Types Of Information We Collect
We collect two basic types of information – personal information and anonymous information– and we may use personal and anonymous information to create a third type of information, aggregate information. “Personal information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address and telephone number. When anonymous information is directly or indirectly associated with personal information, this anonymous information also is treated as personal information.
We collect the following categories of information:
* Registration information you provide when you create an account, including your first name and surname, country of residence, gender, date of birth, email address, username and password
* Transaction information you provide when you request information or purchase a product or service from us, whether on our sites or through our applications, including your postal address, telephone number and payment information
* Information you provide in public forums on our sites and applications (“Sites”)
* Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information
* Information you provide to us when you use our Sites, our applications on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account
* Location information when you use our Sites, including location information either provided by a mobile device interacting with one of our Sites (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information
* Usage, viewing and technical data, including your device identifier or IP address, when you visit our Sites, use our content on third-party sites or platforms or open emails we send
How We Collect Your Information
* We may collect information through technology, such as cookies, Flash cookies and Web beacons, including when you visit our Sites or use our content on third-party sites or platforms using one or more devices. Please see below for further information, including Do Not Track and how to disable cookies.
* We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.
Use Of Your Information By Garden Players
Garden Players LLC will be the “data controller” for your information and will have access to your information where it performs services for the following purposes:
* Provide you with the products and services you request
* Communicate with you about your account or transactions with us and send you information about features on our Sites or changes to our policies
* Consistent with local law and choices and controls that may be available to you we may use information collected from you, or from devices associated with you, to:
* Send you offers and promotions for our products and services or third-party products and services
* Personalize content and experiences
* Optimize or improve our products, services and operations
* Detect, investigate and prevent activities that may violate our policies or be illegal
Sharing Your Information With Other Companies
We will not share your personal information outside Garden Players 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
* 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 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
Your Controls And Choices
You may request access to the personal information we hold about you and that we amend or delete it. You may unsubscribe from our mailing list.
You may exercise your controls and choices, or request access to your personal information, by contacting us, or following instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact us at firstname.lastname@example.org.
Data Security, Integrity And Retention
The Information We Collect From Children, How We Use It, And How And When We Communicate With Parents
GP offers, and will introduce, various sites, social media channels and applications to its users (“Sites”), some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our Sites offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at email@example.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Content Generated by a Child
Certain activities on our Sites may allow children to create or manipulate content and save it with GP. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. If, in addition to collecting content that includes personal information, GP also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
About Verifiable Parental Consent:
Email Consent. In the event GP wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
High-Level Consent. In the event GP collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a GP representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site <http://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html>.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission. Please see Content Generated by a Child Section above for more information on our collection, notice, and consent policies.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, GP may need to ask for the child’s online contact information, such as an email address. GP will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a Site. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed applications that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
If a child-directed GP Site collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
* provide children with access to features and activities on our sites and applications
* customize content and improve our sites and applications
* conduct technical research and analysis to address the performance of our Sites
* generate anonymous reporting for use by GP
In the event we collect (or allow others to collect) such information from children on our Sites for other purposes, we will notify parents and obtain separate consent prior to such collection.
Please contact us at the mailing address or email below with questions about the operators’ privacy policies and collection and use practices:
50 Ascan Ave.
Forest Hills, NY 11375
Parental Choices And Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has registered for a GP account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
- Parents can request access to and delete their child’s personal information by emailing firstname.lastname@example.org.
- Parents can contact us to request access to, change, or delete their child’s personal information by sending an email to us at email@example.com.. A valid request to delete personal information will be accommodated within a reasonable time.
Parents may contact us directly at:
50 Ascan Ave. Forest Hills, NY 11375
In any correspondence such as e-mail or mail, please include the child’s name and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
Data Transfers, Storage And Processing Globally
Comments And Questions
Notice to California Residents: If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Garden Players to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. See Your California Privacy Rights page for more information.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by GP to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us:
CA Privacy Rights
50 Ascan Ave.
Forest Hills, NY 11375
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to email@example.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.