Kids Privacy Policy
Last Updated: January 27, 2008
We at weplay.com (“weplay”) are dedicated to protecting the privacy of kids under the age of 13 and handling any personal information we obtain from children under the age of 13 with care and respect. This Kids Privacy Policy is designed to answer your questions regarding our privacy policies and principles regarding children under the age of 13 who use the Web site located at http://www.weplay.com (“Site”).
Building on our general Privacy Policy (http://www.weplay.com/t/privacy), we recognize the need to provide additional privacy protections when children visit the site. We explain those additional protections here in this Kids Privacy Policy (“Kids Policy”). For your convenience, this Kids Policy uses terms that are defined in our general Privacy Policy. Where our general Privacy Policy conflicts with this Kids Policy, this Kids Policy shall govern. Otherwise, the terms of our general Privacy Policy shall apply in .
The Children’s Online Privacy Protection Act (“COPPA”) requires that we (a) inform parents and legal guardians about how we collect, use and disclose personal information from children under 13 years of age, (b) obtain the prior verifiable consent of parents and guardians in order for children under 13 years of age to use certain features of the site, (c) do not collect more information than is reasonably necessary for a child to participate in a given activity on this site and (d) provide the parent with the ability to review and delete the information collected about their child. When we discuss “kids” in this Kids Policy, we mean children under 13 years of age. When we use the term “parent” in this Kids Policy, we mean to include legal guardians.
Privo's Privacy Assurance Program
weplay, Inc. (http://www.weplay.com) is a participant in the Privo’s Privacy Assurance Program. As part of participating in the Privacy Assurance Program, weplay adheres to the strict information collection, use and disclosure requirements. Privo is an independent, third party organization committed to safeguarding children's personal information collected online, and to helping parents and their children exercise control over personal information while exploring the Internet. The seal displayed on this page indicates that weplay has established privacy practices and has agreed to submit to Privo’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at privacy@weplay.com. If you have further concerns after you have contacted weplay, you can contact Privo directly at privacy@privo.com.
What types of personal information do we collect from and about kids?
This Kids Policy uses the terms “personally identifiable information” and “personal information” synonymously. When we use either, we mean information that specifically identifies a particular individual, such as the individual’s first and last name, e-mail address, postal address or phone number and any demographic or other information about a user, such as gender or a user’s number of children, when such information is directly associated with personally identifiable information. Personal information does not include “aggregate” information, which is data we collect about a group or category of products, services or customers, from which individual customer identities have been removed. For example, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data.
Direct Collection: Kids can surf the site and view sample content and can maintain a limited access account without any personal information being collected. Once we know that a user attempting to register for the Service is under the age of 13, we do not collect personal information from that kid unless they complete registration on the site with prior verifiable parental consent, except as permitted in accordance with applicable law. For example, we may collect a kid’s name and email address to the extent reasonably necessary to protect the safety of a child participant on the Site, to protect the security or integrity of the Site, to take precautions against liability, to respond to judicial process or to provide information to law enforcement agencies or for an investigation on matters related to public safety. In addition, we may collect a child’s email address to respond to certain specific requests of a child (such as answering a child’s question, requesting a subscription to an online newsletter or signing up for a contest), provided that in certain circumstances we may be required to notify parents that we have collected such information and give parents the opportunity to request that we make no further use of such information. The child’s name and parent’s email address may also be collected in order to obtain parental consent. Additionally, weplay may provide the “limited access account” child with the ability to participate in any of the weplay marketing and/or promotional programs which the data is used only for internal purposes (where no information is shared or publicly disclosed). This requires an email sent to the parent requesting their affirmative consent. The process by which we obtain a parent’s consent to the collection of information on the Site for interactive features is discussed below.
If we obtain verifiable parental consent, kids may participate in certain interactive features located on the Site now or in the future, such as chat rooms, instant messaging, sending e-mail, posting on message boards or forums and other similar interactive activities (the “Interactive Activities”), and such kids may provide personal information about himself or herself in connection with such Interactive Activities. For example, a kid may provide images that could reasonably be used to identify them and may provide written statements and descriptions that could disclose personal information.
Passive Collection: Please see the “Automatically Collected Information” section of our general Privacy Policy to learn about information that is passively collected on our Site through technology such as cookies.
How do we use and share the personally identifiable information that we have collected about kids?
We use personal information from kids to complete transactions requested by them, to provide customer services, to customize and develop our products or services, to respond to questions, problems or complaints, to request feedback, to send administrative communications, promotional materials (including special offers and promotions) and information about our products and service, and for other specified purposes for which the personal information was provided and any purpose relating thereto. Please see our general Privacy Policy for a more detailed description of the use of personally identifiable information.
We do not share any personal information about a kid with any third parties other than (a) to third-party service providers and consultants ("Service Providers") who assist us in performing internal functions in connection with the operation of our business, such as fulfilling orders, processing payments or other information, assisting in verifying parental consent and complying with other applicable regulations, performing internal analysis of the Site or administering surveys on our behalf, (b) in connection with mergers and business transfers as set forth in our general Privacy Policy, and (c) disclosures required by law and to help protect the rights, security and safety of the Site, weplay, our users or others, as set forth in our general Privacy Policy. Service Providers have agreed not to use or retain personal information obtained in connection with the Site for any purpose other than to carry out the services for us and to maintain the confidentiality, security and integrity of all such personal information obtained in connection with the site.
Parents and kids should note that any information that kids post to message boards or other Interactive Activities will be accessible by other users of the Interactive Activities with whom the kids allows to access their profile and could be used to send the kid, or anyone else identified in the information posted by the kid, unsolicited messages. Kids should not post any personally identifiable information, including, without limitation, names, phone numbers, or email addresses, in connection with any Interactive Activities. Parents should talk to their children about not posting personal information in connection with their participation in Interactive Activities on the Site.
Parents have the right to consent to our collection and use of personal information from their child without also consenting to our disclosure of such information to third parties (except for disclosures to third parties who provide support for the internal operations of the Site and who do not use or disclose that information for any other purpose). Parents will be given the opportunity to exercise this right by indicating their intention to do so when providing their consent to their kid’s registration (as described below). Note that all sites that are directed to children under 13 are prohibited by law from conditioning a kid’s participation in an online activity on the kid’s providing more personal information than is reasonably necessary.
How do we notify and obtain consent from parents for the collection of information from their kids?
Except as outlined above, we do not collect personal information from kids unless they complete registration on the Site with prior verifiable parental consent. If a kid attempts to register and indicates that his or her age is under 13, the account will automatically be flagged as a limited access account that restricts access to certain weplay features and we will inform the kid that verifiable parental consent is required before he or she may have a -access account. If a kid would like a full-access account, we will ask the kid to provide us with his or her first name and their parent’s email address so that we may contact them to request consent. Until verifiable parental consent is obtained, the child will only have access to certain features of the Site and will not be able to post content or free form comments in user forums on the Site.
We will then send an email to the parent’s email address containing our notice to parents of our practices regarding use, collection and disclosure of personal information about kids (the "Notice to Parents") and requesting verifiable consent to the child’s registration as outlined in the Notice to Parents.
We will retain the parent’s email address for a reasonable time to allow the parent to consent to the kid’s registration and to provide a means for the parent to authenticate themselves if they desire access to the child’s account. If the parent does not provide consent within a reasonable time, we will delete the email address and we will not collect any personal information from the kid.
How can parents review, change or delete personal information collected from their kids?
Parents have the right to review and have deleted from our records personal information collected from their child. Further, at any time parents may refuse to permit us to collect further personal information from their kid(s). We use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their kids. A parent can access, change, or delete his or her kid’s personal information by logging on to the kid’s account (in which case the parent will need to have his or her kid’s email address and password), or by logging in to his/her own account if it is seamlessly linked to their child’s account. The login page contains instructions explaining how to recover a password if the kid has forgotten it. A parent can also contact us to access, change, or delete the personal information that we have collected from his or her kid by sending an e-mail to privacy@weplay.com. Please include the child’s email address and the parent’s e-mail address in the e-mail so that we can better assist you with your inquiry or request.
How will we notify parents if our Kids Policy changes?
We may amend this Kids Policy at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share kids’ personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Kids Policy only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.
What kinds of security measures do we take to safeguard your personally identifiable information?
The security measures for the Site are described in the “Network and Information Security” section of our general Privacy Policy.
Who do guests contact with questions or concerns about our Kids Policy?
The operator of this site is weplay, Inc. If you need further assistance, please send an e-mail with your questions, comments or concerns to privacy@weplay.com or contact as at:
Attn: weplay, Inc.
weplay, Inc. c/o MLB Advanced Media
75 Ninth Ave, 5th Floor
New York, NY 10011
We would be happy to assist you.