Effective October 31, 2018
First and foremost, we want you to know that the protection of children, is always our first consideration. The App is a fun, educational and engaging place for children. Some of the parts of this App are interactive, meaning you can add things to the App, like pictures, your voice and other things.
We encourage all parents to actively participate in their children’s Internet usage by providing them with guidance to help ensure that they have a safe and rewarding online experience. We encourage parents and children to visit and review the United States Government Federal Trade Commission App: www.OnGuardOnline.gov for tips from on protecting children’s privacy online. Internet safety should be important to everyone, and we hope you take it as seriously as we do.
B. Registration on our App
You must be at least the age of Majority (18 in the United States; older in some jurisdictions) to register with us. Please do not provide any of your information to us if you are under the age of 18 and have not obtained parental consent. We do not knowingly collect or maintain any PII about anyone under age of 13, nor is this information knowingly used by us for any marketing or promotional purposes.
If we become aware that you are under the age of Majority and are attempting to or have submitted personal information via the App, we will not accept such information and we will take steps to remove such information from our records. This may involve us having to access and verify your age and other relevant details.
- What information we collect about you and why;
- How we use information about you;
- How your information may be shared;
- How we store and process information about you;
- When and how we communicate with you;
- How long we may keep personal information about you;
- How you can opt-out from receiving communications from us;
- Information over the Internet and other Apps;
- Offensive or inappropriate content;
- Legal disclaimer;
- How to contact us;
1. What information we collect about you and why:
We may collect two types of information: personally identifiable information (“PII”) and information that is not personally identifiable (“Non PII”).
A. What PII Do We Collect?
- When you register with us, we ask for information such as your name, email address, postal address, contact details or notes of interest related to our App. E-mail addresses will only be accepted from people who are of sufficient age to submit this information. For more information about parental involvement, please see Section A above titled, “Children.”
- We may capture user information when users send us questions or comments via e-mail. Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an e-mail will not enroll you on our e-mail list unless you specifically request it.
- At certain points where personal information is collected on our site, there may be a box where you may indicate you would like to be on a mailing list to receive information about other HITN products and services and about ways to support HITN. This opt-in box only appears in places where the department collecting personal information maintains such lists. At any time you can add or remove your name from a HITN list by contacting us at email@example.com.
- We may capture certain information automatically on our Apps, including the user’s Internet protocol address, mobile device identification number, browser type, page access history, linking information, click stream data, page visits, page views, and/or web site log files.
B. PII Not Collected by HITN
- Users may also take photos, record audio, participate in a live camera feed and create user profiles featuring a Cleo & Cuquin avatar and nickname (“Interactive Features”). These Interactive Features are stored on the devices owned by the individual users only and not accessible by HITN.
C. What Non PII Do We Collect?
- For some of our online activities – such as polls, surveys, games or contests – We may ask users to provide information that is not personally identifiable, such as a first name (without a last name).
- Analytics remain within the App only – these analytics include, but are not limited to: (a) basic App usage [installs, account creation, log-in/log-out status, guest status, platform, daily retention, sessions, user segments per country and per platform, English versus Spanish usage and number of pictures the user takes in App] (b) App success ratios [general progress, page/activity attempts and misses]; (c) monetization [third-party companies versus Retail Kit purchases]; (d) level progression [start, fail, complete and skip]; and (e) game analytics [monetization and progression].
2. How we use information about you:
A. We may use the PII we collect in the following ways:
- to contact users with updates and relevant information about our products and services because they have signed up to do so. If you would no longer like to receive promotional e-mails or other communications from us, please refer to the “How you can opt-out from receiving communications from us” Section below;
- to provide users with personalized offers, promotions, news, events and other information relevant to them because they have signed up to do so;
- to quickly process user requests for information and to allow us to respond efficiently to user questions;
- to monitor App statistics;
- to respond to or satisfy legal requirements, such as a court order, a subpoena, or a law enforcement agency’s or other public agency’s (including schools or children services) request;
- to help prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our App, to help protect the security or integrity of our App, or to enable us to take precautions against liability;
- to provide information to service providers or such companies who provide support for the operations of our App and who do not use or disclose the information for any other purpose;
- to administer a contest, promotion, survey, or other feature; and
- to allow us to disclose your information to the extent permitted by law, as described more fully below.
3. How your information may be shared:
Except as set forth below, we do not sell, trade, or otherwise transfer to third parties our users’ PII unless we receive their consent. That being said, in the following situations, we may share PII with outside parties:
- Subsidiaries and Affiliates. We may transfer personally identifiable information to our subsidiaries and corporate affiliates;
- App Consultants and Service Providers. We may disclose personal information to third party consultants and service providers (such as providers of hosting, support, maintenance; third party payment processing agencies; and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service the us and the App;
- Reorganization or Sale. In the event that we merge with or become a part of another organization, or in the event that we are sold, we sell all or substantially all of our assets, or we are otherwise reorganized, the information you provide will be one of the transferred assets to the acquiring or reorganized entity;
- To Help Protect Minor Users of Our App. In the event that the safety of our users is threatened, and we are able to do something about that by sharing PII with third parties, we reserve the right to do so. This may be done to prevent the instigation of a crime, to help facilitate an investigation related to public safety, to help protect the safety of a child using our App, to help protect the security or integrity of our App, or to enable us to take precautions against liability;
- As Otherwise Allowed by Law. We may transfer personal information to third parties where we are expressly authorized by applicable law to do so;
- Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer that aggregated information to third parties;
- With your express consent.
4. How we store and process information about you:
This App is hosted in the United States. In order to communicate with you about offers and opportunities and other news, the information that we collect from you may be transferred to, stored, used and processed by HITN in the United States or one of our service providers based in the United States or outside of the United States. Such entities may be engaged in, among other things: (i) preparing and sending newsletters to which you subscribe; and (ii) the provision of support services.
YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR INFORMATION WITH US, OR MAKE USE OF THIS APP.
TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISIDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.
5. When and how we communicate with you:
We may use the information we collect to contact you by mail, email and telephone (including automated calls, and by SMS text messages and other multimedia electronic messages such as picture messaging).
We will not send you unsolicited premium rate SMS messages (which are SMS messages you pay to receive), although your service provider may impose a charge on any messages that you receive. Please check with your service provider for details.
You can unsubscribe from promotional emails and other commercial communications by following the instructions contained within the communication. Please note that due to marketing production schedules you may receive any messages already in production.
6. How long we will hold personal information about you
We will hold personal information about you on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with HITN, subject to any applicable laws and/or regulations. In the case that you wish to cancel your registration as a member of the App once an account is deleted, we will not use the personal information about you other than for administrative purposes, but it stays on the system for a period of one year for administration purposes before being deleted.
7. How you can opt-out from receiving communications from us:
At any time you can add or remove your name from a HITN list by contacting us at firstname.lastname@example.org.
We will endeavor to comply with your request as soon as reasonably practicable. Please keep in mind that if you opt-out of receiving promotional messages from this App, we will continue to send you transactional messages and important account-related information regarding this App or products or services offered through this App.
9. Information over the Internet and other Apps
The Internet is a global network and, therefore, there are times when information about you travels globally and may not always be completely secure. If you provide us with information over the Internet, this will be at your own risk. By using the App, you agree and authorize us to process information in this way. However, please be assured that we use commercially reasonable procedures and security features to prevent unauthorized access to information about you.
10. Offensive or inappropriate content
If you post or send offensive, inappropriate or objectionable content anywhere on or to the App, or otherwise engage in any disruptive behavior on the App, we may use the personal information we hold about you to stop such behavior. Where we reasonably believe that you are or may be in breach of any applicable laws (for example, but without limitation, content you have posted may be defamatory), we may use the personal information we hold to inform relevant third parties such as your email/Internet provider or law enforcement agencies about the content and your behavior.
11. Legal disclaimer
We are not responsible nor will be liable to you in any way for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee nor do we represent that our performance will be error free, and to the maximum extent permitted by law we will not be liable for any direct, indirect, incidental, consequential or punitive damages or other loss suffered by you and relating to the use or release of your personal information.
YOUR CALIFORNIA PRIVACY RIGHTS
12. How to contact us
We welcome your questions, comments and concerns about privacy. Please contact us at email@example.com with any questions or comments you may have regarding the privacy of your information.
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