PJ Our Way COPPA Privacy Policy

Last Updated September 23, 2014

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 COPPA 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 currently located at www.pjourway.org and/or any mobile applications we may offer, including without limitation the PJ Our Way engagement program, together with associated and successor websites, applications, and services.  The policies outlined in this COPPA Privacy Policy are intended to supplement the information appearing in the PJ Our Way General Privacy Policy. Where the PJ Our Way COPPA Privacy Policy conflicts with the PJ Our Way General Privacy Policy concerning information about a Child, the terms of this PJ Our Way COPPA 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:

Harold Grinspoon Foundation
PJ Our Way
67 Hunt Street, Suite 100
Agawam, MA 01001
Telephone Number: (413) 276-0800
info@pjourway.org

The personal information that may be collected from Children by or on behalf of HGF includes the following: first and last name; e-mail address; username; password;  phone number; birthdate; gender; age; current location; zip code; state; year of birth; books selected; book reviews and preferences; address; billing and credit card information; avatar image; shipping information; photograph, video, or audio file containing a Child’s image or voice; web page the Child is currently viewing; last web page visited; date and time the Child logged on to or accessed the Service; Child’s IP address; device properties, including, but not limited to unique device identifier or other device identifier; device software platform and firmware; mobile phone carrier; information logged from a Child’s hardware or device; software; hardware; applications; browser information; Internet and online usage information; geolocation information; and activity on the Service.  When prompted to create a username and avatar, we advise users to use non-personally identifiable information – i.e., select a screen name that is not similar to a user’s actual name and select an avatar that does not display the user’s image – because such information can be publicly available to all users.  In addition, as described in further detail below, the Service features various Public Areas (as hereinafter defined) that enable Children to make personal information publicly available.  

The collected information may be used to fulfill a requested transaction and provide the Service; 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 keep records; 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.

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 we may file their 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.

The operator does not disclose personal information collected from Children to third parties other than to persons who provide support for the operations of the Service and who do not use the information for any other purpose, except as follows:


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.

Third Parties Generally.

We may disclose information (including personal information) collected from Children, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties 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. We may also provide to third parties personal information. For example, we might share Children’s responses to questionnaires and e-mail addresses with third parties in order for third parties to contact users about products and services that may be of interest. The third parties to which we may provide or who may independently directly collect personal information may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties.

Partners.

In connection with our operations and in providing the Service, we partner with philanthropists as well as educational, religious, and community programs and organizations.  We may provide to these partners information collected from Children so that our partners may contact Children and/or their family members about products, services, events, and programming that may be of interest.

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 COPPA Privacy Policy.

Affiliates.

We may disclose personal information collected from Children to our Affiliates. For purposes of this COPPA 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 COPPA Privacy Policy. 

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. These Public Areas are open to the public and should not be considered private. We cannot prevent such information from being used in a manner that may violate this COPPA Privacy Policy, the law, or a Child’s personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

Any information Children share in a Public Area (including personal information) is by design open to the public and is not private. You and your Child should think carefully before posting any information in any Public Area. What Children post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. As with any public forum on any website, the information posted may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If a Child mistakenly posts personal information in a Public Area, the Child or their parent can send us an e-mail to request that we remove it by contacting us at info@pjourway.org. You should understand that in some cases, we may not be able to remove a Child’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:

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, 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.

Changes to this COPPA Privacy Policy

We reserve the right to amend this COPPA 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.