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Last Updated: February 2014
Key Points in Plain English
1. No Third Party Ads: We never place advertising from other companies in our apps or website.
2. No Personally Identifiable Data: No personally identifiable information is collected in our apps such as name, email or address. We do collect anonymous device information solely to support the proper working of the app.
3. Disabled Web Links: All links out of our apps are disabled by default. The links are for grown-ups and are there to provide necessary information and ways to get in touch.
4. Data & Plug-Ins: For development purposes, we use aggregated and anonymous information about app usage and app performance that is provided by a third party app data service called ‘Flurry Restricted’. We are confident this is a COPPA Compliant plug-in. See www.coppa.org for more info on COPPA.
5. In-App Purchase: The Dragon Shapes app contains one in-app purchase accessed within a gated ‘Grown-ups’ area. The in-app purchase unlocks the full version which includes all 50 puzzles. The purpose is to allow families to try the app before deciding to purchase. We don’t believe in hidden, misleading or child-targeted in-app purchases.
SECTION 1. ABOUT THIS POLICY
1.1 ABOUT US
Dragon Shapes: Geometry Challenge and Shape Arts: Create and Share (‘Apps’) are developed by Lighthouse Learning Studios Limited (‘Lighthouse Learning’, ‘We’, ‘Us’). Lighthouse Learning is registered in England (Company Number: 08331878) and our registered office address is: Lighthouse Learning, Sussex Innovation Centre, Science Park Square, University of Sussex, Falmer, Brighton, East Sussex, BN1 9SB, United Kingdom.
1.2 OUR COMMITMENTS TO SAFETY AND PRIVACY
Lighthouse Learning strives to provide safe learning opportunities for children. We take your privacy concerns seriously and recognize the heightened need to specifically protect the privacy and safety of children. In the Apps, we don’t allow third party ads, we don’t collect personal information and we don’t target children with purchases or links to the web. We welcome feedback and suggestions. If you would like to contact us about improving children’s privacy and safety in our apps, please email us at email@example.com.
This policy covers the Apps, websites and practices of Lighthouse Learning. This policy does not apply to the practices of companies that Lighthouse Learning does not own or control, or to individuals that Lighthouse Learning does not employ or manage. Our Apps and websites may contain links to third-party sites. Lighthouse Learning cannot take responsibility for the content or privacy policies of any third-party sites. Lighthouse Learning encourages you to carefully review the privacy policies of any third party sites or applications you use.
1.5 CONTACT INFORMATION
SECTION 2. OUR APPS
2.1 PERSONALLY IDENTIFIABLE INFORMATION
No personally identifiable information, such as name or email address, is collected within the Apps. The Apps contain gated links to Lighthouse Learning web pages where you may send personal information to us. Please see the ‘Web Links’ section below. Also see Section 3 below for details about how we handle personal information that you share with us.
2.2 AUTOMATICALLY COLLECTED ANONYMOUS AND AGGREGATED INFORMATION
Lighthouse Learning uses aggregated and anonymous information about the usage and performance of the Apps. When you use the Apps, usage information may be automatically recorded using different types of technology. This information is non-personally identifiable usage data in aggregate form for statistical measuring purposes. It may include information about devices, country locations, app usage sessions, app usage frequency, app page views, completion of puzzles, usage of specific app features and app errors. Lighthouse Learning uses third party providers for the collection and handling of this information, such as app data analytics companies and app store companies. We currently use a service called ‘Flurry Restricted’ Lighthouse Learning uses this information to improve the look, functionality and content of the Apps and related services. This type of data enables Lighthouse Learning to determine how the Apps are used in order for us to revise, improve and develop our products and services. Lighthouse Learning will not disclose this information or use any aggregate information in a manner that would allow for a user to be personally identified.
2.3 WEB LINKS
The Apps contains carefully presented links to some web pages intended for adults. All links out of the Apps are disabled by default. The links are intended for the purpose of providing you with necessary information and ways to get in touch. Links can be enabled and disabled using Settings in the gated Grown-ups area. A list of all links: our website, email address, Apple app review page, social media pages (Facebook, YouTube, Pinterest, Twitter), Newsletter sign up page, Feedback page, and full terms and conditions on our website.
The Apps may deliver notifications to your device. You can disable these notifications in your device’s settings. Notifications relate specifically to the Apps and are based on usage of the app, for example, information about puzzle completion or app features. Notifications are delivered locally from your copy of the app to your device. We do not use any ‘push notification’ services.
SECTION 3. PERSONAL INFORMATION YOU SHARE WITH US
To protect the children using our Apps, we take all reasonable steps to abide by the guidelines set forth in the Children’s Online Privacy Protection Act (COPPA). For more information about COPPA, please visitwww.ftc.gov/privacy/privacyinitiatives/childrens.html
3.2 THE DATA PROTECTION ACT
Lighthouse Learning complies with UK data protection legislation such as the Data Protection Act 1998. This regulates the processing of personal data relating to you by UK companies and grants you various rights in respect of your personal data.
3.3 PERSONALLY IDENTIFIABLE INFORMATION
Personally identifiable information means information that identifies a person or can be used to identify a person such as name or email address. The Lighthouse Learning website includes pages where personally identifiable information can be entered by you and collected by Lighthouse Learning. The purposes of these web pages include, for example, providing feedback and signing up for an email newsletter subscription. These web pages are intended solely for adults and it is not the intention of Lighthouse Learning to collect personally identifiable information from children. If we suspect a child has contacted us via our web pages, we take reasonable steps to identify and delete this information.
3.4 EMAIL SIGN UP
Lighthouse Learning gathers the personal information you enter in the email subscription or Newsletter sign up pages accessible via our website. During the sign up process, you (an adult user) may provide your name and email address. You may also tell us if you are a parent or teacher, for the purposes of sending you relevant information. Newsletters are monthly emails that include news and blog articles. From time to time Lighthouse Learning may also send emails containing announcements, special offers, contests, sweepstakes or other promotions run by Lighthouse Learning. Lighthouse Learning may request information or feedback from users in the form of surveys or other feedback requests as part of its continuing work to improve products and services.
3.5 NO SPAM POLICY
Lighthouse Learning has a no spam policy. We are committed to only sending email we believe will be of genuine interest and at a reasonable frequency. Lighthouse Learning does not pass on your contact details to third parties.
3.6 EDITING YOUR EMAIL INFORMATION AND UNSUBSCRIBING
You may edit the name and email address information that we hold, edit your email preferences or unsubscribe at any time by using the links contained in our email footers or by contacting us at firstname.lastname@example.org. If you unsubscribe you will be completely removed from our email list.
3.7 COMMUNICATIONS FROM YOU
If you contact Lighthouse Learning by email or phone, Lighthouse Learning will use any personally identifiable information you provide (such as name, phone number or email address) only to respond to your inquiry. Lighthouse Learning may ask you for additional information in the course of providing technical support services or for product development purposes. If you choose to provide such information, you are giving Lighthouse Learning the permission to use and store it for those purposes, in accordance with this policy.
3.8 HOW PERSONAL INFORMATION IS USED
Lighthouse Learning uses the personal information you share in order to provide services or communicate with you. Under certain circumstances (for example if you win a contest) we may publish your personally identifiable information with your prior consent. Lighthouse Learning also uses the information that you provide to understand your preferences, to improve the way the Apps works and looks, and to create new features and functionality.
3.9 REQUIRED BY LAW
Lighthouse Learning may disclose information if required to do so by law or in the good-faith belief that such action is necessary to comply with the law. In some cases, we may make such disclosures without first providing notice to you.
3.10 MERGER OR ACQUISITION, SALE OF BUSINESS OR ASSETS
In the event that Lighthouse Learning is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from you as part of such merger, acquisition, sale, or other change of control. In some cases, Lighthouse Learning may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. In the event that all or substantially all of Lighthouse Learning assets are sold, given, or otherwise transferred to another entity, all user information collected as part of access to and use of Lighthouse Learning products or services would likely be transferred to that entity as well. By using Lighthouse Learning products or services, you acknowledge that such transfers may occur, and that any acquirer of Lighthouse Learning may continue to use its information as set forth in this policy.
3.11 OTHER PURPOSES
Lighthouse Learning also reserves the right to disclose user information that we believe, in good faith, is appropriate or necessary to take precautions against liability; protect Lighthouse Learning from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Apps; or to protect the rights, property, or personal safety of Lighthouse Learning or others.
3.12 THIRD PARTY DISCLOSURE
From time to time Lighthouse Learning may engage third party providers for technical or other services. Lighthouse Learning will use all reasonable commercial efforts to ensure that such parties are obligated to keep information secure and confidential. Lighthouse Learning may disclose personal information to the extent necessary to enforce our Terms of Service, or to otherwise protect the rights of users. This includes exchanging information with other companies and organizations for fraud protection. Moreover, to the extent necessary to comply with court orders or with requests by law enforcement or governmental agencies, Lighthouse Learning may provide personally identifiable information to the required third parties.