Club Penguin
Club Penguin: Classic Privacy Policy

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Club Penguin: Classic is committed to providing a fun, entertaining, and safe website for people of all ages. We are dedicated to safeguarding any personal information collected online and to helping parents and children learn how to exercise control over personal information while exploring the Internet. We ensure that our privacy policy and our information practices adhere to the U.S. Department of Commerce's Safe Harbor Principles and the Canadian federal and provincial privacy legislation. Because many of the visitors to this site are children, we take care that our content is suitable for children. In addition, we take special measures to help children protect their privacy while online. For example, we do not ask children to disclose more personal information than is necessary for them to participate in a particular activity, and we take efforts to prevent children from posting contact information.

To help ensure a rewarding online experience for our visitors - and for the parents of our visitors who are children - we provide you with this summary of our information practices.

As we continue to offer our visitors new and different types of content and services, we may modify our practices from time to time. However, we will treat all personal information we collect in accordance with the privacy notice in effect at the time the information is collected.

1. The Information We Collect

At Club Penguin, the only personally identifiable information we collect from users 12 years old and younger is a parents valid email address. And, we ONLY use this information to send these users one message to activate their Club Penguin: Classic account.

Club Penguin: Classic requires users 13 years and older to enter either their or their parent or guardian’s valid email address in order to activate their account.

For some of our online activities - such as polls or surveys - we may ask users to provide additional information that is not personally identifiable, such as country of residence or a visitor's favorite color.

We do not knowingly collect names and email addresses from children under 13. We always require children under 13 to use a parent or guardians email address instead.

Additionally, when visitors come to our site, we automatically collect some non-personally identifiable "computer" information, such as the type of computer operating system (e.g., Windows XP or Mac OS), the user's "IP Address", the web browser (e.g., Netscape, Internet Explorer) being used, and information regarding the Internet service provider.

Finally, we collect personal and financial information from members as set out in Section 6 of this Privacy Policy, and also from customers of the Club Penguin: Classic Shop.  At Club Penguin, we respect your personal privacy and we will never use your confidential customer information for any purpose other than processing payments to Club Penguin: Classic or fulfilling your merchandise order.  The personal and financial information that you enter to purchase a membership or enable a purchase from Club Penguin: Classic Shop is not stored by Club Penguin, but only by our financial institution for the purpose of processing credit card payments made to Club Penguin. This information is safeguarded with extremely high, bank-level security and all credit card processing is done using completely secure, above industry standard encryption to secure and encrypt your credit card transaction and other personal information.

2. How We Use the Information

We have created an internal news system that allows us to communicate with the players without sending them information to their personal email address. We do not keep any personal information we obtain beyond the time it is needed. Sometimes we use a visitor's email address to track usage and to ensure users are following the site's Terms and Conditions.

We encourage users to submit their original artwork or other materials via email attachment. We do however, retain control of how all materials are used and displayed on the Club Penguin: Classic website. Once the artwork or other material is received it is immediately processed and the email is deleted.

We sometimes use the non-personally identifiable information that we collect to improve the design and content of our site, to personalize our visitors' experience on Club Penguin, and to offer products, programs, and services. We also may use this information in the aggregate to analyze site usage, as well as to offer products, programs, or services.

We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency's or other public agency's (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime. Finally, we may disclose information to a prospective purchaser of Club Penguin: Classic acquiring all or most of the assets relating to Club Penguin, to the extent permitted by law.

We may transfer personal information and store it outside of the jurisdiction in which a member of Club Penguin: Classic is located and, although such personal information will be protected by the security measures described in this privacy policy, it will be also be subject to local laws,

We will not use or transfer personally identifiable information in ways that are materially different from the ones described above without also providing parental notification of such practices and obtaining consent for any materially different uses.

3. Collection of Information for Third-Party Sites and Sponsors

Club Penguin: Classic is proud of the fact that we do not allow third-party companies to solicit or advertise to our users. Our intention is to keep Club Penguin: Classic free from any sort of direct advertising.

4. Cookies

Club Penguin: Classic uses a software technology called "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any personally identifiable information. Although cookies could enable us to relate a visitor's use of this web site to personal information that a visitor has provided, such as an email address, we do not use them for this purpose. We do use "cookies" to determine how many visitors we have and how often they visit various sections of our site.

5. Security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

6. Financial Information

If you decide to purchase a membership for you or your child, additional information will be required at the time of purchase. That information is not stored by Club Penguin: Classic and is only stored by our financial institution for the purpose of processing payments made to Club Penguin. That information is safeguarded with extremely high, bank-level security and it will never be used for any other purposes.

7. Parental Review of Information

Parents, please send a letter or postcard to our Privacy Manager at the mailing address provided below if you would like to do any of the following:

Access the personally identifiable information that Club Penguin: Classic has collected online from your child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect or maintain such information.

Please be sure to include your email address and a telephone number where we can reach you. To protect your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about your child.

8. Contact Us

Contact us should you have any inquiries regarding the privacy policy and/or practices.

All BBB OnLine Privacy Program participants are required to work with the program's dispute resolution process. The Privacy Program will only accept complaints regarding the misuse of personally identifiable information by a website operator. For more information about the Privacy Program dispute resolution process visit www.bbbonline.org/privacy/dr.asp

9. A Final Note to Parents

The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit the SafeKids.com site and look through the “Kids Rules” section together. Your efforts to instill responsible information practices will help steer your children to age-appropriate sites and will go a long way toward ensuring that your children have enriching experiences online.

10. Effective Date

The privacy policy set out above is effective as of January 1, 2006, and applies to all information previously obtained by Club Penguin. Club Penguin: Classic reserves the right to change its privacy policy at its sole discretion. Club Penguin: Classic users will be informed of any such change by Club Penguin: Classic posting a new privacy policy on the Club Penguin: Classic website. The effective date of any change of privacy policy will be clearly marked.

If you have any questions please contact us.