Last Modified: December 30, 2016
- Types of Information We Collect
- How We Collect Your Information
- Use of Your Information by Kidibank™
- Sharing Your Information with Other Companies
- Your Controls and Choices
- Children’s Privacy
- Data Security, Integrity and Retention
- Data Transfers, Storage and Processing Globally
- Comments and Questions
1. Types of Information We Collect
We collect two basic types of information – personal information and anonymous information.
We collect the following categories of information:
- Registration information you provide when you create an account, including your first name and surname, country of residence, email address and password
- Transaction information via your Paypal account if using the Bid Days feature
- Information you provide to us when you use our site and application
- Location information when you visit our site or use our application, including location information either provided by a mobile device interacting with our site or application (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information
- Usage, viewing and technical data, including your device identifier or IP address, when you visit our site, use our application on third-party sites or platforms or open emails we send
2. How We Collect Your Information
3. Use of Your Information by Kidibank™
Unless prohibited under applicable law, Kidibank™ will only use your information on their own behalf (as a data controller) for the following purposes:
- Provide you with the products and services you request
- Communicate with you about your account or transactions with us and send you information about features on our sites and applications or changes to our policies
Consistent with local law and choices and controls that may be available to you:
- Send you offers and promotions for our products and services or third-party products and services
- Personalize content and experiences
- Optimize or improve our products, services and operations
- Detect, investigate and prevent activities that may violate our policies or be illegal
4. Sharing Your Information with Other Companies
We will not share your personal information outside Kidibank™ except in limited circumstances, including:
When you allow us to share your personal information with another company, such as:
- Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services
- Directing us to share your personal information with third-party sites or platforms, such as social networking sites
5. Your Controls and Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices may include:
- You may correct, update and delete your registration account
- You may change your choices for subscriptions, newsletters and alerts
- You may choose whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you
- You may choose whether we share your personal information with other companies so they can send you offers and promotions about their products and services
- You may request access to the personal information we hold about you and that we amend or delete it
You may exercise your controls and choices, or request access to your personal information, by contacting us at email@example.com.
Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact us at firstname.lastname@example.org to top page
6. Children’s Privacy
We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our site and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
- Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information
- In accordance with applicable law, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children
- Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity
- Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted
7. Data Security, Integrity and Retention
8. Data Transfers, Storage and Processing Globally
Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of standard contractual clauses when transferring personal information from Australia.back to top page
10. Comments and Questions
1. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents
Kidibank™ offers to its users access to the Kidibank.com web site and application, some of which have children’s interfaces, and others that are intended for users of all ages and their families. Our site and application offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfil the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Children can only be registered onto the Kidibank™ by a parent or guardian. During the registration process, we may ask the parent to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name, the child’s account username, and password. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us and features can function without it. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at email@example.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Content Generated by a Child
Certain activities on our site and application allow children to create or manipulate content and save it with Kidibank™. These activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent.
About Verifiable Parental Consent:
Email Consent. In the event Kidibank™ wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
High-Level Consent. In the event Kidibank™ collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed application that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
If a child-directed Kidibank™ site or application collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
- provide children with access to features and activities on our site and application
- customize content and improve our sites and applications
- conduct research and analysis to address the performance of our sites and applications
- generate anonymous reporting for use by Kidibank™
In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection. Please contact us at firstname.lastname@example.org with questions about the operators’ privacy policies and collection and use practices:
2. When Information Collected From Children Is Available To Others
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose 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 (including schools or children services) 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 using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
3. Parental Choices and Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has access to a Kidibank™ account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
- Parents can request access to and delete their child’s personal information by logging on to the child’s account through Kidibank™ Family settings page. Parents will need their child’s username and password. The Your Account home page explains how to recover a password if the child cannot recall it.
- Parents can contact Kidibank™ to request access to, change, or delete their child’s personal information by sending an email to us at email@example.com. A valid request to delete personal information will be accommodated within a reasonable time.
In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
Aggregate Information. Aggregate information means information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual user.
Anonymous Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual user.
Application. Application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile or other platforms and environments, including those operated by third parties, which permits us to interact directly with our users.
Children. Children means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. In the United States and Latin America, the term “children” refers to individuals under 13 years of age.
Data Controller. The data controller is responsible for the personal information collected from sites and applications.
Data Processor. A data processor is a person or entity that processes personal information on behalf of a data controller (or data controllers) and is permitted to perform data processing only as directed by the data controller(s).
IP Address. An IP address is associated with the access point through which you enter the Internet, and is typically controlled by your Internet Service Provider (ISP), your company, or your university. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our sites and applications, and we may combine IP addresses with personal information.
Notice. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.
Parents. Parents means a parent or legal guardian.
Personal information. Personal information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address and telephone number. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.
Public Forums. Our site and application may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages,
and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information
may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party. To request removal of your personal information
from a public forum on one of our sites or applications, please contact firstname.lastname@example.org.
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