CynjaSpace Privacy Policy

This Privacy Policy was last modified on June 14, 2016.

CynjaTech (“us”, “we”, or “our”) operates the CynjaSpace™ application (the “Application”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from Members of the Application.

This privacy policy describes the treatment of information provided or collected on the Application and explains the treatment of information provided or collected on applications we make available on third-party sites or platforms if disclosed to you in connection with use of the Application. We follow this privacy policy in accordance with local law in the places where we operate.

This privacy policy is meant to define a simple set of principles and rules to which all Members of a digital trust network agree so that they may share identity and personal data with greater confidence that it will be protected and only used as authorized.

Overview:

All data shared with the Application belongs to you.

The Application uses data only with your explicit consent.

Your data will only be shared with other Members to whom you have given explicit consent.

Contents:

Types of Information We Collect
How We Collect Your Information
Use of Your Information by CynjaTech
Sharing Your Information with Other Companies
Your Controls and Choices
Children’s Privacy
Data Security, Integrity and Retention
Data Transfers, Storage and Processing Globally
Changes to this Privacy Policy
Questions

1. Types of Information We Collect

We collect two basic types of information – personal information and anonymous information.  We may use personal and anonymous information to create a third type of information, aggregate information. We collect the following categories of information:

• The CynjaSpace™ registration information you provide when you create an account, including your first name and surname, email address, mobile phone number, username and password. Only those adults over the age of 18 may create a CynjaSpace™ family account.
• Transaction information you provide when you request information through our Application, including your postal address, telephone number and payment information.
• Information you provide to us when you use our Application on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your Member account.
• Usage, viewing and technical data, including your device identifier or IP address, when you use our application.

2. How We Collect Your Information

We collect information you provide to us when you request products, services or information from us, register with us, participate in other activities on our Application, or otherwise interact with us. The information we collect is covered by this privacy policy. Privacy choices you have made on any third-party site or platform you visit while using our products will not apply to our use of the information we have collected directly through our Application.

We collect information through registering and using our Application.

3. Use of Your Information by CynjaTech

CynjaTech may not give its affiliates access to your information unless you explicitly consent to share your data to provide you with the products and services you request.

The Member must provide explicit consent for CynjaTech and third-parties to communicate with you about your account or transactions with us and send you information about features on our Application or changes to our policies.

We will only send you offers and promotions for our products and services or third-party products and services with your explicit consent.

We will use your data with your explicit consent to personalize content and experiences.

Only with explicit consent will we provide you with advertising based on your activity on our Application.

We will optimize or improve our products, services and operations based on anonymized information about our Members.

4. Sharing Your Information with Other Companies

We will not share your personal information outside CynjaTech except in limited circumstances, including:

• When you allow us to share your personal information with another company, such as directing us to share your personal information with third-party sites or platforms including social networking sites. Once we share your personal information with another company, the information received by the other company becomes subject to the other company’s privacy practices.
• When companies perform services on our behalf, like package delivery and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law.
• When we share personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our Members and third parties, to protect our rights and property and the rights and property of our Members and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law.

5. Your Controls and Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with local law, your controls and choices may include:

• You may correct, update and delete your Membership registration account.
• You may change your choices for subscriptions, newsletters and alerts.
• You may choose whether to receive offers and promotions for our products and services, or products and services that we think may be of interest to you.
• You may choose whether we share your personal information with other companies so they can send you offers and promotions about their products and services.
• You may choose whether to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers on our Application.
• You may request access to the personal information we hold about you and that we amend or delete it.
• You may exercise your controls and choices, or request access to your personal information, by visiting your account, e-mailing info@cynja.com, or following instructions provided in communications sent to you. If you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding personal information about you that we process or retain, please contact info@cynja.com.

6. Children’s Privacy

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on the Application. Some features on our Application are age-gated so that children cannot use them, and we do not collect personal information from children in connection with those features. On our Application the parent can create, manage and control each child’s account. Parents are always able to view what the child is doing and change access rights for the child at their will. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:

• Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information.
• In accordance with applicable law, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children.
• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in the Application.
• Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.

For additional information about our practices regarding children’s personal information, please read our Children’s Privacy Policy below.

7. Data Security, Integrity and Retention

The security, integrity and confidentiality of your information are important to us. We have implemented technical, administrative and physical security measures that are designed to protect user information from unauthorized access, disclosure, use and modification. From time to time, we review our security procedures to consider new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

8. Data Transfers, Storage and Processing Globally

We operate globally. If you provided us consent to share your personal information to our affiliates, we may transfer your personal information to CynjaTech affiliates or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

9. Changes to this Privacy Policy

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will notify you if these changes are material and, where required by applicable law, we will obtain your consent.

10. Questions

If you have any questions about this Privacy Policy, please contact us at info@cynja.com.

Some features in our Application may contain links to websites not owned or controlled by us and we are not responsible for the privacy practices of those websites. We encourage you to be aware when you leave our Application and to read the privacy policies of other websites.

Notice to California Residents: If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content.

Children’s Privacy Policy

CynjaTech is committed to protecting Members’ privacy, especially children. This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information about or provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This policy complies with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States.

1. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents

Our Application may collect information from children. Below are our information collection policies and when and how we will notify parents or seek parental consent. If we collect personal information from a child, we will retain that information only as long as reasonably necessary to complete the activity, ensure the security of our users and our services, or as required by law. If we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek a parent’s consent for that collection.

Registration

Only parents are allowed to register children with our Application so their child may view content, play games, and participate in contests, among other things. During the registration process, we may ask the parent to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and surname, the child’s account username, and password. A parent can choose not to share their child’s information with us, but certain features cannot function without it. As a result, a child may not be able to access some features if required information has not been provided. We do not require a parent to provide more information about their child than is reasonably necessary in order to participate in our Application.

Consistent with the requirements of COPPA, since this Application may be considered a child-targeted application, we do not collect any personal information from your child. We may collect aggregated anonymized information on the operation of the features used by your child for technical support and internal technical improvements. If you believe your child is participating in a CynjaTech activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please contact us at info@cynja.com.  We will not use email addresses provided for parental consent purposes to market to the parent.

Content Generated by a Child

Certain activities on our Application allow children to create or manipulate content and save it. These activities do not require a child to provide personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, parents must consent before their child may share the created content. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information.

About Verifiable Parental Consent

Email Consent. COPPA requires that we first seek a parent or guardian’s consent by email before collecting personal information from a child. Our email will explain what information we are collecting, how we plan to use it, whether it will be made available to third parties, how a parent can provide consent, and how a parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.

Chat

Certain games and activities that are directed to children allow users to communicate directly with other Members by means of a chat system. Parents may approve or deny access to our Application’s chat system in the parental control area of our Application. Children may only connect to others with the express approval of the parent. Parents may also block or delete approved chat connections at any time. Children may block approved chat connections at any time. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we encourage other Members to flag inappropriate communications. We strongly encourage children who use these interactive features on our Application never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters. We also recommend that parents carefully supervise their children when the children participate in activities on our Application. Our Application offers parents a full transcript of all child chats for their review in the Reports section of the parental control area.

Web

The Application offers children a parent-controlled browser feature that places some protections while surfing the web. When using this browser children will access websites not controlled by CynjaTech. Any data shared by the user or child with those websites belongs to that entity and not CynjaTech. Parents may utilize our Application’s blacklist feature to prevent their children from visiting websites with whom they do not want their child to share data.

Email Contact with a Child

Our Application does not collect information shared to us by a child. We do not maintain child email addresses in our system. Only parents may register for our Application on behalf of their children.

Push Notifications

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and that communicate to the device holder even when the application is not in use. In keeping our Member’s privacy in mind, our Application utilizes local push notifications that do not require any device identifiers to provide this service.

Geolocation Data

Your family’s privacy is important to us. Our Application does not collect geolocation information.

Persistent Identifiers

When children interact with us, certain information may automatically be collected and then aggregated and anonymized, in order to make our Application more interesting and useful for our business purposes. Examples include aggregated anonymized data that may include:  type of computer operating system, child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our Application, and information regarding the online or mobile service provider. This information is collected using technologies tied to the Member’s personal cloud identifiers or user identifications. This data will be used for internal purposes only, in order to:

• provide children with access to features and activities on our Application
• provide parents with access to reporting and permissioning feature in our Application
• customize content and improve our Application
• conduct research and analysis to address the performance of our Application
• generate anonymous reports for internal business use only.

We will obtain parental consent prior to collection if we are going to collect (or allow others to collect) information from children on our Application for other purposes.

The list of third-party operators who collect persistent identifiers on our Application may be found here.

CynjaTech™ LLC
P.O. Box 65916
Washington, DC 20035
United States of America
Phone: +1.202.507.8125
Email: info@cynja.com

2. When Information Collected From Children Is Available To Others

We also may share or disclose personal information collected from parents about their children in a limited number of instances, including the following:

• We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
• We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent a crime, facilitate an investigation related to public safety, or protect the safety of a child using our Application; (iii) to protect the security or integrity of Application, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

3. Parental Choices and Controls

At any time, a parent can refuse to permit us to collect further personal information from his or her child, and can request that we delete the personal information we have collected in connection with that child’s account. A request to delete records may lead to a termination of your account.

Once a parent has registered for their child on our Application, a parent can access, change, or delete the personally identifiable information that we have collected from the parent about his or her child by logging into their parent account on the Application and accessing their child’s account. Parents can do this with their own username and password. Parents may also request assistance in accessing their child’s account information by emailing info@cynja.com.