PRIVACY POLICY
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INTRODUCTION
This Privacy Policy applies to the sites ("Sites") owned, operated, or controlled by CCA and B, LLC d/b/a The Lumistella Company (the “Company”), its affiliates and all entities and brands under its control such as The Elf on the Shelf®, Elf Pets®, Elf Mates®, et. al, including all trademarks owned or controlled by such entities, collectively referred to herein as "we," "us" or "our"., including, but not limited to: elfontheshelf.com, ccaandb.com, santasnorthpole.com and the services ("Services") including mobile applications published to Google Play and iTunes App Stores or other related internet-based technologies owned, maintained, or managed by us, are intended for use by the whole family, which may include young children with parental participation and supervision.
We recognize the importance of protecting any information collected from the users (each "User" or collectively, "Users," referred to herein as "you" or "your") of our Sites and Services, and we have established this Privacy Policy to inform you about the types of information we gather about you while using our Sites and Services. This includes how we may use that information, whether we disclose it to anyone, and the choices you have regarding use of and correction of the information. When you use our Sites and Services and input information, you expressly consent to the use of such information according to this Privacy Policy. We understand your privacy is important. We encourage you to refer to this policy on an ongoing basis to stay up to date on our most current privacy practices, which may change from time to time as an effort to remain compliant with relevant privacy regulation. The date that this policy was last changed is noted above. If any future modification requires us to provide notice to a parent or receive parental consent, we will take the steps necessary to comply with those requirements at that time.
YOU NEED TO AGREE TO THIS PRIVACY POLICY AND THE TERMS OF USE, OR IF YOU HAVE NOT REACHED THE AGE OF MAJORITY IN YOUR JURISDICTION, A PARENT OR LEGAL GUARDIAN, MUST READ AND ACCEPT THEM ON YOUR BEHALF. IF YOU, OR YOUR PARENT/GUARDIAN ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THIS PRIVACY POLICY OR THE TERMS OF USE, PLEASE EXIT THE SERVICE NOW AND DO NOT DOWNLOAD, ACCESS OR USE OUR SITES AND SERVICES.
Contact us at info@pmgaustralia.com concerning anything you do not understand.
CHANGES TO THIS POLICY
We may make changes to the policy from time to time so please be sure to check regularly. If we make a material change to this policy and we have your contact details, we will contact you before we make the change.
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CHILDREN'S PRIVACY
KIDS PRIVACY ASSURED BY PRIVO: COPPA SAFE HARBOR CERTIFICATION
The Company is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program ("the Program"). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the link below. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates the Company has established COPPA compliant privacy practices and has agreed to submit to PRIVO's oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at (03) 9726 0195 or info@pmgaustrlaia.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.
To view the PRIVO verified page for the COPPA safe harbor program please visit this link: https://cert.privo.com/#/companies/elfontheshelf
The following is intended to provide additional clarification on specific Services we offer:
- Mobile Applications (iOS and Google Play mobile applications published by us)
- We do not collect any personal information from children in our mobile applications.
- The Company uses the 3rd party services listed below to collect technical information, in aggregate, for reporting, analytics, and performance monitoring.
- Some mobile applications utilize alerts, which you may control via the alert setting within the application. The alerts are not sent remotely by a server.
- Geolocation information is collected by our mobile applications and websites at the city level.
- SantasNorthPole.com website
- This site does not contain advertisements.
- The Write a Letter to Santa feature on www.santasnorthpole.com does not store any information from the user. The content of the letter is disposed immediately after the form is submitted.
- The Company uses the 3rd party services listed below to collect technical information, in aggregate, for reporting, analytics, and performance monitoring.
TYPES OF INFORMATION WE COLLECT FROM CHILDREN
When a child registers for an account, we collect their date of birth, username and password. We also collect a parent email address to seek consent. We also use the parent’s email address for basic account administration. Account creation is used on SantasNorthPole.com to provide a user profile which allows a user to save their game state and save related, site-specific information to help provide a more enjoyable user experience;
THIRD PARTY SERVICE PROVIDERS USED IN RELATION TO CHILDREN
We work with the following third-party service providers in relation to children under 13 years old. These third parties do not share our user's information.
- We work with Google Analytics on both our Sites and Services to provide our service and to better understand your use of it, this third party use anonymized information and is not allowed to share your data. For more information on Google Analytics see here.
- We work with Firebase on our Sites and Services (specifically, mobile applications) to help monitor performance, your usage, and assess any issues with the application. For more information on Firebase, see here.
- We use Crashlytics on our Sites and Services (specifically Ideas for Scout Elves) to track crash reporting, application logging, online review and statistical analysis of application logs. For more information on Crashlytics, see here
- We use FusionAuth, an identity and access management tool, to provide compliant authentication, authorization, and user management on our Site (specifically santasnorthpole.com). For more information on FusionAuth, see here: https://fusionauth.io/product-privacy-policy.
- Some of the features on our Sites and Services are directed to parents and adults, we do not intentionally or knowingly seek Submissions from children under 13 years old in connection with those features. Any content submitted by children under 13 years, including Submissions through the Write a Letter to Santa feature, is not stored or retained.
For more information in our privacy practices related to children, please contact info@pmgaustralia.com.
HOW TO UPDATE OR REMOVE YOUR INFORMATION
We retain your information and content for as long as necessary to provide our service. If you or your child wish to opt out of services, review your information or delete it, please contact us at: PMG Australia 1/42 Ramset Drive, Chirnside Park VIC 3133 Phone Number: (03) 9726 0195 E-mail: info@pmgaustralia.com
- Mobile Applications (iOS and Google Play mobile applications published by us)
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GENERAL PRIVACY POLICY
TYPES OF INFORMATION WE COLLECT
- Marketing information you provide to us when you opt-in to receive emails from us; and
- Analytics information when you visit our sites or use our applications, including usage, viewing and technical data, when you visit our sites, use our applications on third-party sites or platforms or open emails we send. This information is collected anonymously.
HOW WE COLLECT YOUR INFORMATION
We collect information you provide to us when you request products, services or information from us, register with us, participate in public forums or other activities on our sites and applications, respond to customer surveys, or otherwise interact with us. Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this Privacy Policy and the information the third-party site or platform collects is subject to the third-party site or platform's privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications.
We collect information through technology, such as cookies, Flash cookies, tags, Web beacons, pixels, and JavaScript (alone or in conjunction with cookies) when you visit our sites and applications or use our applications on third-party sites or platforms. Please see our Cookie Policy for more information.
INFORMATION SHARING
We will not share your personal information outside of our affiliated companies (defined below) except in limited circumstances, including:
- When you allow us to share your personal information with another company, such as:
- Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services (but only with specific consent).
- Directing us to share your personal information with third-party sites or platforms, such as social networking sites (Please note that once we share your personal information with another company, the information received by the other company becomes subject to the other company's privacy practices.)
- When companies perform services on our behalf, like email delivery, package delivery and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.
- When we engage in partnerships with other brands where we may temporarily provide the ability for re-targeting campaigns.
- When we share personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to provide the Sites and Services to you, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process or in other cases that disclosure is required by law.
- In addition to the third parties listed in the children's section above, we use the following third parties on our general audience properties to provide you the functionality required to fully utilize our Sites and Services:
- Zendesk: Zendesk helps us provide customer service. Zendesk is not allowed to share our user data. For Zendesk's Privacy Policy, click here.
- Google Analytics: Google Analytics helps us to better understand your use of our Sites and Services. This third party uses anonymized information and is not allowed to share your data. For Google's Privacy Policy, click here.
- Google Tag Manager: We use Google Tag Manager to enhance our ability to manage event tracking in Google Analytics, such as tracking button clicks. For Google's Privacy Policy, click here.
- New Relic: New Relic provides application monitoring services, which allow us to understand how our Sites and Services are functioning and performing, which can include information about your browser, operating system and hardware, as well as your usage of our site. For New Relic's Privacy Policy, click here.
- Facebook: We utilize Facebook to allow users to share content from our Sites and Services to their social media account(s) and for ad-tracking. For Facebook's Privacy Policy, click here.
- Pinterest: We utilize Pinterest to allow users to share content from our Sites and Services to their social media account(s) and for ad-tracking. For Pinterest's Privacy Policy, click here.
- Instagram: We utilize Instagram to allow users to share content from our Sites and Services to their social media account(s) and for ad-tracking. For Instagram's Privacy Policy, click here.
- Twitter: We utilize Twitter to allow users to share content from our Sites and Services to their social media account(s) and for ad-tracking. For Twitter's Privacy Policy, click here.
- Alexa Metrics: We use Alexa to help understand how our Sites and Services are ranking and performing. For Alexa's Privacy Policy, click here.
- MailChimp: MailChimp allows us to send email marketing information and transactional emails to your registered email account. You have the option to unsubscribe at any time from this service from the links included in email communications. For Mailchimp's Privacy Policy, click here.
- Shopify: Shopify is the ecommerce platform we utilize to offer online sale of our products. This service allows you to purchase and pay for items; and provides tracking information for your order. For Shopify's Privacy Policy, click here.
- AWS: Amazon Web Services ("AWS") is a cloud platform which provides for the core functionality of our Sites and Services. For AWS's Privacy Policy, click here.
- We work with Firebase on our Sites and Services (specifically our mobile applications) to help monitor performance, your usage, and assess any issues with the application. For more information on Firebase, see here: https://firebase.google.com/support/privacy.
- We use Crashlytics on our Sites and Services (specifically Ideas for Scout Elves) to track crash reporting, application logging, online review and statistical analysis of application logs. For more information on Crashlytics, see here: https://firebase.google.com/terms/crashlytics.
YOUR CONTROLS AND CHOICES
We provide you the ability to exercise controls and choices regarding our collection, use of, and sharing of your information. In accordance with local law, your controls and choices may include:
- You may change your choices for subscriptions, newsletters and alerts.
- You may choose whether to receive offers and promotions from us for our products and services, or products and services that we think may be of interest to you.
- You may choose whether we share your personal information with other companies so they can send you offers and promotions about their products and services.
- You may request access to the personal information we collect about you and that we amend or delete it. You may also request third parties with whom we have shared the information do the same. Please send any requests to info@pmgaustralia.com.
DATA SECURITY AND INTEGRITY
The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.
DATA TRANSFERS, STORAGE AND PROCESSING
Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. To the extent required by law, the Company will provide you with reasonable access to the personal information collected through our Websites or apps.
When we collect your information, we keep it for as long as necessary to provide our services, conduct business with you, comply with the purposes outlined in our privacy policy, comply with our legal obligations, resolve disputes and enforce any agreements. You can, at any time, always change your preferences by opting in or out to preferences or services in the same way you first gave consent, also, you can request access to your personal data, have any inaccuracies rectified, or request erasure of your personal information by mailing or sending an email, using the company contact information provided below, your personal data will at all times be kept confidential and secure in harmony with applicable privacy laws and managed in accordance with the consent you have provided to us.
Under CCPA (California Consumer Privacy Act. 2018), California residents have the right to know the categories and pieces of information we have collected, disclosed or used in the past twelve months, in addition you have the right to delete your personal information, subject to certain exceptions, the right to opt-out of the sale of your personal information, we may require the verification of your identity prior to processing some of your request, the information you provide to verify your identity will not be used for any other purpose. Finally, residents of California will not be discriminated for exercising the rights before mentioned.
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COMMENTS AND QUESTIONS
If you need further explanation, have comments or questions about our privacy policy practices or have questions about your child's use of the service including reviewing or requesting deletion of your child's information, please contact the Company's Compliance Department at:
PMG Australia
1/42 Ramset Drive, Chirnside Park VIC 3133 Phone Number: (03) 9726 0195 E-mail: info@pmgaustralia.com