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Virtual Piggy Privacy Policy

LAST UPDATED: February 25, 2014

Click here for the PDF version

Oink SM by Virtual Piggy, Inc. (“Virtual Piggy,” “we,” or “us”) provides technology platforms designed for the management of the under-18 age group in the global online market. Oink SM; is an online system, provided by Virtual Piggy, Inc., that enables Parents (defined below) to control and guide youth through their online transactions and allows individuals to make authorized purchases from us and participating merchants.


We appreciate concern about online privacy issues and want you to be familiar with how we collect, use and disclose your Personal Information (as defined below).  This Privacy Policy (the “Policy”) governs  use by you or any authorized users on your account of any online service location (e.g., web site or mobile app) that posts a link to this Policy (each a “Site”) (including, without limitation, both mobile and online versions of our Sites), and also applies to use of interactive features, widgets (e.g., the Piggy Pick), plug-ins, applications, content, downloads and/or other services: (i) that we own and control and make available through a Site; or (ii) that posts a link to this Policy (collectively, the “Service”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, except to the extent we combine such data with Personal Information that we have ourselves collected under this Policy.  This Policy does not apply to our data collection activities offline or otherwise outside of our Service, unless otherwise set forth herein, nor does this Policy govern the collection, use or disclosure of information by any affiliate or subsidiary (collectively, “Affiliated Entities”) or by third parties. 


Our Services include a Site that is directed to Children and teens, but not primarily those under thirteen (13) years of age, which is at www.oink.oink.com (formerly www.virtualpiggykids.com and myvirtualpiggy.com) (“Youth Site”).  As more fully set forth in the Children’s Privacy Policy at Section 3 below, we may restrict certain activities based on age as required by the Children’s Online Privacy Protection Act (“COPPA”) in the United States.  Our other Services are intended for a general audience (“General Audience Sites”), but as a best practice we age screen certain functions for these sites as well. In all cases, we age screen account registration.  Our General Audience Sites include include www.oink.com and mall.oink.com.  Our Oink mobile apps have both youth and general audience experiences. 


To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of collection), those additional terms shall govern such data collection and use.


In addition, please review the Service’s Terms of Service, which governs your use of the Service. By using our Service, you consent to our Policy and Terms of Service and our collection, use and sharing of your information and data, and other activities, as described below.

 

Table of Contents

It is important that you read and understand the entire Policy before using the Service. To ease review, each Section below contains a heading that links to the full explanation.

1. Privacy Seals

2. Changes in this Privacy Policy

3. Children's Privacy Policy

4. Types of Information Collected

a. An Overview of the Information We Collect and How

b. Specific Information We Collect

5. How Information Is Used

6. How Personal Information Is Disclosed

7. Links and Third Party Sites

8. Third Party Services

9. Third Party Advertisers

10. Data Security

11. Changing or Deleting Information

12. Your California Privacy Rights

13. Your Rights Outside of the United States

14. Jurisdictional Issues

15. Contacting Us

 

1. Privacy Seals


Virtual Piggy has been awarded TRUSTe’s Privacy Seal signifying that this Policy and our practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your Personal Information.  The TRUSTe program covers the Site, www.oink.com.  TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions.  If you have questions or complaints regarding our Policy or practices, please contact us at [email protected].  If you are not satisfied with our response, you can contact TRUSTe here (https://feedback-form.truste.com/watchdog/request)


Additionally, this Policy and the certification seal shown on this page confirm that our Service abides by the terms of Entertainment Software Rating Board’s (“ESRB”) Privacy Certified Program. ESRB’s Privacy Certified Program is designed to ensure that a website’s information disclosure practices are responsible and appropriate. To protect your privacy, we have voluntarily undertaken this privacy initiative and all of our Services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection and use practices. As part of this privacy program, we are subject to frequent audits of our websites and other enforcement and accountability mechanisms administered independently by ESRB, including regarding compliance with U.S. Children’s privacy laws and regulations.

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2. Changes in this Privacy Policy


From time to time, we may need to change our Policy because of changes in the law, technology, our business, or our attempts to better serve user needs. If we decide to change our Policy, we may post the changes within the Policy itself, with an alert on the homepage or in other places we deem appropriate. If we change how we use your Personal Information, we may notify you here, by email, internal message system or by means of a notice on our homepage. We reserve the right to modify this Policy at any time, so please review it frequently. All information collected after any updates to the Policy may be subject to the new policy; provided, however, that Personal Information collected under a prior version of the Policy may not be used in a way materially different than allowed under the version of the Policy in effect at the time the data was collected unless you consent.

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3. Children's Privacy Policy


We share Parents’ concern about the safety of children online.  We comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and the new regulations implementing it, as revised effective July 1, 2013 (“COPPA Rule”), to the extent they apply to us and to our Services.  We do not knowingly collect Children’s Personal Information (defined below) from children under the age of 13 (each a “Child” and collectively “Children”) if doing so requires verified parental consent under COPPA.  We may collect from Children an email address of a parent, guardian or authorized adult (collectively, “Parent”) to provide notifications of a Child’s participation on the Youth Site, however, the notices include instructions to the Parent on how to terminate the notices and delete the Parent’s email address and the Child’s account.  Also, in connection with related customer service inquiries, we may collect Children’s Personal Information from Children where verified parental consent is not required, subject to compliance with the COPPA Rule (e.g., to respond to an inquiry or request from a Child).  “Children’s Personal Information” means personal information as defined in Section 312.2 of the COPPA Rule. Further, we undertake a variety of ways to minimize collecting Children’s Personal Information from Children, and to avoid the need for our participating merchants from doing so in connection with a Child’s initiation of a proposed e-commerce transaction. 


Only a Parent may fully activate a Sub Account (defined below) and fully activate a Virtual Piggy profile for a Child.  Otherwise, the Child’s activities on our Youth Site are restricted to browsing content and engaging in activities that do not require verified parental consent under COPPA.  A Parent who elects to create an account for their Child that permits more than such browsing, provides any Personal Information required to set up a Sub Account for that Child, including a profile and account profile(s) of Children, including the Child’s Virtual Piggy User ID and Password.  This way we are collecting such information from the Parent, not the Child, we can enable Parent controls and we can facilitate e-commerce transactions requested by the Child between the Parent and the merchant rather than between the Child and the merchant.  Even after a Parent has set up a Child’s profile and account, a Child’s use of our service and participation and access to the Youth Site is not conditional upon his/her providing any Children’s Personal Information that requires verified parental consent under COPPA.  Everything else necessary to facilitate merchant transactions comes from the Parent and the Parent can control what transactions can be facilitated by our Service.  Youth, 13 years of age and older, may submit Personal Information themselves and may be able to activate a fully functional Oink account without parental consent.


Our Youth Site is operated as a so-called mixed use site pursuant to Section 312.2 of the COPPA Rule and we accordingly employ efforts to prevent the collection, use and disclosure of Children’s Personal Information from users who identify themselves as under 13 without first complying with applicable notice and parental consent requirements of COPPA.  Without limitation, we do not make available to youth that we know to be under 13 years of age the ability to publicly post Children’s Personal Information on the Youth Site, including via third party social media plug-ins.  We may, however, make such tools available to youth that represent they are 13 years of age or older.  We also may provide youth, including Children, with tools to privately send an outbound-only message via the Service to their Parents, if their Parents have created a Primary Account (defined below) (e.g., transaction request message and wishlist submission).  In any event, a Child’s use of Oink and participation and access to the Youth Site will not be conditional upon his/her providing any more Personal Information than is reasonably necessary for them to participate in an activity on the Site.  We do not share Children’s Personal Information knowingly collected from a Child with any third party, other than our service providers and agents necessary to provide the Service, except to the extent permitted or compelled by applicable law (e.g., to law enforcement or in connection with public safety).  We may, however, share Personal Information collected from Parents (and youth 13 years of age and older) with third parties as otherwise set forth in the other Sections of this Policy.

We collect the following Non-Personal Information from Children when they use the Wishlist functionality via our Service: the url for the merchant site and the particular products, services, games or other items they wish to purchase from the merchant using the Service including a description and price of the item.  We may also allow Children to include a personalized message with a variety of requests to the Parent (such as, store permissions, funding options, shopping preferences, goals and Wishlist) where such requests and message are for the Parent’s benefit and not publicly available


Inquiries and requests regarding the collection, use, processing, sharing and transfer of Children’s Personal Information in connection with our Services, including to notify us that your Child may have submitted Personal Information to us without your consent, may be directed to us as set forth in Section 15 below.

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4. Types of Information Collected

a. An Overview of the Information We Collect and How

Individuals thirteen (13) years of age and above (“Individuals”) may create a functional Primary Oink Account (“Primary Account”). Only Parents may create profiles for other individuals (“Sub Accounts”). Other than Children’s Personal Information, which is addressed separately in Section 3 above, on the Service, as a Primary Account holder we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you and your family members personally, such as your first and last name, email address, phone numbers and home addresses (“Personal Information”); and (2) demographic information, such as information about you and your family member’s gender, age and potentially other information (“Demographic Information”).  Further, we may ask Sub Account holders, over the age of thirteen (13), for Personal Information. We may collect this information through various forms and in various places on the Service, including account registration forms, contact us forms, or when you otherwise interact with the Service.  To the extent we combine Demographic Information with your Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Policy.


In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we may treat it as Personal Information.


This Usage Information may include:

  • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to our Service;
  • the areas within our Service that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, among other information.

Demographic Information and Usage Information are collectively “Non-Personal Information”, except to the extent combined with Personal Information.

When you visit and interact with the Service, Virtual Piggy and its third party service providers may also collect other Non-Personal Information (for example, a catalog of the Site pages you visit). This Non-Personal Information is generally collected through the Service using various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

  • Server Log Files. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. IP addresses may be used for purposes such as calculating Site usage levels, helping diagnose problems with the Site’s servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
  • Mobile Device Data. Your Device Identifier such as UDID, ODIN, Apple IFA, etc. and use analytic tools in connection therewith.
  • Environmental Variables. Certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version may be automatically collected. These environmental variables are collected by most websites, and can be used to optimize your experience on the Site.
  • Cookies. A cookie is a small file placed on your computer’s hard drive when you visit a website. The cookie gives you a unique, random ID, and this ID enables our Site to readily recognize each user on a subsequent visit to our Site. For example, a cookie may indicate the preferences you selected on a prior visit. This facilitates more efficient browsing on subsequent visits, by using your preferences to customize the content and/or layout of our Site. We may use cookies in this fashion. We also use cookies to store encrypted user id/password to support a “remember me” option so that you do not have to log in again the next time you visit the Site. You are free to set your Web browsers to prevent the acceptance of cookies. However, if you do so, certain functionality of our Service may not work. We do not link the information we store in cookies to any Personal Information you submit while on our Site.


We may use Tracking Technologies for a variety of purposes, including:

  • Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality.
  • Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Service.
  • Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you sign in to our Service or keeping track of our specified preferences, including in terms of the presentation of content on our Service.
  • Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Service based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements, content that have been delivered to you. Further information on this, and your opt-out choices, is found in Section 5 and Section 9 below.


We obtain your consent to our information storage or collection practices by providing you with transparent information in our Policy and Cookie Statement and providing you with the opportunity to make a choice to disable cookies as set forth above. Please note that we are not required to obtain your consent to the information collection practices identified above that are strictly necessary. You have the right to object to other use of information storage or collection techniques and further information on this right for marketing-related purposes is found in Section 11 below.


There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Further, third parties may use Tracking Technologies with our Service. We may not control those Tracking Technologies and we are not responsible for them; provided, however, that on our Youth Site we require third parties to take steps to ensure that such activities are consistent with the requirement of COPPA for Children. You consent to potentially encountering third party Tracking Technologies in connection with use of our Service as described above and accept that our statements under this Policy do not apply to the Tracking Technologies or practices of such third parties, except to the extent of our COPPA obligations regarding the Youth Site. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

b. Specific Information We Collect

Without limitation, the following are examples of information we collect from you on the Service:


We may collect the following Personal Information from Individuals who are 13 years of age or older when they create an Oink account: first and last name, Child’s name, if applicable (Note: Only if a Child’s actual full name is provided by Parent, a Parent does NOT need to use Child’s actual name for a Child profile), street addresses, email addresses, and telephone numbers.


We may collect the following Non-Personal Information from Individuals when they create an Oink account: nickname for child profile (if applicable, and if a child’s actual name is not used), gender, date of birth, age and other Demographic Information about family members, time zone, information used as reminders of password and user IDs, transaction thresholds, allowances, budgets, preferences, lists, preferences, shopping behaviors, goals, personalized messages, comments, reviews, ratings, interests, and allowed merchants, websites and applications.


We may collect credit card and other payment system information from a Primary Account holder, including card number, expiration date, billing address and CVV number to use to process approved purchase transactions, which may be initiated by a Primary or Sub Account holder.  For security reasons, we do not store your sensitive credit card or payment system information on our servers; we use a third party hosting provider, to store and transmit that information via our application databases in accordance with PCI (Payment Card Industry) Data Security Standards.  Such vendor(s) are required by us to agree to abide by the terms of this Policy in connection with the use and protection of your data.


We also gather purchasing and transaction information based on purchases made using the Service for reporting to Primary Account holders and participating merchants and for facilitating payment processing and customer service.  This purchasing and transaction information may be compiled and analyzed on an individual, account and aggregated basis and used by us in connection with our Service. 


We collect the following Personal Information from merchant contact persons when they register on our Site to become a participating merchant: first and last name, email address, street address and phone number.  We also collect from merchants various types of Non-Personal Information.

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5. How Information Is Used


Our primary purpose for collecting information is to provide the Service. We use Personal Information in the following ways:

  • Purchase Transactions.  We may use Personal Information, including credit card and other payment system information, to process requested purchase transactions initiated by a Child using the Service and to enable the delivery of products purchased using the Service.  Purchase and transaction information may be used for reporting to Parents and participating merchants and processing transactions.
  • Notifications and Alerts.  Email and telephone numbers, and internal Service messaging, may be used to provide Primary and Sub Account holders (subject to COPPA requirements) with transaction alerts, approval requests or other reporting, notices or alerts.  We may also use a Parent’s email address provided by a Child to send an initial email notice to Parents regarding their Child’s use of the Youth Site, and will use it for subsequent notice regarding their Child’s activities unless the Parent elects to discontinue such notices. Additionally, we may send invitations and alerts to individuals as requested by the Primary or Sub Account holder, including invitations to provide funding, purchase a gift or view a wishlist.
  • Administrative Communications.  From time to time, in our sole discretion, we may use Personal Information to send you important information regarding the Service or the Site(s), changes to our terms, conditions, and policies and/or other administrative or transactional information.
  • Other Communications.  From time to time, we may use Personal Information to inform you of products, programs, services and promotions that we believe may be of interest to you.
  • Promotions.  We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”) through the Site.  We may ask Primary or Sub Account holders, if applicable, for certain Personal Information (such as name and email address) when entering and, if applicable, winning a Promotion.  You should carefully review the rules, if any, of each Promotion in which you participate through the Site, as they may contain additional important information about our use of Personal Information about you.  To the extent that the terms and conditions of such rules concerning the treatment of Personal Information about you conflict with this Policy, the terms and conditions of such rules shall control.
  • Internal Business Purposes.  We may also use Personal Information for our internal business purposes, such as audits, research and analysis to maintain, protect and improve the Service and the Site, ensure the technical functioning of the Service and the Site and develop new services.
  • Children’s Personal Information.   Notwithstanding anything to the contrary in this section, we only use Children’s Personal Information knowingly collected from a Child as set forth in Section 3 above.


As Non-Personal Information (excluding any Children’s Personal Information collected from a Child) does not personally identify Sub Account holders, if applicable,, we may use such information related to Primary and Sub Accounts that for a variety of purposes, such as helping us to provide you with the highest quality services.  In addition, we reserve the right to share such Non-Personal Information, which does not personally identify you or your Sub Account holders, if applicable,, with Affiliated Entities and other third parties, for any purpose, subject to Section 3 .  We may provide Non-Personal Information, including Demographic Information about Primary and Sub Accounts (subject to Section 3), such as gender, age, transaction or purchase history and wishlist items to participating merchants in order to assist them in tailoring their offerings to you, your Sub Account holders,, or otherwise.  We may use Non-Personal information such as account activity to order items in a preferred manner or to show or hide offers (e.g., offers that may no longer be available or that have already been used and cannot be used again) or show or hide tips or quizzes based on use and interests.

 

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6. How Personal Information Is Disclosed


We do not share, sell, rent or trade your Personal Information other than as disclosed below or otherwise within this Policy. We may disclose your Personal Information to third parties as follows:

  • Merchants and Transactions.  We may share with participating merchants and their agents and service providers Personal Information and other transaction information in connection with requested transactions, to facilitate authorized purchases and delivery of products purchased from the participating merchant using the Service and in connection with related customer service.  We may share credit card and other payment system information, and to the extent necessary other Personal Information, with participating merchants and their payment processors to process purchase transactions between you and a merchant, which if applicable, may be initiated by a Sub Account holder using the Service.
  • Third Party Service Providers. We work with third parties who provide services related to the operation of the Service, including, but not limited to, payment processing, operating and hosting our Site and/or our platform, data storage, email and/or text messaging delivery services, analytics, ad and content hosting and serving, and contractors who assist with programming and technical aspects of our Site. We reserve the right to share Personal Information with such third parties in connection with enabling them to provide such services.
  • Promotions. We reserve the right to share Personal Information in connection with promotions with third parties sponsors of such promotions (irrespective of whether such promotions are hosted by us), in accordance with the rules and notices applicable to such promotion. You should carefully review the rules and notices, if any, of each promotion in which you participate through the Site, as they may include opt-in or-opt out provisions regarding sharing of your Personal Information with third parties contain additional important information about a sponsor’s or other third parties’ use of your Personal Information. To the extent that the terms and conditions of such rules or notices conflict with this Policy, the terms and conditions of such rules or notices shall control.
  • Business Transfer / Change of Control. Subject to applicable law, we reserve the right to transfer any and all information that we collect to an Affiliated Entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Virtual Piggy’s business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • Law enforcement; emergencies; compliance. Subject to applicable law, we reserve the right to disclose Personal Information and any other information we collect as we believe to be appropriate (a) under applicable law; (b) to comply with legal process served on us, as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us; (c) to respond to governmental requests; (d) to enforce our Terms of Service; (e) to protect our operations or those of any Affiliated Entities; (f) to protect the rights, privacy, safety or property of Virtual Piggy, the Affiliated Entities, you or others; and (g) to respond to any claims and permit us to pursue available remedies or limit the damages that we may sustain.
  • Children’s Personal Information. Notwithstanding anything to the contrary in this section, we only transfer Children’s Personal Information knowingly collected from a Child as set forth in Section 3 above.

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7. Links and Third Party Sites.


The Service may contain links to third party websites or online services.  These linked locations (including, without limitation, the websites or online services of Affiliated Entities) are not under Virtual Piggy’s control and we are not responsible for the privacy practices, the contents of or any products or services sold from any such linked location.  We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked location by Virtual Piggy.  If you or your Sub Account holders, if applicable, provide Personal Information through any such third party website or service, your transaction may occur on such third party’s location (not the Service) and the Personal Information you provide may be collected by, and controlled by the privacy policy of that third party.  We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.  For your convenience, the following link below may take you to a list of our participating merchants along with links to their privacy policies, which list may be updated from time to time: http://www.oink.com/third-party-policies.

PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES AND PARTICIPATING MERCHANTS.

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8. Third Party Services.


You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.


The Service may include functionality that allows certain kinds of interactions between the Service and your account on a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Service, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Service, or otherwise link accounts. If we offer and you choose to use this functionality to access our Service, the third-party site or application may send Personal Information about you to the Service. If so, we will then treat it as Personal Information under this Policy, since we are collecting it as a result of your accessing of and interaction on our Service. In addition, we may provide third-party sites’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Policy. Virtual Piggy may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Service.


To the extent we permit such third party services to integrate with our Youth Site, we will require COPPA compliance in connection therewith for Children, as more fully set forth in Section 3. Older youth may be able to engage with such third party services via our Service without restriction.

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9. Third Party Advertisers.


The Service may use third parties to serve advertisements on the Service and may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing and serving of ads and of our content; provided, however, that we do not have third party advertising on the Youth Site. Network advertisers are third parties that display advertisements, which may be based on your visits to the Service. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested.


The Service’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain Usage Information regarding users of your Device via a Device Identifier. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.


Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third-party advertisers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.


However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. Further, while we may use a variety of companies to serve advertisements on the Service, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer may be allowed under their own rules to deliver targeted content and/or ads to you, which may affect this and other sites, but does not mean you may no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s web site accessible by the above link.

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10. Data Security


The security of your Personal Information is important to us.  We follow generally accepted industry standards to protect the information you submit to us.  Unfortunately, no data transmission over the Internet or other digital media can be guaranteed to be 100% secure.  Once we receive your information, we use HTTPS encryption to transmit sensitive information such as credit card numbers and user ID and passwords.  All Personal Information you provide for the Oink Service is stored on secure third party infrastructure in accordance with their security procedures and the Payment Card Industry Data Security Standard.  User ID and password are used to access and view the Personal Information and certain other Oink account information as well as to make a transaction using the Oink Service.  We recommend that you do not divulge and you inform your Sub Account holders, if any, that they not divulge Oink user IDs and passwords to anyone.  Ultimately, you are responsible for maintaining the secrecy of your Oink User IDs and passwords and Virtual Piggy shall not be responsible or liable in any way for damages or losses resulting from a Primary or Sub Account holder divulging or not protecting their user IDs and/or passwords.

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11. Changing or Deleting Information


If you or your Sub Account holders would like to review, correct, update or delete Personal Information or Non-Personal Information, you or they, as appropriate, may do so by logging into their Oink account and correcting, updating or in some cases deleting such information.  Please note that if required information (marked with an astersisk) is deleted, the Service may not function and may no longer be used in whole or in part.  A Primary Account holder may elect to close their account, in which event, any Sub Account profiles and Primary account will be deactivated such that the users cannot log-in nor transact.  Additionally, credit card expiration dates and any payment account tokens (e.g., PayPal) will be deleted.  If a Parent would like to remove a Sub Account profile from their Primary account, we will delete or null the Sub Account profile name, username, password, email address, and phone number, as applicable.  If you would like us to delete your Personal Information, send this request to [email protected]  If there have not been any transactions on the account, we will delete or null Primary Account holder last name, shipping address, payment account information, Child profile name, username, password, email addresses, and phone numbers, each as applicable within 30 days of receipt of your request.  In the event there have been transactions on the account, we will delete or null this same information except as required to support or report such transactions.  If a Primary Account holder is unable to correct, update or delete their information as described above or wishes to terminate his/her Sub Account and use of the Service other than to browse the Youth Site, they should contact Virtual Piggy at [email protected] with their specific request.  Please note that, as more fully explained above, we may need to retain certain transaction information for business record keeping and reporting purposes, and, notwithstanding anything to the contrary, there may also be residual information that may remain within our databases and other records, which may not be removed. 


We are not responsible for removing information from the databases of third parties with whom we have already shared information.  We may retain your information for as long as your Oink account is active or as needed to provide you services or to maintain reasonable business records, but undertake no duty to do so.  Notwithstanding anything to the contrary, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as permitted or required by applicable law.  If you no longer wish to receive electronic newsletters and/or promotional emails that we may send to you, you may opt-out of receiving them by following the opt-out instructions included in each newsletter or email.  If your attempts to opt-out by these methods are unsuccessful, you should email us at [email protected] with your request.  We may elect to also offer users the opportunity to opt-out of certain specific commercial emails, but not all, by logging into their Parent profile in their Oink account and updating the communication settings or as part of the unsubscribe options in the emails.  Even if you unsubscribe (i.e., opt-out) to commercial emails, we may still contact you for transactional purposes (e.g., to respond to a customer service request).

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12. Your California Privacy Rights.

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes if we do so without giving you the opportunity to opt-in or opt-out of such sharing. However, we do not automatically share our customer’s personal information (as defined by such law) with unaffiliated third parties for their own direct marketing purposes

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13. Your Rights Outside the United States


If you are resident in Europe, you have the right to ask us not to process certain of your personal data as defined under the applicable European data protection laws (or provide it to third parties to process) for marketing purposes. You can exercise your right, if applicable, to prevent such processing at any time by indicating who you are and any contact information you have previously provided to us, asking us to cease processing your personal data and indicating your jurisdiction of residence by contacting us as set forth in Section 15 below.


If you are located outside of the United States, please be aware that information we collect, including Personal Information, may be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Policy.


EU And Switzerland Residents


Personal information collected on our Site may be stored and processed in the United States. By using our Site you consent to any such transfer of information outside of your country.  Virtual Piggy complies with the U.S.-E.U. Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Virtual Piggy has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement.  To learn more about the Safe Harbor program, and to view Virtual Piggy’s certification, please visit http://www.export.gov/safeharbor/.

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14. Jurisdictional Issues.


The Site is controlled and operated by Virtual Piggy from the United States, and is primarily intended for users located in the United States and Europe. Virtual Piggy does not represent or warrant that the Site or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

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15. Contacting Us.


If you have any questions regarding this Policy or our information practices, please contact us by email at [email protected], or write us at the address below or call (310) 853-1950.  Please note that email communications may not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.

Virtual Piggy, Inc.
1221 Hermosa Ave., Suite 210
Hermosa Beach, CA 90254
Attention: Customer Service

Virtual Piggy, Inc. is a licensee of the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy inquiry or your privacy inquiry has not been satisfactorily addressed, please contact ESRB at http://www.esrb.org/privacy/contact.jsp, or contact:

ESRB
Attn.: Director, Privacy Online
317 Madison Avenue, 22nd Floor
New York, NY 10017
[email protected]

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© Copyright 2013 Virtual Piggy, Inc. All rights reserved.

 ///End of Policy///

The following third parties that collect information from you on the Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

Party

Service

For More Information

Use of Tracking Technologies

Privacy Choices

Google/Doubleclick

Google Analytics for Display Advertisers, Ads Preferences Manager, and Google Analytics Opt-out Browser Add-on

http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409

http://www.google.com/settings/ads/onweb/?hl=en&sig=ACi0TCg8VN3Fad5_pDOsAS8a4...

https://tools.google.com/dlpage/gaoptout/

Yes

See information links in prior column

PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and may add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the applicable third parties regarding their privacy and data security policies and practices.

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