At codeSpark we care very much about your privacy. As creators of apps for children, we aim to follow the best practices as specified by the “Know what’s inside” program and the kidSAFE Seal Program,and aim to comply with The Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, please reference this simple one-page informational guide from the kidSAFE Seal Program: www.kidsafeseal.com/knowaboutcoppa.html.

We strive to be upfront about what our Apps contain, so there are no hidden surprises. This Privacy Policy describes the ways in which codeSpark, Inc. (collectively, “Company” or “We”) collects, uses and discloses information about you and the children who use the codeSpark websites (the “Site”), applications (“Apps”) and online products and services that link to this policy (collectively, the “Services”). By using the Services you agree to the handling of your information in accordance with this Privacy Policy.

A few key points upfront:

• The Services do not include any pop up ads or other third party advertisements.
• During registration the only information we may ask you to provide about a child/student who will be using the Services is the child’s first name and last initial.
• Other than the fees for purchasing a subscription for the Services, where applicable, there are no in app purchases.
• You have the right to request a copy to review and delete the information We have collected about you at any time.

WHAT KIND OF INFORMATION WE COLLECT

In the course of providing our Services, We collect certain information. Some of the information you give us, like your email address and country location. Other information We collect automatically as you use the Services, like your logging in activities. We only collect your information in furtherance of our legitimate interest of providing you with our Services, and to improve the Services, and we do not sell this information.

Automatic Collection: Like most digital companies, we may use common technologies such as cookies and other technologies to better understand users’ interactions with our games, websites and other services (the “Services”). These technologies help us keep track of user behavior, tell us which parts of our Services people have visited and are using, and facilitate and measure the effectiveness of activities. If you use any of our Services, we may also collect data related to the device on which the App is loaded. In particular, for analytics, we are using third party services of Mixpanel and Google Analytics. They store this data securely and do not share it with anyone else. We are using a restricted version of their analytics product designed for use with apps for children, meaning that the anonymous data created from our Apps isn’t used anywhere else in their system, it’s only for us to improve the apps, including information on App crashes, usage time, games played and problems missed.

Volunteered: In order for you to use the Services, you must create an account. This account safeguards the work you create on codeSpark, allows you access your work from multiple devices, and allows multiple related people to use codeSpark on the same device. When you (parents and teachers) create an account, register with us, send us an email, or provide other information with us in any other way, we will collect and store the information you share. You do not have to share this information with us, but without it, you may not be able to access certain features or participate in certain aspects of the Services.

The Services may enable you to input (first) names for multiple players, which allow you to set up multiple profiles on a single device. The Apps will track each child’s play data separately to provide personalized activities and levels for each profile. Only parents or educators may sign up for a parent or school account by entering through a parental gate. When you sign up for a parent account, we collect and verify the parent’s email address so we can notify you about your child(ren)’s activities when using the Apps. With such an account, we provide to you additional services, such as multiple profiles, your child’s progress reports and additional resources. The Profile Names, zip code level location, along with birth month and year, will be collected in order to personalize your reports.

For school accounts and school-based services, a school administrator or educator signs up for a school account, whereupon we collect the administrator’s or educator’s name, email address, school name and city. An educator sets up student nicknames or first names and accessibility options.

The Services will collect student play data thru persistent identifiers that are then linked to individual student nicknames or first names (not full names). This allows us to provide progress reports. All information collected from our Services are for internal purposes to provide and improve the Services and for use and benefit of the students, schools, and parents only. We rely on teachers and schools to obtain parental consents if and when they are necessary.

Third Party Analytics: This Site uses third party services to assist us with marketing to previous visitors to our Sites, including Google’s services which enable re-marketing on the Google search results pages or websites in Google's networks. The Services use cookies or web beacons to serve ads based on someone's prior web browsing history to then show ads and other reminders that you visited. The Services also collect information about your internet browsing, such as your ISP, the browser you used to visit our Sites and whether you have Flash installed, in order to show certain ads relevant to the pages you have visited. Any data collected will be used in accordance with this privacy policy.

Publicly Posted: If you post information on public areas of the Site which are intended for grown-ups only (i.e. comments or blog), that information is visible to and may be collected, stored and used by anyone. We recommend you be cautious about giving out personally identifiable information to others or sharing personally identifiable information in public or online forums. We are not responsible for the actions of any third parties with whom you share personally identifiable information.

Credit Cards: You can become a subscriber by purchasing a subscription to the Services within the Apps, where allowed by the App marketplace partners. When You subscribe to our Services, the order process may request a credit card or other payment information (i.e. PayPal). Order information is done through the Sites or via iTunes and Android App Stores directly and we do not collect or process or store any of your personal information or credit card information during the billing process ourselves. We use a third party service provider to process payments made on our Sites. Sales made via the app itself are processed through the marketplace partners directly (i.e.iTunes or Google Play), so your credit card information is not collected or retained by Us.

HOW DO WE USE THE INFORMATION WE COLLECT?

In general, we collect and use your information to provide the Services, to provide support for the Services, to respond to user requests and inquiries, to mainain a record of our dealings with users, to facilitate your use of and our administration and operation of the Services; and to improve our offerings.

WHEN DO WE SHARE OR DISCLOSE YOUR INFORMATION

Anonymous Information. Anonymous or aggregated information that does not identify you personally, like usage and metrics information, referring website addresses, and “aggregate” information may be shared with others, including developers, potential investors, marketers, and business partners. Anonymous information helps us understand trends and user needs so that we can better design new products and services and refine existing products and services to serve our customers better.

Personally identifiable information, or Personal Data as such term is defined below (“Personal Information”), is information that can identify you individually, such as an individual’s name or email address. Your Personal information may be shared as follows:

1. Your Personal Information may be shared with anyone who is helping us make the Services available and functional under contract and with safeguards. These include third-party vendors, technical agents, subcontractors, and our affiliates and consultants who assist us in performing functions to operate our Services. These functions include, for example, web site hosting, maintenance, data analysis, customer support, email delivery services, infrastructure services, customer service, technical agents, analytics and metrics services. These third parties will be restricted in the way they can use your Personal Information and will need to keep your information confidential and secure.
2. We may also share Personal Information during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation. If codeSpark or its assets is purchased, all associated data and information will be transferred
3. If you give us permission, we may share your Personal Information with third parties who might send you marketing and promotional information.
4. We may also disclose your Personal Information if permitted or required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users or business partners.

CHILDREN’S PRIVACY

As noted earlier in this policy, we do not knowingly collect or share personally identifiable information from or about children under 13. This Site may be accessible to children but the Site is targeted for parents and adults and is not intended for children under age 13. When children use our Apps, we do not request any personally identifiable information from them, and any information about a child/student requested from a parent/teacher is non-personal information such as a nickname or child’s first name and last initial. We may give teachers the option to provide a parent’s email address for each student user so that we can inform parents of their child’s activities when using our Apps.

CALIFORNIA PRIVACY RIGHTS

Under California law, California residents are entitled to ask us for a notice describing what categories of personal customer information we have shared with third parties or corporate affiliates for direct marketing purposes in the past 12 months. If you are a California resident and would like a copy of this notice, please submit a written request to the codeSpark, 130 W. Union Street, Pasadena, CA 91103. In your request, please specify that you want a “California Privacy Notice.” We are not responsible for notices that are not labeled or are sent improperly. Please allow up to thirty days for this notice to be provided.

EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE

We respect your privacy rights and provide you with reasonable access and rights to the Personal Data (as this term is referred to for individuals located in the countries of the EU, UK or Switzerland pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as GDPR)) that you may have provided through your use of the Products. If you live in the European Economic Area (EEA), and wish to access, amend, delete, or transfer any Personal Data we hold about you, you may contact us as set forth in the “Who We Are. Contact Us” section below.

You may update, correct, or delete your Personal Data and preferences at any time by request to us at the email below. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at the email below. You also have a right to lodge a complaint with data protection authorities.

INTERNATIONAL TRANSFERS

Where we transfer your Personal Data outside the European Economic Area (EEA), we rely on approved standard EU Model Clauses so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.

To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the “Who We Are. Contact Us” section below.

OPT OUTS; REMOVAL OF CONTENT.

We permit all users to request an Opt out from receiving marketing emails, texts, or other marketing communications from us on a going-forward basis please submit a written request to the email address below. In your request, please specify that “Marketing Opt Out.” We will try to comply with your opt-out request as soon as reasonably practicable. Please note that if you opt out as described above, this will apply to marketing messages from us only. We will not be able to remove your personally identifiable information from the database of any third parties to whom you have previously authorized us to share such information. Please also note that we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

In addition, Adult Users may contact us at any time to request that we provide for their review, or delete from our records, any information they have provided about child/student users associated with their account.  This includes the ability to request that we discontinue any further collection or use of their child/student’s information.

If you would like us to remove publicly visible content posted by you, please send an email with the words “Content Removal” in the subject line to privacy@code-spark.org and include a description of the content and its location.

If we delete content, please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforcement of our agreements.

GENERAL & DATA SECURITY

Information that we collect is stored on servers that we manage, using standard security procedures and practices appropriate to the nature of the information. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Services and you do so at your own risk. All Information, including your personally identifiable information, may be maintained on servers or databases located outside your state or country or to a jurisdiction where the privacy laws may not be as protective as those in your location.

If you are located outside of the United States, please be advised that we process and store information in the United States and your use of our Services constitutes your consent to and understanding of this processing. This Privacy Policy shall be governed by and construed in accordance with the laws of the State of California applicable to agreements made and performed in California, excluding the application of the conflict of laws provisions. This Privacy Policy is subject to the Terms of Service which terms are incorporated herein by reference, and unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service.

CHANGES TO THIS POLICY

We reserve the right to change this Privacy Policy at any time, and will do so by posting changes to this Privacy Policy on the Site.  If we make material changes to our handling of personally identifiable information previously collected from you, we may notify you more prominently and obtain your prior consent.

WHO WE ARE. CONTACT US

We welcome your feedback. If you have any comments or questions about this Privacy Policy or our privacy practices, please email privacy@code-spark.org.

codeSpark
130 W. Union Ave
Pasadena, CA 91103
626.585.6900
privacy@codepark.com

Effective: May 25, 2018.