- The information we collect
- What we do with the information
- How we store the information
- How someone can get their information removed from our services
- Who we share the information with and why
- Who they can contact for more information
- Most importantly, how we handle information from minors under the age of 13
OUR COMMITMENT TO PRIVACY
This policy does not apply to websites or services or practices of companies that Change Gamers doesn’t own or control, such as third party services you might access through links or other features on the Service. These other services have their own privacy policies, and we encourage you to review them before providing them with personal information.
Protection of privacy is especially important to us. Change Gamers respects and follows the rules and expectations set forth in the Children’s Online Privacy Protection Act (COPPA) that went into effect in the United States on April 21, 2000. COPPA aims to protect the online privacy of children under the age of 13 (“child” or “children”) by restricting how much Personally Identifiable Information (PII) is collected and by requiring parental consent for activities that make use of PII. Additionally, Change Gamers respects the Personal Information Protection and Electronic Documents Act (PIDEDA) of Canada and the Personal Information Protection Act (PIPA) of British Columbia, Canada. Both PIDEDA and PIPA more generally outline how organizations collect, use and disclose personal information in the course of commercial business. For more information about COPPA and generally protecting children’s online privacy, please visit OnGuard Online. For more information about PIDEDA, please visit the Government of Canada. For more information on PIPA, please visit the Government of British Columbia.
WHAT INFORMATION DOES CHANGE GAMERS COLLECT AND HOW IS IT USED?
When creating an account on the Service, we ask for birthday to identify children 12 years or younger.
If a new member identifies as a child, we collect country, username, password, parent email address, and optionally province/state, and school name
- Country is used to determine access to some features of the app. Certain features of the Service are not available to our US members.
- Username and password are used to create a unique account in the service. We actively discourage children from using their real names and license software and tools from Two Hat Security (SIFT) to catch usernames that include naughty words and personal information. We do not retain the birthday of a child after sign up.
- Parent will be contacted by the Service via the parent email address provided by the child. The Service uses the “email plus” method described in COPPA to acquire consent from a parent or guardian.
- School name can be optionally provided to allow students in our I CAN Schools program to register at their school.
- Province or state information is used to narrow down the choices when selecting school name.
- We do not hold onto the birthdate of a child following the account creation process.
If a new member identifies as an adult, 13 years or older, we collect their personal email address and city of residence.
- Email address is used by the Service to help recover lost account credentials.
- City is used present local article, project, event, and media (content) to the child.
Parents are able to provide consent for their child using the Service through a Parent Tool. The Parent Tool allows the parent to change any of the child’s information, including username and password. The Parent Tool also allows the parent to optionally provide birthday and city.
Through the Service members are able to share stories and comments, also known as User Generated Content (UGC). Stories can include a photo and up to 5000 characters of text. Comments can include up to 250 characters of text. All UGC is reviewed and moderated by Change Gamers to ensure it upholds the spirit of our Service and does not include any personally identifying information (PII). Approved UGC is made available to all members of the Service and never privately between two or more members. We believe private, or group sharing promotes negative online behaviour. We also believe it is important for parents to stay informed of their child’s activity online and as such we notify the parent via email whenever their child shares UGC. We encourage you to review the rules for posting content set forth in the “User Conduct” section of our Terms of Service.
Through the course of using the Service we will automatically collect generic usage information as set forth in the “Information collected automatically” section below. We use this information to provide the Service to the member, for security and safety purposes, or as required by law or to enforce our Terms.
We will not require children to provide more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a child in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek the parent’s consent for that collection. We do not disclose any personal information about children to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other users.
Information collected from children (including information collected automatically) is never used or disclosed to third parties for advertising, including any kind of first- or third-party behaviorally targeted advertising. Children’s personal information is never sold or rented to anyone, including marketers or advertisers.
HOW LONG DOES CHANGE GAMERS KEEP CHILDREN’S INFORMATION?
A parent must activate their child’s account within 7 days of account creation. After 7 days, the account is automatically removed and any personal information associated with the account is permanently deleted.
Once activated, we only keep a child’s personal information for as long as his or her account remains active, unless we are required by law to retain it, need it to ensure the security of our community or our Service, or to enforce our Terms.
If a child’s account is inactive for twelve months or more, Change Gamers will automatically delete the account, including all personal information provided by the child or collected by Change Gamers from the child.
Parents who wish to have their child’s account deleted can use links sent to them at the time the account was created to immediately and permanently remove their child from the Service.
INFORMATION COLLECTED AUTOMATICALLY
Like most internet-based services, we (or our service providers) may automatically receive and log generic information about you when you use the Service. For example, this could include the frequency and duration of your visits to the Service, the browser you use, and the platform of the device you use.
The technologies and information we automatically collect may include:
- Cookies and other similar technologies: We (or our service providers) may use various technologies to collect and store information when you visit our Service including, clear GIFs (also known as “web beacons”), “tags”, “scripts”, and “cookies”. We use both session and persistent cookies: a session cookie disappears after you close your browser; a persistent cookie remains after you close your browser (although it can be removed) and may be used by your browser to identify you on subsequent visits to the Service. We may also use, collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5). Like many services, Change Gamers uses these technologies to tailor the Service for you, and to help the Service work better for you – for example, by remembering recent search choices.
- Device information: We may collect device-specific information such as your operating system type, hardware version, screen resolution, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Service is performing and improve Change Gamers for you on your particular device.
- Log information: Like most online services, when you use our Service, we automatically collect and store certain information in our server logs. Examples include things like:
- Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the Service.
- IP Address
- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
This information helps us make decisions about what we should work on next – for example, by showing which features are most (or least!) popular.
- Location information: When you use our Service we may collect and process information about your geographic location based on your IP address. We do this to derive amalgamated anonymized information about how well (or not!) our Services is used in certain geographic areas. We do not associate precise geolocation data with a child’s personal information and will not track the specific location of a child at a given moment in time.
HOW DOES CHANGE GAMERS USE THE AUTOMATIC INFORMATION IT COLLECTS
First and foremost, you should know that Change Gamers does not sell or rent any of your, or your child’s, personal information to any third party for any purpose — including for advertising or marketing purposes. We use the information we collect to provide the best experience. More specifically, this information is used to:
- Provide and improve the Service, for example by developing new products and features, or by reporting errors within the service.
- Respond to your requests for information or customer support.
- Customize the Service for you, and improve your experience with it.
- Most crucially, to protect our community by making sure the Service remains safe and secure.
CHANGE GAMERS DONATIONS
A key aspect of the Service is the ability for members to contribute micro donations to a project of a Non Profit Organization (NPO) or Charity and, optionally, for that donation to be match by a Corporate Sponsor (Sponsor). To make a donation, Parents must first deposit money into a child’s account via a secure online credit card payment form. The link to this payment form is provided to the parent via the email sent to the parent following account activation.
To complete the transaction, Change Gamers provides relevant anonymized, aggregated, non-personally identifiable statistics to NPOs and Sponsors. Change Gamers will never share personal information of a child with an NPO or Sponsor. Change Gamers ensures a hundred percent of the child’s donation is passed along to the NPO.
WILL CHANGE GAMERS SHARE ANY INFORMATION IT COLLECTS?
- Analytics Services: We use analytics services, including mobile analytics software, to help us understand and improve how the Service is being used. These services may collect, store and use information in order to help us understand things like how often you use the Service, the events that occur within the application, usage, performance data, and from where the application was downloaded. A list of all of our third party services is included below.
- Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with users, partners or the press in order to, for example, demonstrate how the Service is used, spot industry trends, or to provide marketing materials for Change Gamers. Any aggregated information shared this way will not contain any personal information.
- Legal Requirements: We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of Change Gamers, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests.
In the unlikely event that Change Gamers goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third party.
- With your consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or other third parties.
HOW DOES CHANGE GAMERS PROTECT AND SECURE MY INFORMATION?
Your I CAN App account is protected by a password. You can help us protect against unauthorized access to your account by keeping your password secret at all times.
The security of your personal information is important to us. We work hard to protect the Service, and we maintain administrative, technical and physical safeguards designed to protect against unauthorized use, disclosure of or access to personal information. In particular:
- Our engineering team is dedicated to keeping your personal information secure
- We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems
- We continually develop and implement features to keep your personal information safe – for example, when you enter any information anywhere on the Service, we encrypt the transmission of that information using secure socket layer technology (SSL) by default
- We ensure passwords are stored and transferred securely using encryption and salted hashing
- We automatically delete inactive accounts after a specific period of time, as per our retention policy, described in the “How Long Does Change Gamers Keep Children’s Information?” section
Although we make concerted good faith efforts to maintain the security of personal information, and we work hard to ensure the integrity and security of our systems, no practices are 100% immune, and we can’t guarantee the security of information. Outages, attacks, human error, system failure, unauthorized use or other factors may compromise the security of user information at any time. If we learn of a security breach, we will attempt to notify you electronically (subject to any applicable laws) so that you can take appropriate protective steps; for example, we may post a notice on our homepage (www.changegamers.com) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
WHAT COMMUNICATIONS WILL I RECEIVE FROM CHANGE GAMERS?
If you registered on Change Gamers we may send you messages and updates regarding your account, including privacy and security notices, updates regarding the Service, and information regarding products, features or services from Change Gamers. If you have an account with us, we’ll also use your email address to contact you for customer service purposes, or for any legal matters that arise in the course of business.
If you download and install the iOS app on an Apple device, available from the Apple App Store, you will optionally receive push notifications for activity related to your account that occurs while you are not using the Service.
HOW WILL CHANGE GAMERS NOTIFY ME OF CHANGES TO THIS POLICY?
In addition, if we ever make significant changes to the types of personal information we collect from children, or how we use it, we will notify parents in order to obtain parental consent or notice for those new practices.
THIRD PARTY SERVICE PROVIDERS
It’s important to us that we keep your information safe and secure. To best provide our Services, and keep your information safe, we work with a few other companies. These companies will only have access to the information they need to provide the Change Gamers service.
Here is a list of the essential service providers we work with, and their respective privacy policies to provide a great Change Gamers experience.
- Google Analytics for analytics on our website
- Kissmetrics for analytics on our app
- MailChimpa for sending email from our app
- Two Hat Security for moderating and validating usernames
- Watson from IBM for moderating and validating user generated content
- Perspective from Google for moderating and validating user generated content
- Sight Engine for moderating and validating user generated content
HOW CAN I CONTACT CHANGE GAMERS WITH QUESTIONS?
Unit 300, 1353 Ellis Street
Attention: Chief Privacy Officer