSpeech”, “we”, or “us”) are designed to inform visitors and link them to the best of what we have to offer on the platforms and gadgets they choose. Our Privacy Policy is made to be clear for visitors to explore, read, and comprehend while also providing transparency into our privacy policies and philosophies. We are committed to protecting and respecting the privacy of your personal information.
The goal of the app BubuSpeech is to use cutting-edge technology to better comprehend speech impediments and behaviors. Android devices, iPhones, and iPads can all run the research. In order to advance this technology and maybe create new screening and therapeutic tools for developmental and speech issues, BubuSpeech will use the data that families submit
1. About this Privacy Policy
The privacy of its users (hereinafter referred to as “you” or “user”), is respected by MLARAEST OÜ, with its registered office at 15551, Sepapaja tn 6, Lasnamäe linnaosa, Tallinn, Estonia (hereinafter referred to as “BubuSpeech”, “we”, or “us”). We think it’s critical for you to be well-informed when using our applications so that you can decide what information we collect through those applications, what we do with it, how we process it, who we share it with, and how you can exercise your rights and control over how that information is processed.
To make sure you are completely informed, we advise you to read this Privacy Policy in its entirety.
2. Types of data we collect
We may collect several types of information from you, including personal and non-personal information, as defined below and depending on the nature of your engagement with the Application, all of which is explained below.
Non-personal information is information that may be made available or gathered as a result of your use of the Application and may include aggregated usage information and technical information transmitted by your device, including certain software and hardware information such as: device brand, screen size, type of operating system, type of device, language preference, the time and date you access our Application, your actions within our Application (e.g., registration, pausing, etc.), the URLs that lead you to our Application, search queries within our Application, and so on, as well as your approximate geo-location (country).
Personal information is information that can be used to identify an individual or that can be used to identify an individual with reasonable effort. Personal information comprises information that you freely supply as well as identifiers such as your internet protocol («IP«) address.
Certain personal information about you is not needed by law. You can always refuse to supply some personal information, but you understand that doing so may preclude you from participating in certain activities within the Application.
If we combine personal and non-personal information, the combined information will be considered as personal information for the duration of the combination.
Please read below about the information we gather, why we collect it, and how we utilize it:
2.1. In order to use the application and related activities, you will need to sign up for a subscription through your app store account as a parent. We will use this information to carry out our contract with the parent and offer access to the Application’s specified activities.
2.2. If you contact us for help or other concerns, or if you post a remark by any accessible methods of communication, you will be expected to provide us with a valid email address, as well as your name. We will only use your information to respond to your enquiries directly and provide you with the service you have requested on a one-time basis.
2.3. If you willingly subscribe to our newsletter, we will require you to supply us with a valid email address. You may unsubscribe at any time by clicking the unsubscribe link in the newsletter’s body or contacting customer service at bubuspeech@gmail.com. We will use your email address to provide you information about our Application and to keep you up to date on new goods, related news, upgrades, and so on.
2.4. If you choose to register with or allow access to a third-party social networking or integrated service (hereafter referred to as “Integrated Service”), such as Facebook, Google, or Apple, we may collect personal information linked with your Integrated Service account. You may also be able to share extra information with BubuSpeech via an Integrated Service. If you choose to supply such information, whether during registration or otherwise, you are providing BubuSpeech with personal information that will be treated as such and used in line with this Privacy Policy.
2.5. GEO location info is approximate. We will only use this information to establish the user’s country and offer relevant content.
2.6. Prior to installing the application, you will be prompted to provide access to your device’s camera, storage, phone, and microphone. Certain aspects of the Application need access, such as allowing the user to access the camera through the Application and use the face detection or voice detection capabilities. We will not save or collect any voice records or photos stored on the device.
2.7. We also collect some technical non-personal information about your usage of the Application, such as the length of time you spent browsing specific sections of the Application, and so on. We use this technical non-personal information for the following purposes: operating, providing, maintaining, protecting, managing, customizing, and improving our Application and the way we offer them; enhancing the experience with the Application; auditing and tracking usage statistics and traffic flow, and detecting fraud, security, or technical issues in connection with the Application; perform research, for analytical and statistical purposes, to improve our Application.
As we need to collect more personal information in addition to the personal information listed above, we will submit a request to a parent and acquire consent prior to collection, as needed by relevant legislation. We may utilize aggregated, non-specific data for analytical purposes. This data is anonymous and will not be connected to any personally identifiable information. We may freely share such statistics information with our partners.
Truedepth API from Apple
BubuSpeech tracks the movement of your eyes and lips using the device’s TrueDepth camera technology. This enables a one-of-a-kind user experience – a game you can play with your face. This capability is only available since the app has access to your device’s camera. This access can be turned on or off at any moment in the settings of your device.
The camera pictures and depth data generated by them are solely used for gaming. The live video stream is never utilized, and the data it contains is never saved, either locally or remotely. To obtain depth data from Apple’s APIs, camera access is necessary.
This information is only retained on the device for the length of your current gaming session. The data is destroyed every time the home screen is displayed or the program is closed. This information is used to improve your gameplay experience and avoid accidental leaps.
Face data is never remotely stored, transferred to other parties, or utilized for non-game activities. The facial data is only stored on your smartphone and is never transferred to another device.
3. How do we collect data
We may gather the following information based on the nature of your engagement with the Application: automatically – BubuSpeech automatically collects information transmitted from the device; freely submitted by you – that is, if and when you choose to supply us with information, such as through a registration procedure, newsletter registration, contact us communications, and so on.
4. Information disclosure
WE DO NOT SHARE, SELL, RENT, OR OTHERWISE DISTRIBUTE ANY OF YOUR PERSONAL INFORMATION WITH OR TO ANY INDEPENDENT THIRD PARTIES, EXCEPT AS EXPRESSLY STATED BELOW:
4.1. Authorized Disclosures – When you consent to a certain disclosure, we may release personal information to third parties. Please keep in mind that anytime we share your information with another third party, your information becomes subject to the privacy standards of that other third party.
4.2. Business Transfers – If we sell our company or a portion of it, we may transfer our databases holding personal information. In that case, our connected or acquiring firms shall take on the rights and duties outlined in this Privacy Policy.
4.3. We may be required to share information (including personal information) collected if the information is required by law to prevent, investigate, or take action regarding illegal activities, situations involving potential threats to physical safety, rights, property, or of any person, suspected fraud and violations of our terms and agreements, and in response to legal process, court orders, subpoenas, or to establish or exercise our legal rights.
4.4. Business Partners, Service Providers, Affiliates, and Subcontractors. We may disclose information (including personal information) to trusted affiliates, personnel, licensors, contractors, service providers, subcontractors, and business partners who may use such information to assist us in providing the Application and related features to you. We permit these third-party service providers to use personal information exclusively to perform the services requested.
4.5. Identifiers. We may exchange identifiers in order to operate our company and provide the Application, which includes detecting fraud, security, or technical difficulties with the Application.
5. Retention of data
We maintain this obtained information for as long as it is required for the above-mentioned objectives, all in conformity with relevant laws, or until people express a choice to opt-out or delete their personal information. We reserve the right, in our sole discretion, to remove or modify information from our systems without notification if we believe it is no longer required for such reasons.
6. Personal information protection
We have put in place reasonable security measures to safeguard the confidentiality, security, and integrity of the information we collect, as well as to prevent unauthorized access and use of information in violation of this Privacy Policy. Although we make commercially reasonable steps to keep your information private while it is in our possession, please be aware that no security methods are perfect or impregnable.
7. Contests and surveys
We may run an e-mail survey or an online contest from time to time and gather traditional personal information, demographic information, usage information, and other materials that you freely submit to us for internal analysis, marketing, and brand development. Participating in a survey or an online contest is entirely optional. We will utilize the data to improve the usability of our services. The information acquired through surveys will be anonymised and aggregated. We may use information acquired through competitions to administer the contest and contact you in accordance with the terms and conditions of the contest.
8. Third party sites and services
This Privacy Policy only applies to information collected by BubuSpeech via the Application and does not extend to any other websites, apps, or services. Parts of the Application may include links to the use of third-party services such as icons, shortcuts, programs, or other ways of access. Though we make every attempt to examine such services and assure their suitability for our users, we have no control over Third-Party Services, and you use them at your own risk. We cannot assume responsibility for any such third-party services’ privacy policies, and we are not responsible for any content made accessible by them. BubuSpeech does not support any third-party services and advises you to use them with caution.
9. CCPA Rights (California residents)
If you live in California, You have the right to request access to, or that we delete, any of your private data at any point in the future. Please be aware that, where authorized by relevant legislation, we reserve the right to charge a nominal fee for access to and disclosure of your personal information, which will be informed to you. Under California law, certain data may be excluded from such demands. For instance, we may keep particular data for legal reasons and to protect our Services.
BubuSpeech does not “sell” personal information as defined by the CCPA. Nonetheless, BubuSpeech will fulfill any “opt-out of sale” requests received from our users and will take reasonable steps in order to avoid any additional downstream sales. BubuSpeech does disclose personal information in accordance with the terms of this Privacy Policy.
If you live in California and want to exercise your CCPA rights, please contact us at bubuspeech@gmail.com.
10. Outside the United States Users
The Application and its associated services are supplied, maintained, and hosted in the United States, and their operation is controlled by US law. If you use the Application and/or associated services from outside the United States, please be advised that your information may be transmitted to, stored in, and processed in the United States and other countries where we have operations. The United States’ data protection and other rules may not be as extensive as those in your nation. By using the Application and/or connected services, you agree that your information will be transmitted to our facilities as well as the facilities of the third parties with whom we share your information as specified in this Privacy Policy.
11. EEA residents
The EU General Data Protection Regulation (the “GDPR”) is set to come into force on May 25, 2018, throughout the EEA, Switzerland, and the United Kingdom. The GDPR compels BubuSpeech and those who use our Application to inform users about the processing of their “Personal Data.” Under the GDPR, “Personal Data” refers to data that identifies or can identify a specific unique person or device, such as names, addresses, cookie identifiers, Mobile IDs, exact location data, and biometric data.
11.1. Legal Basis for Personal Data Processing
The GDPR compels us to inform you of the legal basis on which we treat any Personal Data about you. The legal basis for us collecting your Personal Data for the reasons listed in Section 2 above is generally because:
- You gave your permission. We rely on your permission to store and access information stored on your device. We do so in order to comply with the ePrivacy Directive. We may opt to collect consent in other situations as well, in which case we shall follow any laws governing such consent and its withdrawal;
- Our legitimate interest is served by the processing. In some situations, we use legitimate interest as a legal basis for processing Personal Data in order to offer services to ourselves and/or other data controllers. This type of processing extends beyond the initial collecting of mobile IDs. For example, one legitimate interest on which we rely is preserving the security of our services, such as detecting fraud or ensuring that flaws are found and corrected;
- Contractual obligations. We may process sensitive data as required by a contractual agreement (such as our client records and contact information);
- Legal responsibilities. Furthermore, certain data processing may be required in order for us to meet our legal or regulatory requirements.
11.2. Transfers of Personal Information
We may need to move your personal information outside of the jurisdiction from which it initially originated since BubuSpeech collaborates with worldwide firms and technology. For example, we may transmit your data to third parties with which we collaborate who are situated in jurisdictions other than the EEA, Switzerland, or the United Kingdom and who have no or less stringent laws regarding data protection than those in Europe.
We take efforts to ensure sufficient protections are in place to secure your Personal Data when we send it outside of the EEA, Switzerland, or the UK. For further information regarding the protections we have set in place to protect your private information and privacy rights in these cases, please contact us at the address shown below.
11.3. Retention of Personal Data
In general, we keep your Personal Data for as long as it is required to perform our services or for other significant reasons such as complying with legal responsibilities, resolving disputes, and enforcing our agreements.
11.4. Your Data Subject Rights
The GDPR grants you certain rights in relation to Personal Data held by data controllers about you, including the right to access Personal Data, request correction of Personal Data, request restriction or deletion of Personal Data, and object to the processing of your Personal Data.
- You have the right to object. You have the right to object to the processing of personal information about you based on legitimate interests. You may always opt out of future personal information gathering by us and our partners by uninstalling all Applications from all of your devices.
- You have the right to acess.You have the right to know what information we have on file for you and, in some situations, to have it disclosed to you. If you desire to exercise your right, please contact us and let us know that you wish to exercise your right of access and what information you would like to obtain in particular. We retain the right to request adequate proof of your identification before providing you with any information. Please keep in mind that we may not be able to share all of the information you request, for example, if it involves personal information about another individual.
- Right to have personal information corrected. We make every effort to ensure that the information we have on file for you is correct and up to date. If you discover that any of the data we have on file for you is wrong, please contact us at bubuspeech@gmail.com and we will fix it as quickly as possible.
- Data removal. You have the right to request that we delete any personal information we have on file for you. If you want to do so, please email us at bubuspeech@gmail.com. We retain the right to require additional data to verify your identity before proceeding with your request. We will erase the personal data you requested us to remove as soon as we get all of the information we need to identify you, but we will always do so within one month of receiving your request and verifying your identification. Please keep in mind that we may nevertheless keep part or all of such information, for example, in order to comply with our legal responsibilities and to defend or enforce legal rights. We may also save your information anonymously.
- The capacity to move data. In some cases, you may request that we give you the personal data you have submitted to us so that you can transfer it to another data controller. If you want to do so, please email us at bubuspeech@gmail.com.
- Processing limitations. In some situations, you may be able to request that the processing of your personal data can be restricted.
- The ability to file a complaint. You have the option of filing a complaint against us. In order to do so, consult the regulatory authorities in your own country.
12. Questions or complaints
If you have any questions or concerns regarding the use or sharing of your personal information, please contact us at bubuspeech@gmail.com. Within 45 days of receiving your complaint, we shall investigate and endeavor to settle any complaints or disputes involving the use or disclosure of personal information.
13. Changes in this Privacy Policy
This Policy may vary from time to time, and if there are significant changes, we will post the modified terms and inform you through email. Amended conditions will apply to new users immediately and to existing users 10 days after they are posted. You should examine the Privacy Policy on a regular basis to stay up to date on any changes. You agree that displaying an updated Privacy Policy as real notification to you is acceptable. Continued usage of the Application following the posting of any modifications to this Privacy Policy as of the “Last Updated” date below (or, if appropriate, notification) indicates your acceptance of such changes.
If you disagree with the new Privacy Policy, please discontinue using our Application and inform us at bubuspeech@gmail.com.
14. Contact information
Please contact us at bubuspeech@gmail.com if you have any complaints or concerns regarding our Privacy Policy or
MLARAEST OÜ
15551
Sepapaja tn 6
Lasnamäe linnaosa
Tallinn
Estonia
MLARAEST OÜ, LAST UPDATE AUGUST 2023