Privacy Policy

Your privacy is our top concern. We work hard to earn and keep your trust, so we adhere to the following principles to protect your privacy:

• We will not rent or sell your personally identifiable information to third parties for marketing purposes
• We will not share your contact information with another user
• We recognize the importance of privacy and use reasonable efforts to secure your information for unauthorized disclosure
Effective Date: This policy was last updated on July 7, 2014.

Clever Dragons is a Member of the PRIVO’s PRIVO-Cert™ Safe Harbor Certification Program (“the Program”). As a participating member in the Program, Clever Dragons adheres to the strict information collection, use and disclosure requirements set forth by the Program. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. PRIVO aims to help parents and their children exercise control over personal information while exploring the Internet. The PRIVO certification seal posted on this page indicates that Clever Dragons has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +1 (650) 644-7753 or privacy@clever-dragons.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

We will use reasonable efforts to comply with the stated privacy principles and will take prompt corrective action when we learn of any failure to comply with them. We sometimes release alpha and beta versions of our products, which are further refined before the release of the final version. Because these products are still in a test phase, we may not always catch an unintended privacy issue, despite our efforts to do so. As such, we welcome user feedback on any privacy concerns you may have. In light of the above and because of the complex and constantly changing nature of our technology and business, Clever Dragons does not guarantee error-free performance under this privacy policy. Clever Dragons or Miaplaza, Inc., shall not be liable for any incidental, consequential or punitive damages relating to this privacy policy.

Please read this privacy policy to learn more about:
1. What personally identifiable information of yours is collected by Clever Dragons.
2. The use of cookies and log files.
3. Children’s use of the site or app.
4. How the information is used.
5. With whom the information may be shared.
6. How you can access and change your account information.
7. What security procedures are in place to protect the loss, misuse or alteration of information collected by Clever Dragons.
8. How to contact us.

Clever Dragons offers for its members a community designed for young boys, where they can interact with friends, practice school material, engage in learning activities, play games and view videos. The Service is provided through Clever Dragons’s web site currently located at www.clever-dragons.com ("Site"). Clever Dragons is a service provided by miaplaza, Inc. (“Miaplaza”, also referred to in this Privacy Policy as “Miaplaza" or "Clever Dragons”) of PO Box 183, Menlo Park, CA 94026 USA.

Please note that this privacy policy is provided under, and subject to, the Clever Dragons User Agreement.

Information Collection
Trial Registration:
In order to become a Clever Dragons trial user, one must first create a boy’s account on this web site. To create an account, a boy is required to provide the following information: his first name and last name initial, plus a password for his account. He also is asked to provide an email account for the parent. The parent is then sent an email and is asked to click on a link to verify the email account; however this verification is not required for the boy to start his trial membership. A parent that clicks on the verification link will be offered to register for a fully verified parental account, as discussed below in the Full Registration section.

All boys with trial registration status only see messages that have been pre-monitored by Clever Dragons. See the discussion of monitoring in the section “Communication between Users” below. Trial registration members cannot become “Real World Friends” as described below in the section “Clever Dragons Friends.”

If a parent email is verified, when the associated boy later logs on to the site, he is offered to provide his own email address. This email address may be used to notify him of pending, pre-monitored messages or of new offerings on the site. He is also offered to share his birth date, which allows customization of his experience on Clever Dragons.

Full Registration:
In order to become a Clever Dragons Fully Registered, paying user, one must create a parent account on this web site. To create a parent account, a parent is required to provide the following information about the parent or guardian of the boy user: parent/guardian first name and last name, email address and an account password. Further the parent is required to make at least a symbolic payment through a third-party payment service; however, Clever Dragons never receives this credit card information. The payment is required to verify adult status and establish the parent’s identity.

The boy is asked for the same sets of information with Full Registration as with Trial Registration, as discussed above. In addition, the boy user is provided a code that can be exchanged with friends to form Clever Dragons Real World Friends relationships, as described in the “Clever Dragons Friends” section below.

For either registration type, Trial or Full, the boy may also provide information about himself in the child’s Profile section, such as his favorite color and what he’s doing now. Parts of this Profile are viewable by all users, while certain sections can only be seen by the boy’s friends or his own Real World Friends. As noted below, apart from communication between mutual Real World Friends, these information postings are pre-moderated for appropriateness. See below on interactions between users that are allowed for Real World Friends and Regular Friends.

Clever Dragons does not condition a child’s participation in an activity on the disclosure of more information than is reasonably necessary to participate.

Clever Dragons Friends:
Boys want to connect with friends and it's important for building social skills; thus, we want to encourage social interaction, but we want it to be in a safer setting than is typical for the Internet. There are two types of friends on Clever Dragons.

1. Friends/Regular Friends - Boys can become friends on Clever Dragons by inviting each other to start a friendship. All communication between friends is reviewed by a site moderator (i.e., pre-moderated) before it can be read by the intended recipients to prevent inappropriate commentary and divulging of personal information.

2. Real World Friends - Real World Friends are friends that boys already have outside of Clever Dragons. On Clever Dragons Real World Friends can chat with each other and engage in other person-to-person communication that is not necessarily monitored by a site moderator. To become linked as Real World Friends on Clever Dragons, both boys have to exchange their individual personal friendship codes. We currently take measures to get this to happen outside of Clever Dragons. In the future we may alter this procedure, as we may come up with new, good ways of protecting the boys while encouraging social interaction. If we do, we’ll notify you first.

A user can see, without pre-moderation, only postings made by a given user’s own Real World Friends. Moderator approval is required before Regular Friends see all other postings, such as those posted by a Regular Friend who happens also to be the Real World Friend of the user’s Real World Friend.

A boy can end a Clever Dragons friend or Real World Friend connection at any time using the friends management features of the site.

Cookies & Log Files

Like most web sites, Clever Dragons uses cookies and web log files to track site usage. A cookie is a tiny data file that resides on your computer that allows Clever Dragons to recognize you as a user when you return to our site using the same computer and web browser. Unfortunately, if your browser settings do not allow cookies, you will not be able to use our website. Like the information you enter at registration or in your Profile settings, cookie and log file data is used to customize your experience on the web site.

Clever Dragons uses what is called a "session" cookie, which identifies a particular visit to the Clever Dragons site. Session cookies expire after a short time or when you close your web browser.

In addition, if you enable the automatic login feature, a "persistent" cookie stays on your computer between sessions to allow Clever Dragons to recognize your user account the next time you visit. This cookie is removed if you turn off this automatic login or if you switch users. At this time Clever Dragons does not use other "persistent" cookies.

Due to the communication standards on the Internet, when you visit the Clever Dragons web site we automatically receive the URL of the site from which you came and the site to which you are going when you leave Clever Dragons. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your ISP. This information is used to analyze overall trends to help us improve the Clever Dragons service, but is not linked to personally identifiable information in any way.

Information Use
The information you choose to provide on this site is used to help you describe yourself to other users. In addition, Clever Dragons collects certain types of information in order to operate and improve our service to you and other users. For example, we use third party Google Analytics to gather aggregate data on how many visit what Clever Dragons pages, what paths are taken by members to get to Clever Dragons, which browsers are used most, and other statistics. Miaplaza, Inc. is the sole owner of the information collected on this site and this third party is prohibited from sharing data. For more information on Google Analytics, click here.

We transfer Information and Personally Identifiable Information between Europe (Germany) and the United States. By visiting our Web site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in this policy. In addition, such data may be stored on servers located outside your resident jurisdiction, which may have less stringent privacy practices than your own jurisdiction. Please note that Clever Dragons’s own policies adhere to all requirements of the United States for its users from the USA. By providing us with your data, you consent to the transfer of such data.

Clever Dragons Communications
Clever Dragons will communicate with you through email and notices posted on this website. These include occasional emails to inform you about various features of the service.

Customized Content
Information you provide at registration or in your Account Management section is also used to customize your experience on the web site. For example, the language used for many menu items is changed according to the setting on your Account Management page.

Information Sharing
Sharing Information with Third Parties:
Clever Dragons takes the privacy of our users very seriously. We will never sell, rent, or otherwise provide your personally identifiable information to any third parties for marketing purposes. We will only share your personally identifiable information with third parties to carry out your instructions, to provide specific services. For instance, we use a payment and credit card processing company to bill users for subscription fees. We also use third party software development firms and server hosting services. None of these third parties retain, share, or store any personally identifiable information except to provide these services and are bound by strict confidentiality agreements which limit their use of such information.

For more information on the third parties we work with, please email us at privacy@clever-dragons.com.

Communication between Users:
Certain parts of the site allow for text communication between any Clever Dragons user, including a member’s:
• Profile
• Comments to games and videos
• Submissions to “motto” chats


Only a member’s friends see what is written in:
• Emails
• Certain elements of the member's Profile
• Guestbook comments


Only a member's Real World Friends see:
• A chat between himself and the Real World Friend member
• The birthday (without year) of the friend

With the exception of communication between Real World Friends, all communication on Clever Dragons is reviewed by site moderators before it is published (pre-moderation). This is to prevent inappropriate commentary and divulging of personal information to others. While our site monitors are diligent, some questionable comments may slip through; thus, please let us know if you register communication between boys that is not appropriate.

If the member uses any of the communication function within this website and discloses personally identifiable information, you should be aware that such information could be read, collected or used by other users. While we have moderation functions, some filters and other measures in place to hinder it, we and our systems are not perfect. By verifying your account, you agree to work with us to address problems with personally identifiable information slipping through and entering the site, and you agree that Clever Dragons cannot be held liable for inadvertent errors.

Emails initiated by a boy, such as invitation emails to join him on Clever Dragons, will never list his personal information apart from what is written by him for that email specifically, nor will it specify the people to whom he is directly connected unless he has added this information. Note that the sender’s first name will be added to the email so that the recipient can understand who it is from. Email text added by the boy will be pre-moderated before being included in an email.

We will not knowingly release personal information or unmoderated user submissions to those who are not Clever Dragons members.

Legal Disclaimer:
It is possible that we may need to disclose personal information when required by law. We will disclose such information wherein we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on our company or to exercise our legal rights or defend against legal claims.

Information Safeguards
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you please contact us mp-feedback@miaplaza.com

Accessing and Changing Your Account Information
You can review the personal information you provided us and make any desired changes to the information, or to the settings for your Clever Dragons account, at any time by logging in to your account on the Clever Dragons website and editing the account and profile information. To request that we close your account and remove your information, please send us your request and we will take care of it. Please send your request using an email account that you have registered with Clever Dragons under your name. You will receive a response to requests sent to us within five business days of our receiving it.

Changes to this Privacy Policy
Clever Dragons may update this privacy policy. In the event there are significant changes in the way we treat your personal information, we will send a notice to the primary email address specified in your Clever Dragons account or by displaying a prominent notice on this site. However, it is your responsibility to review the privacy policy from time to time so you will be aware of changes.

Questions or Comments
If you have questions or comments about this privacy policy, please contact us at (650) 644-7753 or via email to johannes.ziegler@miaplaza.com, or by mail at PO Box 183, Menlo Park, CA 94026 USA.
 

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