I. INFORMATION THAT WE COLLECT ON OR THROUGH THE SERVICES
A. Personal Information
All Visitors: Visitors to the Services that are over 18 may register and opt-in to receive Common Sense Networks email newsletters by providing their email address and zip code. Please note that our newsletters are not currently available to any Registered Users under the age of 18. If you are a visitor who is under 18 you should not attempt to sign-up for our newsletters.
We also may collect Personal Information through surveys or questionnaires. Your participation in surveys and questionnaires is entirely voluntary.
Adult Registered Users: If you wish to become a Registered User, you must be 18 or older and provide us with certain Personal Information as part of the registration process, including, for example, name, email address, password and age. We additionally ask for zip code or country of residence. The Service does not allow for Social Sign-on or log-in. Registration must be done directly on the Service.
If you are an adult Registered User, you may also optionally choose to provide us with information about your children to create profile(s) for each child, such as their ages and first names, so we can present an experience tailored to the age of the child in the Services and within our email newsletters. The profiles that you may create for children are not publicly available on the Service.
Account Deletion: If you decide that you no longer want to be a Registered User, you can delete your account and your child’s profile information at any time. To delete your account, login to your account, visit your Account Settings page, and then click the "Close my Account" link located towards the bottom of the page. Once you delete your account, all of your Personal Information stored in your account and Profile on our site will be removed. Or, you can contact us at email@example.com request that we delete your content and account for you.
While we do allow registered users to delete their accounts and profiles on the Service, note that the California Consumer Privacy Act (“CCPA”) does not apply to the Services because we do not buy or sell consumer Personal Information. However, we support the legislation and encourage you to learn more about your rights at www.donotsell.org.
B. Collection of Information by Our Service Providers
C. Cookies and Other Technologies
Certain information, like aggregated information or high-level location information, such as the browser language and country during the user session, is treated as non-personal information unless applicable law requires otherwise. We may use or disclose such information for any purpose. We will utilize analytics solutions, which ultimately leverage cookies. We are not sharing or selling this data with third parties. We will be tracking based on a User Profile ID. For instance, we may compile and share aggregate data about the geographic locations or other demographics of our Registered Users, provided that this information does not personally identify any of these Registered Users.
II. HOW WE USE INFORMATION COLLECTED ON THE SITE
A. How We Use Personal Information
We use Personal Information to process requests made through our Services, such as requests or comments submitted through our Services. You may opt-out of receiving any email communication from us at any time by clicking the "unsubscribe" or “manage my email preferences” links located at the bottom of newsletters, or by sending a request to firstname.lastname@example.org.
Fulfillment of Requests. We may use Personal Information about you to fulfill the purpose for which such information was provided (e.g., to send newsletters to you or respond to your requests or inquiries and provide related customer service).
Additional Communications. If you register to become a Registered User of our community or sign up to receive one of our e-newsletters, we may use the Personal Information submitted in connection with your application to contact you with surveys or important communications regarding Common Sense Networks. We may additionally use Personal Information to contact you about Common Sense Networks content, features, opportunities, and products that may be of interest to you; provided that we will not include third party products or promotional content in any communications to Registered Users unless we request and receive opt-ins from Registered Users to receive such messages or communication.
Internal Operations and Analysis. We may also use Personal Information about you for our internal business purposes, such as data analysis, audits, enhancing or modifying our products and services, and so forth.
Other uses. Personal Information may be used for certain other internal operations of the Service, including maintaining or analyzing the functioning of the Service, performing network communications, authenticating users to the Service or personalizing content, serving contextual ads or frequency capping, protecting the security or integrity of the user or the site, legal or regulatory compliance, or fulfilling a child’s request under the one-time contact or multiple contact exceptions.
We may also use Personal Information to personalize your experience on the Services by presenting content and market opportunities and products tailored to you and to allow you to participate in sweepstakes, contests and similar promotions and to administer these activities; provided that we will not include third party products or promotional content in any communications to Registered Users unless we request and receive opt-ins from Registered Users to receive such messages or communication.
III. HOW WE DISCLOSE INFORMATION COLLECTED ON THE SERVICES
Except as expressly provided in this Policy, we will not share any Personal Information about you without your prior consent.
Profile Information. Each Registered User may have a Profile on the Site, which may include the Registered User's name or screen name and registration date. You can change or remove information from your Profile by logging into the Site and clicking the "My Account" links located in your personal Account section.
Third-Party Service Providers. We work with third-parties who provide services such as data analysis, payment processing, order fulfillment, infrastructure provision, information technology services, content personalization, email delivery services, and market research or third-parties who provide other services to help improve or operate our Services. We may share Personal Information about you with third-parties solely for the purpose of enabling them to provide these services to us. These service providers are given access to Personal Information needed to perform their functions, but are restricted from using the Personal Information for purposes other than providing services for us. When we engage a third-party who will need to access and process your Personal Information as part of their services, we ascertain that the third-party is capable and obligated to provide at least the same level of data privacy and protection as we hold ourselves to. Our third-parties are required to notify us if they determine they can no longer meet the expected level of data privacy and protection, and we monitor for compliance to our data protection terms based on the nature of the services being provided.
Law Enforcement; Emergencies; Compliance. Notwithstanding any other provision of this Policy to the contrary, we reserve the right to use your Personal Information, and to disclose it to others, as we believe to be necessary or appropriate: (a) under a requirement of applicable law, (b) to comply with legal process, (c) to respond to governmental requests, (d) to enforce our Terms of Service, (e) to protect our operations, (f) for assistance in fraud detection and prevention; (g) to protect the rights, privacy, safety or property of Common Sense Networks, you or others, (h) to permit us to pursue available remedies or limit the damages that we may sustain, and (i) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as the sale of the Site or Services, a merger, consolidation, reorganization, joint venture, assignment, or bankruptcy or similar proceedings.
Personal Information about you may be transferred, stored, and processed by us or the third-parties we work with in countries whose data protection laws and regulations may be different to those of your country. We allow transfers of Personal Information made between countries or regions in a fashion that complies with applicable law.
VI. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We keep your Personal Information only for as long as it is warranted to provide our Services, fulfill our commitments to you, and/or adhere to legal or regulatory requirements. If you are a Registered User, we keep your Personal Information for the duration of our relationship. Certain Personal Information may be kept and archived for longer though, as required for recordkeeping purposes or backing up Services’ data for example. When Personal Information has expired, or is no longer needed and does not have to be retained, we may return, delete, destroy, or anonymize it, epending on what method is systematically and procedurally possible, most secure, and what our related retention commitments are.
VII. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Advertising. CSN is committed to the highest standards for safe kids advertising and complies with the Children’s Online Privacy Protection Act (COPPA) and all relevant regulations. In order to make the Service free for users, however, the Service will contain advertising, but the advertising will only contain contextual display advertising and will not use User Information to target advertisements. Please refer to Section II.A for relevant uses of Personal Information as relates to advertising operations. In addition, you may request a copy of the CSN Ad Guidelines by emailing email@example.com.
Links. For your convenience and information, we may provide links to websites and other third-party services and content that is not owned or operated by us. The third-party websites, services and content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. The inclusion of a link or such third-party services/content on the Services does not imply our endorsement of the linked site, or that content or service.
Security. We seek to use reasonable administrative, organizational, technical, and physical measures to help protect the Personal Information you provide to us from loss, misuse, and unauthorized disclosure, alteration, or destruction. Only authorized personnel have access to Personal Information you provide to us and each employee with access to Personal Information is obligated to maintain its integrity and confidentiality. User data for the Services is encrypted both in transit and at rest. Unfortunately, no data transmission can be guaranteed to be 100% secure or error free. If you have reason to believe that your interaction with us is no longer secure, you should immediately notify us in accordance with the section below entitled "Contacting Us." Please note that if you notify us by physical mail, this will delay the time it takes for us to respond to the problem. We follow all industry standard security protocols and safeguards against breach, but in the unlikely case of a security breach, we will notify all Registered Users of such breach within 48 hours of its occurrence.
VIII. CONTACTING US
If you have any questions or requests about this Policy, or the practices of the Services, please contact us firstname.lastname@example.org write to us at:
Common Sense Networks
699 8th Street, Suite C150
San Francisco, CA 94103
The following describes Personal Data that is collected in the Service.
Category of Personal Data collected: Identity Data What this includes: Adult Registered Users: Name, username or similar identifier, age, and password and other log-in credentials. Adult Registered Users’ children: If our Adult Registered Users choose to provide it to us, we may also receive the ages and first names of Adult Registered Users’ children.
Category of Personal Data collected: Contact Data What this includes: Adult Registered Users: zip/postal code email address.
Category of Personal Data collected: Parental Data What this includes: Any other Personal Data that you choose to provide us during the course of our correspondence relating to the administration of your Profile.
Category of Personal Data collected: Communication Interaction Data What this includes: Adult Registered Users: information about your engagement with our email newsletters that is collected by the User Profile ID referred to in Section I.C. above describing Cookies.
Category of Personal Data collected: Analytics Data What this includes: We use Google Analytics to collect certain internet log information and the details of the behaviour patterns of people who visit the Site. We configure Google Analytics and to avoid collecting any information which could directly identify a person. We do not seek to identify those visitors whose interactions with the Site are being monitored.
Category of Personal Data collected: Survey Data What this includes: Depending on the survey, in addition to certain Identity Data and Contact Data, we will also collect any other information requested by, or that you submit in response to, a survey (e.g., opinions of parents and other respondents).