Effective Date: June 2, 2015
If you are under the age of 13, your parent or guardian must provide consent for Snypr’s collection of personally identifable information from you and for your use of the Snypr Services before you sign up to use the Snypr Services. Please see the section below titled “For Children Under 13 and Their Parents or Guardians.”
For Children Under 13 and Their Parents or Guardians:
Children under the age of 13 (each, a “child” and collectively, “children”) may register with the Snypr Services after we have obtained verifiable parental consent in accordance with the Children’s Online Privacy Protection Act (“COPPA”).
Snypr asks prospective users of the Snypr Services to provide a username and birth date information as the first steps in the registration process. For each prospective user under the age of 13, we then collect the email address of the child’s parent or guardian so that we may give the parent or guardian notice of our information collection, use and sharing practices and obtain verifiable parental consent for the child’s use of the Snypr Services. We do not save or store any information submitted by or collected from a child except for the email address of the child’s parent or guardian until we have obtained verifiable parental consent from the parent or guardian. If we do not obtain parental consent within a reasonable time after collecting the parent or guardian’s email address from the child, we will delete such information from our records.
In our follow-up communication with parents and guardians, we describe the types of information we collect from our users and how we use, store and share such information. We also provide information on how a parent or guardian can give consent for the collection, use and disclosure of a child’s personal information (as defined by COPPA) by signing our consent form and sending it to Snypr by fax, mail or electronic scan (the “print-and-send” method).
We will not require children to disclose more information than is reasonably necessary to participate in the games made available through the Snypr Services. A parent or guardian may review a child’s personal information collected by or through the Snypr Services at any time and request the deletion of such information or stop the collection of further information from the child by contacting Snypr at firstname.lastname@example.org. A parent or guardian may also request that we do not disclose a child’s personal information to third parties, unless such third parties provide services or functionality that enable us to provide the Snypr Services.
Information Snypr May Collect:
Personally Identifiable Data. “Personally Identifiable Data” means information that alone or when in combination with other information may be used to readily identify or contact you, such as your name, email address or photograph, or other information about you that is directly linked to Personally Identifiable Data.
Usage Data. “Usage Data” means certain information that we, our third-party service providers or social media services that we integrate into the Snypr Services may collect through a variety of technologies, such as cookies and web beacons, that may automatically or passively collect information when you visit or interact with the Snypr Services. Usage Data may include, but is not limited to, your IP address, time spent on the Snypr Services, the type of browser, device or operating system you use or the URL that referred you to the Snypr Service.
If we associate Usage Data with your Personally Identifiable Data, we will treat the combined information as Personally Identifiable Data. In accordance with COPPA, we consider persistent identifiers that can be used to recognize a user over time and across different sites as a child’s personal information.
How Snypr Gathers Information:
Information Collected Directly From You. We may collect Personally Identifiable Data when you register for the Snypr Services, visit certain areas or access certain features of the Snypr Services, subscribe to any communications from us or otherwise voluntarily provide Personally Identifiable Data to us.
To register for the Snypr Services, you will need to provide us with Personally Identifiable Data including your email address, gender and birthday. We will also ask for a username to associate with your account. Because usernames are publicly viewable by all users of our App(s), we advise that you select a username that does not include your first and last name or online contact information, such as identifiers that you use in connection with your email account or instant messaging services. We may also request that you provide additional information to participate in games made available through the Snypr Services, such as information related to your sports practices, events and training activities, and to help us personalize your experiences with and improve the Snypr Services.
Information from Your Use of the Snypr Services. We may collect Personally Identifiable Data and Usage Data from you as you use the Snypr Services. For example, we may monitor and collect information related to your in-App activity, such as which games you have played and how often you have logged your sports and training activities through the Snypr Services. We may also collect information from the mobile device you use to access the Snypr Services, such as your device identification number.
Your User Content. “User Content” means the information that you may post, submit, upload, publish, display, transmit or otherwise share through the Snypr Services, including but not limited to photographs or other images for use as account pictures, information related to your sports activities and “high fives” or other messages you select to send to other users through the Snypr Services. We may not consider all User Content to be Personally Identifiable Data, so please use caution and common sense when sharing or posting.
Information from Customer Service. We may collect Personally Identifiable Data and Usage Data through your communications with our customer service team.
Information from Third-Party Integrated Services. We may collect information, including Personally Identifiable Data and Usage Data, from social media websites, applications or other third-party services that we integrate into the Snypr Services (collectively, “Third-Party Integrated Services”) if you are aged 13 or over and you choose to connect to your Snypr account using any such Third-Party Integrated Service. For example, if we have enabled your ability to log in to the Snypr Services by using your Facebook credentials and you choose to do so, we may collect Personally Identifiable Data from your Facebook profile, such as your email address, profile picture and friend list.
For information on how Snypr may share information that we have collected about you with Third-Party Integrated Services, please see the section titled “Third-Party Websites and Applications—Third-Party Integrated Services” below.
Cookies, Automatic Data Collection, and Related Technologies. When you access or use the Snypr Services, we may engage, receive, collect and store certain types of information through automatic data collection tools including cookies, pixel tags, web beacons, embedded web links and similar technologies. These technologies may collect information including, but not limited to, your Internet Protocol (IP) address, browser type, the date and time that you use the Snypr Services, referring/exit pages and URLs, number of clicks, cookies that may uniquely identify your browser and information about your mobile device. Additionally, if you are aged 13 or over and you choose to connect to your Snypr account using a Third-Party Integrated Service, such Third-Party Integrated Service may use these or similar technologies to collect information about your use of the Snypr Services.
Cookies are small text files placed in visitors’ web browsers to store their preferences or provide certain functionality. Most browsers allow you to block and delete cookies. Certain features of the Snypr Services may not work properly if you block or delete cookies.
By using the Snypr Services, you are authorizing us to gather, parse and retain data, including Personally Identifiable Data, related to the provision of the Snypr Services. We will retain personal information (as defined by COPPA) collected from children only as long as is reasonably necessary to fulfill the purpose for which it was collected. Parents or guardians may contact Snypr at email@example.com to review any such personal information that we have collected, and may request that we update, delete or stop collecting such personal information.
How Snypr Uses Your Information:
Internal and Service-Related Usage. We use information, including Personally Identifiable Data, for internal and service-related purposes and may provide it to third parties that facilitate our provision of the Snypr Services. We may use any data we collect to provide and improve the Snypr Services.
Your User Content Posted to the Snypr Services. When you post User Content, such as a photograph or image for use as an account picture or information related to your sports activities, our employees and service providers may review, categorize and display such information in providing the Snypr Services to you and other users. Any User Content you post will be publicly available to other users unless you have expressly opted to use the Snypr Services as a “private” user. If your account settings are “public,” do not post any information that you want to keep private. Snypr reserves the right to remove User Content for any reason without notice to you.
Service Communications. We may contact you using the email address you provide to us (or your parent or guardian’s email address, if applicable) to verify your account and for informational and operational purposes, such as account management, customer service or system maintenance.
Marketing. We do not rent, sell or share Personally Identifiable Data about you with other people or nonaffiliated companies for their direct marketing purposes. We also do not provide any Personally Identifiable Data to any third-party ad networks. We may use your Personally Identifiable Data and other information to communicate with you by an in-App notification to provide you with information about games and other features of the Snypr Service that we think may be of interest to you.
Aggregate Data. We may de-identify and aggregate data collected through the Snypr Services and use it for any purpose. It is important to remember that such information does not identify you individually.
How Snypr May Share Your Information:
Vendors and Service Providers. We may share any information, including Personally Identifiable Data, that we receive with vendors and service providers retained in connection with our internal business purposes or the provision of the Snypr Services.
Social Networking and Other Website Services. If you are aged 13 or over, the Snypr Services may allow you to share information, including Personally Identifiable Data, with third-party services and social networking websites such as Facebook. We do not share your Personally Identifiable Data with such services or websites unless you direct the Snypr Services to share it by connecting your Snypr account to your account with such a service or website. The use of your information by third-party services and social networking websites will be governed by their privacy policies, and you may be able to modify your privacy settings on their websites.
As Required By Law and Similar Disclosures. We may access, preserve and disclose your Personally Identifiable Data, other account information and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect your, our or others’ rights, property or safety.
Merger, Sale or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
With Your Consent. We may also disclose your Personally Identifiable Data with your permission or, if applicable, your parent or guardian’s permission.
Third-Party Websites and Applications:
Third-Party Integrated Services. If you are aged 13 or over, you may be able to access certain third-party applications or content by connecting your Snypr account to Third-Party Integrated Services. If you choose to connect your Snypr account to these Third-Party Integrated Services, you may be requested to log-in and sync your Snypr account with such Services. If you opt to integrate or use Third-Party Integrated Services with the Snypr Services, such Third-Party Integrated Services may gain access to certain information that you have provided to us, including Personally Identifiable Data. Please remember that the manner in which Third-Party Integrated Services use, store and disclose your information is governed solely by the policies of such Third-Party Integrated Services. We have no liability or responsibility for the privacy and information security practices or other actions of any Third-Party Integrated Services that you choose to access through your Snypr account.
Security of Your Information:
If you are using the Snypr Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and the global processing of such information. By providing your information you consent to any transfer and processing of your information in accordance with this Policy.
Update Your Information or Pose a Question or Suggestion:
Changes in Collection or Use of Personal Information from Children Under 13. We will obtain parental consent in accordance with COPPA before changing how we collect, share or otherwise use personal information (as defined by COPPA) from children under the age of 13.
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