PJ Our Way Children's Privacy Policy

Last Revised: July 10, 2018

The Children’s Online Privacy Protection Act (“COPPA”) regulates online collection of information from persons under the age of 13 (collectively, “Children”; individually, a “Child”). The information in this Children’s Privacy Policy outlines our commitment as an operator of the Service (as hereinafter defined) to protect the privacy and safety online of Children. As used herein, the term “Service” means the services available on the PJ Our Way website (the “PJ Our Way Website”) currently located at www.pjourway.org, including without limitation the PJ Our Way engagement program, together with associated and successor websites, applications, and services. As used herein, the term “personal information,” as defined in Section 312.2 of COPPA, includes, but is not limited to, names, addresses, photos, geolocation information, online contact information and persistent identifiers that can be used to recognize a user over time and across different online services.

The policies outlined in this Children’s Privacy Policy are intended to supplement the information appearing in the PJ Our Way General Privacy Policy. Where the PJ Our Way Children’s Privacy Policy conflicts with the PJ Our Way General Privacy Policy concerning information about a Child, the terms of this PJ Our Way Children’s Privacy Policy will prevail over the PJ Our Way General Privacy Policy.

The operator collecting or maintaining personal information from Children, or on whose behalf such personal information is collected or maintained, through the Service is The Harold Grinspoon Foundation (“HGF”). Any inquiries regarding the Service's privacy policies should be directed to:

The Harold Grinspoon Foundation
PJ Our Way

67 Hunt Street, Suite 100
Agawam, MA 01001
Telephone Number: (413) 276-0800
info@pjourway.org

CARU COPPA Safe Harbor

This privacy policy and the Children’s Advertising Review Unit (“CARU”) seal shown on our PJ Our Way Website confirm that HGF is a valid licensee and participating member in CARU’s COPPA Safe Harbor program. To protect your privacy, we have voluntarily undertaken this privacy initiative. CARU has reviewed and certified that we meet established online information collection and use practices on the PJ Our Way Website.

As part of CARU, we are subject to audits and frequent monitoring of our websites and other enforcement and accountability mechanisms administered independently by CARU.

If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact CARU at:

CARU
Attn: Director
112 Madison Avenue, 3rd Floor
New York, NY 10016
info@caru.bbb.org

Information We Collect

We collect information in two ways: directly and passively.

Information we collect directly from Children include birthdate, zip code and a parent or guardian’s email for the purpose of obtaining verifiable parental consent.

From the parent or guardian, by or on behalf of HGF, we collect information about the Child and parent including the following: first and last name of parent and Child; e-mail address of Child (optional); username; password for Child’s account; phone number; birthdate; gender; age; current location; zip code; state; books selected; address; avatar image; and shipping information.

When prompted to create a username and avatar, we have safety measures in place preventing a user from creating an avatar by using personally identifiable information. Avatars are created by choosing from a pre-selected sampling of colors and designs. Our PJ Our Way Website contains a mechanism that prevents users from creating usernames that contain their first or last names.

Information we collect passively while Children use this service: We may use tracking technologies including cookies and action tags to track the web pages the Child views; last web page visited; date and time the Child logged on to or accessed the Service; Child’s IP address; browser information; Internet and online usage information; geolocation information; and activity on the Service.

For more information on use of cookies and action tags, see our General Privacy Policy

How We Use, Share, or Disclose Personal Information

Once a Child’s account has been verified and approved, we may use the collected information to fulfill a requested transaction and provide the Service, such as sending out the monthly book selection to the Child’s home.

In addition, if Children identify themselves to us by sending us an e-mail or calling us with questions or comments, we may use their information (including personal information) to respond to their questions or comments and then delete the email address. We may file their non-personal questions or comments for future reference. For clarification, but not limitation, we may use for any lawful purposes, including without limitation, benchmarking, development of best practices, and research and statistical purposes, information collected from Children in aggregate formats.

We also use certain personal information to help us understand who uses the Service; for internal operations such as operating and improving the Service; to perform statistical analysis of user behavior; to evaluate and improve the Service; to contact users for customer service purposes; to send users important service announcements and updates regarding the Service; to facilitate the delivery of advertising; to develop other products and Services; to market back and/or make recommendations to the Child or a family member; and so that we and third parties can contact the Child or a family member about products and services that may be of interest to them and provide them with targeted feedback.

Disclosure and Sharing of Personal Information

Public Areas

The Service features various community and blog areas and other public forums (the “Public Areas”) where Children can share information, post book reviews, and post questions for others to answer. In these areas, PJ Our Way pre-moderates book reviews and comments for personal information before they are published on the PJ Our Way Website.

PJ Our Way Team

A group of select Children make up the PJ Our Way Team. The PJ Our Way Team posts reviews, photos, videos and blog posts on the PJ Our Way Website with the help of our editorial staff. General members of the PJ Our Way Website cannot sign up for the PJ Our Way Team, and are not able to upload videos, photos or otherwise disclose personal information in these areas.

Sharing Information with Third Parties

We share information with third parties in two ways:

(1) Support for Internal Operations

We share information with third party service providers to help us run our service including to help us understand who uses the Service; for internal operations such as general record keeping as well as operating and improving the Service; to perform statistical analysis of user behavior; to evaluate and improve the Service; to contact users for customer service purposes; to send users important service announcements and updates regarding the Service; and to develop other products and Services.

A list of these providers can be found here.

(2) Sharing Information with Third Party Community Partners

We may share personal information with our third-party community partners to provide program promotional and advertisement-related services. For example, we partner with local Jewish organizations such as federations or Jewish community centers who may contact parents via email, mail or through advertisements about products, services, events or programming that might be of interest. See a list of our community partners.

Separately, on an anonymous basis, we may share Children’s responses to questionnaires with our community partners. This sharing is intended to help our community partners generally understand what products and services may be of interest to our users.

We might also inform third party partners regarding the number of Children who use the Service, the demographic breakdown of the Children who use the Service, or the products and/or services purchased using the Service and the vendors of such products and services.

Other Instances Where We May Share Personal Information

Sale of Business

We reserve the right to transfer the personal information collected from Children to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of HGF or any of its Affiliates, provided that the third party agrees to adhere to the terms of this Children’s Privacy Policy.

Affiliates

We may disclose personal information collected from Children to our Affiliates. For purposes of this Children’s Privacy Policy, an “Affiliate” means any person or entity that directly or indirectly controls, is controlled by or is under common control with HGF, whether by ownership or otherwise (including without limitation, a parent company or subsidiary). Any information collected from Children that we provide to our Affiliates will be treated by those Affiliates in accordance with the terms of this Children’s Privacy Policy.

Parents

We may disclose any and all personal information collected from a Child to the parent who registered the Child for the Service. (As used herein, the term “parent” includes a legal guardian.)

Laws and Legal Rights

We may disclose information (including personal information) collected from Children if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personal information collected from Children in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the PJ Our Way Terms of Use, to detect fraud, or to protect the safety and/or security of our users, including the Child, the Service or the general public.

Verifiable Parental Consent

When a Child seeks to register for our PJ Our Way, we do not collect information directly from the Child other than a date of birth.

After providing a direct notice of our information collection practices to a parent or guardian, we use the services of ChildGuardOnline™ to verify a parent’s identity and affirm his or her consent. Once a parent’s identity has been confirmed and the account is approved, a parent can choose a username and password for the Child’s account.

A parent can revoke consent at any time by contacting us at: info@pjourway.org

Review and Deletion of Children’s Personal Information

We are not permitted to condition a Child’s participation in an activity on the Child’s disclosure of more personal information than is reasonably necessary to participate in the activity.

In addition, the parent of a Child may: (a) consent to the collection and use of the Child’s personal information without consenting to the disclosure of that information to third parties except as necessary to operate the Service; (b) review and have deleted the personal information of the Child; and (c) refuse to permit further collection or use of the Child’s personal information. If you wish to do any of the above, please contact us at:

The Harold Grinspoon Foundation
PJ Our Way

67 Hunt Street, Suite 100
Agawam, MA 01001
Telephone Number: (413) 276-0800
info@pjourway.org

Please note, however, that because the collected information is necessary to provide certain functionality, certain aspects of the Service, products, offerings, features, and/or resources may not work properly, or at all, if consent is revoked, if a parent refuses to allow us to further use or collect a Child's information, or if a parent directs us to delete the information in accordance with the rights described above.

We will be happy to review, update or remove information and/or content as appropriate. Residual copies of personal and/or content that have been removed from the PJ Our Way Website may remain in our backup systems for approximately one month. We may still retain your personal information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.

Changes to this Children’s Privacy Policy

We reserve the right to amend this Children’s Privacy Policy at any time. Please check this page periodically for changes. If we intend to make a material change in the collection, use, or disclosure practices with respect to a Child’s previously-collected personal information to which a parent previously has consented, we will obtain the parent’s consent to such changes.

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