COPPA Notice

Pocketalk offers handheld interpretation and translation devices to consumers, businesses, and schools. When Pocketalk offers devices and services to schools, students who use Pocketalk devices through their school can include users under 13 (hereinafter, “children” or “child”. This notice supplements our Privacy Policy and is meant to help schools and parents and guardians understand what personal information we collect from children) and how we use and disclose that personal information when schools use our Pocketalk devices and Pocketalk Ventana administrative portal.

The Children’s Online Privacy Protection Act requires that we obtain verifiable parental consent before we collect personal information from children but permits us to obtain such authorization from schools where children use our products and services through their school. We rely on the schools that use our devices and services to authorize the collection, use, and disclosure of children’s personal information on parents’ behalf. We will not collect, use, or disclose children’s personal information if the school does not authorize or withdraws authorization of such collection, use, or disclosure, or if the school communicates that the children’s parents do not consent to the collection, use, or disclosure of the children’s personal information.

Personal Information We Collect

Upon receiving school authorization to collect personal information from children, we collect the following information:

Information children provide directly. We will collect personal information children provide to us and to schools who use our service. For example, when children use our devices to translate speech, texts and/or voice audio streams are sent to our vendors who recognize speech and convert the speech to text and translate the text to the desired language. The text is then sent to the child’s device and a copy is sent to a portal hosted by our vendors that school administrators may review and access.

Information we collect automatically. When children use the devices through services we provide to their schools, the servers and other systems that we use to provide these services automatically collects International Mobile Equipment Identifier, Internet Protocol (IP) address, pseudonymous identifiers, and device type.

• Usage data. We automatically log activity on the devices, including pages viewed, how long a user spends on a page, access times, and other details about use of and actions on our devices.

Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about likely preferences or other characteristics (“inferences”). For example, we infer general geographic location (such as city, state, and country) based on IP address, and we may infer what language is spoken for the purposes of translation and assigning an appropriate translation engine.

When children are asked to provide personal information, they may decline. But if they choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

How we use children’s personal information

We process children’s personal information on behalf of schools to provide the services and for business operations, development, and research, personalization, and customer support.

How we disclose children’s personal information

We disclose personal information as directed by, and to, schools we provide services to or as we determine necessary to provide the services the schools or our users requested or authorized to the extent lawful under applicable law. In addition, we disclose each of the categories of personal information described above, to the types of third parties described below, for the following business purposes

• Service providers. We provide personal information to vendors or agents working on our behalf. For example, companies we’ve hired to provide speech to text and language translation services, customer service support or assist in protecting and securing our systems and services may need access to personal information to provide those functions. The latest list of Service Providers can be found here.
• Affiliates. We enable access to personal information across our parent company, subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.
• Corporate transactions. We may disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Legal and law enforcement. We will access, disclose, and preserve personal information when we believe doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Security, safety, and protecting rights. We will disclose personal information if we believe it is necessary to:
  • protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
  • operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or
  • protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

Finally, we may disclose de-identified information in accordance with applicable law.

Educational Records and FERPA Compliance

Pocketalk stores some limited information that may qualify as ‘Educational Records’ under the Family Educational Rights and Privacy Act (“FERPA”). In accordance with FERPA, Pocketalk uses such Educational Records only to provide its service to students, their parents, and their teachers and does not sell or rent this information to any third parties. Furthermore, the service enables students and/or their parents to access and review their own Educational Records at any time.

Rights to children’s personal information

Parents have the right to provide consent to our collection, use, and disclosure of their children’s personal information and to withdraw consent and stop additional collection, use and disclosure of such personal information. Parents also have rights to access their children’s personal information and to delete it (parents may also have other rights depending on their location, such as to correct children’s personal information). Because we provide devices to schools and rely on schools to authorize our collection, use, and disclosure of personal information on behalf of parents, schools may exercise these rights on behalf of parents. Schools that wish to exercise these parental rights with respect a child’s personal information or that have questions regarding our collection, use, and disclosure of children’s personal information should contact us at +1-888-721-3592. Parents of children using our devices through their schools should contact their school if they have questions about their child’s personal information or wish to exercise parental rights.

We will delete children’s information (and any information about their parents) if we are requested to delete that information by the school.

We retain children’s personal information according to the contractual obligations set forth in our agreements with the children’s schools, until the school requests deletion of the data, or to comply with other legal obligations to retain such data.

Duration of the processing and retention period

The text of translation results are stored on student devices until students, their parents, or schools choose to delete this data. Schools can also choose when to delete text of translation results on the school administrative portal.

Contact us

You may contact us at:
Pocketalk Corporation
Hamamatsuchou PREX 4F, 2-2-12 Shiba, Minato-ku, Tokyo, Japan
privacy@pocketalk.com
+1-888-721-3592

Effective Date: January 13, 2025