Updated: November 1, 2013
The Information We Collect
We may also request a user name and email address when a user submits a form through the "Contact Us" portion of the Club Penguin website so that we may respond to the inquiry. We collect the e-mail address for the sole purpose of responding directly on a one-time basis to a specific inquiry.
Additionally, when visitors come to our site, we may passively collect certain non-personally identifiable computer information, such as the type of computer operating system (e.g., Windows XP or Mac OS), the user's IP Address, the web browser (e.g., Firefox, Internet Explorer) being used, the frequency with which guests visit various parts of our sites, and information regarding the Internet service provider, in order to make our sites more interesting and useful to you and for various purposes related to our business. We or one of our contractors on our behalf may collect this non-personally identifiable information through the use of software technologies such as unique identifiers or "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn on/off all cookies. You do this through your browser (like Firefox or Internet Explorer) settings. Please note that most browsers are automatically set to accept cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your Web experience smoother, and some of our services may not function properly.
If personal information is not provided to us, then Club Penguin may not agree to Club Penguin membership and may not be able to provide access to certain content and functionality on the Club Penguin website, or to provide other information, products or services which may be requested.
How We Use, Disclose, and Store the Information We Collect
We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena, or where we disclose information to data processors who act on our behalf (service providers or other group companies who provide support for the operations of our website and who do not use or disclose the information for any other purpose). To the extent permitted by applicable law, we also may disclose PII in response to a law enforcement agency's or other public agency's (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our website, protect the security or integrity of our website, or enable us to take precautions against liability.
If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or business transfer, we may transfer PII to a third party as part of that transaction, to the extent permitted by applicable law.
Collection of Information for Third-Party Sites and Sponsors
Operators collect and maintain information from children through Club Penguin and we comply with the U.S. Children’s Online Privacy Protection Act. The list of operators may be found here. Questions about the operators’ privacy policies and use of children’s information may be directed to:
c/o Disney Canada Inc.
Suite 500 - 1628 Dickson Ave.
Kelowna, British Columbia, V1Y 9X1
The security of your personal information is important to us. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. When you enter sensitive information, such as your credit card number, or our membership subscription form, we encrypt that information using secure socket layer technology (SSL).
As noted in Section 1, if a child registrant wants to acquire a paid membership, the parent's full name, email address, credit card billing information including mailing address will be required at the time of purchase. That information is not stored by Club Penguin, and, instead, is stored by our payments processing vendor for the purpose of processing payments made to Club Penguin and for fraud prevention purposes. That information is safeguarded with appropriate security, and it will not be used for other purposes. Furthermore, our payments processing vendor has agreed to maintain the confidentiality, security, and integrity of the personal and financial information it obtains from the Club Penguin website, and only to use this information on our behalf. Our financial institution is bound by all applicable privacy laws relating to the provision of financial services.
Access to Information, and Objection to Information Collection and Retention
Please contact us as provided in Section 7 if you would like to access the PII that we have collected online from you or your child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect or maintain such information. The deletion of data may lead to a termination of the Club Penguin account and/or membership.
Please be sure to include your email address and a telephone number where we can reach you. We will respond to access requests within 30 days. To protect you and your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.
c/o Disney Online Studios Canada Inc.
Suite 500 - 1628 Dickson Ave.
Kelowna, British Columbia, V1Y 9X1
You may also telephone us at +1-877-261-9482 (US and Canada) or +1-250-469-6380. (If you are not 18 years of age or older, you must have your parent or guardian's permission to call this number.)
Please be assured that any personal information that you provide in communications to the above e-mail and postal mail addresses and telephone numbers will not be used to send you promotional materials, unless you so request.
A Final Note to Parents
The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit the GetNetWise.org site and look through the "Kids Safety" section together. Your efforts to instill responsible information practices will help steer your children to age-appropriate sites and will go a long way toward ensuring that your children have enriching experiences online.
If you believe that Club Penguin has not responded to your inquiry or your inquiry has not been satisfactorily addressed, you may contact TRUSTe here or the United States Federal Trade Commission through its online consumer complaint form available here.