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Our privacy commitment
In support of Lucero Speaks’ mission to help teens, teens, and caregivers find sanctuary and experience a journey of self-discovery (we call this an “Exploration”) using our online wellness app and content, we are committed to protecting the privacy of our users and providing a safe, online environment. Lucero Speaks is committed to only collecting from Teen, Tween, or Caregiver Explorers (we describe in more detail the various users of our app below) the information needed to make each child’s Exploration their own and make it as good as possible and permit a Teen, Tween or Caregiver of a Tween to share progress of that Teen or Tween with any Explorer within that youth’s online group (“Crew”).
Lucero Speaks does not allow third-party advertising in an Exploration, and Lucero Speaks does not sell, lease, or otherwise trade for value any personal information of any App Users. App User information is only used to provide and improve our App. This Privacy Policy describes the way in which Lucero Speaks, LLC (who we call “Lucero Speaks,” “we” or “us”) collects, uses, discloses, and safeguards personal information provided to us by children, parents, caregivers, guardians and others (who we call “App Users” or “Explorers” or “you”) when they use our downloadable app or any other location that links to this Privacy Policy (we refer to this as the “App”). Table of Contents
We collect certain information from App Users, depending on the type of App User who is using the App. These are the types of App Users:
A Caregiver, Tween or Teen Explorer account will be linked to a Crew through invitation by a Crew Captain (and acceptance by the Caregiver, Tween or Teen). A Teen or Tween Explorer may or may not be linked to a Crew, as elected by that Teen or Tween Explorer. With respect to Tweens only, any parent or other legal guardian of a Tween, whether or not that person is a Caregiver Explorer, must approve a Tween creating an account and starting to use the App, and that parent or legal guardian can request access to the information in that Tween’s account. More information on each type of account can be found in our Terms of Use.
Information Collected From Users We collect information from App Users when they send it to us. For example, when you accept an invitation to join a Crew and create an account, provide a response to a prompt in the Exploration, or otherwise contact us with a customer support question, chat, comment, or request, we may collect and use this information you provide as more detailed below. If you submit any information relating to other people in connection with your use of the Services, you are telling us that you have the authority to do that and you permit Lucero Speaks to use and share the information in accordance with this Privacy Policy.
Teen or Tween ExplorersWe collect information about Teen or Tween Explorers when a Teen or Tween Explorer establishes an account, either by (i) being invited to join a Crew and to create an account by the Crew Captain (in the case of a Tween, with approval of the Tween’s parent or guardian, whether or not that parent or guardian is a Caregiver Explorer), (ii) when a Teen Explorer creates an account on their own, or (iii) when a Tween Explorer creates an account on their own with approval of the Tweens parent or guardian. We are committed to collecting the minimum amount of information about Teens or Tweens as is needed to operate the App. When a Lucero Speaks Teen or Tween Explorer account is created, we collect the Teen or Tween’s:
Teen and Tween Explorers will create their own unique username. Usernames are used to log in but are not visible to other App Users except for Tween and Teen Explorers and/or Caregivers within the same Crew. After creating a username, the Teen or Tween Explorer then selects a fictional avatar name and appearance from a list of options, which are the only ways that Explorers are differentiated within a Crew.
Caregiver Explorers
When registering with Lucero Speaks, Caregivers are asked to provide personal information consisting of email address, username, and a password for their account. Lucero Speaks may also collect from Caregivers the information listed under the Teen or Tween Explorers section above regarding Teen or Tween Explorers associated with Caregivers for purposes of linking the Teen or Tween and Caregiver accounts in the same Crew. As with Teen and Tween Explorers, Caregiver Explorers will create their own unique username, fictional avatar name and appearance from a list of options. For Explorers with a paid membership, we may also collect payment information. Note, Lucero Speaks does NOT directly store credit card information — all credit card information and transactions are stored by our third-party payment providers, such as the app store through which you purchased your membership.
Information Collected From Devices and Use of the App
Exploration Results
As Explorers use the App, we collect information on the features they interact with, social and emotional skills they encounter, and questions answered (“Exploration Results”). This information could include, but is not limited to, data on which activities an Explorer completes, Lucero Speak created content that Explorers can send back and forth — like an image that says “You are awesome!”, and log entries from their Exploration, such as “What I like to do when I feel happy” and “Things that help when I am feeling stressed”. As described further in the next section, we use Exploration Results to customize an Explorer’s Exploration and for analysis (but only after being de-Identified or aggregated as described below). Certain Exploration Results are shared with all Explorers in a Crew such as the number of spins on a feature called spark, what island/day an Explorer is on in an Exploration/Journey, and what badges they have earned. Other components of a Tween’s or Teen’s Exploration Results may be visible to their parent or legal guardian and made available by their parent or legal guardian to Caregiver(s) in the Crew to allow for monitoring of the Teen or Tween’s progress. Explorers each have the option to share other Exploration Results with other Explorers within their Crew, in addition to the basic Exploration Results we discuss above which are shared automatically with the rest of the Crew.
Device data and information collected by technology (e.g., cookies)
Like most websites and online services, Lucero Speaks automatically collect certain technical information from your computer or mobile device over time and across different websites when you use the App, such as your IP address, your browser type, your operating system, the pages you view on the App, the pages you view immediately before and after you access the App, and other information about your use of the App. All of this information may be collected through use of “cookies,” which are small text files that the App save on your computer using your web browser and access when you return, and other similar technologies, like “pixel tags,” which are pieces of code placed on a web page that can collect information about whether a User has been to a certain web page or clicked on a specific advertisement.
The information collected through these technologies includes information about the way you arrive at and use our website, products and services, including the pages you visit, the links you click, how frequently you access the product, or whether you open emails or click links contained in the emails we send you. It also includes information about high-level geographic location, such as a User’s state or region as approximated by the User’s IP address, for reasons such as associating a User with the appropriate Exploration, product improvement, and sending locally relevant marketing communications to Caregivers. We and our third-party providers also collect analytics data, for example through the use of tools such as Google Analytics, to measure traffic and usage trends for the website and to understand more about the demographics and behaviors of our Users. We also use third-party advertising providers to collect information about Caregivers who visit areas of the App that are not directed to Teen or Tween Explorers. This includes information used to deliver interest-based advertising to Caregivers, including advertising for our App, when those Users visit third-party websites, and provide us with statistics about the effectiveness of our advertising on third-party websites.
We and our third-party providers may use the information collected through these technologies for the purposes described in this Privacy Policy, including delivering content, analyzing our Users’ experience on the App, and delivering advertising to Caregivers when they visit other websites and applications. Cookies and these other technologies placed within the Lucero Speaks Game or within other areas of the App directed to Teen or Tweens will be used only in support of the Service’s internal operations, like providing access to the Games and their features, individualizing content, and improving and optimizing the App. We do not allow third-party targeted advertising providers to collect information from the Teen or Tween-directed portions of the App.
Information from Third Parties
We may obtain information about you or your use of the App from third parties and sources, such as our vendors, like single sign-on providers you can use to log into the App, web hosting providers, or analytics providers. In certain circumstances, you may give us permission to access your information from some of these services offered by third parties. The information we obtain from third-party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies. You are responsible for reviewing the privacy policies of these third parties and adjusting your settings to meet your preferences. When you access the App through third-party platforms, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.
How we use Caregiver information
We use the Caregiver information we collect for the following purposes:
How we use Explorer information
We use the Explorer information we collect for the following purposes:
No advertisements are delivered by Lucero Speaks to Teen or Tweens through the Service. How we use all User information We use all User information we collect for the following purposes:
De-Identified or Aggregated Information
From the information collected through the Services, Lucero Speaks may create de-identified or aggregated data. What this means is we remove certain identifiers and delineative features of the data collected that make it personally identifiable to a particular User so that it no longer allows a User to be directly or indirectly identified. We may use or disclose such de-identified or aggregated data for lawful and legitimate business purposes, including to analyze, build and improve the Services and promote our business. When we share such information, it will not be shared in a way that could be used to identify a User.
We only share information collected in limited circumstances. We do not disclose the personal information of Teen or Tweens to third parties for marketing or promotional purposes.
We share User information with third parties as follows:
The User information we collect is stored and processed in environments designed to allow only authorized individuals to access the infrastructure where this information is stored. Because we understand and respect the trust placed in us to properly protect your information, Lucero Speaks takes great care to maintain commercially reasonable standards of data security and protection and continues to implement those measures for our infrastructure where User information is stored.
Lucero Speaks and its service providers maintain strict administrative, technical, and physical measures designed to safeguard the information we process. We use industry-standard SSL encryption when collecting or transferring your information. Other safeguards include but are not limited to data encryption, firewalls, multi-factor authentication for our personnel with access to your information, and physical-access controls.
You can protect against unauthorized account access by selecting and protecting passwords appropriately, including using unique, multi-character passwords, ensuring devices are only accessed by those authorized to use them and taking care to sign out of online accounts (not just Lucero Speaks, but all online accounts) after you or your Teen or Tween Explorers are finished using them.
Access to information associated with User accounts is limited to those Lucero Speaks staff members who require such access to support our App, who are designated and trained to maintain the security and confidentiality of User information.
Access, correction or deletion of information
Caregiver Explorers have the right to access, correct or delete their personal information which is collected and used by Lucero Speaks. Personal information can be accessed and changed by contacting our customer support at support@lucerospeaks.com . You also can access and review certain account-related details by logging into your online account.
Caregiver Explorers of a Tween or a Tween may contact our customer support at any time to request access to, deletion of, or correction of any personal information we have collected from or about their Tween Explorer child associated with their account, including a request to us to cease collecting personal information from those Tween Explorers. Please be aware a request to delete or cease collecting personal information may lead to closing of the relevant User’s account or the inability to use the products or App or certain portions of the products or App. If a Teen who is 16 years old or younger is a citizen of the European Union, a parent or legal guardian of that Teen can also contact us for the above purposes.
When a correction, deletion or other change to Teen or Tween Explorer personal information is requested and validated, Lucero Speaks will make the correction, deletion or other change as soon as reasonably practicable and in accordance with privacy laws.
Upon request by an Explorer, we will delete the Explorer from the Crew.
Opting out of email communications
You can opt out of receiving commercial or promotional emails from Lucero Speaks by following the unsubscribe instructions indicated in the email, manage your communication preferences or by contacting customer service. Lucero Speaks communication preferences can be managed through our preference center, available through a link in the footer of our commercial or promotional emails, through which App Users can specify which types of communications they would like to receive.
California privacy rights
California law also grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:
If you are a California resident and would like to exercise any of these rights, please submit an email request to support@lucerospeaks.com with the subject line, “California Rights Request.” We may need to verify your identity before processing your request, which may require additional personal information from you, or that you log into your Lucero Speaks account. In certain circumstances, we may decline or limit the scope of our compliance with your request, particularly where we are unable to verify your identity or locate your information, or as permitted by law.
If you are submitting a request through an authorized agent, the authorized agent must provide us with your signed written permission stating that the agent is authorized to make the request on your behalf. We may also request that any authorized agents verify their identity and may reach out to you directly to confirm that you have provided the agent with your permission to submit the request on your behalf.
Users resident in the European Economic Area (EEA), United Kingdom, and SwitzerlandIf you are a resident of the EEA, UK, or Switzerland, the following information applies with respect to personal information (or personal data) collected through your use of our App. As noted above, Lucero Speaks processes personal information consistent with our disclosures in this Privacy Policy.
We process personal information on the following legal bases:
Note, the information we collect may be transferred, stored and processed in Canada and the United States or any other country where we or our processors maintain offices. We will work to make transfers of personal information to a third country or an international organization subject to appropriate safeguards under applicable law.
You are entitled to the rights under Chapter III of the EU General Data Protection Regulation and the UK GDPR, or Section 2 of the Swiss Federal Act on Data Protection concerning the processing of your information, which includes rights to access, correct, delete, restrict or object to our use of, or receive a portable copy of your personal information. You also have a right to lodge a complaint with your local data protection regulator. To make a request or otherwise exercise your rights, please contact us at support@lucerospeaks.com . To honor such a request, we will need to verify your identity and residency, which may require additional supporting information.
In our commitment to protect the privacy of children, Lucero Speaks does not ask for or require children to provide personal information beyond that which is reasonably necessary to support the operation of Lucero Speaks’ App.
Information collected from our Teen or Tween Explorers is never disclosed for third-party advertising or any kind of behaviorally targeted advertising. For information on how consumers can ask questions or file complaints related to Lucero Speaks’ Privacy Policy and practices, please email support@lucerospeaks.com .
Information collected through the App may be transferred, stored and processed in Canada and the United States or any other country where we, or affiliates, or our processors maintain offices, which may not provide the same level of protection for your personal information as your country, state, or province of residence, in which case it will be subject to and may be available to the government under the laws of that jurisdiction, including law enforcement, regulatory, and national security authorities.
We retain your personal information for as long as we have a relationship with you, although we retain the right to delete User accounts after a period of inactivity. After our relationship has ended, we also may retain your personal information for as long as required by law or to investigate or defend against potential legal claims.
If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page and updating the Last Modified date at the bottom of this policy. If we make any changes that materially change the ways we process or protect your information going forward, we will provide additional notification of changes. If we make any revisions that materially change the ways in which we use or share the information previously collected from you through the App, we will give you the opportunity to consent to such changes before applying them to that information.
If you have questions or concerns regarding the way in which your personal information has been used, please contact us at support@lucerospeaks.com , or by mail at 501 Congress Avenue, Suite 150, Austin, Texas, 78701.
Last Modified Date: November 25, 2022
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