WinKids sites and applications are created to educate and connect guests with the best that we have to offer on the platforms and devices our guests prefer. Our privacy policy is designed to provide transparency into our privacy practices and principles, in a format that our guests can navigate, read and understand. We are dedicated to treating your personal information with care and respect.

Privacy Policy

This privacy policy describes the treatment of information provided or collected on the sites where this privacy policy is posted. It also explains the treatment of information provided or collected on applications we make available on third-party sites or platforms if disclosed to you in connection with use of the application. We follow this privacy policy in accordance with local law in the places where we operate.

1. Types of Information We Collect

2. How We Collect Your Information

3. Use of Your Information by The WinKids Family of Companies

4. Sharing Your Information with Other Companies

5. Your Controls and Choices

6. Children’s Privacy

7. Data Security, Integrity and Retention

8. Data Transfers, Storage and Processing Globally

9. Changes to this Privacy Policy

10. Comments and Questions

1. Types of Information We Collect

We collect two basic types of information – personal information and anonymous information – and we may use personal and anonymous information to create a third type of information, aggregate 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, gender, date of birth, email address, username and password

• Transaction information you provide when you request information or purchase a product or service from us, whether on our sites or through our applications, including your postal address, telephone number and payment information

• Information you provide in public forums on our sites and applications

• Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information

• Information you provide to us when you use our sites and applications, our applications on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account

• Location information when you visit our sites or use our applications, including location information either provided by a mobile device interacting with one of our sites or applications (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 sites, use our applications on third-party sites or platforms or open emails we send back to top of page

2. How We Collect Your Information

• We collect information you provide to us when you request products, services or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to customer surveys, or otherwise interact with us. Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.

• We collect information through technology, such as cookies, Flash cookies and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms. Please visit Online Tracking and Advertising for further information, including Do Not Track and how to disable cookies.

• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically.

3. Use of Your Information by WinKids

• WinKids does not collect information from the user of the app, users can be sure that the functions of the app do not collect information to deliver them to third parties, the application is only responsible for generating user statistics which can be viewed in one of its sections , the information of these statistics is not shared with third parties and does not leave the device.

4. Sharing Your Information

• WinKids does not collect information from the user of the app, users can be sure that the functions of the app do not collect information to deliver them to third parties, the application is only responsible for generating user statistics which can be viewed in one of its sections , the information of these statistics is not shared with third parties and does not leave the device.

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 you want to share your personal information with other companies so they can send you informations about their products and services

• You may choose whether to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers here

• 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 visiting Communication Choices, contacting Guest Services, or following instructions provided in communications sent to you. 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 Guest Services.

6. Children’s Privacy

• WinKids does not collect information from the user of the app, users can be sure that the functions of the app do not collect information to deliver them to third parties, the application is only responsible for generating user statistics which can be viewed in one of its sections , the information of these statistics is not shared with third parties and does not leave the device.

Children’s Online Privacy Policy

WinKids, including for example WinKids Child and WinKids Family, is committed to protecting the privacy of children who use our sites and applications. This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States and Latin America regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online; https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online .

a. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents

WinKids offers to its users a range of sites and applications, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our sites and applications 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 fulfill 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.

Registration

Children can, in many cases, register with our sites and applications to view content, play games, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. Please note that family or children can choose whether to share their information with us, but certain features cannot function without it. As a result, family or children may not be able to access certain features if required information has not been provided. 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. 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 sites and applications allow children to create or manipulate content and save it with WinKids. Some of 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. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, WinKids also plans to post the content publicly or share it with a others for the others’ own use, we will obtain a higher level of parental consent.

About Verifiable Parental Consent:

Email Consent. In the event WinKids 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 WinKids 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 verification, speaking to a trained customer service representative by telephone, 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.

Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

Email Contact with a Child

On occasion, in order to respond to a question or request from a child, WinKids may need to ask for the child’s online contact information, such as an email address. WinKids will delete this information immediately after responding to the question or request.

In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a site, game/activity, television show, personality/character, or feature movie. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.

Geolocation Data

If a child-directed WinKids 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.

Persistent Identifiers

When children interact with us, certain information may automatically be collected, both to make our sites and applications more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, HTML5 cookies, web beacons, and other unique identifiers (which we define under the “Online Tracking Technologies” section of our general Privacy Policy). This information may be collected by WinKids. This data is principally used for internal purposes only, in order to:

• provide children with access to features and activities on our sites and applications

• 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 WinKids

• 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 the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices.

b. 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.

c. 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 registered for a WinKids.com 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 the Member Services Home Page located here. Parents will need their child’s username and password. A valid request to delete personal information will be accommodated within a reasonable time.

Data Security, Integrity and Retention

The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

8. Data Transfers, Storage and Processing Globally

We operate globally and may transfer your personal information to individual companies of WinKids in locations around the world for the purposes described in this privacy policy. 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 abide by the Safe Harbor Principles as set forth by the U.S. Department of Commerce, use standard contract 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 the Safe Harbor Principles when transferring personal information from Australia.

10. Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.

11. Comments and Questions

If you have a comment or question about this privacy policy, please contact Guest Services. Our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

Definitions

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 guest.

Anonymous Information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest.

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 others, which permits us to interact directly with our guests.

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 the subsidiary or affiliated entity of WinKids that is responsible for the personal information collected from sites and applications, as follows:

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).

Member. Member means a subsidiary or affiliated entity that is part of WinKids Companies.

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 sites and applications 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. To request removal of your personal information from a public forum on one of our sites or applications, please contact Guest Services.

WinKids Apps and Websites WinKids refers to WinKids and its subsidiary and affiliated entities, which offer their products and services under various brand names. These companies engage in a number of businesses, including educational games, apps, motion pictures and television, publishing, consumer products and interactive services.