Ganz, an Ontario partnership, located at One Pearce Road, Woodbridge, Ontario L4L 3T2 and companies affiliated with it (collectively, "Ganz"), are committed to protecting the privacy and confidentiality of personal information entrusted to us. Some of the websites owned and operated by Ganz, including but not limited to www.webkinz.com have, special concerns about the privacy of users who are children under the age of 18, and we comply with applicable law regarding collection of information from children, including the United States' Children's Online Privacy Protection Act ("COPPA"), Canada's Personal Information Protection and Electronic Documents Act, and the EU Data Privacy Directive. These and other applicable laws have special requirements regarding notification to parents and legal guardians (either of which is called a "parent" in this policy) of what personal information is being collected from their child and how that information is used and shared. Parents are strongly encouraged to participate in their children's online activities and monitor their children's use of emails and engagement in other electronic communication. If you are resident in the United States we encourage you to visit http://www.ftc.gov/privacy/privacyinitiatives/childrens.html for more information about COPPA and children's privacy.
What Is Personal Information?
When this Children's Privacy Policy uses the term "personally identifiable information" ("PII"), we mean information that identifies a particular individual, such as the individual's full name (first name and surname together), postal address, and email address. When certain other information such as your favorite Webkinz pet, or other non-identifiable information is directly associated with PII, this other information also becomes PII for purposes of this Children's Privacy Policy. Some jurisdictions may call personally identifiable information "personal data" or "personally identifying information," and may include opinions about or related to a user in the definition of PII. We sometimes refer to PII in this Children's Privacy Policy as "personal information."
What Is the Scope of Our Children's Privacy Policy?
This Children's Privacy Policy addresses our policies and procedures relating to the personal information collected from children under the age of 18. This Children's Privacy Policy is intended to assist you, the parent, in understanding Ganz's policies and procedures relating to our management of your child's personal information.
What Personal Information Does Ganz Collect, and Why?
We collect information in a variety of ways on the site. We will collect no more personally identifiable information from your child than is reasonably necessary for your child to participate in an online activity.
- Registration: When your child registers for his or her online Webkinz account, we ask for only his or her first name, birthday, gender, country of residence, and, if you live in Canada and the USA, we also collect the state or province of residence where the child lives. None of this is personally identifiable information, because it cannot be used to contact or identify the child offline. During the registration process, the child is also asked to create a user name and password. Your child should not use any personally identifiable information as his or her user name, as this user name may be visible to others on the site.
- Surveys and Feedback: We may collect aggregate information in connection with surveys or other online activities that allow your child to give us feedback. We do not collect any personally identifiable information in connection with surveys or feedback requests, nor is the information provided connected to any personally identifiable information we may have about the child.
- Site Management: We may collect information through technology (such as logging IP addresses) for routine system administration purposes, to make our Website more interesting and useful to you and your child, or to manage content delivery. For instance, we collect IP addresses and use technology to track traffic patterns on the site. Once your child has logged into the website, we track your child's activities by using logs of database transactions and server interactions. This data is used to maintain your child's pets' status on the website. We also use this information to understand which areas of our website are most appealing or least appealing and to deliver content that is specific to your country or area of residence. Our site also uses cookies, which are pieces of information that a website sends to your child's computer while he or she is viewing the website. Cookies provide information to the site so that the site will remember the user. These technical methods may involve the transmission of information either directly to us or to our third party service providers who are subject to the protections described in this Children's Privacy Policy. None of the information collected through these methods is connected to or associated with any other information about your child.
- Email Communication from You: If your child contacts us by email, we use the email address (which is personally identifiable information) only to respond to your child's specific request or question, after which the address is deleted. If we ask for your (the parent's) email address, we keep that information and use it only for the purpose of providing notices to you and requesting parental consent as required under applicable law.
- Mail Communication from You: If your child wishes to submit a Crafty Critterz idea to www.webkinz.com, you must print out and send the Crafty Critterz submission form along with the idea. The submission form requires your child's user name and name of his or her favorite pet, and your (the parent's) name and signature.
- KinzChat. When using KinzChat, members select pre-constructed messages from chat menus. Members CANNOT type in their own messages, and no personal information can be disclosed. Parental consent is not required for KinzChat. In the KinzChat PLUS area, messages are limited to words from our restricted dictionary, which attempts to exclude all numbers, common proper names and place names, and other personal information. If your child requests access to the KinzChat PLUS area, he or she will be prompted to invite you to the Parent's Area to create a Parent Account which will require that you provide your first name, last name and email address. We use this information only for the purpose of providing notice to you and requesting parental consent as required under applicable law.
- Safety and Security: We may collect your child's first name and email address and your email address where necessary for your child's safety. We may also collect your child's name and email address for the limited purposes of protecting the security and integrity of the site, taking precautions against liability, responding to the judicial process, or for law enforcement on a matter related to public safety.
What Kind of Personal Information Does Ganz Disclose, to Whom and Why?
Ganz may share your child's personal information with the other members of the Ganz corporate group, and their respective successors and assigns, but only to the extent required to fulfill the purposes identified under the heading "What Personal Information Does Ganz Collect, and Why?" You may request that Ganz not share your child's personal information with any of the other members of the Ganz corporate group by contacting our Customer Service Department as described below. In addition to this inter-corporate sharing, Ganz may disclose your personal information to third parties as follows:
- To Third Parties To Perform Processing and Other Specialized Services: At times, Ganz may use outside organizations to perform specialized services such as, but not limited to, payment processing. These service providers are only given the information needed to perform those services and they are bound contractually to protect the confidentiality, privacy and security of your information and to limit the use of your information to the service being provided.
- To Third Parties in the Event of Legal Reasons: We advise you that we may disclose personal information to the government or other legal or regulatory authorities (i) if so ordered by a court of law or (ii) for other legal reasons, such as (a) to comply with legal process such as a search warrant, subpoena or court order; (b) to protect the company's rights and property; (c) to investigate reports of fraud or of users sending material using a false email address or users sending harassing, threatening, or abusive messages; (d) to protect against misuse or unauthorized use of our Website; or (e) in emergencies, such as when we believe someone's physical safety is at risk. In some cases, disclosure may be required by law to be without notice to you.
- To a Third Party in the Event of a Significant Transaction or Other Event: In the case of any significant transaction or event involving Ganz or any of its related entities or divisions such as, by way of example, a sale, merger, amalgamation, financing, re-organization, liquidation, or insolvency, other parties to the transaction and their professional advisors may need to have access to Ganz's customer lists and various databases as part of the due diligence process. In this event, Ganz would only provide such access under terms of a strict confidentiality agreement. Also, upon completion of the transaction or event, your personal information would be transferred to Ganz's successor-in-interest to be used only for the purposes for which it was collected.
How is a Parent Contacted to Obtain Consent to the Collection of a Child's Personal Information?
When your child is asked to provide personal information, we will first collect your (the parent's) email address and use this information to contact you (the parent) by email to notify you that your child wishes to provide personally identifiable information to us, describe the purposes for which the personal information is collected, and provide you with an opportunity to opt-out of the collection of the information.
For example, if your child requests access to the KinzChat PLUS area, he or she will be prompted to invite you to the Parent's Area to create a Parent Account. After creating a Parent Account, you will receive an email requesting your consent for your child's access to the KinzChat PLUS area. When you receive the email, click on the Accept link to allow your child into the KinzChat PLUS area. If you would rather not allow your child to play in the KinzChat PLUS area, click on the Decline link, or simply ignore the email. Alternatively, you can at any time use our Parent Account feature to block your child's access to KinzChat PLUS.
How Can Parents Access, Update or Delete the Personal Information That Has Been Collected From Their Child?
If you have any questions or comments about Ganz's Children's Privacy Policy, would like to change how your child's personal information be collected, used or disclosed, would like to access or update your child's personal information or would like to refuse to permit us to collect further personal information from your child, you may contact our webmaster at privacy_officer@ganz.com from your (the parent's) email address and we will assist you with your request, in accordance with applicable law. Personal information provided by email may not be secure, and by requesting a copy of your child's personal information, you assume the risks associated with the email transmission of our reply. In the event that Ganz may, consistent with applicable law, decline to provide you or your parent or guardian with the information requested, and we choose to so decline, we will provide the reason why. A request of a copy of the personal information we keep about you, depending on the laws of your country, must be made in writing giving details with which Ganz can identify you. Ganz will reply to such requests as required under applicable law.
Notification of Changes in the Children's Privacy Policy
This Children's Privacy Policy outlines the information usage practices of Ganz. By accessing, browsing or using this Website, you signify your agreement to the terms and conditions of this Privacy Policy. When submitting your or your child's personal information to Ganz, you will be prompted to expressly indicate your agreement to the terms and conditions of this policy. If you do not agree to this policy, please do not submit your personal information to us. We reserve the right, at our discretion, to change, modify, add or remove portions of our Children's Privacy Policy at any time. If at some point in the future, there is a material change to our information usage practices that affects you or your child's personal information, you will be notified of such change by a conspicuous posting on the Website and will be prompted to elect whether or not you agree to the change.
For Questions or Comments Regarding the Children's Privacy Policy:
If you have any questions or comments about Ganz's Children's Privacy Policy, please contact the Customer Service Department at the address, phone number or email address listed below:
Ganz
Customer Service
Telephone: toll free: 1-866-932-5469 (US and Canada)
Mail: One Pearce Road, Woodbridge, Ontario L4L 3T2
Attention: Customer Service Representative
Email: privacy_officer@ganz.com
Effective Date: May 27, 2009.