1. Information We Collect
The circumstances in which parents may provide information include, without limitation, when they register for the Services, access various content or features, sign up to receive emails or other communications, use community features such as our parent community blogs and discussion forums, participate in promotions, use a send-to-a-friend feature, or directly contact us with questions or feedback. The information that parents may provide includes:
- Contact information, such as first and last name, e-mail address, postal address, and telephone number;
- The child’s first name and demographic information, such as age, grade level, birth date and gender;
- User name, password, and answers for password reminders;
- Search queries;
- Country and/or state of residence;
- Communications preferences;
- Comments and other information posted in our interactive online forums;
- Correspondence and other information that you provide, including purchase confirmations and receipts;
- Survey-type information, such as information about the parent’s or child’s hobbies, attitudes, interests, skills, and education level; and
- Billing information, including credit card information, when you purchase Services.
Children may provide first name and grade in child profiles on some child-facing Services.
We also may collect certain information automatically when parents or children use the Services, including:
- Usage data that shows how parents and children use and interact with the Services across their devices, including information about how your child performs and progresses on activities when using the Services (such as play duration, correct answers, etc.);
- Child’s wish list selections, if a parent has authorized the child’s access to the LeapFrog App Center from certain Services;
- Your browser type and operating system, sites you visited before and after visiting the Services, information about the device you use, the links you click, and the pages you view within the Services, connection date, and other server log information;
- Account and order identifiers, order history of the products that you purchase or download online;
- Persistent identifiers, such as LeapFrog device identification numbers and your Internet Protocol (IP) address, which is the number automatically assigned to your computer or device whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- Information collected through cookies, web beacons, and similar technologies; and
- Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded.
We also may obtain additional data, or enhance, update, or add to our existing records with information we acquire from third-party sources, such as data aggregators and third party promotional partners. When parents access third-party services, such as Facebook or Twitter, through the Services to share information about the Services with others, we may collect information from these third-party services.
2. Use of Information
We may use information that we collect through the Services for a variety of purposes, including to:
- Provide the products and services you requested, including responding to your Customer Support requests..
- For our legitimate interests, namely to:
– respond to correspondence that we receive from you;
– provide you with information about products and services that we think might be of interest to you or that you request, including personalized reports that show parents the learning progress for each child or student player for their account;
– send you transactional or administrative communications;
– maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
– customize and personalize your use of the Services to better meet your needs and the needs of your children;
– sell or merge part of our business.
- To meet our legal obligations, for example, under accounting and tax laws, and to respond to an enforcement or legal process.
- With your consent to:
– provide you with product news and special offers;
– transfer your information to the U.S. and Hong Kong, as explained below; and
– as otherwise described to you at the point of collection or pursuant to your consent.
3. Sharing of Information
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Corporate Parents, Affiliates, and Subsidiaries. We may share your information with our corporate parent (including Infantree Pte Ltd), subsidiaries, and other affiliated entities for a variety of purposes, including business, operational, and marketing purposes.
- Service Providers. We may share your information with the following third parties:
– Service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, process payment information, perform analyses, or send communications for us);
– Distributors who sell our Services in the country in which you reside; and
– Vendors LeapFrog employs in connection with marketing and advertising campaigns.
- Select Business Partners. We may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. We will obtain your permission prior to such sharing if required by law. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, LeapFrog is not responsible for the privacy practices of these business partners, which may use your information for their own purposes.
- In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction.
- Other Parties with Your Consent. We may share information with third parties when you consent to such sharing, including when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. When parents choose to access third-party services, such as Facebook or Twitter, through the Services, these third-party services may be able to collect information and notify connections on the third-party services about the parent’s use of the Services, in accordance with their own privacy policies. Parents also consent to the disclosure of information when they use password-protected parts of the Services to transfer content to cloud storage, social media, or other recipients.
- Aggregate Information. We may disclose to third parties information that does not identify individual users, such as aggregate website usage data or demographic reports.
4. Data Security
We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us. While we strive to protect your information and privacy, please note that no data transmission or storage can be guaranteed to be 100% secure.
For your protection, before selling or otherwise transferring ownership of a LeapFrog-connected device, please be sure to securely remove all information from the device itself, including any play data. For more information, please contact LeapFrog Consumer Service using the information provided below.
5. Children’s Privacy
As a leading manufacturer of children’s educational toy products, LeapFrog recognizes the importance of protecting children’s information and strongly encourages parents to be actively involved in their children’s online activities.
We take steps to avoid collecting personal information from children. For example, while children may use some of our products to take photographs, create artwork, and record voice memos or video, this content is stored locally on the device and is not transferred to LeapFrog’s server. In addition, children may access child-friendly activities or play areas using only a username (such as a nickname or character name) or similar non-personal login information. Chat functionality and similar interactive features are designed to help prevent children from revealing their full names, email addresses, or similar information that could identify the child. For example, interactive chats may require children to choose from a pre-selected menu of short phrases or emoticons that do not contain personally identifiable information. We do not knowingly collect, use, or disclose personal information from children without prior parental consent, except as permitted by law.
Parents can access and control their children’s information and activities. For online play areas that contain interactive features, parents may be given additional controls to manage their children’s online activities, including the ability to set play time limits and turn certain features on and off. Prior to taking such actions, the parent may be required to log in to his or her LeapFrog account or otherwise verify his or her identity. Please note that you may need to separately access and update each child profile under your account in order for certain controls to take effect on every child’s profile. In addition, some of these controls only impact the transfer of data from the software application on your computer to LeapFrog, and not the transfer of data from the device to your computer.
If you have questions concerning our information practices with respect to children, or if you would like to review, have deleted, or stop the further collection of your child’s personal information, you may email us at firstname.lastname@example.org.
7. Links to Third Party Sites and Services
8. International Data Transfers
By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States and Hong Kong, or other countries and territories. While some of these countries may not offer the same level of privacy protection as your own, LeapFrog commits to uphold the privacy protections as explained in this Policy.
9. California Residents
It is our policy not to share your personal information with third parties for their direct marketing purposes unless you are first given the opportunity to opt out of such sharing. You may opt out of any disclosure of your personal information for direct marketing purposes at no cost by editing your account profile either on our website or on the Service. If you wish to learn more about our policy, please contact us using the information provided below.
Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, LeapFrog currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
10. Access to Information
LeapFrog provides you with the ability to review and correct certain information that you have provided to us. If you wish to access or update your information, you may do so by logging in to an account management section on the Service. These areas are usually marked clearly as “My Account,” “Your Account,” “Edit Profile,” “Settings,” or similar names, and may offer a variety of options that allow you to update information, delete accounts or profiles, or otherwise maintain control over how your information is collected, stored, used, or shared by LeapFrog.
If you reside in the European Economic Area, you have certain rights in respect of your personal information, subject to limitations in national law. These rights include a right of access, rectification, restriction, opposition, deletion and portability, and the right to withdraw your consent. Unless these rights can be exercised as explained above, you can contact us at email@example.com or at the address below.
11. Communications Preferences
You may choose to receive promotional emails, newsletters, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. Please note that opt-out requests may take up to 5 business days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature. For example, we may contact you concerning any purchases you have made with us, even if you opt out of receiving unsolicited commercial email messages.
12. Data Retention
We only retain your information for as long as it is necessary for the purposes for which it was collected.
13. Contact Us
Singapore and Malaysia:
Infantree Pte Ltd
Attn: Consumer Service
421 Tagore Industrial Avenue #02-31/32
Tagore 8, Singapore 787805
U.S. and Canada:
LeapFrog Enterprises, Inc.
Attn: Consumer Service
6401 Hollis Street, Suite 100
Emeryville, CA 94608-1071
Australia and New Zealand:
VTech Electronics (Australia) Pty Limited
Suite 4, Level 6, 22 Albert Road
1800 862 155
Rest of World:
LeapFrog Enterprises, Inc.
Attn: Consumer Service
6401 Hollis Street, Suite 100
Emeryville, CA 94608-1071
If you reside in the European Economic Area and you still have concerns about our collection and use of your information, you have a right to lodge a complaint with the Supervisory Authority for data protection in your country, such as the ICO in the UK or the CNIL in France.