- Information of Users Under Age 13 is Treated Differently
- Parental Consent
- What Information Do We Collect From Children?
- How Do We Use the Information We Collect From Children?
- Will ePals Share My Child's Personal Information with Third Parties?
- How Can I Review, Change or Delete the Personal Information ePals has Collected From My Child?
- What Information Do We Collect From Individuals 13 Years Old and Over?
- How Do We Use Information that We Collect From Individuals Over the Age of 13?
- Will ePals Share Teens' and Adults' Personal Information with Third Parties?
EFFECTIVE DATE: September 25, 2013
This policy does not apply to websites, offerings or practices of companies that ePals does not own or control, or to individuals that ePals does not employ or manage.
TRUSTe is an independent organization whose mission is to advance privacy and trust among consumers and organizations globally, through its leading privacy trustmark and innovative trust solutions.
USERS UNDER THE AGE OF THIRTEEN ARE TREATED DIFFERENTLY:
We neither rent nor sell your Personal Information or Child Related Personal Information. In certain circumstances, we may share your Personal Information and Child Related Personal Information in personally identifiable form, as described below.
I. PRIVACY NOTICE FOR CHILDREN UNDER 13
ePals limits the collection of personal information from children to only that which is necessary to obtain parental consent or to participate in an ePals program or activity after we have obtained parental consent. If you are under age 13, you are not allowed to subscribe to any of the Services or create an account without the permission of your parent, guardian, or teacher. In addition to the required consent, it is a good idea to request assistance from your parent, guardian or teacher in setting up your Account.
Parental Consent (and Teacher and Guardian Consent)
We require a parent or guardian to consent before a child under the age of 13 can become a member of ePals or to use any of the Services. In addition, during the registration process, we only collect limited personal information (i.e., parent's name and email address) for the purposes of obtaining a parent's permission for his/her child to become a member of ePals.
For some ePals' products and services, teachers and school administrators may provide consent on behalf of parents. As a parent, you should consult your school's acceptable use policy for more information about your child’s school's policies and practices for protecting children on the Internet.
Parents can provide consent by email, fax, or postal mail for their children to use the following Services: SchoolMail365® and the Global Community™. Complete email instructions are provided in the parental consent form available at the following link: Consent Form Link.
To provide consent by fax or post, parents should fill out the parental consent form, sign it and either fax it toll free from North America to 1-309-412-0018 or mail it to
ePals Legal Department
13625-A Dulles Technology Drive
Herndon, VA 20171
If we receive consent from a parent, teacher or school administrator, an authorized ePals Administrator will activate the child's membership.
We will seek consent from parents for their children to use In2Books® products and services through use of a credit card verification during the registration process, or parents will receive an email from ePals/In2Books® asking for their consent. Parents will be asked to provide consent by email, or fax. If a parent provides email consent, ePals will follow up with a confirmatory email to the parent.
If you are a student under 13, please do not send any personal information about yourself to us unless (and until) you have first obtained consent from your parent, guardian or authorized teacher, and please do not send any personal information other than the limited information we request from you in connection with the Services.
What Information Do We Collect From Children?
Non-Personally Identifiable Information: we may collect the following types of personally identifiable information directly from children: first name; last name; date of birth; email address; ePals email address; password; nickname; IP address; grade level; mailing address; and parent's name and email address. We may also generate a login ID for the child that is different than the child's actual name.
Because we receive and store information that Users enter on the Services, whether via computer, mobile phone, other wireless device, we may also passively collect personally identifiable information that Users (including children) choose to post on our online forums as well as cookies from children's computers.
Non-Personally Identifiable Information: We may collect certain non-personally identifiable information from visitors to our site, such as the date and time of their visit, the type of browser used (e.g., Netscape, Internet Explorer), the type of operating system used (e.g., Windows Server 2003 or Mac OS X), the ISP from which the visitor receives Internet access, and aggregate information regarding what pages users of the site access or visit.
We may also collect non-personally identifiable information from registered members (such as the member's favorite pet or favorite book) and match it to personally identifiable information (such as the member's name) in our database. Such combined information is kept in our internal database under the member's user name.
How Do We Use the Information We Collect From Children?
Use of Personally Identifiable Information:
We may use the personally identifiable information that we collect from a child: (1) to determine whether he or she is eligible to use the Services; (2) to obtain consent from his or her parent, teacher or school administrator for the child to use the Services; (3) to provide an interactive online experience; (4) to provide customization and content recommendations; (5) to provide educational content that we believe that the child may be interested in or would benefit from; (6) to send newsletters; and (7) to fulfill requests for products or services.
Use of Non-Personally Identifiable Information:
We may use non-personally identifiable information (such as cookies and Web surfing habits associated with IP addresses) to improve the design, content and performance of the Services. We also may use this information in the aggregate to analyze site usage and the popularity of the Services (individually or collectively).
We may collect certain non-personally identifiable information from registered users (such as the member's favorite pet or favorite book) and match it to personally identifiable information (such as the member's name) in our database. Such combined information is kept in our internal database under the member's user name. We do not share such information with third parties, but we may use it for statistical purposes later, such as to say, 25 percent of In2Books® third-graders have goldfish!
Will ePals Share My Child's Personal Information with Third Parties?
We may disclose personally identifiable and/or non-personally identifiable in certain limited circumstances, as set forth in Section III below.
Please note that by their very nature, certain functionality offered as part of interactive services (e.g., email accounts, chatrooms, blogs, message boards, and etc.,) allow children to disclose personally identifiable information (such as their real names, addresses or phone numbers) about themselves or others. We strive to prevent and discourage children from disclosing personally identifiable information through the Services. For example, we caution children not to disclose this information while using the Services, and we endeavor to monitor our online forums and use filters, among other things, in order to prevent this information from appearing in public areas such as blogs and chatrooms on the Sites when we see it. However, these methods are not foolproof, and children may, despite our efforts, sometimes disclose personally identifiable information in their correspondence (e.g., in their exchange of letters in the In2Books® programs), and in our online forums. Parents and teachers should advise their children and students not to share any personally identifiable or contact information online, even if such personal information is provided in correspondence only between individuals.
Can I Review, Change or Delete the Child Related Personal Information ePals has Collected From My Child?
Yes, you can. You can review the Child Related Personal Information related to your child by making a request, as described below, at any time. You can also have the Child Related Personal Information related to your child deleted as described below and end authorization for further collection of such information by us. If you wish to view, delete or modify information:
- For ePals' Global Community™, SchoolMail365®: Members (including parents) can review or edit, any Child Related Personal Information related to their child (such as the child’s name, phone number, email or postal address) by logging in to the Global Community™, SchoolMail365™ and going to the preferences or settings page. Parents can also request that a child's account be deleted at any time by emailing ePals Support.
- For In2Books®: Members (including parents) can log into their accounts on www.In2Books.com, click the "Manage Account" button in the navigation bar, and then click on the "Personal Information and Security" link under the My Children column. To protect your child's personal information, you will be required to enter a user name and password and answer an account security question. For more information, or if you need assistance, send an email to ePals Support.
We will respond to your request to access thirty (30) days.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to ePals Support.
II. INFORMATION THAT WE COLLECT FROM INDIVIDUALS 13 YEARS OLD AND OVER
Our privacy practices for data that we collect online from individuals 13 years old and over are generally similar to those for information that we collect from users under 13 years old.
What Information Do We Collect From Individuals 13 Years Old and Over?
For all ePals' products (i.e., SchoolMail365® In2Books®, and the Global Community™): We may collect personally identifiable and non-personally identifiable information including, but not limited to: first and last name, date of birth, credit card information, security question and answer, nickname, information related to hobbies and preferences, email address, unique login name and password, home street address and/or telephone number, grade level, school name and address, and school telephone number. We may also generate a unique login ID for use on the ePals site.
Teachers who register on our site may create and post an online profile, with fields for class- and school-specific information, and brief description of their class(es) for matching purposes. A Teacher can elect to suppress his or her profile so that it does not surface during class-matching (in the Find Classroom area), provided, however, that the profile would be accessible if such teacher asks to join another teacher’s project or submits a project to the Join Project listing.
It is our policy not to create profiles for any user identified by our system as being under 13 years old or identified as a student.
We may allow ePals' members 13 years old and over to refer friends to the site. If this feature is used, we will ask the member for the friend's name and email address. ePals will automatically send the friend a one-time email inviting them to visit the site. If the recipient chooses not to register, he or she may contact us at ePals Support and ask us to remove his or her name and email address from our database.
Non-Personally Identifiable Information: We may use non-personally identifiable information that we collect from users over 13 years old to improve the design and content of our site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze site usage.
We may also collect non-personally identifiable information from registered users (such as the member's music tastes or hobbies) and match it to personally identifiable information (such as the member's name) in our database. Such combined information is kept in our internal database under the member's user name. We do not share such information with third parties, but we may use it for statistical purposes.
How Do We Use Information that We Collect From Individuals Over the Age of 13?
We may use the personally identifiable information that we collect online from users over the age of 13 to obtain parental, teacher or school administrator consent for children to use the service, to provide an interactive online experience (including interactive features such as greeting cards and chatrooms), to send newsletters, to make reading recommendations, to facilitate collaborative projects, to provide educational content that we believe that the child may be interested in or would benefit from, to collect, fulfill, and bill for books, products or services, and to post testimonials. We receive permission before testimonials are posted on our site.
What does ePals use my information for?
When you use the Services, you may set up your personal profile, send messages, perform searches and queries, and transmit information through various channels, depending upon what category of user you are registered as (e.g., student, parent or teacher) ("User Category"), and as permitted by the functionality of the Services. The information we gather from users enables us to personalize and improve the Services, and allows users to set up a user account and profile through the Services.
- Personal Information
Personal Information or Child Related Personal Information you provide may be used for responding to your requests for certain information and services, customizing your experience, and communicating with you about the Services.
- Your email address
- Your friend’s email address
If you are a teacher and you provide us with another teacher’s name and email address, we will automatically send that teacher an email inviting him or her to visit the Services. We store this information for the sole purpose of sending such email (and, if applicable, subsequent “reminder” emails) and tracking the success of our referral program. The referred teacher may contact us at firstname.lastname@example.org to request that we remove this information from our database.
- Usage Information
ePals uses this type of aggregate data to enable us to figure out how often users use parts of the Services, so that we can make the Services more appealing and relevant to users, and customize and improve the Services. As part of our use of information, we may provide aggregate information to our partners (in a non-personally-identifiable format) about how our users use our site. We share this type of statistical data so that our partners also understand how often people use our partners' services and the Services -- to help us improve the Services (including by having great partner content and services). We may link usage information to Personal Information and Child Related Personal Information that we collect through the Services, but we will only use this linked information internally (for example, to customize your experience), and will not disclose it in linked format to third parties (unless such third parties are acting solely as our agents). Additionally, certain usage-related information may be viewable in your user profile that may be displayed to other users, depending on your User Category; for example, certain “badges” may displayed in your profile (e.g., indicating successful completion of certain activities).
- Mobile Usage Information
This information is used to determine the device capabilities and usage trends which allows us to better understand which devices we should support and what features are most frequently used.
III. INFORMATION SHARED WITH THIRD PARTIES
We may disclose personally identifiable and/or non-personally identifiable with third parties in certain limited circumstances, as set forth below:
- Businesses We Do Not Control
In certain situations, we may share such information with affiliates, partners, and third party vendors who may offer or sell items or provide services to you through the Services (either alone or jointly with us). We may, for example, work jointly with other businesses to offer or sell products or provide services, or we may work with third party websites to enhance your online experience. These transactions or services may or may not be commercial in nature. We will share your Personal Information or Child Related Personal Information with that business only to the extent that it is related to such transaction or service. Such services may include the ability for you to automatically transmit information you input on the Services to your profile or account on a third party website, or to automatically transmit information you input on a third party website to your Services profile. These third parties have agreed to maintain the confidentiality, security and integrity of any personally identifiable information provided to them through the Services. As we noted above, we have no control over the policies and practices of third party websites (or other offerings) as to privacy or anything else, so please review all third party websites' policies before disclosing any Personal Information or Child Related Personal Information or other content on the Services or on any third party website (via the automatic transmissions discussed above or otherwise). ePals is not in a position to, and is not responsible for, reviewing or verifying the accuracy of any third party’s data collection or use policies, or their compliance with such policies. If you have any concerns regarding any third party (e.g., if you would like a third party to cease contacting you or delete any of your information), please contact such third party directly (unless you are a minor, in which case please discuss your concerns with your parent or guardian). Certain third parties deliver ads into the Services. Those third parties and their respective ad policies are here.
We engage certain other companies and people to perform tasks on our behalf and sometimes need to share your information with them to provide products or services to you. Examples may include sending email, analyzing data, processing payments, providing user services, providing customer service, processing parental consents, and/or monitoring online forums and chatrooms. These third parties: (a) have agreed to maintain the confidentiality, security and integrity of personally identifiable information; and (b) do not have any right to use Personal Information or Child Related Personal Information except as necessary to assist us.
- Service Provider, Sub-Processors / Onward Transfer
- Business Transfers
If ePals, or some or all of its assets, were acquired or otherwise transferred, or in the unlikely event that ePals goes out of business or enters bankruptcy, user information may be transferred to or acquired by a third party.
- Protection of ePals and Others
- Aggregate Anonymous Information
We may disclose aggregate, anonymous information for educational research purposes.
If you have any inquiries regarding our partner’s privacy practices or how they use your child’s personal information, please contact us directly at ePals Support.
IV. LINKS TO THIRD PARTY WEB SITES
For the benefit of our members, our sites link to other websites. We are not responsible for the data collection practices on those other sites. We recommend that you to carefully review those sites' privacy policies before submitting personal information there.
Cookies and Website Information
Like most commercial websites, we use "cookie" technology and web server logs to collect information about how our website is used.
Cookies are small data files that a Website writes to your computer hard drive for record-keeping purposes. Cookies identify you as a unique customer and store your personal preferences, as well as technical information (including click through and click stream data). Cookies can either be permanent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).
The cookies allow our web servers to recognize the computers used to access our websites. Cookies facilitate delivery of certain content to users as they move from page to page on our websites, including by remembering the information about the session.
You may adjust your browser to reject cookies from us or from any other Web site. If you just wish to browse our site without logging in or registering as a member, you can set your browser not to accept cookies. Please consult the "Help" section of your browser for more information. There are, however, certain features of the Services that can be accessed only in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of those features.
VI. DELETION OF ACCOUNTS AND RETENTION OF CERTAIN INFORMATION
You may revise or request deletion of your ePals account by sending a request to ePals Support. Such request should clearly identify your Account and specify that you are requesting deletion of your Account. You should also provide contact information so that we may, if we deem appropriate, verify the authenticity of your request. Please note that some unrevised information may remain in our records after revision of such information, and some information may remain after deletion of your account, or in cached and archived pages. Some information may remain viewable elsewhere to the extent that it was copied or stored by other users. We may use any aggregated data derived from or incorporating your Personal Information after you delete your information, but not in a manner that would identify you personally.
We will retain your Personal Information or Child Related Personal Information for as long as your account is active or as long as needed to provide you the Services; we also may retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
VII. SECURITY PRACTICES
We strive to protect the confidentiality, security and integrity of the personal information we collect from children and adults. We have put in place physical, electronic and administrative procedures to safeguard and to help prevent unauthorized access to and maintain the security of personally identifiable information collected through this site. This information is maintained on secure servers and is accessible to authorized personnel only on a "need to know" basis.
Your ePals account Personal Information or Child Related Personal Information is protected by a password for your privacy and security. We also use coding practices which take steps to prevent attack on our Services from web browsers and malicious scripts.
You may help protect against unauthorized access to your account and Personal Information or Child Related Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
When you enter sensitive information (such as a credit card number) in our Credit purchasing process, we encrypt the transmission of that information using secure socket layer technology (SSL).
ePals endeavors to keep your information private; however, we cannot guarantee security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information. For additional information about the security measures we use in connection with the Services, please contact us at ePals Support.
VIII. CHANGES TO THIS POLICY
If we make changes in the way we use Personal Information or Child Related Personal Information, we will notify you either: (i) via email prior to the effective date of the change; or (ii) by posting an announcement on the Services with two (2) weeks notice prior to the effective date of the change.
IX. USERS OUTSIDE THE UNITED STATES
ePals complies with the U.S. – E.U. Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. ePals has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please click here.
X. FOR MORE INFORMATION
ePals Legal Department
13625-A Dulles Technology Drive
Herndon, VA 20171
Phone: (703) 885-3401