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Togetherville Privacy Policy
Togetherville is a real-person network for you and your children, where the people your children are connected to are all Parent-approved. They include only your Togetherville-using friends and relatives, and their children, as well as your child’s real-world friends from school and other activities. To make this system work, we use real names and real photographs. Our objective is to help parents and legal guardians ( “Parents” ) raise the next generation of digital citizens, so we have created a transparent and accountable system for adults and kids. In Togetherville, kids are safe to be themselves rather than hiding behind avatars and screen names. Sharing with approved friends, relatives and schoolmates is an inherent feature of Togetherville.

This is our privacy policy and we will comply with it, as well as applicable U.S. privacy laws, including the Children's Online Privacy Protection Act (COPPA), when we gather and use information from users of our services.

We pledge transparency about the information we monitor and collect from you. We encourage you to read this privacy policy to understand what we do with the information we collect from you, but we want to first emphasize what we  DO NOT do with your personal information.

  • We DO NOT share or sell your personal information to anyone without your permission, or as described in this privacy policy (see "Business Transactions” below).
  • We DO NOT allow inappropriate content or ads to disrupt your children's experience.
  • We DO NOT send you newsletters or promotional mail or email if you tell us not to.

By using or accessing Togetherville, and agreeing to our Terms of Service, you hereby agree to accept the practices described in this privacy policy.

TRUSTe Children’s Privacy Seal Program

Togetherville has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your Personal Information.  The TRUSTe program does not cover information that may be collected through downloadable software. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@togetherville.com. If you are not satisfied with our response you can contact TRUSTe here.

Why we collect Personal Information about users

In order to create an online network for your children that reflects their real-world friends, we need to collect some personally identifiable information from Parents to set up their children's accounts, including their children’s names, dates of birth, genders, schools and profile pictures. Among other things, we use this information to:

  • Build the children's networks ("neighborhoods”) based upon the social networks of their Parents, as well as Parent-approved real-world friends from school and activities.
  • Personalize children’s online experiences in art creation, content favorites, comment forums, etc.
  • Enable Parents to review the information collected from their children at any time.
  • Deliver virtual rewards to children for positive online performance, such as winning games or challenges.
  • Contact Parents about their accounts and their children’s activities, notify Parents about their children’s friend requests and get Parental approval.
  • Send updates about our service by email to Parents.
  • Ask for Parental feedback to help make our service better.
  • Send information to Parents about products and information that we think will be of interest. Parents can ask not to receive promotional emails.

Parents have complete control over their own and their children’s information.

A child's participation in or access to an activity is not conditional upon him/her providing more Personal Information than is reasonably necessary for that activity. At any time, Parents may visit the "Account Settings” section of Togetherville ( http://grownups.togetherville.com/grownup/settings/edit ) to see the Personal Information we have collected. That is where Parents can opt to not receive any promotional email from us, and ask us to delete or disable their children’s account.

If your children are under age 13, we must have ”verifiable parental consent” before we collect and use your children's Personal Information. We require that all child accounts be created by Parents in order to ensure that we obtain this consent before obtaining any Personal Information from children.

The Togetherville blog ( http://blog.togetherville.com ) that is publicly accessible from the homepage and Grownup pages are intended for adults. We do not knowingly collect personally identifiable information from children on the blog. Note to Parents of children under the age of 13:  Your children are not allowed to create an account in Togetherville - you have to do it for them. You are welcome to call us at (650) 488-8341 to review any Personal Information we have collected about your child. If you desire, you may request that we delete this information and/or specify that we not collect any further Personal Information from your child. Please note that we will need to verify the identity of anyone requesting information about a child to ensure that the person is in fact the child's Parent, and that a request for us to delete all Personal Information about a child requires us to cancel the child's account.

How we collect, use, and disclose information about child users

Parents register on Togetherville, and, once they give verifiable Parental consent, can add their children to the site. We only ask Parents to supply their children's personally identifiable information such as their name, gender, age, picture, and school at registration. In addition, we connect information collected from your child with registration information and we share that information with Parent-approved friends, relatives and schoolmates. All of this Personal Information provided by children is always visible to their Parent. Parents can disable or delete any of their child’s information by logging in and accessing their children’s profiles.

Children's participation in or access to activities is not conditioned on them providing any more Personal Information than is reasonably necessary for that activity. All communication is moderated by the Togetherville staff.

Togetherville is a social network and relies on genuine interactions amongst all users. Sharing with Parent-approved friends, relatives, and schoolmates is an inherent feature of Togetherville. For children to be active members of their own online neighborhoods, their parents must authorize Togetherville to collect Personal Information from their children. This information includes messages to friends, comments, answers to surveys, art, and photos.

Parents’ consent is also required for the use and disclosure of their children’s Personal Information. To use the Togetherville service, Parents must provide verifiable consent using 1) a credit card transaction, 2) a printed signed consent form that can be returned to Togetherville via fax, mail, or a scanned file attached to an email, or 3) a call to a toll free number (1-866-460-2325) to verify with a Togetherville staff member (9am to 5pm PST, Monday-Friday).

Togetherville gathers usage data regarding your Togetherville activity, as well as your children’s activity, to share directly with Parent-approved friends, relatives, and schoolmates through your user stream. In addition, we use the data to optimize the Togetherville service, personalize user’s experience, and send promotional emails to Parents. We also use aggregated data that does not identify you or your children personally to improve our service and develop new features.

The child account registration process

Before a Parent can create a child account they must complete the High Level Verification process. Parents can provide verifiable consent through the use of a credit card transaction or a signed printed consent form, or a call to a toll free number (1-866-460-2325) operated by a Togetherville staff member (9am to 5pm PST, Monday - Friday).

Upon verification, a Parent must enter their child’s first name and user ID. Gender, date of birth, profile picture, and elementary school are all optional information. Additionally, a Parent must enter a password for their child's account, which is encrypted and stored in the Togetherville database, but is not known to Togetherville.

Upon the creation of a child's account in Togetherville, we provide the Parent with a Direct Notice by email that describes the information collected about the child and other helpful information about the site.

Information handling in communication and content features

Data about specific user activities that may be collected include, and are not limited to, data regarding games played, creation tools and applications that children play, use, or share, pictures and videos they view or share, people with whom they communicate and the frequency and content of these communications, content they like and select as their favorites, and the amount of time spent on the service.

Togetherville uses safe communication mechanisms. Communication between children as well as between adults and children occurs in two ways (T-text and Me-text). T-text is canned text that is entered by the Togetherville staff. Me-text is text that is entered by users. Me-text is first passed through an automated white-list filter to determine the appropriateness of the text. If it passes through the filter successfully, it is published directly to Togetherville without human moderation. The filter is not guaranteed to remove all inappropriate content prior to posting. However, our Moderators still personally review all auto-approved text after it has been posted and they can remove inappropriate submissions that are not removed by the white-list filter. We also allow children to submit their own "quips” for approval by Togetherville’s moderation system.

The Togetherville Trumpet allows kids to express their thoughts and opinions around a specific topic or question. Kids are prompted with a message similar to “I love my grandparents because…” All Trumpet submissions must be approved by a Togetherville moderator. Additionally, a request is sent to Parents to approve the submission for use in Togetherville. Once approved, other children and adults in Togetherville can see their responses.

All Trumpets and quips are reviewed by our staff for appropriateness and to ensure that they do not include Personal Information before posting. We require children to agree not to provide any Personal Information when using these features. We also review the submissions for the purpose of removing Personal Information before posting. Togetherville also collects information on children's performance within specific games and academic content to evaluate their performance and provide them with suitably challenging and engaging content.

Togetherville does not share any information collected in Togetherville with Facebook. However, Parents can share information on Facebook such as art their children have created, quips the children have posted, messages the children have sent, videos and apps the children have liked, and honors the children have achieved.

Togetherville does not collect more Personal Information from children than is necessary to use its services. Togetherville collects this Personal Information in trust for Parents and uses it to improve the quality of services it delivers to child and adult users.

How we collect and use information about our grownup users

We require all adults accessing Togetherville to have an account on Facebook. Facebook's Terms of Service require that members be above the age of 13. The login credentials associated with these Facebook accounts is used by adults to access and join Togetherville. To further verify their identity, we require all adult users to provide us the same email address they have provided to Facebook to create their account in Togetherville, and to provide verifiable parental consent to our privacy practices. When you register using Facebook we will transfer your social graph (connections) to your Togetherville account. In Togetherville you will know which of your Facebook friends are also members of Togetherville. Only friends that allow the sharing of their Facebook profiles will be available to you on Togetherville.

To the extent allowed under Facebook rule, Togetherville uses certain information from Facebook that the adult has made publicly available, including name, profile picture, and friends list. Adults use their Facebook login username and password to access Togetherville after the account has been created.

Togetherville gathers usage data regarding your Togetherville activity using tracking technologies (See “Use of clear GIFs and Cookies” below), as well as your children’s activity, to share directly with Togetherville Parent-approved friends, relatives, and schoolmates through your user streams. In addition, we use the data to optimize the site’s features, personalize user’s experience, and send promotional emails to Parents. We also use aggregated data that does not identify you or your children personally to improve our existing service and develop new features.

Data about specific activities that may be collected include, and are not limited to, data regarding games, creation tools and applications adults use or share, pictures and videos they view or share, people with whom they communicate and the frequency and content of those communications, content they like and select as their favorites, and the amount of time spent online. Additionally, we store the friend connections created by Parents on behalf of their children as well as the transaction history of all commerce transactions done through Togetherville.

Togetherville uses safe communication mechanisms. Communication content provided by adults goes through the same filtration and moderation standards as content provided by children.

Parents have ultimate control over their children's accounts.

Only Parents are permitted to create Togetherville accounts for their children. Parents are provided full transparency into all their children's Togetherville activity and have unrestricted access to the accounts their children have in Togetherville through the Togetherville application in Facebook.

A Parent may disable her or his child's account (which will suspend the account) or delete it completely at any time through the settings offered on Togetherville. In addition, a Parent may delete her or his own account, which will in turn permanently delete any child accounts registered by that Parent. A Parent may also request that we delete her or his child’s account by sending an email message to support@togetherville.com, with the child's login name and password, requesting that the account be cancelled. When we delete a Parent or child account as described above, all of the information associated with those accounts will be permanently deleted from the Togetherville database. Keep in mind, however, that this will not affect any information Facebook has independently collected in connection with your use of Togetherville, and it will not remove the Togetherville application from your Facebook account. Please consult Facebook.com for information regarding its privacy policies and practices.

Parents can designate other grownups, including the child’s other parent, step-parents or other caregivers, to participate in the management of certain aspects of the child’s Togetherville experience. These include approving friendships or Trumpets, and deleting friends or specific content from the child’s account. These designated grownups will also receive all alerts sent by Togetherville pertaining to the child’s online activity. The Parent who created the child’s account can revoke management privileges assigned to these designated grownups at any time from their Togetherville settings page.

We may share your Personal Information for safety reasons.

We are proud of the neighborhood community feel of Togetherville and are concerned about the safety of all people in Togetherville. We disclose Personal Information about Togetherville users in cases where it is required by law or where we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Web site, or is otherwise reasonable to protect someone from possible injury, we may do so.

Communications from the Togetherville team

When children in Togetherville engage in various direct activities, like sending messages, gifts or artwork, or when they comment on interactions that Parent-approved friends and relatives have also participated in, those approved friends and relatives will receive alerts within Togetherville, and in the recent application activity interface in Facebook, if Togetherville has been bookmarked by the Parent.

We frequently contact Parents and Parent-approved friends and relatives who are connected to children in Togetherville via their email accounts for various reasons, including:

  • Updates and changes to a child's account
  • Notifications of achievements, gifts, artwork or messages shared from children
  • Friend invitations, notifications of friends who have joined Togetherville, or requests from children to add new people to their neighborhoods
  • Upcoming birthdays or special Togetherville events
  • Notification of any material changes to the site or information collection and use

These communications are necessary to maintain a high level of engagement with children and Parents in Togetherville. However, adult Togetherville users will have the option to turn off email notifications from their settings page. If you turn off the email option, you will no longer receive promotional emails. All promotional emails will also contain an ‘unsubscribe' option in each communication if you choose to opt-out of these emails. If you turn off the email option, you will stop receiving email notifications regarding certain activities and features you and your child use in Togetherville. However, you will still be able to sign in and use the notification feature within Togetherville to obtain updates regarding you and your children’s use of these activities and features. In addition, even if you turn off the email option, we will still continue to send you certain administrative emails regarding actions you initiate on your child’s account, such as account updates or requests to dele your child’s account, as well as emails regarding friend requests initiated by your child.

Inviting friends via Facebook

Togetherville utilizes Parents’ Facebook “social graphs” to make inviting friends to join their children's Togetherville neighborhoods easy. We provide a very simple Facebook invitation tool that, subject to the terms of Facebook, allows Togetherville users to invite their Facebook friends to join Togetherville. We collect information about these invitations to make it easier for users to re-invite friends who do not accept initial invitations, to track the success of this invitation feature, and to inform Parents when their friends join Togetherville.

Inviting friends via email

Grownups: If you choose to use our email invitation service to tell friends about our site, we will ask for these friends’ email addresses. Upon your request, we will send these friends a one-time email inviting them to visit the site and, where appropriate, join the neighborhood of which you are part. Togetherville stores this information only for the purpose of sending this one-time email, tracking the success of our referral program, and making it easy for you to re-invite friends who have not accepted invitations. If you have invited friends to your Togetherville network, you will be notified when they join so you can add them to your Togetherville neighborhood.

Your children can help you invite friends too

Children can only initiate friendships with other children who are already using Togetherville. There are three categories of children with whom they can initiate a friendship request.

  1. Children of the Parents’ Facebook friends already on Togetherville
  2. Children for whom they have the secret friending code
  3. Children who are in the same school community (code also required)

Children in Togetherville cannot directly invite or add new members to their neighborhoods, but they can ask their Parents to extend invitations on their behalf. Parents of each child must approve each of their children’s friend connections. We store information about these invitations to make the children’s friend requests more accessible to their Parents and to track the success of our friending features.

Parents may disclose their children’s schools to Togetherville to enroll them as members of Togetherville school communities. We collect this information about children’s schools from their Parents as part of the child registration process and only for the purpose of organizing school communities.

When children in Togetherville have completed works of art or other achievements, they have the ability to send notice of these events to people who are not in Togetherville via their email addresses. Children provide Togetherville with email addresses to complete these interactions. Children may not edit the contents or title of the message, and the message will not be linked to a Togetherville corporate email address, nor will the message include the child's full name. Togetherville stores this information only for the purpose of sending this one-time email, tracking the success of our referral program, making it easy to re-engage with these people in the future, and notifying Parents about the message.

Use of clear GIFs and cookies

Cookies are files that your Internet browser puts on your computer when you visit a website. ( Here is an explanatory Youtube video about cookies made by Google engineers- http://www.youtube.com/watch?v=XfZLztx8cKI ) We use cookies to tell us how often you visit our site, and what pages you go to on our site. The cookies do not contain any Personal Information as defined under COPPA about children under 13.

Sometimes we use files from other companies (called third-party cookies) to help us see where people go on our website so that we may improve our services. Third-party cookies do not contain any personally identifiable information, so the third parties generating the cookies cannot identify or contact you as a result of these uses.

We also use a third party service that uses clear gif images to track what pages you visit and in what sequence. These Clear Gifs do not contain any personally identifiable information. The third party service cannot identify or contact you as a result of this use.

Some of our business partners (e.g., tracking utility company) use cookies and Web beacons on our site. We do not exercise control over or have access to these tracking technologies.

Use of Flash LSOs

In some instances, we use local shared objects (LSOs), also known as Flash cookies, to store your high game scores. Third Parties, with whom we partner to provide certain features on our site, use Flash cookies to collect and store information.

Flash cookies are different from browser cookies because of their amount of, type of, and how data is stored.  Cookie management tools provided by your browser will not remove Flash cookies.  To learn how to manage privacy and storage settings for Flash cookies, visit the Flash Player settings manager: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118

Links to other sites

While we do not intentionally direct our child users to third-party sites outside Togetherville, they may inadvertently link to other sites from within the Togetherville application. Togetherville does not make these sites available, and we cannot be responsible for what they post on their sites. If you or your child provide any information to these other sites, different rules regarding the collection and use of that Personal Information may apply. We are not responsible for the policies or practices of third parties. Contact these entities directly or review their respective privacy policies if you have any questions about their use of the information collected.

Data retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

Togetherville has implemented a commercially reasonable safeguards to protect the Personal Information, including sensitive data such as credit card information, submitted to us, both during transmission and once we receive it. Although we take certain security measures to protect your privacy, please be aware that no security measures are perfect or impenetrable. Please keep in mind that we cannot and do not guarantee that content you post in Togetherville will not be viewed by unauthorized persons and that you post content in Togetherville at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in Togetherville. Please understand that, even after removal, copies of user content may remain viewable in cached and archived pages, or if other users have copied or stored your user content.

Business transactions

In the event Togetherville, Inc. goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or prominent notice on our Web site for 30 days if a change in ownership or control is likely to materially affect the way Personal Information about our users will be handled.

Feedback information

Togetherville may from time to time ask you to provide information on your Togetherville experiences, which will be used to measure and improve quality. You are at no time obliged to provide such information. Togetherville reserves the right to use anonymized information that does not identify you personally for marketing purposes, for instance by displaying selected comments without a user's identity on the Togetherville.com website or in communications from the Togetherville Team.

Applicable law

We control and operate Togetherville from the United States and subject exclusively to the laws and jurisdiction of the United States. Please note that we do not represent or warrant that Togetherville is appropriate for use in any particular jurisdiction. Those who choose to access Togetherville do so at their own initiative and are responsible for complying with all local laws, rules and regulations.

Modifications of the privacy policy

Togetherville reserves the right to modify its privacy policy at any time and will notify you by posting any such changes in a revised privacy policy on the website. Such modifications will become effective on the day they are posted as noted in the policy. Togetherville encourages you to frequently review the privacy policy for any modifications. Unless stated otherwise, our current privacy policy applies to all information that we have about you and your account.

If we make material changes as to how we use Personal Information collected from Parents and children, we will notify Parents by email in order to obtain verifiable Parental consent for the new uses of the child's Personal Information.

Contacting Togetherville

If you have any questions, comments or concerns about Togetherville's privacy policy, email us at privacy@togetherville.com or contact us at:

Togetherville, Inc.
395 Page Mill Road, 2nd Floor
Palo Alto, CA 94306
feedback@togetherville.com
Phone: 1-866-460-2325

Effective: February 16, 2011

© Copyright 2011 Togetherville, Inc. All Rights Reserved.

Facebook Privacy Video
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