Updated: July 1st, 2013
Information we collect
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:
Non-Identifiable or Aggregated Data: When you interact with MindSnacks through the Services, we receive and store certain personally non-identifiable data. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. MindSnacks may store such information itself or such information may be included in databases owned and maintained by MindSnacks affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Services, the number of visitors to each page of our Site or game of our apps, the domain names of our visitors’ Internet service providers, and how our users use and interact with the MindSnacks Services.
Also, in an ongoing effort to better understand and serve the users of the Services, MindSnacks often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. MindSnacks may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. MindSnacks may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Our Use of Your Personal Data and Other Information
Our Disclosure of Your Personal Data and Other Information
MindSnacks is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: MindSnacks, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: MindSnacks may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of MindSnacks, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
You can use the Site without providing any Personal Data. Some of our mobile apps, for example those directed toward children under the age of 13, also do not require the provision of Personal Data. The remainder of our mobile apps, however, require users to provide Personal Data, specifically email address, in order to access the entirety of that app’s functionality. You may request that we delete your account, and any information associated with your account, but please note that we may be required (by law or otherwise) to retain this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete your information, it will be deleted from the active database but may remain in our archives.
Integrating Third Party Services within the Services
One of the special features of the Service is that it allows you to enable various online third party services, such as social media and networking services, (“Third Party Services”) to be directly integrated into your MindSnacks experience. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third Party Services. By enabling such Third Party Services, you are allowing us to pass your log-in information to these service providers for this purpose. When you add a Third Party Service account to the Service, we will collect your login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed solely by the policies of such third parties, and MindSnacks shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within the Service.
Security: MindSnacks takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
Other Terms and Conditions: Your access to and use of the Services is subject to the Terms of Service.
Access to Information; Contacting MindSnacks: To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
You may contact us as follows: email@example.com
MindSnacks cares about the online privacy of children, and therefore encourages parents and legal guardians to become involved in the online activities of their children and to discuss the child’s use of the Internet and disclosure of information to any parties.
As it relates to children’s privacy, MindSnacks develops two types of mobile apps:
1) The first is designed specifically for children under the age of 13, and includes, at this time, our Kids’ Vocabulary app. Apps of this type do not collect personally identifiable data of any form, nor do they require the creation of user accounts.
2) All other apps are general-audience apps designed for users 13 years of age or older. Full use of these apps requires the creation of user accounts and therefore the collection and submission of personally identifiable data. As stated in our Terms of Service, users under the age of 13 should not register for these apps.
If we obtain actual knowledge that a user of this second category of mobile apps is under 13 years old (for example through a survey or customer support email), MindSnacks acts according to the directives set by The Children’s Online Privacy Protection Act (COPPA). For general-audience apps where MindSnacks obtains actual knowledge that a user is under 13 years old, COPPA requires that website operators adhere to specific guidelines regarding the collection and handling of personally identifiable information about these children under the age of 13. For more information about COPPA and your child’s rights to online privacy, visit the Children’s Privacy section of the FTC’s website here.
COPPA requires that website operators provide parents with certain information and obtain parental consent prior to permitting children under the age of 13 to access or continue accessing Services that collect personally identifiable information.
A. What types of information do we collect about children?
1) Children can view content on our website without any personally identifiable data being collected.
2) During the registration process for our Kids’ Vocabulary app, we collect a username, but no email or password. We do not collect email addresses of children under the age of 13 (or of any other users of our child-directed apps).
3) During the registration process for our general audience mobile apps, we collect a user’s email address and password. Our Terms of Service states that children under the age of 13 should not register for our general audience mobile apps, and these general audience apps are not directed toward children under the age of 13.
All of our apps receive and store personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify a user or track his or her behavior across sites or apps.
B. How do we use and share the personally identifiable information that we have collected about children after receiving parental consent?
1) In general, we do not share personal information with third parties. That said, MindSnacks occasionally contracts with third parties that provide support for the internal operations of the Service. These contracted third parties do not use or disclose personal information except for the limited support role for which they have been contracted, examples of which are set forth below. In the rare event that we do possess personal information about children, we will not share it with these third parties unless we have Parental Consent as outlined by COPPA.
1a) To personalize communications from MindSnacks to a child (such as news and updates), we may use the child’s name, or the email address of the child’s parent or guardian. MindSnacks may, from time to time, contract with third parties to perform these communication services on its behalf and may disclose a child’s information to such third parties. In addition, personal information regarding a child may be disclosed in the course of a child’s participation in certain interactive features such as message boards.
1b) MindSnacks may also, from time to time, disclose a child’s information to affiliates or to third parties it has contracted with to perform certain services on its behalf or to administer certain member benefits.
C. How do we notify and obtain consent from parents for the collection of information from a child?
D. How can parents access, change or delete personally identifiable information about their child?
At any time parents can refuse to permit us to collect further personally identifiable data from their child and can request that any personally identifiable data we have collected be deleted from our records. Parents can access, change, or delete the personally identifiable data that we have collected from their child by contacting our customer service at firstname.lastname@example.org. Please include the e-mail address associated with the account so that we can better assist you with your inquiry or request.
F. Who do parents contact with questions?
If you need further assistance, please contact us at:MindSnacks, Inc.
ATTN: Legal Department
1479 Folsom Street
San Francisco, CA 94103
You may also telephone us at (415) 400-4626 or email us at email@example.com. (If you are not 18 years of age or older, you must have your parent or guardian’s permission to call this number.)
CONSENT OF PARENT OR LEGAL GUARDIAN
MindSnacks’ child-directed app (viz. Kids’ Vocab) does not collect personally identifiable data. Because we do not collect personally identifiable data, COPPA does not require us to collect consent from a parent or legal guardian -- nor could we since we do not collect the relevant contact information.