Privacy Policy
Last Updated: October 20th, 2023
Welcome to Pitch Pals® (“Pitch Pals”). We are committed to providing children with musical educational materials where every activity is just as fun as it is educational and where you can feel confident that your children’s privacy is protected.
This Privacy Policy describes the ways in which Pitch Pals (collectively, “we,” “our,” “us,” or “Pitch Pals”) collect, use, and disclose information about you and the children who use your Account through the Pitch Pals App, website, and online services (“Apps”) that link to this policy (collectively, the “Services”).
Please read this Privacy Policy closely. By using the Services, you agree to the handling of your information in accordance with this Privacy Policy. If you provide us with your information (directly or indirectly through our service providers) we treat your information according to this Privacy Policy. We will only use your Personal Information in accordance with this Privacy Policy. If we need to use your Personal Information for any other purpose, other than as disclosed herein, we will update this Privacy Policy, as explained under Section 14 (Changes to Our Privacy Policy) below.
Summary of Key Points
You should read this entire Privacy Policy and our Terms of Service, but here are some key points:
- 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 seriously, and we never monetize your PI; we use it to enhance your experience with opportunities like special promotions and offers.
- During account 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), and age.
- Other than in the places and for the purposes explicitly disclosed in this Privacy Policy, we do not knowingly collect any PI directly from Child Users under age 13.
- 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 2 (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 at any time as described in Section 15 (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 12 (Location of Information Processing).
Table of Contents
- Types of Accounts, Services, and Users
- Information Collection
- How We Use Information
- When We Disclose Information to Third Parties
- How to Access, Change, or Delete Account Information
- Account Cancellation and Reactivation; Data Deletion
- California Privacy Rights
- GDPR Privacy Rights
- Information We Collect and Share
- Our Retention of Personal Information
- Links to Other Services
- Location of Information Processing
- Security
- Changes to Our Privacy Policy
- Contact Us
1. Types of Accounts, Services, and Users
How we collect, use, and disclose information depends on the type of user. We currently offer Accounts that support multiple users through the Services. 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, collectively referred to as Users.
2. 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 play games. However, we will only use or disclose this information in accordance with this policy and applicable law. Please see Section 4 (When We Disclose Information to Third Parties) below for more information and how we limit disclosure of Child User information.
Adult Users
Adult Users are asked to provide certain PI about themselves when registering for any Account, including email address. 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 Premium Account. 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.
Child Users
Certain activities allow Child Users to create or upload certain content—such as audio files on the Services. 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. This information may be stored for uture access by you or your Child, but is not sold, transferred, or otherwise accessible by third-parties Any such content will be immediately and irrevocably deleted either upon your request or deletion of the account.
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, and the number of questions answered correctly or incorrectly.
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 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.
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 with the Services, and delivering advertising to visitors to our website 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. 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 Users who are logged in to their Accounts. More information about the use of cookies is set forth below.
Cookies
We use cookies, which are small text files placed on your device, to collect certain internet log information and visitor behavior information. More information about cookies is available at www.aboutcookies.org. We use cookies to recognize your device and to provide and improve our Services as described below. 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 reenter 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.
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.
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, Instagram or TikTok. The social network will record that you have done this. Except as otherwise provided in this policy, such as when an individual has opted-out of our sharing PI, 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.
Push Notifications If you have 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.
3. 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 Pitch Pals.
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’s Area. For security purposes, the Parent’s Area is password protected. For certain 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 fulfil your requests, retrieve your password, or provide technical support. 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.
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 educational efficacy of the Services; 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 experience 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).
4. When We Disclose Information to Third Parties
Information collected from both Adult and Child Users will not be disclosed except for the following purposes, which include our operations purposes:
- To third parties who perform certain services for us, such as process credit cards or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are
permitted by this Privacy Policy. By continuing to use the Services, you are intentionally directing us to transmit the information submitted to us by Adult Users to our affiliates and business partners for business purposes, such as executing transactions and preventing fraud. - 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.
- Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisers, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.
In addition, 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.
5. 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 Area. In addition, Adult Users may contact us at any time as described in Section 15 (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.
When we change or delete any PI at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.
6. Account Cancellation and Reactivation; Data Deletion
At any time, Adult Users may cancel their Accounts through the Parent’s Area section of the Services.
For Accounts that have been canceled if the Account remains inactive for 24 months, we will delete all Child User PI in our active databases associated with the Account (Account Information), unless otherwise stated in this Privacy Policy. The 24 months is provided so that you have the ability, following cancellation of a Family Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. We will not use Child User PI for any other purpose other than for reactivation of the Account. However, we provide no guarantee, and shall have no liability or obligation to ensure that all Account Information and Services-related progress will be available or accessible or all learning or personalization features will be able to be recovered or resumed. If a User requests that PI be deleted prior to the end of the 24-month period of inactivity, we will take commercially reasonable steps to satisfy that request; provided, however, that if the User is a California resident the provisions of Section 7 or Section 8 below shall be followed. For Accounts, other information that Adult Users have provided, such as the Adult User’s email address, the age (only year but not birthday or month), number of children associated with the Account, and the subscription price and length, will be retained for a total of 5 years following cancellation.
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.
Please note that following a request to delete information or your Account under Sections 5 or 6 of this Privacy Policy, information including PI may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.
7. California Privacy Rights
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 CCPA, 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, including contacting your Educational Institution who may provide us with
guidance on your request. Please note, however, that we may need or be required to keep such information 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 Do Not Sell My Personal Information.
For details on exercising these rights, please see “Exercising Access, Disclosure, Data Portability, and Deletion Rights” below.
8. GDPR Privacy Rights
Under applicable law, including the GDPR, you may have a number of rights, including:
– the right not to provide your personal data to us; the right of access to your personal data;
– the right to request rectification of inaccuracies;
– the right to request the erasure, or restriction of processing, of your personal data;
– the right to object to the processing of your personal data;
– the right to have your personal data transferred to another controller;
– the right to withdraw consent; and
– the right to submit a Data Subject Access Request, a Data Subject Erasure Request
For details on exercising these rights, please see “Exercising Access, Disclosure, Data Portability, and
Deletion Rights” below.
9. Information We Collect and Share
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
We have collected the following categories of Personal Information from or about consumers within the last 12 months:
| Collected | |||
| Category | Examples | Adult | Child |
| A real name, alias, unique personal identifier, | |||
| online identifier, Internet Protocol address, | |||
| email address, telephone number, Account | |||
| A. Identifiers | name, or other similar identifiers | Yes | Yes |
| A name, signature, social security number, | |||
| physical characteristics or description, address, | |||
| telephone number, passport number, driver’s | |||
| license or state identification card number, | |||
| insurance policy number, education, | |||
| B. Personal information | employment, employment history, bank | ||
| account number, credit card number, debit card | |||
| categories listed in the | |||
| number, or any other financial information, | |||
| California Customer | Yes | ||
| medical information, or health insurance | |||
| Records statute (Cal. Civ. | (First name | ||
| information | |||
| Code § 1798.80(e)) | Yes | only) | |
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 may use or disclose the Personal Information we collect from each of the Categories of Personal Information listed above for one or more of the following purposes:
To fulfill or meet the reason you provided the information;
To provide, support, personalize, and develop our Services;
To process your requests;
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and to monitor and improve our responses;
To provide customer service;
To understand how Users interact with our Services;
To conduct research, testing, analysis, and development;
To detect security incidents and prevent fraud;
To debug and repair errors;
To create, maintain, customize, and secure your Account with us;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
As described to you when collecting your personal information or as otherwise set forth in the CCPA;
To advance our commercial and economic interests, such as delivering interest-based advertising of our products and services to Adult Users and analyzing the effectiveness of our advertising;
and
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Users/consumers is among the assets transferred.
Categories of Personal Information We Share: We may share your Personal Information by disclosing it to a third party for a business purpose described below. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
In the preceding 12 months, we have also disclosed the following categories of PI for one or more business purposes:
| Category of Third-Party Recipients | ||
| Personal Information | Business Purpose Disclosures of Adult and Child | |
| Category | Personal Information | Sales |
| Affiliates, partners, parent/subsidiary | ||
| organizations, service providers, advertising | ||
| networks (only applies to Adult PI), and | Advertising | |
| A. Identifiers | government entities | Networks |
| Affiliates, partners, parent/subsidiary | ||
| B: California Customer | organizations, service providers, advertising | |
| Records personal | networks (only applies to Adult PI), and | Advertising |
| information categories | government entities | Networks |
| C: Protected classification | ||
| characteristics under | ||
| California or federal law | None | None |
| D. Commercial information | None | None |
| E. Biometric information | None | None |
| Category of Third-Party Recipients | ||
| Personal Information | Business Purpose Disclosures of Adult and Child | |
| Category | Personal Information | Sales |
| Advertising | ||
| F. Internet or other similar | networks and | |
| network activity | None | partners |
| G. Geolocation data | None | None |
| H. Sensory data | None | None |
| I. Professional or | ||
| employment-related | ||
| information | None | None |
| J: Non-public education | ||
| information | None | None |
| Affiliates, partners, parent/subsidiary | ||
| K. Inferences drawn from | organizations, service providers, advertising | |
| other Personal Information | networks, and government entities | None |
10. Our Retention of Personal Information
We retain Personal Information for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business such purposes as complying with our legal obligations, resolving disputes, and enforcing our agreements. We decide how long we need personal information on a case-by-case basis. We may consider the following factors when making retention decisions:
Whether we need to keep some of your Personal Information to maintain your Account;
Whether we are required by law to keep some types of Personal Information for certain periods of time to comply with our legal obligations; and
Whether we need some of your Personal Information for other business purposes, such as to prevent harm and ensure safety and security of our Sites; investigate possible violations of our terms and conditions of use; or protect ourselves.
If we determine your Personal Information is no longer necessary using the factors above, we will generally destroy or anonymize that Personal Information.
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 15
(Contact Us) below. Only you, or a person designated by or registered with your local
government 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.
Non-Discrimination
We fully support your privacy rights and will not discriminate against you for exercising any of your CCP 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 Pitch Pals, 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 15, 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 15, below.
11. 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 to access the parts of the app from which they are accessible . 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.
12. Location of Information Processing
The Services are controlled and operated by us from the United Kingdom. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including but not limited to the United Kingdom, United States, and/or Canada, 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.
13. Security
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 endpoint authentication 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 when 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. 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) 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 15 (Contact Us) below.
14. Changes to Our Privacy Policy
We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).
15. Contact Us
You may contact us below if you have any questions, complaints, or other issues related to this Privacy
Policy and issues related to your or a Child User’s information for which you are responsible:
For all Accounts
Email address: [email protected]
