LAST UPDATED: JANUARY 2020
We care deeply about making sure children are safe online and have extra privacy processes in place to make sure we’re keeping our younger fans safe when they’re using our Website. In fact, some features have age gated so to prevent children from inadvertently using such features. We also take all reasonable care to secure that we don’t knowingly collect, store, use or process personal information from children who may use those features without proper parental consent.
WHAT KIND OF INFORMATION DOES ZURU COLLECT?
A. Information provided by Children
Children may view much of the Website’s content without providing personal information (for example, first and last name, e-mail or postal address or telephone number (collectively, “Personal Information”).
ZURU may collect a Child’s e-mail address under the following limited one-time use circumstances:
- if your Child sends a request to us, we will keep their e-mail address to respond to them. We will then delete their e-mail address from our system once we have responded to them; or
- if your Child enters a competition, sweepstake or contest, we will ask the Child to give us the Parent’s e-mail address, too, so that we can tell the Parent that the Child has registered for the competition, sweepstake or contest. If we need more than the Child’s e-mail address and first name (or screen name) to enter your Child in the competition, sweepstake or contest, we will notify the Parent, explain what information we need and ask that the Parent provide it. For example, we will ask the Parent for the Parent’s mailing address so that we can send, for your Child, any prizes the Child wins, or for the Parent’s telephone number so that we can tell the Parent when the Child has won. Any information a Parent or the Child gives us in these circumstances will be deleted from our database once the competition, sweepstake or contest is concluded, and after any legally required period for keeping such information has ended.
Other than the one-time use exceptions set out above, if a Child provides more than just the Child’s e-mail address in order to participate in a particular activity, such as receiving e-mail newsletters, we will ask the Child for the Parent’s e-mail address so that we can notify the Parent of the Child’s request and obtain the Parent’s permission. When we ask for the Parent’s permission, we will tell the Parent what we will do with the information the Parent or Child provides us. We will not keep the Child’s e-mail address unless the Parent gives us permission to do so.
B. Information collected through the use of our Website
ZURU collects information on our Website’s visitors collectively including which sections of the Website are most frequently visited, how often and for how long (collectively, “Usage Information”). This is done through cookies and other technologies. This data is used as aggregated, non-Personal Information. Cookies do not contain any Personal Information about a specific user. ZURU uses Usage Information to improve and enhance our online service. You may disable cookies using your browser’s preferences, but some features of the Website may not function if you do so. We do not share this information externally.
PARENTAL CHOICES AND CONTROLS
At any time, Parents or guardians can review the personal information we have collected about the Child, request deletion, or refuse to allow further collection or use of that information. If you need to make a data-related request, contact us at firstname.lastname@example.org. Please let us know your child’s username, email address along with your own email address and digital signature to confirm you are the right Parent. We’ll need to confirm your identity as the parent or guardian of the child before granting access to the child’s personal information. We will respond to your request within 30 days.
WHAT DOES ZURU DO WITH THE INFORMATION WE COLLECT?
We may use a Child’s Personal Information or Usage Information:
- to provide a Child with service he chose like receiving an email newsletter;
- to enable a Child to participate in a variety of the Website’s features or enter competitions, sweepstakes or contests;
- to contact the Child and Parent with regard to the Child’s use of the Website and, in our discretion, changes to the Website and/or Website’s policies; or
REQUESTING PARENTAL CONSENT
If a child under the age of 16 accesses an online channel that’s designed for children by using an age gate, we’ll email the child’s parent or guardian before collecting any personal information from the child. The parent or guardian has the option to agree to the collection and use of the child’s information without consenting to the disclosure of the information to third parties. If a Parent think that a Parent’s child is taking part in an online activity that collects their personal information and the parent/guardian hasn’t received an email to know or seeking parental consent, please contact us at email@example.com. We won’t use email addresses provided for parental consent for any other purpose.
DOES ZURU SHARE ANY INFORMATION?
We may share your Child’s Personal Information to meet legal processes or if disclosure is required by law:
- in the event we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law;
- at the request of governmental authorities conducting an investigation; or
- to protect the personal safety or rights of any individual.
A member of our Customer Service team will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.