YOUR PRIVACY RIGHTS – Last Revised Date: 01 June 2021
This Privacy Policy describes what information MagicHabitsLabs Ltd (“MagicHabits” “we,” “our,” or “us”) may collect and how we usesuch information when you visit or use our website at (the “Site”) and/or our applications,including those for use on mobile devices, tablets, personal computers, and anyother devices that connect to the internet (collectively “MagicHabits Applications”). The Site and MagicHabits Applications are collectively referred to herein asthe “Services.”

By using the Services, you consent tothe collection, use, and sharing of your and your children’s information by MagicHabits in accordance with this Privacy Policy and consentto the Terms of Use and End User License Agreement, which are incorporated herein by reference. For users in the United States, the term “children,” asused herein, refers to minors under the age of 13. For users outside of theUnited States, “children” refers to those under the age of digital majority.For additional information about our practices regarding children’s personalinformation, please see Section 1.1.1 (Children’s Personal Information) andSection 5 (Children’s Privacy Rights) below.

‍It is important for users of theServices to read the Privacy Policy carefully. The Privacy Policy may changeover time in coordination with new or different services that we may provide inthe future, or for other reasons. We have provided a “Last Revised Date” at thetop of the Privacy Policy, which reflects the date that this Privacy Policy wasmost recently updated so that users can be aware of the Privacy Policy ineffect at all times. We encourage all users to occasionally refer to thisPrivacy Policy so that they can remain aware of our current privacy practices.

1.1. Personal Information: MagicHabits collects “Personal Information” from you at various times and places on the Site and MagicHabits Applications. Personal Information means information relating to a particular individual,such as the individual’s name and email address. PersonalInformation also includes your “Children’s Personal Information,” as definedbelow in Section1.

Children’s Personal Information: With your consent, MagicHabitsLtd may collect your “Children’s Personal Information.” Children’s PersonalInformation may include information you voluntarily submit to us such as yourchild’s first name, date of birth and gender, or it may include information we collect fromyour child as a result of your use of the Services, such as your child’s deviceaccess times (e.g., we may collect information relating to how long your childuses or accesses his or her device to support our “allowance” feature), deviceidentifier numbers, serial numbers, geolocation information, and otherinternet, device, or electronic network activity information. In order toprovide the Services, we may also collect from your child’s device informationrelating to which apps are installed on your child’s device and informationrelating to your child’s device permission status (e.g., if your child hasdisabled the usage permissions on his/her device required to provide theServices, that information may be collected or if the device can no longer be“seen”). We may also collect information from your child’s device about yourchild’s usage and activity in connection with the Services (e.g., error/crashreporting, usage analytics such as screen views, your child’s use of anyhyperlinks available within the Services, time on page, and page hits).
For additional information about our practices regarding Children’s Personal Information, please see Section 5 (Children’s Privacy Rights) below.
In regard to the European Union, our collection of personal information from a child is limitedand controlled by the parent.

1.2. Non-Personal Information: Non-Personal Information means information that does not identify, and cannot reasonably be used to identify, an individual. We collect Non-Personal Information, for example, when we track the total number of visitors to the Site, the number of visitors to a particular page of the Site, and/or other such technical information. This data may be used to diagnose problems with theServices, gather demographic and geographic information to improve our Servicesor marketing efforts, improve our Services, and for similar purposes.Non-Personal Information includes aggregated and/or de-identified information. MagicHabits reserves the right to use and disclose Non-Personal Information in its sole discretion.

2.1. Voluntarily Provided Information: MagicHabits may collect Personal Information, including your Children’s Personal Information, whenever you voluntarily provide such information including, for example, when you conduct business with us, use our Services, requestinformation or materials from us, create or update any MagicHabits accounts,when you voluntarily send Screenshots, or when you communicate with us aboutquestions or concerns. Examples ofthe type of information you may voluntarily provide include:   Your first name, email address, and any updates to that      information thereafter;
Information relating to your child, such as your child’s name, birthdate, and gender, (see Section 1.1.1. (Children’s Personal Information) for more information); and  If you sign up for any of our paid Services, your credit card or debit card information (such as card type, last four digits of your card, and expiration date) and other financial data and transaction history that we need to process your payment and provide the paid Services.

2.2 Services-Related Information: We may collect Personal Information, including your Children’s PersonalInformation, as a result of your use of the Services. This includes, for example:   Schedules you may create as part of the Services (e.g., to      schedule device access for your child’s device and related screen time allowance information); and Information relating to which apps are installed on your child’s device and information relating to your child’s device status/permission status (e.g., if your child has disabled the usage permissions on his/her device required to provide the Services, that information may be collected or if the device can no longer be “seen”) (see Section 1.1.1. (Children’s Personal Information) for more information).

2.3. Information Obtained from Third Parties: In limited circumstances, we may collect your Personal Information from third parties. For example, the payment processors we work with generally provide uswith information related to you, such as a unique token that enables you tomake additional purchases using the information they’ve stored, includingrecurring payments if you authorize automatic renewals, and your card’s type,expiration date, and certain digits of your card number. We do not collect your Children’s Personal Information from third parties.

2.4. Cookies and Similar Technologies: When you use the Services, we and certain third parties may use “cookies” andsimilar technologies like pixels, web beacons, and local storage (collectively,“Collection Technology”) to collect information. We do not use CollectionTechnology to collect Children’s Personal Information. For example,when you use our Services, we may use Collection Technology to collect certaindevice information, such as: device operating system, device operating systemversion, IP addresses, access times, browser type and language, browser version, and device identifier numbers. We may also use Collection Technology to collect information about your usage and activity related to the Services(e.g., error/crash reporting, usage analytics, your use of any hyperlinksavailable within the Services, time on page, and page hits), and chat analyticswhen the chat feature is used.You have the right to choose whether or not to accept cookies. However, they are animportant part of how the Services work, so you should be aware that if you choose to refuse or remove cookies, it could affect the availability and functionality of the Services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove orreject browser cookies. To do so, please follow the instructions provided byyour browser.Removing or rejecting browser cookies does not necessarily affect third-party flash cookiesor other web trackers, which may be used by us or our partners in connection with the Sites. To delete or disable flash cookies, please visit this site for more information. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit

2.5. Third-Party Analytics: We mayuse third-party analytics tools including, for example, Google Analytics, tohelp us measure traffic and usage trends for the Services. These tools maycollect your Personal Information, including Children’s Personal Information,sent by your devices or our Services that assists us in improving the Services.You can read Googles’ privacy policy, which applies to Google Analytics, byvisiting this link.

Personal Information we collect may be used for the purposes listed below. Children’s Personal Information is used in accordance with Section 5.3 below.

3.1. To provide, develop, maintain, operate, and improve our Services;

3.2. To understand you and your preferences to enhance your experienceand provide a more personalized Service;

3.3. To process and fulfill a request or other transaction submitted by you, including, for example, to process payment transactions and to respond to your comments and questions and provide customer support;

3.4. To communicate with you including, for example, to send you Services-related information including confirmations, invoices, technicalnotices, updates, security alerts, and support and administrative messages;

3.5. For our own marketing purposes. To this end, we may communicatewith you about new contests, promotions, rewards, upcoming events, and othernews about our Services and our selected partners;

3.6. For our business operations (e.g., billing, auditing, reporting,and statistical analysis);

3.7. To meet or comply with any applicable law, regulation, legalprocess, or other legal obligation; protect or prevent harm, fraud, orfinancial loss; or promote, detect, investigate and help prevent security,fraud or technical issues; and protect our legitimate business interests andlegal rights; and

3.8. In connection with corporation transactions, which refers to transfers of Personal Information in the event we sell or transfer, or areconsidering selling or transferring, all or a portion of our business orassets.

4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES MagicHabits may share your Personal Information to third parties as listed below. Disclosure of Children’s Personal Information shall occur in accordance with Section 5.4 below.

4.1. With Your Consent: We may share your information, including Personal Information, with another company when you allow us to do so (i.e., when we have obtained your consent).

4.2. Service Providers: We may shareyour information, including Personal Information, with third parties to assist in our business operations (e.g., to process payments, store data, deliver information, and perform other similar functions); administrative functions;marketing functions; and/or to provide the MagicHabits Applications services you have requested (collectively, “Service Providers”). ServiceProviders are prohibited from using your Personal Information for purposes other than those requested by us or required by law.

4.3. Major Transactions: We may share your information, including Personal Information, as part, of or inconnection with, a merger, acquisition, assignment, as part of debt financing,the sale of company assets, or in any similar transaction, or to the extent as may be required in the unlikely event of insolvency bankruptcy, or a receivership.

4.4. Professional Advisors: We may share information with our legal, financial, and other advisors in connection with the corporate transactions described above or in connection with themanagement of our business and operations.

4.5. Disclosures Under Special Circumstances: We may share your information, including Personal Information, when we believe doing so may be appropriate, including but not limited to when it may be legally required, necessary to comply with laws, or in response to lawful requests or legal process. We may also share such information where we believe it may limit our liability in an actual or potential lawsuit, or where otherwise necessary to protect our rights, interests and/or property (including,without limitation, to enforce our agreements), or the rights, interests and/orproperty of our agents, independent contractors, customers, and others.

5. CHILDREN’S PRIVACY RIGHTSMagicHabits does not sell products or services to children. The Services are not intended for children to submit Personal Information to MagicHabits without the consent of their legal guardians. In compliance with the Children’s Online Privacy Protection Act (“COPPA”), please see below:

5.1. The types of Personal Information we collect from children are detailed above in Section 1.1.1 (Children’s Personal Information).

5.2. How we collect information from children is detailed above in Section 2 (How We Collect Information).

5.3. MagicHabits uses Children’s Personal Information for the purposes listed below:   Provide, develop, maintain, operate, and improve our Services,  Process and fulfill a request or other transaction submitted by you, including, for example, to respond to comments and questions and provide customer support;  Communicate with you including, for example, to send you      Services-related information, including confirmations, invoices,      technical notices, updates, security alerts, and support and      administrative messages;  For our business operations (e.g., auditing, reporting, and statistical analysis);  To meet or comply with any applicable law, regulation, legal process or other legal obligation; protect or prevent harm, fraud, or financial loss; or promote, detect, investigate and help prevent security, fraud or technical issues; and protect our legitimate business interests and legal rights; and  For corporation transactions, which refers to transfers of Personal Information in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.

5.4. We may share or disclose Children’s Personal Information in alimited number of instances, including the following:
We may share Children’s Personal Information with our Service     Providers if necessary for them to perform a business, professional, or technology support function for us.

Please see Appendix A for a list of Service Providers (i.e., third-party operators) who may collect Children’s Personal Information through the Services. Please contact us at the mailing address, email, or phone number listed in Section 15 (Contact Us) with questions about our, or our Service Providers’, privacy policies and   practices.  We may disclose Children’s Personal Information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child; (iii) to protect the security or integrity of our Services; or (iv) enable us to take precautions against liability.

5.5. We will not collect more information from your children than is reasonably necessary to provide the Services. In accordance with COPPA, you may upon request,review the Children’s Personal Information we have collected from your child,such as name, address, telephone number, email address, and direct us to deletesuch information, and/or refuse us to allow any further collection or use ofyour Children’s Personal Information. To exercise your rights, please contactus by email at
For European Union data subjects, our collection ofpersonal data from a child is limited and controlled by the parent.

We maintain reasonable security procedures toprotect the confidentiality, security, and integrity of the Personal Information we collect. Such practices include using technical controls tosecure the information that we collect, as appropriate, including Secure SocketLayer (SSL) and password protections. MagicHabits cannot guarantee the security of the information on and sent from theServices. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the controlof MagicHabits to intercept or access transmissions or private communicationsunlawfully. Neither MagicHabits nor any of our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission isdone at your own risk.

The Services may contain third-party links orinclude third-party integrations. Through these links and integrations, you maybe providing information (including Personal Information) directly to the third-party, us, or both. You acknowledge and agree that we are not responsiblefor how those third parties collect or use your information. The information we collect is covered by this privacy policy, and the information the third-party collects is subject to the third-party’s privacy practices. Privacy choices youhave made on any third-party site or platform will not apply to our use of theinformation we have collected directly through our Services. You should reviewthe privacy policies of every third-party service that you visit or see, including those third parties you interact with through our Services.

You may request to view and, if necessary, correctPersonal Information we collect about you. To do so, please contact us by usingone of the contact methods provided in Section 11 (Contact Us) below. Please include your full name and email address in all requests.

We allow you to choose which forms of communication you receive from us. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receivingpromotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

10.1. Shine the Light: We do not sell, disclose, trade, or rent your Personal Information to third parties tomarket their own products or services.
10.2. Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals to the onlineservices that you visit. We currently do not respond to “Do Not Track” orsimilar signals. To find out more about “Do Not Track,” please visit
10.3. California Consumer Privacy Act:The California Consumer Privacy Act (“CCPA”) affords California consumers certain rights over their Personal Information. Please see our California Privacy Notice foran outline of those rights and an explanation of how such rights may be exercised.

This Section 11 (Notice to European Union Data Subject – General Data Protection Regulation) applies specifically to European Union data subjects. For the purpose of this section, terms used but notdefined shall have the meaning ascribed to them in the General Data ProtectionRegulation.
11.1. Data Subject Rights: You have the following rights with respect to your Personal Information where and to the extent they apply to your particular processing:   The right to request a copy of your Personal Information which MagicHabits holds about you;  The right to request that MagicHabits corrects any Personal Information if it is found to be inaccurate or out of date;  The right to request your Personal Information is erased where it is no longer necessary for MagicHabits to retain such data;  The right to withdraw your consent to the processing of your Personal Information at any time; The right to request that the MagicHabits provide you with your Personal Information and where possible, to transmit that data directly to another data controller (where applicable);  The right, where there is a dispute in relation to the accuracy or processing of your Personal Information, to request a restriction is placed on further processing; and  The right to lodge a complaint with a European Union Data Protection or Supervisory Authority.

11.2. Exercise of Data Subject Rights: You may let us know of your desire to enforce any of the rights described in this Privacy Policy by sending an email to, and we will respond within thetime required by applicable. Please note that we may ask you to verify your identity before taking further action on your request. Please also note that laws and contractual frameworks limit your exercise of these data rights; we welcome you to ask us questions any time, and we will answer them as described above.

11.3. Right to Withdraw Consent to Processing: Where you have provided your consent to the processing of your Personal     Information by MagicHabits you may withdraw your consent at any time by sending a communication to MagicHabits specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where:   you contest the accuracy of your Personal Information;  the processing is unlawful, and you oppose the erasure of your      Personal Information;  we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or  you have objected to the processing and pending the verification      whether the legitimate grounds of the MagicHabits override your own.

11.4. Complaints to Supervisory Authorities:We invite you to let us know about any and all issues regarding our data processing activities or this Privacy Policy, and we will respond to you within 30 days of receipt of such notification. If you consider that our processing ofyour Personal Information infringes European Union data protection laws, in particular if you are an EU resident, you have a legal right to lodge a complaint with asupervisory authority responsible for data protection. You may do so in the EUmember state of your habitual residence, your place of work, or the place ofthe alleged infringement. For example, in the United Kingdom this is theInformation Commissioner’s Office, and in Ireland this is the Data ProtectionCommissioner.

The data that we collect from you will be processedand stored at a destination located in the United States. We transfer data to destinations outside of theEuropean Union as a necessary part of the performance of the Services, or with your consent, as applicable.

We keep your personal data to enable your continueduse of the Services, for as long as it is required to fulfill the relevant purposes described in this Privacy Policy, as may be required by law such asfor tax and accounting purposes, or as otherwise communicated to you.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site. Wemay, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Site. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified. Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. If you do not accept this Privacy Policy, you must discontinue use of the Services.

If you have any questions regarding this PrivacyPolicy, please contact us at to the attn: DataProtection Officer – Legal.