Privacy Statement

This is a privacy policy for Tweekaboo. Our website is located at http://www.tweekaboo.com

Tweekaboo is owned and operated by Tweekaboo Ltd. We are a company limited by shares which is registered in the Republic of Ireland.

Our registered office/place of business is at:
Unit 7 South Ring Business Park
Kinsale Road
Cork
Co. Cork
Ireland

We are the Data Controller for all personal data which is processed through this site.
We invite you to contact us if you have questions about this policy.

Reviews & Updates

This Privacy Statement has been prepared for the BETA release of TWEEKABOO.com. It is effective from and is under regular review as part of beta testing.

We conduct regular reviews of our Data Protection Policies and Privacy Statement as part of a best practice approach to information governance.

Our reviews are conducted:

  1. Annually, or
  2. As part of the implementation of new products, services or features through the site, or
  3. In response to customer feedback, or
  4. In response to feedback or input from the Office of the Data Protection Commissioner
  5. In response to changes in legislation.

Notification of Changes

When changes to our Privacy Statement are proposed, we will communicate the proposed changes to our customers in advance for their reference and to allow for questions or comments to be raised. The changes will be communicated to the account owner

By signing up to the service you consent to receiving email communications relating to changes to Terms and Conditions and Privacy Statements

Continued use of the service after a change in Privacy Statement will constitute acceptance of the revised Privacy Policies.

When we collect information from you, we tell you what we intend to do with it; if we later want to use that information for a different purpose, we shall first send you an email setting out our plans - and it will be up to you whether or not we do so

What data we are collecting and what we will use it for

We aim to meet the highest standards in how we manage and protect the personal data you provide to us to deliver our services to you. We are the sole owner of any information we collect. We never sell, share, or rent this information unless we first disclose the fact in this privacy statement.

We process data for the following purposes:

Creating Your Account

We collect the following personal information during the initial site registration process:

Information Required/Optional
Your First Name (Given Name) Required
Your Family Name Required
Your email address Required

We use this data to create the Account Owner Profile. This Account Owner Profile will automatically be created as one of the “Parent” roles for any child profiles created under this account.

Your email address will be used as your login to the Tweekaboo platform.

Creating a “Parent Profile”

When you have registered and provided your contact details (see “Uploading Photos and other content from your Phone” below) you will be able to create and edit your Parent Profile.

In this you will be able to provide information about your parent role (e.g. “Mom”, “Dad”). This is mandatory information at this time. You can also upload a photograph of yourself for your Personal Profile.

Information Required/Optional
Parent Role Required
Photograph Required

Creating “2nd Parent” Login

The Account Holder can invite another person to have a “parent” role in the Tweekaboo account for their partner or another person. This is done by the Account Holder providing certain information to allow us to generate an invitation to the other party.

Information Required/Optional
Parent 2 First Name (Given Name) Required
Parent 2 Family Name Required
Parent 2 Family Name Required
Parent Role Required

The email address provided here will be used as the user login for the second Parent role holder in your Tweekaboo account.

Creating Family Profile

Tweekabo is built around the idea of a “Family” grouping. Therefore we capture an amount of information which can identify a family group. Apart from the basic “Family Name” (which is a free text label for your Family group) we capture some basic information about where your family entity is located so we can correctly apply relevant Privacy regulations that might apply outside the EU.

We also allow you to upload a “Family Photo”. This can be any image, like a Family Crest or a family group photo. It is an optional item on your family profile and will be visible to other tweekaboo users who you invite to connect with your family for sharing content on the tweekaboo platform (for example, family or friends).

Information Required/Optional
Family Name Required
Country Required
State/County Required
Family Photo Required

Creating a Child Profile

Tweekaboo’s core mission is to help you record and share memories for and with your children. To that end we allow you to create a profile for each of your children. We capture the minimum necessary information to start creating that profile.

Information Required/Optional
Child first name Required
Gender Required
Date of Birth Required
Profile Photo Optional

Related uses we will put this information to would include:

Profile photographs of children will not be shared with people other than the Account Holder (Parent 1) and the second created Parent role.

Inviting Family & Friends

Family and friends can become part of your Tweekaboo network. You do this by inviting them to join via Tweekaboo.com. At a minimum we require their name and an email address to create their basic user profile.

Uploading Photos and other content from your Phone

We provide two mechanisms to allow you to upload photographs and other content from your mobile phone.

iPhone users can use the tweekaboo iPhone app. In order for the application to function, we require you to provide your account login credentials in the application. This will then allow the iPhone app to upload directly to your account based on your unique system generated user ID.

For other scenarios, you must provide the following information

Information Required/Optional
The email address you would be sending from on your phone Required
Your main mobile phone number Required
A second mobile phone number Optional

We use these two pieces of information to ensure that content you email to us from your phone (or phones) is associated with the correct account on our service.

This information is displayed to you in your “Parent Profile” so you can easily edit it and keep it updated.

Email Marketing

We will use information provided at registration to generate targeted email marketing messages about activities on the site and various offers and promotions from Tweekaboo or our partners.

Emails may be targeted to

We may make use of the “State/Country” field value associated with the Family Profile to assist in matching email recipients with appropriate messages, activities, and offers.

Recipients will be able to opt-out of these communications by selecting options in their Personal profiles. Every email we send will contain a link that will allow individuals to do this and you will be able to make the changes at any time via your personal profile on Tweekaboo.

Processing of Data relating to Children under 13

By the nature of the services which are offered by Tweekaboo it is necessary to process data relating to identifiable persons under the age of 13. This processing is conducted under the following principles:

  1. We recognise that children, regardless of age, have defined rights under EU Data Protection law. As Tweekaboo is an Irish operated service, the relevant legislation is the Data Protection Acts 1988 and 2003. Other jurisdictions may impose additional obligations which we endeavour to comply with as a matter of good practice but without surrendering to the laws of such jurisdictions.
  2. We appreciate that parents and guardians may wish to exercise controls and restraint over the processing of personal data relating to children
  3. Personal data of children which is processed in Tweekaboo will be done at all times with the full knowledge and consent of an identified and identifiable parent. It is not possible, at this time, for the child or a 3rd party to upload content for processing.
  4. At a point in time (at age 13) the child will be given full access to view, amend or delete personal data held about them but will not be able to upload, share, or otherwise broadcast their personal data without approval from a “Parent” role.

Any questions or queries about our approach to supporting the privacy rights of children should be directed to support@tweekaboo.com

Sharing Content on Facebook and other Social Networks

All content uploaded to Tweekaboo is private by default. However, Tweekaboo may provide the facility for you to publish content from your Tweekaboo network to Facebook, other Social Networks, Twitter or via Email should you wish to do so. You will ALWAYS be required to give consent to the sharing of content or personal data in this way.

It is important that you understand that Tweekaboo cannot take any responsibility for where data is shared or with whom it is shared once it has been published outside of our controlled Tweekaboo community.

In general we would advise you to familiarise yourself with the Privacy policies and privacy controls of any 3rd party social network on which you are sharing information about you or your family, irrespective of your use of Tweekaboo.

Feedback and Comments

To send us a message using our feedback forms we collect your name, email address and comments. At your option we may also collect your postal code. This data will be used by ourselves and our agents for contacting you.

Online Polls and Surveys

From time to time we may run on-Iine polls or surveys about issues affecting parents, families or children, or about the services we are offering on Tweekaboo.

If you wish to participate in an online poll or survey, in addition to your answers, we collect your Internet Protocol (IP) address. This data will be used by ourselves and our agents to help validate the results and help prevent multiple entries from individuals. In addition to this a cookie will be placed on your system after participating in a poll or survey. No identifiable information will be stored in this cookie.

Marketing by 3rd parties

Tweekaboo uses revenue generated from advertising by 3rd parties to help us offer our services to you. Tweekaboo will use anonymised data about you and your family group to allow advertisers to target offers and promotions to you. We will never share personally identifying data with 3rd parties without your express consent.

The data which will be used to support marketing would include:

Personal contact details such as email or telephone numbers will never by shared with 3rd parties by us without your clear and informed consent.

Purchasing goods and services through the site

Tweekaboo is constantly developing partnerships with providers of goods and services which might be of interest to or of use to families in our network. In certain circumstances we will support the purchase of goods from 3rd parties through our site (e.g. purchasing of birthday cards or personalised gifts). This may necessitate the transfer of personal data about you and/or your children to allow that transaction to take place.

We will seek your consent for the transfer of data at each instance so you can be sure of the data that is being transferred and why.

Cookies

Cookies are a technology which can be used to provide you with tailored information from a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. Cookies are usually stored as text files (with a filename in the format “cookie_name.txt”) but some Adobe Flash based services can write cookies in a different format.

Our site makes use of cookies. Cookies are used for the following purposes:

You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. You can also delete cookies from your computer using your web-browser or your file system (e.g. windows explorer).

You can control Flash cookies using this tool that can be found on the Adobe website.

To learn more about how to control cookies from this (and other) websites you can visit AboutCookies.org.

Web Bugs

Web bugs are small graphics on a Web site or in a HTML-Email message that enable the creation of log-files. These files are exclusively used to collect information on the usage of the Web site. Web bugs are often invisible to the user because they are typically very small and have the same colour as the background of the Web page or Email message. They are usually present as a file which is 1 pixel by 1 pixel in size, with a file name similar to “1x1.gif”.

Tweekaboo and/or advertisers on this site may make use of Web Bugs for the purposes of tracking your interaction with the site. No personal identifying data will be shared in the course of that tracking. We will make every effort to minimise the use of these web bugs to the minimum necessary.

Log Files and Statistics

We use IP addresses, URI's of requested resources, timestamps and HTTP user-agents to analyse trends, administer the system and gather broad demographic information for aggregate use.

In addition to this we use Google Analytics, a web analytics service provided by Google, Inc ("Google"). Google Analytics uses cookies, to help analyse how visitors use our site. The information generated by the cookie about the use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for Tweekaboo.com and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your Web browser, however please note that if you do this you may not be able to make full use of our website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Links

Our website links to other sites, but we shall always try to warn you when this is the case. Please note that we are not responsible for the privacy practices of other sites: make sure you read their privacy statements if you are concerned about the information they are collecting about you. This statement only applies to our website.

Security

We take every precaution to protect your details. When you submit sensitive information via the website, it is secure both on its way to us and once we receive it. For instance, our membership and donation forms encrypt your credit card number using encryption technology called -- 'secure socket layers' or SSL. If you use Netscape Navigator or Internet Explorer, you can tell whether a page is secure by checking whether there is a locked padlock or key in the right corner of your browser. The URL of the page you are viewing will also begin with https://.

We also do everything in our power to protect your information once we have received it. Our staff can only access your details if they have a specific job to perform, such as dealing with an account enquiry or taking actions necessary under the Terms and Conditions which govern this site. They also have to keep up to date on our security and privacy practices.

Tweekaboo hosting services are provided an Irish registered company utilising servers which are located in the Republic of Ireland.

Please note that the hosting of the tweekaboo.com website and/or personal data submitted by users may be moved to other providers for operational or security reasons. Such changes will be flagged by tweekaboo in an update to our Privacy Policy.

Supplementing Information

We take our responsibilities to protect you from fraud very seriously. To fulfil this obligation, we sometimes may have to supplement the information you give us with information from third party sources – for example, in order to make sure that no-one else is using your credit card. We do not keep this information any longer than we have to.

Correcting/Updating Information

We recognise that details such as your mobile phone number, address, or email address are bound to change over time. Likewise, we recognise that family units can often encounter difficulties which require information to be amended or deleted.

We provide mechanisms through the website to enable individuals to update their own information. You can also submit a request via support@tweekaboo.com if you can’t find an option to make the correction you require or if you need to have a bulk update of data done.

When you submit a request to us via support@tweekaboo.com we will contact you to verify your identity and confirm your authority to make the requested changes. This is done to ensure we are meeting our obligations under the Data Protection Acts 1988 and 2003 to keep data safe and secure and is not intended to cause offence.

Choice/Opt Out

You will always be able to opt out of having your information used for any purpose other than that specifically related to the page where we ask for it. Any mailing lists which you may sign up for through this site will allow you to opt-out of contact.

Likewise, other than communications to the Account Holder or their nominated representative which are necessary for the operation of the site in accordance with our terms and conditions, any member of Tweekaboo.com can opt-out of communications from the site at any time.

Disclosure of Data

Under normal circumstances, Tweekaboo will not make any disclosure of data you provide to any 3rd party. However we will do so:

Right of Access

The Data Protection Acts grant a Right of Access to Personal Data to individuals.

To enquire about Processing

To enquire if we are processing data about you, please send an email to support@tweekaboo.com with the subject line: “Are you processing data about me?”. You will need to provide some personally identifying information in that email to enable us to conduct enquiries in our database. You may be contacted by a representative of Tweekaboo.com to discuss your request and verify your data.

To request a copy of Personal Data

To request a copy of data which we hold about you please send an email to support@tweekaboo.com with the subject line “I would like a copy of the data you hold about me”. You will need to provide personally identifying information to enable us to process your request. You will be contacted by a representative of Tweekaboo to confirm your identity.

We may decline to process your request if we are not satisfied that we can confirm your identity sufficiently to avoid the risk of disclosing data in error. Data can only be disclosed to the individual to whom the data relates. As a result personally identifying data relating to other people (even if they are family members) will be redacted from copies of data we provide to you where it is reasonable and possible to do so.

We will charge the statutory fee of €6.35 for each request for a copy of data. Payment must be made in advance of the data being provided to you.

To request that data be deleted, corrected, blocked from processing, or destroyed

To request that data be deleted, blocked, corrected or destroyed you should send an email to support@tweekaboo.com with the specific request in the subject line (i.e. “Please delete data about me from Tweekaboo”). You must provide enough information in your request for us to be able to identify you.

You will be contacted by a member of the Tweekaboo support team to discuss the nature of your request and confirm the action which you wish to have taken on your behalf.

Customer Feedback

It is important to us that our customers are able to trust our use of their treasured memories. We welcome your feedback on this Privacy Policy and on the functionality and services available on Tweekaboo. We will use this feedback to support continuous improvement of our approach to Privacy and the way Tweekaboo works for you.
You can email your feedback to support@tweekaboo.com