The Cynja LLC Privacy Policy

This Privacy Policy was last modified on July 15, 2016.

Cynja (“us”, “we”, or “our”) operates https://www.cynja.com (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

This privacy policy describes the treatment of information provided or collected on the Site 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.

Overview:

We Do Not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice.

There is no behavioral advertising on our site which means that you will not see any advertising that is targeted to you based on your combined activity on our Site and your activity on other sites and applications.

Third parties that we use to assist with the Site are required to follow this Privacy Policy.

Contents:

Types of Information We Collect
How We Collect Your Information
Use of Your Information by Cynja
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
Comments and Questions

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:

• Subscription information you provide when you register for one of our publications, including your first name and email address.
• Transaction information you provide when you purchase one of our products, including your postal address, telephone number and payment information.
• Information you provide in public forums on our Site.
• Information you provide to us when you use our Site on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform from one of the social media sharing features on our Site.
• Location information when you visit our Site, including location information either provided by a mobile device interacting with our Site or associated with your IP address, where we are permitted by law to process this information.
• Usage, viewing and technical data, including your device identifier or IP address, when you visit our Site, post our site on third-party sites or platforms or open emails we send.

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 public forums or other activities on our site, or otherwise interact with us. When you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our Site.

We collect information through technology, such as cookies and similar technologies like pixels and web beacons, including when you visit our site or share our Site on third-party sites or platforms.

Use of Your Information by The Cynja LLC

Cynja may give its affiliates access to your information where they perform services on behalf of Cynja and, unless prohibited under applicable law, for use on their own behalf for the following purposes:

• Provide you with the products and services you request.
• Communicate with you about your account or transactions with us and send you information about features on our Site or changes to our policies.

Consistent with local law and choices and controls that may be available to you:

• Send you offers and promotions for our products and services or third-party products and services.
• Personalize content and experiences.
• Optimize or improve our products, services and operations.
• Detect, investigate and prevent activities that may violate our policies or be illegal.

Sharing Your Information with Other Companies

We will not share your personal information outside Cynja 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.

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 subscription or newsletter 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 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 subscription 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.

Children’s Privacy

We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our Site and application. Some features on our Site are age-gated so that children cannot use them, and we do not knowingly collect personal information from children in connection with those features. 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 an online activity.
• 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

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 guest 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.

Data Transfers, Storage and Processing Globally

We operate globally and may transfer your personal information to Cynja 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.

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.

Questions

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

Our Site 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 Site or 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

Cynja is committed to protecting users’ privacy.  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.

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

Cynja offers its users the Site. Our Site 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.

Subscription

Consistent with the requirements of COPPA, since this Site may be considered a child-targeted website, we will ask for a parent or guardian email address before we collect any personal information from a child. If you believe your child is participating in an 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@thecynja.com.  We will not use email addresses provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

Content Generated by a Child

Certain activities on our Site allows children to create or manipulate content and save it. Some of 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, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. 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. If Cynja plans to post the content publicly or share it with a third party, we will obtain a higher level of parental consent.

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.

High-Level Consent. If Cynja collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to set up a secure method of communication to confirm their identity in the future.

Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

Contests and Sweepstakes

For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.

Contests and sweepstakes may ask a child to submit his or her own content with his or her entry. We may require parental consent prior to submission. Please see Content Generated by a Child above for more information on our collection, notice, and consent policies.

Email Contact with a Child

In order to respond to a question or request from a child, Cynja may ask for the child’s online contact information, such as an email address. Cynja will delete this information immediately after responding to the question or request.

In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose. One example would be a newsletter that provides updates about our Site or application. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, and to provide the parent an opportunity to prevent further contact with the child. A child may be engaged in more than one ongoing communication, and a parent will be required to “opt-out” of each communication individually.

Geolocation Data

We will request parental consent via e-mail if a child-directed Cynja Site collects geolocation information that is specific enough to identify a street address.

Persistent Identifiers

When children interact with us, certain information may automatically be collected, both to make our Site more interesting and useful, and for our business purposes. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our Site, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by Cynja or by a third party. This data will be used for internal purposes only, in order to:

• provide children with access to features and activities on our Site
• customize content and improve our Site
• conduct research and analysis to address the performance of our Site
• generate anonymous reports

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

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

No third-parties are collecting persistent identifiers on our Site.

Please contact us at the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices:

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

When Information Collected From Children Is Available To Others

In addition to those instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from 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 Site; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

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 newsletter subscription. A request to delete records may lead to a termination of the newsletter subscription or other services.

Parents may also request assistance in accessing their child’s account information by emailing info@cynja.com.