- ABCmouse is certified under kidSAFE’s FTC approved COPPA Safe Harbor program. This means that the product has been independently, reviewed, and certified by kidSAFE to meet certain standards of online safety and privacy.
- Personal Information, or PI, is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- We take your privacy very seriously, and we never monetize your PI; we use it to enhance your experience with opportunities like special promotions and offers.
- During ABCmouse registration, the only information we may ask you to provide about a child who will be using the Services is the child’s first name (or nickname), birth month and year, and gender. We also will ask you to choose an Academic Difficulty Level for each child.
- We do not ask for certain sensitive PI such as social security numbers, driver’s license numbers, or biometric data. However, paying subscribers are asked for payment information when they subscribe. Please see Section 3 (Information Collection) for more information about how we safeguard payment information.
- Because the security of your PI is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by the Services.
- Our Services do not support social or federated login.
- Adult Users (as defined below) may contact us or their Educational Institution, when applicable, at any time as described in Section 13 (Contact Us) to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users. For information about when we automatically delete PI due to Account cancellation or inactivity, please see Section 10 (Location of Information Processing).
- If you have access to the Services through a School Account, additional privacy protections apply because your Educational Institution may provide us with student personally identifiable information (Student Data) as defined by the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g) and its implementing regulations (34 CFR Part 99) (collectively, FERPA). The Educational Institution is responsible for obtaining parental consent and/or ensuring that an exception applies prior to transferring Student Data to the Company, which acts as a third-party vendor school official in this context.
- We will delete, or if requested by the Educational Institution, transfer to the Educational Institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of the agreement with the applicable Educational Institution.
1. COPPA Safe Harbor
ABCmouse is part of the kidSAFE Seal Program. This means that the product has been independently, reviewed, and certified by kidSAFE to meet certain standards of online safety and privacy, and is authorized to display the kidSAFE Seal under kidSAFE’s FTC approved COPPA Safe Harbor program. Under the kidSAFE program users can also report concerns or complaints directly to kidSAFE through this link: https://www.kidsafeseal.com/certifiedproducts/abcmouse.html.
In addition, Child Users are blocked from accessing external links. External links will only be available if an Adult User enters his or her password.
2. Types of Accounts, Services, and Users
How we collect, use, and disclose information depends on the type of Account and the type of user. We currently offer the following types of Accounts through the Services: Family Accounts, Teacher Accounts, Classroom-Linked Accounts, Librarian Accounts, Guest Library Accounts, Personal Library Accounts, Library Home Checkout Accounts, and Community Center Accounts (collectively, Consumer and Other Accounts), which are described in our Terms & Conditions.
We also provide School Accounts, which are only for Educational Institutions. Consumer and Other Accounts and School Accounts are collectively referred to as Accounts, and the provisions of this policy apply to all Accounts. Any difference in how the Consumer and Other Accounts and School Accounts are treated is identified below.
Users of the Services include Child Users (any child under age 18 who uses the learning portion of the Services) and Adult Users (including parents and legal guardians of Child Users, Gift Account purchasers, teachers, librarians, and community center administrators), collectively referred to as Users.
3. Information Collection
There are two general categories of information that we collect.
A. Information Users Provide to Us As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users create an Account, sign up for Services, or contact us with a question, comment, or request, and when Child Users participate in assessments. However, we will only use or disclose this information in accordance with this policy and applicable law. Please see Section 5 (When We Disclose Information to Third Parties) below for more information and how we limit disclosure of Child User information.
Adult Users are asked to provide certain PI about themselves when registering for any Account, including first and last name, email address, and telephone number (which is optional). The other information provided at registration depends on the type of Account or Adult User. For example:
Payment information is collected from Adult Users who purchase a Family Account, including those who purchase a Gift Account for others, unless Adult Users are purchasing through iTunes, PayPal, or other similar mechanisms with which we integrate. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your Account and respond to your requests and questions.
The email address of a parent or legal guardian is collected when the Adult User purchasing a Family Account or setting up a Personal Library Account or Library Home Checkout Account states that he or she is not the legal guardian, or if a teacher or community center administrator provides such addresses in order for parents or legal guardians to connect to the Teacher Account, Community Center Account, or School Account.
The school, library, or community center name and address (state and ZIP code only) are collected from Adult Users who register for a Teacher, Librarian, or Community Center Account. Adult Users who register for a Family, Teacher, Classroom-Linked, Personal Library, Library Home Checkout, Community Center, or School Account are asked to provide the first name (or nickname) and gender and may be asked for the birth month and year of Child Users who will be accessing the Services through their Accounts.
In addition, Adult Users can provide us with information through separate password-protected sections (i.e., the Parent Section or Teacher Dashboard) of the Services. These sections, accessible via the Menu or Settings link on the Services, allow Adult Users to administer their Accounts, including when they add Child Users, provide testimonials, seek customer support, or submit comments or questions.
Previously, on the Adobe Flash version of the Services, certain activities allowed Child Users to create or upload certain free-form content—such as photographs, audio or video files, and artwork—and save it on the Services. When we upgraded to the HTML 5 version of the Services, we removed these features so there is no longer the ability to upload photographs, audio, or video files. Children still can create free-form artwork. We encourage you to use the Services with your Child Users and to view and monitor any content created or uploaded (if applicable) by them. If you would like to review all content saved by your Child Users, you can access this content by clicking on the My Files menu item in each Child User’s About Me section of the Services.
B. Information We Collect from Users We and our third-party service providers collect PI directly from Users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from Adult Users, we may collect information about patterns of usage and order history; from Child Users, we may collect information about patterns of usage, which activities a child commences and completes, when a child starts and stops an activity, which areas of the Services the child frequents, the number of questions answered correctly or incorrectly, how many Tickets the child earns, what virtual items the child selects to exchange for Tickets, and the child’s choice of Avatar and customization.
We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, the approximate geolocation of your computer or mobile device, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
What Are Cookies?
Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, e.g., the IP address) or the User. Cookies may contain information such as registration data and User preferences.
- automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation. When you download and use our App(s), we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;
- collect and store information about your location to provide you with educational experiences or email updates that are tailored for your region. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information;
- we may collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your IP address, geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. In addition, if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our App(s), we may collect and use your geolocation information; and
- we may also use third-party advertising networks to collect cookie information about Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including advertising for our Services, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. Please refer to Section 5 (When We Disclose Information to Third Parties) for more information about what PI is transferred to our third-party advertising measurement partner.
When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.
Types of Cookies
We use the following cookies:
Essential Cookies These cookies are essential to provide you with services available through the Services and enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.
Social Media Cookies These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
Except as otherwise provided in this policy, such as when a California resident has opted-out of our sharing PI for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Services.
Pixel Tags and IFrames
We also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of Users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on web pages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our Users’ PI.
We and our third-party service providers may use the information collected through these technical methods for several purposes, including delivering content, tracking and enhancing our Users’ experience on the Services, and delivering advertising to visitors of www.abcmouse.com when they visit other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. For more information, see (What are Cookies) above. The information collected through these technical methods on the child-directed portions of the Services are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Child Users who are logged into their Accounts.
If you do not want the Services to collect information through cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s Help menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged into your Account, and therefore you would have to log in during each page transition.
Push Notifications and SMS Additionally, if you downloaded the App on your mobile device to access the Services, as part of your use of the Services we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. If you provide us with your mobile phone number, we may send you SMS text messages about your account. Please note that your carrier may charge you for the text messages you receive. To permanently stop receiving SMS text messages from us (if you are located in the U.S. or Canada) text STOP, CANCEL, or UNSUBSCRIBE in reply to any SMS text message sent by us.
4. How We Use Information
We will never monetize the PI of any User of the Services by providing it to a third party in exchange for money, except as described in this policy in the context of a sale of the Company.
We and our third-party service providers may use the information collected from Users as follows:
Adult User Information Information collected from Adult Users may be used:
- To permit you to register and use the Services, including, for example, to send you communications about Child User progress or your Account, or to allow you to provide Feedback through the Parent Section. For security purposes, the Parent Section is password protected. For certain Consumer and Other Accounts, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
- To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. For Consumer and Other Accounts, to provide marketing communications that we believe may be of interest to you. While it is never our intention to send any marketing messages to children, if you believe a Child User has received such a marketing communication, please contact us as described in Section 13 (Contact Us) below. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails, customer support messages, and progress reports for School Accounts.
- To deliver our advertising to you based on your visits to the non-child-directed portions of the Services (such as www.abcmouse.com), for example when you visit third-party websites and applications or via postal mail. We do not currently respond to web browser “do not track” signals due to lack of standardization regarding how that signal should be interpreted; however, you may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.org. California residents have additional rights under the CCPA. For more information please see Section 8 below.
- To measure the effectiveness of our advertising to adults.
Child User Information Information collected from Child Users may be used:
- To measure a Child User’s performance in activities and to adapt a Child User’s learning experience to the Child User’s learning needs.
- To analyze, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account.
Both Adult and Child User Information Information collected from both Adult and Child Users may be used:
- To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.
- To customize, adapt, and personalize Users’ viewing and content-consumption experience, for example, by measuring a Child User’s performance in activities and adapting the Child User’s learning path to their learning needs.
- To maintain and analyze the functioning of the Services.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
5. When We Disclose Information to Third Parties
Information collected from both Adult and Child Users will not be disclosed except as follows:
- Where parents or legal guardians have linked a Family Account to a Teacher Account, as described in the Terms & Conditions, the Adult Users of both Accounts will be able to review the progress and details of their Child Users within both Accounts.
- As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
- Where we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. If required or permitted to do so under the law, and if deemed necessary or warranted, we may provide notice to Users prior to the disclosure.
In addition, with respect to Consumer and Other Accounts, we may use third-party advertising networks and other affiliates in association with cookies, pixel tags, or IFrames, for Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, including our advertising, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.
We do not disclose the PI of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the PI of children under the age of 16 for valuable consideration.
We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified user records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified.
6. How to Access, Change, or Delete Account Information
Consumer and Other Accounts: An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account, by updating information through the Services’ Parent Section or, for Teacher Accounts or Community Center Accounts, by using the Class Builder or Settings feature in the Teacher Dashboard. In addition, Adult Users may contact us at any time as described in Section 13 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their Accounts, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your Account or the inability to use certain Services, and if a Teacher Account or Community Center Account is linked to a Family Account, a request to delete PI in one of the Accounts may be reflected in your other Account.
School Accounts: If you are using the Services through a School Account that is integrated with a school student information system (SIS), unless otherwise required by law, any request to access or make changes to or delete PI including Student Data must be made by the Educational Institution within the SIS. Once the changes are made within the SIS, the changes will automatically appear within the School Account.
If you are using the Services through a School Account and the Educational Institution is not integrating its SIS with the Services, unless otherwise required by law, any request to access, make changes to, or delete PI including Student Data must be made by the Educational Institution's designated administrator for the School Account. The administrators will be provided access to the School Account User Profile pages to update, correct, or delete the information contained therein.
7. Account Cancellation and Reactivation; Data Deletion
At any time, Adult Users, except for Library-related Accounts, Community Center accounts, or School Accounts, may cancel their Accounts through the Parent Section or Teacher Dashboard section of the Services. Librarians and those with Personal Library Accounts or Library Home Checkout Accounts may contact us as described in Section 13 (Contact Us) below to cancel such Accounts.
For Teacher Accounts and Community Center Accounts, if you cancel your Account, we will delete all Account Information 48 hours after the cancellation, unless a Child User’s parent or legal guardian has linked to the Account, in which case we will delete that Child User’s Account Information as described in the previous paragraph. Please note that canceling an entire Teacher Account or Community Center Account will result in the loss of activities and progress data for every Child User, except for Child Users whose parents or legal guardians have linked to the Account. If a Teacher Account or Community Center Account is not canceled, we will delete all Account Information 24 months after the last activity on the Account.
For School Accounts, Adult Users should contact their respective Educational Institution for any questions regarding Account cancellation and data deletion. If an Educational Institutional terminates its agreement with us, we will delete, or if requested by the Educational Institution, transfer to the Educational Institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of the agreement with the applicable Educational Institution.
Upon Account cancellation, de-identified Adult and Child User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.
8. California Privacy Rights
Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their PI. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect PI, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:
- Right to access Personal Information. You may be entitled to receive the specific pieces of your PI we hold.
- Right to data portability. You may be entitled to receive a copy of your electronic PI in a readily-usable format.
- Right to disclosure. You may be entitled to receive information regarding the categories of PI we collected, the sources from which we collected PI, the purposes for which we collected and shared PI, the categories of PI that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of PI that we disclosed for a business purpose in the 12 months preceding your request.
- Right to deletion. You may be entitled to request that we delete the PI that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
- Right to opt-out of certain sharing with third parties. As stated in the Summary of Key Points above, we will never monetize the PI of any User of the Services by providing it to a third party in exchange for money. The CCPA has a broader definition of the term “sell” which includes disclosing PI to any third party for valuable consideration. When we work with our advertising partners, we are disclosing certain information such as cookies for their services, which are of value to us. You may be entitled to direct us to stop disclosing your PI to third parties for monetary or other valuable consideration. You can exercise such right to opt-out .
Information we Collect and Share
In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share PI.
Business and Commercial Purposes for which we use Personal Information: We use and disclose the information we collect from each of the Categories of PI listed below for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, enabling and affecting commercial transactions and advancing our commercial and economic interests, such as delivering interest-based advertising to Adult Users and analyzing the effectiveness of our advertisements and other activities to improve our services, show advertising, market our services, and understand how users interact with our services.
Categories of Personal Information we collect: In the preceding 12 months, we have also disclosed the following categories of PI for one or more business purposes: identifiers, commercial information, internet or electronic network activity information, geolocation data (see Section 3. B. Information we collect from Users), and inferences we draw or derive about users.
Categories of Sources from which we collect Personal Information: We collect PI from each of the aforementioned Categories of PI from You, your child and, if applicable, your child’s teacher, school, library and community center.
Categories of Third Parties with whom we share Personal Information: We share PI from each of the aforementioned Categories of PI with the categories of third parties described in Section 5, including as part of a sale or for commercial or business purposes.
Categories of Personal Information we share with Third Parties: We share, and have shared during the past 12 months, the following categories of PI with third parties, including as part of a sale or for commercial or business purposes: personal identifiers such as name and credit card number to payment processors who act as our service provider; commercial information, such as services subscribed to, obtained or considered; and information regarding your interaction with or use of our products and services, including the Services. We do not sell the PI of children under 16 years of age.
Exercising Access, Disclosure, Data Portability, and Deletion Rights
To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us as set forth in Section 13 (Contact Us) below, or by visiting:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your PI. You may also make a verifiable consumer request on behalf of your Child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PI or an authorized representative. We will verify your request by asking you to provide information related to your interactions with us. We will not otherwise ask for PI from you that we would not otherwise maintain as part of us providing our Services.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use PI provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.
Notice of Financial Incentives
We may offer special incentives to users who enroll in certain promotions. The availability of these promotions to you at any given time will vary. If we offer such programs, we may ask for your PI (such as your email address or certain in-game activities associated with your account) as a prerequisite to your participation in the promotion.
The promotions that may be available to you are:
- Email Offers. When you subscribe to receive emails from the Company, we may offer you special savings in the form of digital coupons for free or discounted products and announcements of sweepstakes, contests, and giveaways. To participate in these email offers, you must provide a valid email address.
You may opt-in to the email offers by visiting our website or navigating through your account. You may also withdraw from these promotions at any time by contacting us at the contact information provided in Section 13, below.
The value we place on the PI that we collect in connection with these promotions is calculated by determining the approximate additional spending per promotion participant, compared to individuals for whom we do not have email addresses, in-game activity history and preferences, or other collected information. You can opt-in to, or opt-out of, our programs at any time through the same means they are offered, or by contacting us at the contact information provided in Section 13, below.
9. Links to Other Services
In certain sections of the Services, we may include links to external websites or applications (for example, Facebook and Twitter). However, to protect children from accessing these external websites, an Adult User will be required to enter a valid password. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.
10. Location of Information Processing
The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.
The security of your PI is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files. We also conduct periodic audits of our security (no less than annually) to apply best practices and reasonable industry standards. However, no data transmission over the Internet can be guaranteed to be completely secure. If there is a breach of our security, we will notify you where required by law or deemed necessary and appropriate under the circumstances.
Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.
We are committed to maintaining the security and confidentiality of your and your children’s information, including, but not limited to, any Student Data, which we receive through School Accounts. Some of the precautions we take include (a) limiting employee access to your and your children’s PI to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to Student Data; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting PI with commercially reasonable technical, contractual, administrative, and physical security safeguards.
Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 13 (Contact Us) below.
13. Contact Us
For all Accounts
Mailing address: Age of Learning, Inc. Attention: Legal Department P.O. Box 230 Glendale, CA 91209 USA Telephone Number: 800.633.3331 Email address: email@example.com