April 28, 2014
Note Regarding Third Parties
Information You Give Us
When you use our Service, you may provide information to us, including, for example: your name or nickname, email address, password, time zone, locale (country and language), personal photo, family photo, Video Mail (defined below), and Story Book (defined below) recordings. If you purchase through the Services or provide verifiable parental consent, we (or our third party service provider) will also hold your credit card numbers or other payment information. If you choose to invite your child to use the Service, you may provide information about your child to us, such as your child’s first name or nickname, month and year of birth, photo, special needs information, subjects to promote, characters to block, games, apps, and videos to include, time limit settings, violence filter settings, and additional languages you want your child to learn. If you choose to invite a Family Member (defined below) to use the Service, you may provide information about your Family Member to us, such as your Family Member’s name or nick name, photo, and email address. We may also combine information we collect from you with information we collect from your child and Family Members.
Information We Automatically Collect
When you use the Services, we automatically collect some information. We may collect information about your usage of and activity on our Services. When you visit our Site, information we may automatically log includes, for example, your operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before visiting our website, errors encountered, URLs visited, pages visited on our Services, time spent on such pages, and search information on our Services. When you download and use our Apps, or access the Services from your device, we may also log information related to your device. We may log, for example, your location, phone number, device type, serial number, device identifiers (e.g., IMEI, MEID, serial number, CID, MID, and eMCC ID Number or SIM card ID), the types and versions of mobile operating systems, applications and software you use, and time-stamped logs of data exchanges.
Local Shared Objects (“Flash Cookies”). We use local shared objects, also known as “Flash cookies,” to store your preferences such as volume control or to display content based upon what you view on our Site to personalize your visit. Third party partners may also provide certain features on our Site and display advertising based upon your Web browsing activity using Flash cookies to collect and store information. Flash cookies are different from other cookies because of the amount of, type of, and way in which data is stored. Cookie management tools provided by your browser usually will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here (or in the EU ). Click here to learn what cookie information is collected on our Site and your choices.
Information Collected Through Advertising
HTC Ads on Third Party Websites. We may use information collected using third-party cookies and web beacons on our Services and in our emails to deliver HTC-branded advertising displayed to you on third-party websites. We also may use cookie information to know when you return to our website after visiting these third-party websites. We use this and other information about you to try to understand your interests and show you relevant advertising about products and services that may interest you.
Use of Your Personal Information
HTC may use your personal information to:
- operate and improve our Site, products, Services, and marketing;
- provide you and your child with a personalized and customized experience, content, and recommendations across all our services;
- respond to your comments and questions and provide customer service;
- provide and deliver products and Services you request to you and your child, including administering your account and sending you reports on your child’s use of the Services;
- send you information related to your requests and purchases, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- communicate with you about upcoming events, news, and marketing about products and services offered by HTC and our selected partners (we do this per your choices below);
- link or combine your personal information with other information we get from third parties, to help understand you and your needs, and provide you with recommendations, and better service; and
- protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
We may create aggregated and de-identified data from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use aggregated and de-identified data for any purpose and disclose aggregated and de-identified data to third parties in our sole discretion.
Sharing Of Personal Information
Information You Share. The Services may allow you to connect and share your information with other people. You may also connect to, and share your information on, third party websites and services (e.g., Facebook). Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.
Information We Share. We may share your personal information as follows:
We may share your personal information for the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets. Business deals may include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
We may share personal information for legal, protection, security, and safety purposes, including:
- to comply with laws or regulatory requirements and to respond to lawful requests and legal process;
- in an emergency, including protecting the safety of our employees and agents, our customers, or any person.
We may share information with those who use the information to provide us services or do work for us.
We may share aggregated and de-identified data with others.
Where We Store Your Information; Transfer Of Your Information
Information Choices and Changes
Our marketing emails tell you how to “opt-out” of receiving marketing emails. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to us through our Contact Information below. You can request to change contact choices, marketing choices and to update, access or make other changes regarding your personal information. You may also make some of these changes by accessing your account management page.
You can use settings on your device and in your browser settings to change how we, and others, can collect certain information about you (e.g., by blocking certain cookies). Read your product manual for more information about device settings and see the Section titled “INFORMATION WE AUTOMATICALLY COLLECT” above.
Security of Your Personal Information
We strive to protect the personal information we get from you through our Services. Although we take steps to use and improve safeguards, no company can prevent every security risk or harm. If you become aware of a vulnerability affecting the Service please email us at the contact below to report it.
Your account lets you use a single user name and password to log on the Service. Please protect your user names and passwords to help prevent anyone from accessing your account.
We are not responsible for the security of third-party applications and services or the data those third-party applications and services may collect about you. Please ask those third parties how they keep your data safe.
Parental Accounts and Kid Mode. Only parents may create an account on the Service and access the “Parent Dashboard”. The “Standard Kid Mode” means the portion of the standard Service that may be accessed by children without Premium Membership. The “Premium Kid Mode” means the portion of the Service that may be accessed by children with paid Premium Membership and their parent’s Credit Card Consent. In addition to the above, from time to time in the sole discretion of Zoodles, Zoodles may offer certain users a “Promotional Standard Kid Mode”, which means the portion of the standard Service that may be accessed by children without Premium Membership but with their parent’s Credit Card Consent, or a “Promotional Premium Kid Mode”, which means the portion of the Service that may be accessed by children with free Premium Membership.
COPPA. Zoodles is required under the Children Online Privacy Protection Act to obtain verifiable parental consent in order to collect, use, or disclose personal information from children. You may provide consent for your child to use the Promotional Standard Kid Mode or Premium Kid Mode by providing your consent as directed by the Service and using your credit card (either to verify that you are an adult (with a small fee) or to purchase the Premium Membership, as applicable) (“Credit Card Consent”). Because the sharing of personal information is part of the nature of the Promotional Standard Kid Mode and Premium Kid Mode, we are not required to provide you the choice of allowing us to collect and use your child’s personal information but not disclose it to third parties. If you provided Credit Card Consent, you have agreed to the collection, use, and disclosure of your child’s personal information in accordance with this Children’s Policy. The consent applies to each child you add to your account.
Information Your Child Gives Us. When your child uses any version of Kid Mode, your child may provide us: their Drawings (described below). When your child uses our Promotional Standard Kid Mode or Premium Kid Mode, your child may provide us: their Video Mail (described below). Please note that we are prohibited from conditioning a child’s participation in a game, the offering of a prize, or another activity on the child’s disclosing more personal information than is reasonably necessary to participate in such activity.
Use of Your Child’s Personal Information. We may use your child’s personal information for the purposes described in the Section titled “USE OF YOUR PERSONAL INFORMATION” above.
Sharing of Your Child’s Personal Information. When your child uses any version of Kid Mode, Family Members (described below) may see your child’s Story Books and you may share your child’s photos with third parties. For Promotional Standard Kid Mode or Premium Kid Mode, you may share your child’s Drawings and Video Mail with third parties and Family Members may see your child’s Video Mail. We may share information to our service providers and acquirers and we may share information as necessary to support the internal operations of the Site and Service, as described in greater detail in the Section titled “INFORMATION WE SHARE” above.
Video Mail. The Video Mail feature of the Service is OFF by default, but you can choose to turn it on within your Parent Dashboard for the Promotional Standard Kid Mode or Premium Kid Mode. Once you turn on the Video Mail feature, you and your child can record short video messages (“Video Mail”). Family Members may record Video Mail as well. Your child may view Video Mail sent to your child by you or Family Members. You may view Video Mail sent to you by your child. A Family Member may view Video Mail sent to the Family Member by your child. You may review and delete all Video Mail.
Art Studio Drawings. The Art Studio Drawing feature of the Service allows your child to draw pictures (“Drawings”). For the Standard Kid Mode or Promotional Premium Kid Mode, the Drawings can be seen by you in the Parent Dashboard and your child in Kid Mode. For the Promotional Standard Kid Mode or Premium Kid Mode, the Drawings can also be seen by Family Members you forward the Drawings to. You may review and delete all Drawings.
Story Books. The Story Book feature of the Service allows you to record story books (“Story Books”) that your child can view. Family Members may record Story Books as well. Story Books can be seen by you in the Parent Dashboard, your child in Kid Mode, and Family Members. You may review and delete all Story Books.
Family Members. You can invite family members (e.g., grandparents, aunts, and uncles) to join your account (“Family Members”), in which case we will send them an invitation to join your account. If they accept such invitation, they may interact with your child in the Service, as described above. You are able to remove a Family Member’s access to your account at any time by following the directions in the Parent Dashboard.
Please note certain features above may be limited from time to time in the sole discretion of Zoodles.
Information Choices and Changes. HTC will retain your child’s personal information for only as long as is reasonably necessary to fulfill the purpose for which the information was collected. You may request deletion of your child’s personal information by contacting us directly (please see contact information below). In such case, we may terminate your child’s use of Promotional Standard Kid Mode or Premium Kid Mode Kid Mode (as applicable); unless you close your account, your child may continue to use Standard Kid Mode or Promotional Premium Kid Mode (as applicable). HTC will delete your child’s information using reasonable measures to protect against unauthorized access to, or use of, the information in connection with its deletion. This Children’s Policy provides a description of the specific types or categories of personal information collected by us from children. You may review your child’s personal information by contacting us directly (please see contact information below). You may at any time refuse to permit HTC’s further use or future online collection of your child’s personal information by terminating your child’s access to Promotional Standard Kid Mode or Premium Kid Mode (as applicable), and directing HTC to delete your child’s personal information (as described above); unless you close your account, your child may continue to use Standard Kid Mode or Promotional Premium Kid Mode (as applicable). We will follow reasonable procedures to ensure that the requestor is a parent of that child before processing any requests. We will not be liable for any disclosure made in good faith and following such reasonable procedures in responding to a request.
Security of Your Child’s Personal Information. Zoodles protects personal information it collects from children as described in the Section titled “SECURITY OF YOUR PERSONAL INFORMATION” above.
We welcome your comments or questions about this Policy. You may contact us at:
HTC America, Inc.
13920 SE Eastgate Way, Suite 200
Bellevue, WA 98005
Attention: Privacy Administrator
Third Party Operators
Third party operators on the Service are listed at the following link: http://www.zoodles.com/z2 and any third party providers of games, apps, and videos you add to the Service.