Disney Children's Privacy Policy

DATED 2016-08-04 · VERSION 20161001_rev01 · COMPARED WITH 20160802_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20160802_rev01 to 20161001_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

+****Updated: 7/14/2016****
+**Updated: 08/04/2016**
 The Walt Disney Family of Companies ("TWDC"), including for example Club Penguin and MarvelKids, is committed to protecting the privacy of children who use our sites and applications. This Children's Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 ("child" or "children"), and uses terms that are defined in our general [Privacy Policy](https://disneyprivacycenter.com/privacy-policy/). This policy is in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA"), and outlines our practices in the United States and Latin America regarding children's personal information. For more information about COPPA and general tips about protecting children's online privacy, please visit [OnGuard Online](http://www.onguardonline.gov/articles/0031-protecting-your-childs-privacy-online).
+TWDC has received TRUSTe's Privacy Seal signifying that this Children's Online Privacy Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification only applies to the digital properties listed on the validation page. If you have questions or concerns regarding our Children's Online Privacy Policy or practices, please contact us at the contact information located in Section 3 below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.
+TWDC has received TRUSTe's Privacy Seal signifying that this Children's Online Privacy Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification only applies to the digital properties listed on the validation page. If you have questions or concerns regarding our Children's Online Privacy Policy or practices, please contact us at the contact information located in Section 3 below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at [https://feedback-form.truste.com/watchdog/request](https://feedback-form.truste.com/watchdog/request).
 #### 1\. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents
 TWDC offers to its users a range of sites and applications, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our sites and applications offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA's requirements, we will either delete the information or immediately seek the parent's consent for that collection.
 ****Registration****
 Children can, in many cases, register with our sites and applications to view content, play games, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian's email address, the child's first name and gender, the child's member or account username, and password. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
+****About the collection of parent email address:**** Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at [privacycontact@disney.com](mailto:privacycontact@disney.com). We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
+**About the collection of parent email address:** Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at [privacycontact@disney.com](mailto:privacycontact@disney.com). We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
 ****Content Generated by a Child****
 Certain activities on our sites and applications allow children to create or manipulate content and save it with TWDC. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, TWDC also plans to post the content publicly or share it with a third party for the third party's own use, we will obtain a higher level of parental consent.
+****About Verifiable Parental Consent:****
+**About Verifiable Parental Consent:**
+****Email Consent.**** In the event TWDC wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian's consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
+**Email Consent.** In the event TWDC wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian's consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
+****High-Level Consent.**** In the event TWDC collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such "high-level" methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent's identity.
+**High-Level Consent.** In the event TWDC collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such "high-level" methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent's identity.
+****Teacher consent in lieu of a parent.**** With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child's educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the [FERPA site](http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html).
+**Teacher consent in lieu of a parent.** With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child's educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the [FERPA site](http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html).
 ****Chat****
 Certain games and activities that are directed to children allow users to communicate directly with other users by means of a chat system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
 Where TWDC employs a chat system that does not filter all or nearly all personal information, we will first seek high-level consent from the parent.
 ****Contests and Sweepstakes****
 For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
+Of course, some contests and sweepstakes ask the child to submit their own created content along with the child's entry. In those instances, we may require parental consent prior to submission. Please see [Content Generated by a Child]() above for more information on our collection, notice, and consent policies.
+Of course, some contests and sweepstakes ask the child to submit their own created content along with the child's entry. In those instances, we may require parental consent prior to submission. Please see [Content Generated by a Child](https://disneyprivacycenter.com/kids-privacy-policy/english/) above for more information on our collection, notice, and consent policies.
 ****Email Contact with a Child****
 On occasion, in order to respond to a question or request from a child, TWDC may need to ask for the child's online contact information, such as an email address. TWDC will delete this information immediately after responding to the question or request.
 In connection with certain activities or services, we may collect a child's online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child's online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a site, game/activity, television show, personality/character, or feature movie. Whenever we collect a child's online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child's information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to "opt-out" of each communication individually.
 #### 3\. Parental Choices and Controls
 At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
 Where a child has registered for a Disney.com account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
+. Parents can request access to and delete their child's personal information by logging on to the child's account through the Member Services Home Page located [here](https://secured.clubpenguin.com/parent-tools/login). Parents will need their child's username and password. The Your Account home page explains how to recover a password if the child cannot recall it.
+. Parents can request access to and delete their child's personal information by logging on to the child's account through the Member Services Home Page located [here](). Parents will need their child's username and password. The Your Account home page explains how to recover a password if the child cannot recall it.
 . Parents can contact Guest Services to request access to, change, or delete their child's personal information by sending an email to us at [ms\_support@help.go.com](mailto:ms_support@help.go.com). A valid request to delete personal information will be accommodated within a reasonable time.
 Parents of Club Penguin users may contact Club Penguin directly at:
 Club Penguin
 c/o Disney Canada Inc.
 Burbank, CA 91521-7667
 United States of America
 Phone: (877) 466-6669 (US and Canada)
 Email: [privacycontact@disney.com](mailto:privacycontact@disney.com)
 In any correspondence such as e-mail or mail, please include the child's username and the parent's email address and telephone number. To protect children's privacy and security, we will take reasonable steps to help verify a parent's identity before granting access to any personal information.
+- [Children's Online Privacy Policy](https://disneyprivacycenter.com/kids-privacy-policy/english/)
+- [Spanish - Latin American](https://disneyprivacycenter.com/kids-privacy-policy/spanish-latin-american/)
+© Disney. All rights reserved.