Privacy Policy

Home / Privacy Policy
Latest Update Effective:  October 12, 2015

Welcome! We have created this Privacy Policy so that you know what information we collect on the PRIVO.com website (the “Site”) [http://www.privo.com/] and through the PRIVO-Lock system, what we do with it, and whether we share or disclose it.

The PRIVO Privacy Policy page addresses the following:

I. Who is PRIVO?

PRIVO.com and the PRIVO-Lock system are operated by Privacy Vaults Online, Inc. d/b/a PRIVO.  PRIVO is a leader in online privacy protection and has been approved by the United States Federal Trade Commission to create and administer a Safe Harbor program to assist online businesses comply with the Children’s Online Privacy Protection Act (“COPPA”).  This Act requires many websites, game platforms, social networks, and mobile apps (each an “Online Service”) to secure parental consent before the Online Service can collect information from the child through the Online Service.

When an Online Service becomes a member of the Safe Harbor, it makes legally binding commitments to PRIVO that it will follow the high standards set out by PRIVO for compliance with COPPA, as well as similar laws that may be implemented in other countries, and best practices developed by the privacy community. You may see a PRIVO Seal on various Online Services.  This Seal shows that the Online Service is a member of the PRIVO Safe Harbor program, but the Online Service is not operated by PRIVO and has its own Privacy Policy and Terms of Service, which you should review and approve before using the Online Service.

II. What is PRIVO-Lock?

As a COPPA Safe Harbor, PRIVO recognized the technological challenges that getting verifiable parental consent can present.  So, PRIVOcreated a suite of online technology services, collectively called the PRIVO-Lock system, that simplifies the process of creating user accounts, logging into those accounts, and, where the user may be a child, securing verifiable parental consent.  While designed with COPPA in mind, the PRIVO-Lock system can be used by any Online Service to set up accounts.  Online Services download the PRIVO API and enable the PRIVO-Lock system to assign users a PRIVO iD for log-in purposes.  You may see the PRIVO-Lock logo and/or the ability to sign up or sign in with a PRIVO iD on a PRIVO-Lock enabled Online Service.  This indicates that the Online Service is a member of the PRIVO-Lock technology, but it is not operated by PRIVO.  In some cases, an Online Service may be using PRIVO-Lock without offering the opportunity to sign up for or sign in with a PRIVO iD.

Adults and teens can also access the PRIVO-Lock system directly on the PRIVO.com Site and create their own PRIVO iD account.  The PRIVO iD is a secure online log-in credential that can be used on PRIVO-Lock enabled Online Services in the Children’s Online Privacy Protection Act-compliant PRIVO iD network.  PRIVO iD account holders have a hub from which they can see all the PRIVO-Lock Enabled Online Services they have registered with, along with the consents they have given for their child(ren) and even yourself to participate on.

THIS PRIVACY POLICY APPLIES TO PRIVO.COM AND PRIVO-LOCK.  This Privacy Policy applies to PRIVO.com and the PRIVO-Lock system, whether accessed from PRIVO.com or from a PRIVO-Lock enabled Online Service.  It addresses how PRIVO uses information collected through PRIVO-Lock.  Because PRIVO-Lock is a service provider to many Online Services, our Privacy Policy cannot, and is not intended to, encompass the privacy practices of the sites and services that use PRIVO-Lock. To understand how our clients use your information, and that of your child, please review their privacy policy.

THIS PRIVACY POLICY IS PART OF THE TERMS OF SERVICE.  This Privacy Policy is part of the Terms of Service for PRIVO.com and PRIVO-Lock.  When you use the Site, you agree to the Terms of Service, including this Privacy Policy.  Please read them before using the Site or PRIVO-Lock.  They can be found here.  If you disagree with any part of the Terms of Service or Privacy Policy, please do not use the Site or register via PRIVO-Lock for an account on this Site or any PRIVO-Lock enabled Online Service.  This Privacy Policy may be changed, expanded, added to, or updated from time to time, in which case, we will post the new policy, which may be done without notice.  Such revisions will be effective immediately, so please check the latest update effective date and review the Privacy Policy regularly. We will not make any material changes to this privacy policy before notifying you and obtaining your consent.

III. What We Collect Directly From You

When a parent or teen registers for a PRIVO iD on the PRIVO.com Site, we ask you for your full name and email address.  We ask you to optionally add a cell phone number to further secure your account. We may also ask for other optional non-personal information, such as occupation, age, gender, income range, education level, number of children, or hobbies.  This information helps us better understand our users and may be used to help verify a user, in connection with issuing and administering the PRIVO iD.

At the time you register, you will have the option to also provide PRIVO with a minimum set of information about each of your children, including the device ID of any devices your child uses which PRIVO will use to create a PRIVO iD child account for each child.  Finally, PRIVO will ask you to choose a method of providing verifiable parental consent for your child’s use of any child account you create.  To learn more about why parental consent is necessary, click here. You will be given the option of choosing to provide us with a credit card number, partial social security number, a driver’s license number, Skype account information, or other data that is reasonably designed to identify the user PRIVO uses third-party sources to verify this information and does not store or use it for any other purpose but for verifying your identity.  You may also provide PRIVO with verifiable parental consent through an offline method, such mailing, faxing or emailing a signed form to PRIVO or calling the PRIVO Customer Service number. When you have completed the registration process, you and any child(ren) for which you have created an account will each receive a PRIVO iD account.  With this account credential, you and your child(ren) can log into any PRIVO-Lock enabled Online Service more quickly and easily.

Alternatively, a child may begin the registration process for an account on a PRIVO-Lock enabled Online Service, such as a child-directed website or mobile app.  On behalf of the PRIVO-enabled Online Service, PRIVO collects from children their first name, date of birth, username, password and depending on the Online Service gender, grade, display name, and child email address if a parent email was provided to help remind them of their password if they forget. A child may provide PRIVO with a parent email address or a PRIVO iD so that PRIVO can contact the parent to get verifiable consent (in the manner described above) to the child’s use of the PRIVO-Lock enabled Online Service.  This information is not required and is not used for any other purposes before the parent gives permission for its use, however, the child may not (by law or the policies of the Online Service) be able to participate in all aspects of the Online Service (for example, chat or photo sharing) until PRIVO has secured verifiable parental consent.  PRIVO does not collect more information than reasonably necessary for a child to participate in a given activity.  The PRIVO-Lock enabled Online Service may collect additional information from your child and will disclose this to you in its privacy policy.

Whenever you visit the Site, you are also given the opportunity to receive PRIVO’s eNewsletter which contains information about developments in the world of online privacy or participate in contests and/or support initiatives. You have the option to opt-out of these activities at any time.  PRIVO.com may enable surveys, chat or blog-type features.  If you choose to provide information in connection with such features, PRIVO will be able to retain it.  In addition, that information will be available for viewing publicly.  Accordingly, you should not post any information you do not want collected or shared publicly.

If you request additional information or seek support when using the Site, we collect your name and contact information to assist us in responding to you. You can also contact us directly at:

Privacy Vaults Online, Inc., d/b/a PRIVO

P.O. Box 1025

Dumfries, VA 22026-1025

703–569–0504 (telephone)

703–783–8752 (fax)

privacy@privo.com (email) Attn: Privacy Officer

IV. What We Do With The Information You Provide

PRIVO only uses information collected directly from you for the purposes stated.  The information you provide when establishing a PRIVO iD account, on PRIVO.com or a PRIVO-Lock enabled Online Service, is used to facilitate registration on our member services and process verifiable parental consent when required by law or client policy. We will also use this information to allow you to grant consent for you or your child to opt into additional PRIVO-Lock enabled Online Services that use the PRIVO iD for log-in. The parental information we collect is shared with only our PRIVO-Lock members that you authorize for that purpose and our third-party verification service(s), which must comply with this Privacy Policy as well. We will also use your information to update you about changes to our policies and to give you information about additional products and services we, or one of our clients, may offer. With your explicit consent, we may share your information with trusted third parties who offer products or services we believe you may find interesting. After opting in, if you do not want us to disclose your information in such a manner, you may opt out of disclosure by following the procedures described in the next section. Upon account creation, you will automatically be signed up to receive our eNewsletter, consent request from a related child, network updates and notifications. Your primary email address will be used for that purpose. At any time, you can opt-out of these communications and/or control your communications settings in your account profile.

Regardless of whether you have opted out of the disclosure of your information, PRIVO will disclose information about you or your child(ren), in a manner that is not aggregated or anonymous, if we believe it is legally necessary to do so, for example, in response to a court order or civil subpoena, or to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose PRIVO to legal liability.  We may also disclose your information to our affiliates, selected business partners, agents and service providers in order to provide you with our products and services.  In addition, in the event of a merger, acquisition, reorganization, bankruptcy or other similar event, PRIVO customer information may be transferred to our successor or assigned but will remain governed by and protected in strict accordance with this Privacy Policy and no further use of customer information will be made without explicit consent.

V. Your Control Over Your Information and the Information of Your Child

When you provide us with consent for you or your child to participate at one of our clients’ Online Services, we give you the option to agree to the collection and use by ourselves and our client of your child’s personal information for internal purposes, without having to agree to the disclosure of your child’s information by us or our client to unaffiliated third parties. To manage your information, or the information we maintain about your child, click “Manage Accounts” once you are logged into your PRIVO iD account.  There, you will be able to see all of the PRIVO-Lock / PRIVO iD enabled Online Services at which you have permitted your child to register, can alter those permissions, can access the personally identifiable information that PRIVO has collected from you or your child, can correct factual errors in such information, and can request to have this information deleted or request that we no longer collect or maintain such information. To protect your child’s privacy and security online, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.

VI. Passively Collected Data

In order to manage, maintain, and improve the Site and the PRIVO-Lock system, we will sometimes passively collect non-personally identifiable information about visitors using the data transfer logs of the Site or “cookies”.  The information we may collect through passive collection technologies, such as “cookies”, includes IP address and browser type, as well as time spent on the Site or areas visited.  Our logs do not normally contain any personally identifiable information and are used only to improve the design, functionality, and content of the Site and to enable us to personalize your experience with the Site. PRIVO utilizes Google Analytics to assist in these efforts by providing general analytical data on use and functionality of the Site for internal purposes. Data that is collected, processed, and stored is secure and kept confidential and PRIVO has opted not to share this data. For more information, visit their Privacy Policy.

PRIVO does not track you, that is, it does not collect personally identifiable information about your online activities over time and across third-party Web sites or online services. The Site does not employ technology that responds to browser signals that permit users to limit tracking.

VII. Security

PRIVO uses generally accepted security measures and safeguards and requires that the third parties it works with agree to do the same. The measures and safeguards include limiting access to the data to those persons who need it to complete their work for PRIVO.

PRIVO may host the registration pages of PRIVO-Lock enabled Online Services. All data is transmitted through an SSL transmission to ensure privacy and security of your family’s information. We have put in place industry standard physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.

VIII. How to update or remove your information

PRIVO keeps your information/content for as long as necessary in providing the services. If you want to opt out of services, review your information, or delete your information, please contact us at privacy@privo.com.

 

Notice to California Residents

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 certain members of PRIVO to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California. To make such a request, please send an email to privacy@privo.com or write us:

Privacy Vaults Online, Inc., d/b/a PRIVO

P.O. Box 1025

Dumfries, VA 22026-1025

703–569–0504 (telephone)

703–783–8752 (fax)

privacy@privo.com (email) Attn: Privacy Officer 

 

Notice to EU/EEA Member State Residents

PRIVO may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.  By using the sites or services, you consent to such transfer.

IX. Third Party Links

The PRIVO-Lock™ system, through the PRIVO iD directory, contains links to many third party online properties. In addition, you may see the “PRIVO” symbol and logo on many of our clients’ sites. Authorized PRIVO-Lock™ clients have made specific, legally–binding assurances to PRIVO about their practices, including a promise to maintain an accurate and up–to–date privacy policy of their own disclosing their data gathering and usage practices. However, apart from this legally binding promise, PRIVO cannot control these third parties, and is not responsible for the policies or practices of PRIVO-Lock clients. We encourage you to carefully review the privacy policies of sites that link to and from the PRIVO website as well as all PRIVO-Lock enabled Online Services, before providing such sites with any personally identifiable information, and to contact us at privacy@privo.com if you believe any PRIVO-Lock enabled Online Service is engaged in practices that are inappropriate, or in any way inconsistent with their publicly posted privacy policies.

X. Final Note to Parents

We encourage you to the visit Online Privacy Matters at http://www.privofoundation.org, PRIVO’s educational initiative, to help kids, parents and educators to use the Internet safely and be aware of, and express, their preferences about information that is collected online and how it is used. In addition, look at the parent resources section in Privo.com. It also contains a number of valuable resources to help parents and children. Your efforts to instill responsible information practices will help steer your children to appropriate online properties, and will go a long way toward ensuring that your children have enriching experiences online.

XI. General Visitors

The PRIVO.com website and the PRIVO-Lock service are available to the general public, not just parents and children. For instance, PRIVO.com is a corporate site and intended for adults. The PRIVO.com Site may also attract general visitors. Those visitors are assumed to be adults. General visitors may sign up for a corporate newsletter, educational tips, or the Online Privacy Matters campaign which utilizes the PRIVO-Lock system. The data collected for these features is limited to full name, email, zip code, and role type.



Contact Us