Last modified: 10/01/20
TABLE OF CONTENTS
10. Data security
GoManda, LLC, a Texas limited liability company ("Company", "our", or "We"), respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the Website gomanda.com and/or gomanda.org, and/or any related mobile applications (collectively, the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
• On the Website.
• In email, text, and other electronic messages between you and the Website.
• Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
• When you make any payments to us.
It does not apply to information collected by:
• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
2. CHILDREN UNDER THE AGE OF 13
This section notifies parents of:
• The types of information we may collect from children.
• How we use the information we collect.
• Our practices for disclosing that information.
• Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.
• All operators that collect or maintain information from children through the Website.
2.1 Information We Collect from Children
Children can access many parts of the Website and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Website.
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.
2.2 Information We Collect Directly
A child must provide us with the following information to register with the Website: the child's first name, last name, and a parent's email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.
We enable registered users to communicate with others on or through the Website through chat, email, our Facebook page and group, our Instagram account, our Youtube account, and posting to public areas of the Site ("Social Features"). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children's use of social features.
2.3 Information We Collect Indirectly
Other users of the Website, including, without limitation, therapists, educators, counselors, and instructors, may provide us with the following information in connection with their respective use of the Website: the child's first name, last name, and a parent's email address. We may request additional information from such users regarding a child, which may or may not be optional. We specify whether information is required or optional when we request it.
2.4 Automatic Information Collection and Tracking
We use technology to automatically collect information from our users, including children, when they access and navigate through the Website and use certain of its features. The information we collect through these technologies may include:
• One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
• Information that identifies a device's location (geolocation information).
We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.
2.5 How We Use Your Child's Information
We use the personal information we collect from your child to:
• Register him or her with the Website;
• Communicate with him or her about activities or features of the Website that may be of interest;
• Track his or her performance in games or other activities; and/or
• To help email his or her progress to parents and/or educators.
We use the information we collect automatically through technology (see “Automatic Information Collection and Tracking”) and other non-personal information we collect to improve the Website and to deliver a better and more personalized experience by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about the child's preferences, allowing us to customize the content according to individual interests.
• Speed up your searches.
2.6 Our Practices for Disclosing Children's Information
We do not share, sell, rent, or transfer children's personal information other than as described in this section.
We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children's personal information:
• To third parties we use to support the internal operations of the Website and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
• If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others, including, without limitation, to:
• protect the safety of a child;
• protect the safety and security of the Website; or
• enable us to take precautions against liability.
• To law enforcement agencies or for an investigation related to public safety.
In addition, if Company is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.
2.7 Social Features
The Website may offer social features, including instant messaging, chat, email, posting on message boards, and our Facebook page and group, our Instagram account, and our Youtube account, that enable children communicate with others on or through the Website. We do not control the types of information your child can send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children's use of social features to ensure they do not disclose their personal information through them.
2.8 Accessing and Correcting Your Child's Personal Information
At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information.
You can review, change, or delete your child's personal information by:
• Logging into your child's account and visiting his or her account profile page.
• Sending us an email at firstname.lastname@example.org. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
2.9 Operators That Collect or Maintain Information from Children
The following are all operators that may collect or maintain personal information from children through the Website:
• Celest Austin, at 2603 Richcreek Road, Austin, Texas 78757, (832) 248-5684, or email@example.com;
• Wix, at 500 Terry A. Francois Boulevard, Sixth Floor, San Francisco, California 94158 or firstname.lastname@example.org; and
• Thrust Interactive, at 75 5th Street NW, Suite 3409, Atlanta, Georgia 30308, (678) 283-1234, or email@example.com.
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of the Website, including information:
• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
• That is about you but individually does not identify you, such as behavior-based elements (for example, how a child answers quizzes and time spent in lessons, and what words a child has mastered); and/or
• About your internet connection, the equipment you use to access the Website, and usage details.
We collect this information:
• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.
3.1 Information You Provide to Us
The information we collect on or through the Website may include:
• Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with the Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Website.
• Your search queries on the Website.
• Behavior-based elements. For example, how a child answers quizzes and time spent in lessons, and log in and log out times.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
3.2 Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on the Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.
The technologies we use for this automatic data collection may include:
• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
5. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
• To present the Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account or subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to the Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on the Website.
• To improve our software and Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
6. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about the Website users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
We may also disclose your personal information:
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
7. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile or by sending us an email with your request to firstname.lastname@example.org.
• Promotional Offers from the Company. If you do not wish to have your /contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product or services purchase, warranty registration, product service experience or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). For this opt-out to function, you must have your browser set to accept all browser cookies.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: firstname.lastname@example.org. However, please know we do not currently sell data triggering that statute's opt-out requirements.
8. ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
9. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit [www.gomanda.org/privacyca].
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
10. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
12. CONTACT INFORMATION