At Kids’ Candor, we will treat your information as we would treat our own. As always, if you have any questions, comments, or concerns, please do not hesitate to reach us at customerservice@kidscandor.com

KIDS’ CANDOR PRIVACY POLICY

This is the general privacy policy ("Privacy Policy") for Kids’ Candor, Inc. (hereinafter referred to collectively as "KC," “us,” or "we") and for our website accessible at www.kidscandor.com (the “Site”). This Privacy Policy applies to all information we collect or acquire from and about consumers and use practices in connection with our Site and the Kids’ Candor program (the “Service”), as well as circumstances under which we disclose information collected from you.

In order to access and use the Site and Services, you must agree to our Online Terms and Conditions (the “Terms and Conditions”) posted on the Site. Persons and organizations with permission to use the Service are considered “Registered Users.” You may view portions of the Site even if you are not a Registered User of the Service. This privacy policy applies to KC’s collection, use and disclosure of Personal Information (defined below) from Registered Users of the Site, as well as from persons who merely visit the Site.

We are committed to respecting your privacy and recognize your desire to protect personal information you share with us. This Privacy Policy describes the types of information we may collect from and/or about you, the treatment of such information, and the choices you have regarding our collection and use of, and your ability to review and update your information. By submitting your information to us, you expressly give us permission to receive, store, process and use such information in accordance with this Privacy Policy. This Privacy Policy also constitutes part of the Terms and Conditions that govern your use of the KC Site and Service. In addition, this Privacy Policy constitutes part of the Terms and Conditions (such as official rules) that govern your participation in any and all events and activities offered or sponsored by us.

Notice To California Residents – Your California Privacy Rights:

Effective January 1, 2005, under California Civil Code Section 1798.83 (known as the "Shine the Light" law), if an individual who is a California resident has provided personal information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual's personal information to a third-party and knows or should have known that such third-party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what personal information was shared and with whom it was shared. A business may comply with this law by: (1) having EITHER a published privacy policy of not sharing a customer's personal information for third-parties' direct marketing use unless the customer has first affirmatively opted in to such sharing OR a published privacy policy of not sharing a customer's personal information for third-parties' direct marketing use if the customer has opted out to prevent his/her personal information from being shared for direct marketing use; AND (2) notifying the customer of his/her right to opt out and providing a cost-free means for the customer to exercise that right.

Any request for a disclosure required under this law should be sent to us via email at customerservice@kidscandor.com. Please note that under this law, we are not required to respond to a customer's request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email address designated above.

1. Types of Information We Collect

Personally Identifiable Information (or "PII") is any information that can identify or is linked to a specific individual, such as your name, mailing address, telephone number (including mobile number), email address, credit card number, debit card number, bank account number, and other financial account information, birth date, gender, occupation, personal interests, demographic, location and household information, etc. To the extent you voluntarily provide your PII to us, we collect such information. For example, we may collect PII from you (to the extent permitted by law): (1) when you sign up for one of our products or services; (2) when you join one of our mailing or contact lists; (3) when you register to participate in an event sponsored by us (such as a contest, sweepstakes, giveaway, promotion, survey, etc.); (4) when you enter into a transaction with us, such as ordering a product from us through our online store; (5) when you use or interact with a product or service of the Site; (6) when you provide or share information using a product or service of the Site; (7) when you send information via message, chat, blog, post or similar functionality using a product or service of the Site; (8) when you create, share or link personal profile using a product or service of the Site; and/or (9) when you submit a request or inquiry to us via the Site or otherwise (each of the foregoing is referred to hereinafter as an "Identification Activity").

It is optional for you to engage in an Identification Activity. However, if you elect to engage in an Identification Activity, we may ask you for certain PII. Depending on the activity, some of the information we ask you to provide may be identified as mandatory and some may be identified as optional. If you do not provide the mandatory information for a particular Identification Activity that requires it, you will not be able to engage in that activity.

Aggregate and Anonymous Information (hereinafter "AAI") is any information that cannot identify or be linked to a specific individual. For example, we may collect anonymous group data (demographics, media habits, online browsing habits, interests and preferences, etc.) about Registered Users or visitors to our Site, participants of our sponsored events and activities, etc. We also collect aggregate traffic data pertaining to the Site, such as: total page views in a given time period; average amount of time that visitors spend on the Site (or a part thereof) each time they visit; etc. Moreover, we may combine "User Activity Information" (as described below) about you and other users of the Site to generate aggregate information that reflects activities, habits, preferences, interests, etc. about our users as a group. We may also collect location-based information such as zip code, city and state name. In addition, we may take PII and make it non-personally identifiable, such as by aggregating your information with information about other individuals, or by removing personally-identifiable elements (such as names) so as to "anonymize" or "de-personalize" your information.

User Activity Information (hereinafter "UAI") refers to information we collect about user activities on the Site. For example, our web servers automatically collect and log "clickstream data" for all visitors to KidsCandor.com, such as IP addresses (which are numerical numbers that are automatically assigned to users' computers and mobile devices when they are surfing the Internet), page requests, pages visited, content viewed, clicks and search queries made, etc. We also use cookies and similar technologies to collect UAI on the Site (see Section 5 below for more information). If and to the extent we use any UAI in a manner that identifies a specific user individually (e.g., if we link or associate such information with a user's name or address), it will be treated as PII. Otherwise, all UAI will be treated as AAI.

2. What We Do With the Information

As a general matter, we use information (PII and AAI) collected from and/or about our users to improve our products and services so that they are appealing to as many people as possible, to administer and maintain operations of the Site, to offer, market and advertise products and services, and to build a strong community for our parents and caregivers.

2.1 Our Own Use of Information

2.1.1 Transactional, Administrative, and Customer Relation Purposes: If you provide information to us in connection with an Identification Activity, we will process and use your information for all purposes related to that activity, including communicating and interacting with you in relation to your activity. For example: (1) if you sign up for a product or service of the Site, we will use your information to set up, administer, service, and communicate with you regarding your account; (2) if you register to enter one of our contests or sweepstakes, we will use your information to process your entry and to conduct and administer the contest or sweepstake (including communicating with you in the event you are selected as a winner); (3) if you join one of our mailing or contact lists, we will use your information to send you or contact you with information that you have requested or that may be of interest to you; and (4) if you order a product or service from us, we will use your information to process and fulfill your order, to communicate with you regarding the same, and to provide customer service to you. Also, if you provide your email address or mailing address to us, we may use such address to send you notices of a transactional, administrative or relationship nature or as required by law, such as notification of a material change in this Privacy Policy and/or the Terms and Conditions for the Site, notification of an actual or suspected security breach that affects your information stored by or for us, public relations announcements, etc.

2.1.2 Marketing & Advertising Purposes:

(1) Email marketing: If you provide your email address or mailing address to us (such as by joining one of our mailing lists), we may use such address to send you product and service offers, promotions, and advertisements from us and/or from our Business Partners. See Section 3.2 below regarding how to opt out of our email marketing.

(2) Mobile marketing: Subject to your prior opt-in consent, we may (i) send marketing and advertising messages via SMS (Short Message Service), MMS (Multimedia Message Service), etc., to your mobile device and/or (ii) send marketing and advertising emails to your wireless email account (e.g., XYZ@att.mobile.net), to inform you about product/service offers, promotions, and advertisements from us and/or from our Business Partners. See Section 3.2 below regarding how to opt out of our mobile marketing (that is, if you wish to opt out of our further use of your information for mobile marketing after you have previously consented to such use).

2.1.3. Market Research Purposes: We may use AAI (including UAI and AAI derived from PII) to conduct market research and analysis for ourselves as well as for our Business Partners.

2.2 Disclosure to Third Parties Outside KC

2.2.1 Disclosure to our Business Partners: We may disclose, sell, and otherwise provide PII, AAI and/or UAI to our Business Partners so that they may market and advertise their products and services directly to our users. See Section 3.2 below regarding how to opt out of such information sharing.

In addition, from time to time, we may co-sponsor events and/or product/service offerings with third parties. If you participate in such co-sponsored events or offerings, any PII and UAI we collect from you based on your participation may be shared with our co-sponsors who may use such information for their own marketing and advertising purposes. YOU MUST CONTACT OUR CO-SPONSORS DIRECTLY IN ORDER TO OPT OUT OF THEIR USE OF YOUR INFORMATION FOR MARKETING AND ADVERTISING PURPOSES.

2.2.2 Disclosure to our Service Providers: We may disclose PII and UAI to our outside vendors and contractors who need to access such information in order to perform services (including, without limitation, transaction/payment processing, order fulfillment, contest/sweepstakes administration and prize fulfillment, data research and analysis, data collection and processing, data storage, data security, hosting and technical support for the Site, and marketing and advertising support) for us (hereinafter referred to collectively as "our Service Providers"). Generally, we require that our Service Providers use your information shared by us solely for the purposes of performing services for us and that they maintain the confidentiality, security and integrity of such information and not further disclose the information to others.

2.2.3 Disclosure under other circumstances: We may disclose PII and UAI to others if doing so is required by law or, in our good faith belief, is reasonably necessary to: (1) comply with legal process (including a court order or subpoena); (2) cooperate with law enforcement; (3) enforce this Privacy Policy and/or the Terms and Conditions for the Site; (4) respond to an emergency; or (5) protect the rights, property or safety of KC, and/or the public. In addition, we may transfer PII and UAI as part of our assets if we (or parts of our businesses) are, sold or transferred to, merged with, or acquired by, a third party. Upon such transfer, the privacy policy of the acquiring entity may govern the further use of your information.

2.2.4 Unrestricted disclosure of AAI: Given the anonymous, non-personally identifiable nature of AAI, there are no restrictions under this Privacy Policy on how we may use, disclose, sell, or otherwise share such information. For example, we may freely share AAI with our Business Partners who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share AAI with our Service Providers in order for them to perform services to us.

3. Information Access & Opt -Out

3.1 Information Access

If you have an active user account on the Site, you may access and update your user account information and preferences at any time (subject to the scheduled maintenance of the Site), by logging into your account and clicking on "My Account" and then changing your preference.

If you do not have an active account on the Site, or if you have provided your information to us offline, you may request to access, delete, update and correct your information as stored by us, by sending your request to us at customerservice@kidscandor.com. Your request will be processed as soon as possible.

3.2 Opt-Out

You can opt out of all our marketing uses (including email marketing, mobile email marketing, mobile message marketing, and telemarketing) of your PII and UAI (if personally identifiable) as well as our sharing of your PII and UAI (if personally identifiable) with our Business Partners for their marketing uses by sending your request via electronic mail at customerservice@kidscandor.com, Subject: Remove From Email List.

We will endeavor to honor your request no later than 10 days after receipt (or within such applicable time period as required by law). To ensure timely processing of your request, please expressly state in your email that you wish to opt out of all further uses and sharing by KC of your personal information for marketing purposes. Your opt out election, once processed by us, will stop, on a going-forward basis, all further marketing uses and sharing of your PII and UAI (if personally identifiable) by KC.

In addition, with respect to certain marketing uses of your PII and UAI (if personally identifiable), you may exercise your opt-out choice through the following alternative methods:

• Our email / mobile email marketing (i.e., sending marketing emails (including our newsletters) to your Internet email account or your mobile email account):
• Use the opt-out means (e.g., an "unsubscribe" link) provided in a marketing email that you have previously received from us.
• Our mobile message marketing (i.e., sending marketing messages via SMS, MMS, etc. to your mobile phone after you have opted in to receive such messages):
• Reply STOP to a marketing message you have received; OR
• Text STOP to the short code used for the messaging program from which you wish to opt out (if you have enrolled in multiple messaging programs on the same short code and wish to opt out from all those programs, text STOP ALL to the short code).

HOWEVER, please note the following:

• For email communications, your opt-out will stop further marketing and promotional emails from us BUT will NOT stop email communications from us relating to your Identification Activity, of a transactional, administrative or relationship nature, or as required by law, such as notification of a material change in this Privacy Policy and/or the Terms & Conditions for the Site, notification of an actual or suspected security breach that affects your Personal Information stored by or for us, public relations announcements, etc.
• Your opt-out will NOT stop continued marketing and advertising uses of your information by those of our Business Partners with whom we have already shared your information prior to your opt-out. To opt out of their further use of your information, you must contact them directly (or use the opt-out means provided by them). Also, if you participate in an event or a product/service offering that is co-sponsored by us with one or more third parties, you must contact our co-sponsor(s) directly in order to opt out of their use of your information for marketing and advertising purposes.

Data retention

We will retain your PII for as long as your account is active or as needed to provide you products or services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. AAI and UAI (if not personally identifiable) may be retained indefinitely.

4. Protecting Children

We take special care to protect the safety and privacy of children. We do not knowingly permit children under age 13 to register on the Site for any product or Service. We do not knowingly collect or solicit Personally Identifiable Information about Users under age 13.

Children under age 13 should always ask their parents or guardians for permission before providing any Personally Identifiable Information to anyone online or through mobile devices. If you are a parent or legal guardian, we urge you to participate in your child's online and mobile activities and to use parental control or other Internet and/or mobile filtering technology to supervise your child's access to the Internet.

5. Cookies & Similar Technologies

A "cookie" is a small amount of data that is sent to your browser from an Internet server and stored in your computer or mobile device. Generally, we use cookies to remind us of who you are, collect UAI about your activities on the Site, tailor our products and services to suit your personal interests, track your status in our promotions, contests and sweepstakes, and/or analyze your visiting patterns. You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it, or you can choose to routinely and manually delete the cookies stored in your computer. If you choose to disable or reject cookies, you may still be able to access some parts of the Site, but you may not have full access to all products and services of the Site.

5.2 Third Party Functionalities

The Site contains links to and/or enables certain third-party functionalities to enhance your experience, including, without limitation, social plug-ins, tools and APIs. Prior to using any third-party functionality (e.g., Facebook "Like" button)on the Site, you should consult the privacy notices of the third-party providers of such functionalities (e.g., Facebook), as we have no control over information that is submitted to, or collected by, such third parties, or how they may use the information. The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices. Your communications and interactions with such third parties are solely between you and them, and are at your own risk.

6. Data Security

Protecting the security of your Personally Identifiable Information that you share with us is of the utmost importance to us. Unfortunately, however, no data transmission over the Internet or any mobile or wireless network and no data storage can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, we cannot guarantee or warrant the security of any information you transmit to or from or within the Site, and you do so at your own risk. By providing your email address to us (whether on the Site or otherwise), you acknowledge and agree that we may notify you by email in the event of a breach of security involving your Personally Identifiable Information.

We urge you to keep your password in a safe place and not to divulge it to anyone. Also, remember to sign off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place, such as a library or an Internet cafe.

7. Links to Third Party Sites, Services or Products

The Site contains links to sites operated and maintained by third-parties, as well as links to products and services (including software) provided by third-parties. We have no control whatsoever over such third-parties, their Internet sites, or their products or services. Once you enter a third-party site, this Privacy Policy will no longer apply, and any information collected from or about you on that third-party site will be governed by the privacy policies and practices of that third party. Third-party sites do not follow our Privacy Policy and their privacy practices may be substantially different from this Privacy Policy. Such third-party sites may send their own cookies to you and may collect data about you and make use of that data in ways that we would not. You access such third-party sites, services or products entirely at your own risk. You should always review and understand the privacy policies and practices for such third-party site, service or product before disclosing any personal information on such site or in exchange for such product or service.

8. Changes to this Privacy Policy

From time to time, we may change this Privacy Policy in whole or in part, to accommodate new technology, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. If you are a registered user or member of the Site (e.g., any of our social networking services), we may notify you of material changes to this Privacy Policy via email and/or may ask you to affirmatively acknowledge and consent to such changes (e.g., by checking a box or clicking a button) at the time of your next account login on the Site.

9. Effective Date of Privacy Policy

This Privacy Policy became effective as of August 2015.