Effective Date: This policy was last updated on January 22, 2019Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification
Miaplaza Inc are included in PRIVO’s Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO seal. 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 COPPA certification seal posted on this page indicates Miaplaza Inc 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 (650) 297 4770 or dataofficer @ miaplaza.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at firstname.lastname@example.org. Information we collect from parents
To become an Clever Dragons member, a parent must register for a parent and child account. The parent is required to provide the following information:
Information we collect from children
- Parent’s first and last name, email address, and a password for the parent account. These are required both to fulfill legal requirements for children’s sites and our contractual obligations to you.
- Child’s first name and first initial of last name, plus a password for his account. This becomes the child’s login identifier and also how the child is known by other members on the site. You may, if you prefer, choose an alternate name as long as the child can remember it.
- Further, the parent is required to make a payment through a third-party payment service; however, Miaplaza Inc (aka, Clever Dragons) never receives this credit card information. The payment is required to verify adult status and establish the parent’s identity and is required to meet laws of the United States of America.
When a user’s associated parent email is verified, that user may optionally 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 the option to share his birthdate, which allows customization of his experience on Clever Dragons. Note: These options are not available to European members due to European privacy regulatory requirements.
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 online friends. As noted below, these information postings are pre-moderated for appropriateness.
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.
Boys can become friends on Clever Dragons by inviting each other to start a friendship.
All communication between members, also 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.Other information we collect:
Cookies, log files and entry/exit URLs
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.Third party service providers
Clever Dragons collects certain types of information in order to operate and improve our service to you and other users. 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 does not share user data. For more information on Google Analytics policies, click here
.Sharing Information with Third Parties
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 and 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. For more information on the third parties we work with, please email us at securityofficer @ miaplaza.com.How we use this information
We transfer Information and Personally Identifiable Information between Europe 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’ 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.
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.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 learning games and teaching videos that are offered to users depend on the grade range settings chosen by the parent.How to update or remove your 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 the parental 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.Content retention
There are four main types of data retained by Miaplaza:
- An individual’s data that does not impact others’ activities, such as a member’s profile information, his virtual currency holdings, or his virtual castle and pets
- Digital objects and messages shared with other members
- Logs of user activities on the site
- Records of parents’ financial transactions with Miaplaza. No credit card data is stored and payments are handled by a third party service provider.
This data is retained as long as reasonable to provide our services to you.
If a user requests account deletion, then their profile and associated data is deleted from our records within 20 business days.Links out
We may include links to third parties from the website or services. Clever Dragons isn’t responsible for these companies and because we have a link doesn’t mean we endorse them. Your use of our services maybe subject to the terms and conditions, terms of service and privacy policies of other services that we don’t control such as mobile app stores, mobile software platforms or payment processors. Please be sure to check their privacy policies if you decide to visit them.Security
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, please contact us at securityofficer @ miaplaza.com.Company contact information
Residents in the European Union are entitled to certain rights with respect to personal information that we hold about them:
- Right of access and portability. The right to obtain access to your personal information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
- Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
- Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information; and
- Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
You may also have the right to make a complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here
. If you need further assistance regarding your rights, please contact us using the contact information provided above and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.