LAST UPDATED: November 19, 2012
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Virtual Piggy, Inc. ("Virtual Piggy" "we," "us") provides technology platforms designed for the management of the under 18 age group in the global online market. Virtual Piggy™ is an online system, provided by Virtual Piggy, Inc., that enables parents to control and guide their children through their online transactions and allows children to make parent authorized purchases through the Internet (the “Service”).
We are concerned 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") describes our practices in connection with Personal Information that we collect through our website located at www.virtualpiggy.com and https://live.virtualpiggy.com (the "Site"). This Policy does not address our practices regarding information that we collect through any website, or by any other means, other than through the Site; nor does this Policy govern the collection, use or disclosure of information by any affiliate or subsidiary (collectively, "Affiliated Entities") or by third parties .
By using the Site, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site and email us at privacy@virtualpiggy.com to let us know your concern.
Virtual Piggy has been awarded TRUSTe's Privacy Seal signifying that this privacy 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.virtualpiggy.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 privacy policy or practices, please contact us at privacy@virtualpiggy.com. If you are not satisfied with our response you can contact TRUSTe here
Additionally, this Privacy Policy and the certification seal shown on this page confirm that our website submits to the terms of ESRB’s Privacy Online Program. ESRB’s Privacy Online 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 websites have been reviewed and certified by ESRB Privacy Online 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.
Table of Contents
1. Changes in this Privacy Policy
2. Children Under 13 Years of Age
3. Types of Information Collected
5. How Personal Information Is Disclosed
6. Links and Third Party Sites
8. Changing or Deleting Information
9. Your California Privacy Rights
1. Changes in this Privacy Policy
From time to time, we may need to change our Privacy Policy because of changes in the law, technology, our business, or our attempts to better serve user needs. If we decide to change our Privacy Policy, we will post the changes within the Privacy Policy itself, with an alert on the homepage or in other places we deem appropriate. If we change how we use your Personal Information (defined below), we will notify you here, by email, or by means of a notice on our homepage. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. All information collected after any updates to the Privacy Policy will be subject to the new policy. If we make material changes to how we use the Personal Information (defined below) collected from children under age 13, we will notify Parents by email in order to obtain verifiable parental consent for the new use of the child’s Personal Information, to the extent required by law.
2. Children Under 13 Years of Age
We are very concerned about the safety of children online. We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) to the extent it applies to us and to our Site. We do not knowingly collect Personal Information from children under the age of 13. Only a parent, guardian or authorized adult (“Parent”) may create a Virtual Piggy account for a child. The Parent provides all information required to set up a parent profile and child profile(s), including the child’s Virtual Piggy User ID and Password. A child’s use of Virtual Piggy and participation and access to the Site is currently not conditional upon his/her providing any Personal Information - they only need their Virtual Piggy User ID and Password. In any event, a child’s use of Virtual Piggy and participation and access to the 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. Parents have a right to consent to our use of their child’s Personal Information without having to consent to the disclosure of that information to third parties, as we do not share your child’s Personal Information with any third party, other than service providers and agents necessary to provide the Service.
3. Types of Information Collected
Virtual Piggy gathers two types of information through the Site: "Personal Information" and "Non-Personal Information". Personal Information is information collected online that can be used to identify, contact or locate an individual. Non-Personal Information is information that does not reveal an individual’s specific identity, such as aggregated information, demographic information and IP addresses. We may associate your Non-Personal Information with your Personal Information.
We collect the following Personal Information from Parents when they create a Virtual Piggy account: Parent’s first and last name, child name (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 address, zip code, email addresses, telephone numbers, Parent user ID and profile name/password, child user ID and child profile name/password.
We collect the following Non-Personal Information from Parents when they create a Virtual Piggy account: nickname for child profile (if child’s actual name is not used), gender, date of birth, age and other demographic information about the child, time zone, information used as reminders of password and user IDs, transaction thresholds, allowed merchants, websites and applications. We collect credit card information from a Parent, including card number, expiration date, billing address and CVV number to use to process approved purchase transactions initiated by a child using their Virtual Piggy account. For security reasons, we do not store your credit card information on our servers; we use GSI Hosting, a third party hosting provider, to store and transmit that information in accordance with PCI (Payment Card Industry) Data Security Standards. GSI Hosting has agreed to abide by the terms of our privacy policy. We also gather purchasing and transaction information based on purchases made using the Virtual Piggy service for reporting to Parents and participating merchants. This purchasing and transaction information may be compiled and analyzed on an individual, account and aggregated basis and used by us for any purpose.
We collect the following Non-Personal Information from children (a) when they use the Wishlist functionality on our Site or a merchant’s site: 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, and (b) particular merchants they would like their Parents authorize as approved merchants.
We collect the following Personal Information from merchants 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 the following Non-Personal Information: primary business contact details and primary technical contact details.
When you visit and interact with the Site, 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 Site from server log files, environmental variables and cookies.
- 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.
- 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 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 text 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, you will not be able to use the ”remember me” option on our Site. We do not link the information we store in cookies to any Personal Information you submit while on our Site. Some of our service providers may use cookies on our Site. We have no access to or control over these cookies. This privacy policy covers the use of cookies by us and does not cover the use of cookies by any third-party providers.
4. 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 will use Personal Information and credit card information to process approved purchase transactions initiated by a child using the Virtual Piggy Service and to enable the delivery of products purchased using the Virtual Piggy Service. Purchase and transaction information will be used for reporting to Parents and participating merchants.
- Notifications and Alerts. Email and telephone numbers will be used to provide Parents with transaction alerts, approval requests or other reporting, notices or alerts that Parents elect to receive in their parent profiles, child profiles or otherwise as part of the Virtual Piggy Service.
- Administrative Communications.From time to time, in our sole discretion, we may use Personal Information to send to you important information regarding the Service or the Site, changes to our terms, conditions, and policies and/or other administrative 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 you or your child for certain Personal Information (such as name and email address) when you enter and, if applicable, win 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.
As Non-Personal Information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-Personal Information, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose. We may provide Non-Personal Information, including demographic information about you and/or your child, such as gender, age, transaction or purchase history and wishlist items to participating merchants in order to assist them in tailoring their offerings to your child or otherwise.
5. 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 Privacy Policy.
- Purchase Transaction Merchants. We will share with participating merchants and their agents and service providers transaction information for authorized purchases and your physical address for delivery of products purchased from the participating merchant using the Virtual Piggy Service. We will share credit card information and to the extent necessary Personal Information with participating merchants and their payment processors to process approved purchase transactions initiated by a child using the Virtual Piggy Service.
- Third Party Service Providers. We work with third parties who provide services including, but not limited to, credit card processing, operating and hosting our Site and/or our platform, data storage, email and/or text messaging delivery services and contractors who assist with programming and technical aspects of our Site. We reserve the right to share Personal Information with such third parties for the sole purpose of 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 applicable to such promotion. For California residents, please refer to your rights here. 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 a sponsor's or other third parties' use of your Personal Information. To the extent that the terms and conditions of such rules conflict with this Policy, the terms and conditions of such rules shall control. If you do not wish to have your Personal Information shared with third parties, you should not participate in our promotions.
- Assignment.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. 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 User Agreement and terms and conditions of the 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.
6. Links and Third Party Sites.
The Site may contain links to third party websites. These linked sites (including without limitation the websites 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 site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Virtual Piggy. If you provide Personal Information through any such third party website, your transaction will occur on such third party's website (not the Site) and the Personal Information you provide will 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 will take you to a list of our Affiliated Merchants along with links to their privacy policies, which list may be updated from time to time: http://www.virtualpiggy.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.
7. 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 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 Virtual Piggy 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 so that only the Parent can access and view the Personal Information and certain other Virtual Piggy account information and a child’s User ID and password are needed to make a transaction using the Virtual Piggy Service. We recommend that you do not divulge and you inform your children that they not divulge Virtual Piggy user IDs and passwords to anyone. Ultimately, you are responsible for maintaining the secrecy of your Virtual Piggy User IDs and passwords and Virtual Piggy shall not be responsible or liable in any way for damages or losses resulting from a Parent or child divulging or not protecting their user IDs and/or passwords.
8. Changing or Deleting Information.
If Parents would like to review, correct, update or delete Personal Information or Non-Personal Information that was previously provided by Parents to us through the Site, they may do so by logging into their Virtual Piggy account and correcting, updating or deleting such information in the Parent profile or child profile(s). Please note that if required information (marked with an asterisk) is deleted, the Virtual Piggy Service will not function and can no longer be used. If a Parent deletes all information from the Parent profile their Virtual Piggy account will be closed and all information except transaction information will be removed from our system. Parents may also elect to delete an entire child profile, in which event such child may no longer use the Virtual Piggy Service. If a Parent is unable to correct, update or delete their information as described above or wishes to refuse further contact with their child by the Site, they should contact Virtual Piggy at privacy@virtualpiggy.com with their specific request. Please note that we may need to retain certain transaction information for record keeping and reporting purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We are not responsible for removing information from the databases of third parties with whom we have already shared information. We will retain your information for as long as your Virtual Piggy Account is active or as needed to provide you services. If you wish to cancel your Virtual Piggy Account or request that we no longer use your Personal Information to provide you Services, Parents should log into their Parent profile in their Virtual Piggy Account and select the “delete” button, and if your attempt to close your account online is unsuccessful, you should contact us at privacy@virtualpiggy.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 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, or logging into your Parent profile and changing the Virtual Piggy communications switch to “off”. If your attempts to opt-out by these methods are unsuccessful, you should email us at privacy@virtualpiggy.com with your request. We also offer Parents the opportunity to opt-out of certain communications by logging into their Parent profile in their Virtual Piggy account and updating the communication settings.
9. Your California Privacy Rights.
Since 2005, 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. However, we do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquires regarding our disclosure policy, please send us an e-mail or write us:
Virtual Piggy, Inc.
Attention: Customer Service
1221 Hermosa Ave., Suite 210
Hermosa Beach, CA 90254
(310) 853-1950
privacy@virtualpiggy.com
10. Third Party Services
We allow Parents to use their Open ID credentials to sign up for our Service. How this works is a Parent enters a userid /password from one of the open ID providers (like Google for example) and we pull in information from their profile so that they will not need to enter the same information again. This is restricted to email address, userid /password. We do not share any Personal Information with the open ID providers; rather we get information from open ID providers to make the sign up process easier for Parents.
11. Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit our Site. Please note that these companies may use information (not including Personal Information) about your visit to this Site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to this Site, these companies may place or recognize a unique cookie on your browser. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit http://www.networkadvertising.org/managing.
12. Jurisdictional Issues.
The Site is controlled and operated by Virtual Piggy from the United States, and is not intended to subject Virtual Piggy or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. 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.
13. Contacting Us.
If you have any questions regarding this Policy or our information practices, please contact us by e-mail at privacy@virtualpiggy.com, write us at the address below or call (310) 853-1950. Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your e-mail 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 Online 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
privacy@esrb.org
© Copyright 2012 Virtual Piggy, Inc. All rights reserved.
