EFFECTIVE DATE: June 22, 2015; Updated: January 28, 2016; February 1, 2018; November 15, 2018; February 28, 2020; November 13, 2020; February 21, 2021; July 14, 2021; October 6, 2021; November 17, 2021; December 13, 2021; January 18, 2022; May 12, 2023.
Section I: Privacy Notice for Children Under 16
Section II: Student Digital Privacy
Section III: Information that We Collect from Individuals 16 Years Old and Over
Section IV: Information Shared with Third Parties
Section V: Deletion of Accounts and Retention of Certain Information
Section VI: Security Practices
Section VII: Changes to this Policy
Section VIII: Users Outside the United States
Section IX: For More Information
Cricket limits the collection of personal information from children to only that which is necessary to obtain parental consent or to participate in a Cricket program or activity after we and/or participating schools and organizations (in the case of CricketTogether™ and TryEngineering Together™) have obtained the correct level of parental consent for the activity the child is participating in. If you are under age 16, you are not allowed to subscribe to any of the Services or create an account without the permission of your parent, guardian, or teacher. In addition to the required consent, it is a good idea to request assistance from your parent or legal guardian in setting up your account, for online Challenges, contests or other activities, if any, for which there is an account associated with use of a particular Service, or your teacher with respect to setting up your account for ePals®. For certain one-time contests, an email for your parent/legal guardian may be requested.
Cricket Media, Inc is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children’s personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates Cricket Media, Inc has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at (703) 885-3400 or firstname.lastname@example.org. If you have further concerns after you have contacted us, you can contact PRIVO directly at email@example.com.
The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids™ Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company’s services meet the program requirements, we conduct regular monitoring and consulting.
In general, Cricket’s programs may collect the following information from parents/guardians or teachers about a child: first name, last name, date of birth, username, IP address, grade level, gender, country, city, mailing address, and parent/guardian’s name and email address. Further details about personal information which may be collected are listed by program below:
Personal Information Collected: First name, last name, gender, grade level, username, city, country, school name, teacher name.
In the case of CricketTogether Virtual Mentoring Portal, we collect a child’s first name and last initial only.
All letters exchanged on these platforms are moderated by the teacher or program coordinator to prevent the sharing of personal information. In the case where a child includes personal information in their letter, the user will be asked to revise the letter before it is shared. If PI is included, it will be stored by Cricket until the letter is revised, or the classroom is closed. When PI is deleted from a letter, it is no longer stored by Cricket.
If participating classroom is using eSign parent/guardian permissions, then parent/guardian name and email address will also be collected. In some instances, that is, only classrooms that have opted into photo sharing in CricketTogether or TryEngineering Together, eMentors and students may include appropriate photographs and images of themselves in their correspondences so long as parent/guardian consent has been obtained. These photographs and images are moderated along with the rest of the correspondence, and never publicly available.
Personal Information Collected When Challenge is Accepting Entries:
When entries are submitted by a parent or guardian on behalf of a child, we collect the child’s first name and last name, date of birth, grade level, school name, school mailing address, parent/guardian full name, parent/guardian email address, parent/guardian phone number, and parent/guardian mailing address.
When entries are submitted by a teacher on behalf of a child, we will also collect the teacher’s full name, email address, phone number, and the school’s name and mailing address.
In connection with activities such as contests/Challenges, we do collect and share children’s images, audio and video submitted through such contest or Challenge but only after full parental consent has been obtained.
Personal Information Collected: First name, last name, username, country, date of birth.
Children are able to post on forums on the ePals Global Community, but such content is moderated and any personally identifiable information is removed and deleted before posting. In some instances, that is, only as between classrooms in the ePals Global Community, may a teacher exchange photos/videos for use in the online projects but not otherwise publicly available.
Personal Information Collected: First name, middle name, last name, gender, date of birth, any special needs, parent/guardian username, parent/guardian email address, parent/guardian full name, and parent/guardian phone number.
Parents/Guardians may also provide a profile photo of the student. Recordings of NeuLingo language practice lessons and lesson notes are stored and accessible to parents/guardians.
When a parent adds a child’s profile to an existing account we will collect their first name, last initial and age. Parents can also add a description of their child’s goals, and notes to their child’s profile.
When a child takes part in a 1:1 or group class, they will share their video and audio with a trusted teacher and potentially other students in the lesson. They will also be able to post notes, whiteboard content and in-session chat, or upload files for others to view (including but not limited to voice recordings, images and video).
Recordings of these classes, including audio and video of a child, sessions, notes, whiteboard content, and in-session text chat, are collected by video communication platform Zoom and stored using video cloud platform Kaltura (and may be accessible by applicable parent/guardian). Please see the section Third Parties Used in Relation to Children for more information.
These recordings are also accessible by Cricket Media, Inc.
All 1:1 and group tutoring sessions are recorded and retained for up to one calendar year from creation.
We may collect certain non-personally identifiable information from visitors to our site, such as the date and time of their visit, the type of browser used, the type of operating system used, the ISP from which the visitor receives Internet access, and aggregate information regarding what pages users of the site access or visit.
We may use the personally identifiable information that we collect from a child: (1) to determine whether they are eligible to use the Services; (2) to obtain consent from their parent/guardian, teacher, or school administrator, as applicable, for the child to use the Services; (3) to provide an interactive online experience; (4) to provide customization and content recommendations; (5) to provide educational content that we believe that the child may be interested in or would benefit from; (6) to fulfil requests for products.
We may use non-personally identifiable information (such as cookies and Web surfing habits associated with IP addresses) to improve the design, content and performance of the Services, including in the case of the CricketTogether product through surveys which results may be shared with educational consultants engaged by Cricket, or in the case of TryEngineering Together with IEEE and entities that may be sponsoring TryEngineering Together programs in schools. We also may use this information in the aggregate to analyze site usage and the popularity of the Services (individually or collectively).
We may disclose personally identifiable and/or non-personally identifiable information in certain limited circumstances, as set forth in Section IV below.
We or teachers or administrators (in connection with Services utilized by teachers or other program administrators with authority to engage participating students such as ePals or CricketTogether or TryEngineering Together), moderate all user generated content to remove any personally identifiable information unless, as is the case of contests or Challenges, we have parent/guardian permission to share this publicly, including on our websites. However, while we take all reasonable steps, where applicable, to ensure that children do not share their personal information no system is foolproof.
|Third-Party Service Provider
|In Which Products is the Service Used
|How the Service is Used in Relation to Children
|CricketTogether, TryEngineering Together, ePals Global Community, eLearning (formerly Fluent City), and Invent It Challenges
Hosting videos which children upload or view.
Hosting recordings of group and 1:1 online classes.
|CricketTogether, TryEngineering Together, ePals Global Community, and Invent It Challenges
|Serving as a User Database, hosting user information, and user-generated content.
|Invent It Challenges
|Serving as a repository for entry submissions.
|CricketTogether, TryEngineering Together
|Serving as a survey tool embedded into the platforms.
|CricketTogether, TryEngineering Together, Invent It Challenges, ePals Global Community
|Storing content viewed by users as well as storing permissions, consent forms, and content submitted by users.
|CricketTogether, TryEngineering Together, Invent It Challenges, ePals Global Community
|Understanding how users are interacting with the products so as to improve experience.
|Serving as the virtual classroom for language-learning sessions.
|eLearning (formerly Fluent City), NeuLingo
|Providing group and 1:1 online classes. Hosting recordings of group and 1:1 online classes that then get transferred to Kaltura.
|eLearning (formerly Fluent City), NeuLingo
|Providing production database, web servers, and backups.
We do not share personal information with unaffiliated parties for their own marketing purposes. See also Section IV “Third Parties” below.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing your user data are:
a) Your consent. You are able to withdraw your consent at any time and can find out how below in relation to each of our services.
b) We have a legitimate interest.
If you have questions or concerns about any of the third parties listed above, or, would like more information about their collection and use practices, please contact us: firstname.lastname@example.org.
For Cricket eLearning (formerly Fluent City): Parents/Guardians can access recordings of their child’s 1:1 Math tutoring sessionsonline classes. Parent/Guardians can review, modify, or delete information about a child at any time,Yes, you can. You can review the Child-Related Personal Information related to your child by making a request, as described below, at any time. You can also have the Child-Related Personal Information related to your child deleted as described below and end authorization for further collection of such information by us. If you wish to view, delete, or modify information:
We will endeavor to respond to any requests for access to a child’s personal information within thirty (30) days.
Cricket, complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:
For more information how to action these rights, please contact us at: email@example.com.
If you are an EU citizen and would like to make a complaint about the way we process your personal data, you can contact the relevant Data Protection Authority (DPA). Please contact us using the details below to find out more.
Teachers may provide consent electronically when creating accounts for their students. Parent consent is required before a student’s content or information is shared outside of the school context.
For those teachers utilizing the Cricket Services as described herein and collecting student information (on behalf of such teacher’s classroom at his/her school receiving Federal funds under programs administered by the U.S. Department of Education, such school may disclose personally identifiable information from a student’s education records to a third party with either written consent of the parent or by meeting one of the exemptions set forth in FERPA (“FERPA Exemption(s)”), including the exemption for Directory Information (“Directory Information Exemption”) or disclosure to school officials with a legitimate educational interest (“School Official Exemption”).
CricketTogether™ verifies the teacher who has created the account for the school by receiving written consent and agreement from the school principal.
If you are a student under 16, please do not send any personal information about yourself to us unless (and until) you have first obtained consent from your parent, guardian or authorized teacher, and please do not send any personal information other than the limited information we request from you in connection with the Services.
We do not show advertising in our services for students and schools.
We do not share your information with any third-party service providers other than for support for internal operations. We work with third party analytics provider Google Analytics to understand the use of our services and improve it. Google Analytics is not allowed to share user data with any other third parties. For more information on Google Analytics click here: https://www.google.com/intl/en/policies/privacy/
We do not share personal information with unaffiliated third parties for their own marketing purposes.
Teachers, parents and eligible students can review, update or have their information deleted at any time by contacting us here: firstname.lastname@example.org
We strive to protect the confidentiality, security and integrity of the personal information we collect. We have put in place physical, electronic and administrative procedures to safeguard and to help prevent unauthorized access to and maintain the security of personally identifiable information collected through this site. This information is maintained on secure servers and is accessible to authorized personnel only on a “need to know” basis.
Your information is protected by a password for your privacy and security. We also use coding practices which take steps to prevent attack on our Services from web browsers and malicious scripts.
The cricketmedia.com site includes an e-commerce section at shop.cricketmedia.com for conducting sales of Cricket magazine subscriptions and products (individually or collectively, “Products”) to customers 18 years of age or older, where customer accounts may be established. This e-commerce section and any other e-commerce ordering function on any site included hereunder and operated by Cricket is intended for use by visitors 18 years of age or older. By ordering a Product from at shop.cricketmedia.com, a customer is representing himself or herself as 18 years of age or older, or otherwise authorized to order.
We may collect personally identifiable and non-personally identifiable information including, but not limited to: first and last name, date of birth, credit card information (for Product purchases), security question and answer, nickname, information related to hobbies and preferences, email address, unique login name and password, home street address (including for Product purchases this may be the home street address of an individual donating his/her purchase and such recipient’s address) and/or telephone number, grade level, school or organization name, school address, and school telephone number. Some or all of the foregoing may be collected from individuals 16 years of age or old in connection with Challenges or contests. Teachers who register for ePals® may create and post an online profile, with fields for class- and school-specific information, and brief description of their class(es) for matching purposes. A Teacher can elect to suppress his or her profile so that it does not surface during class-matching (in the Find Classroom area), provided, however, that the profile would be accessible if such teacher asks to join another teacher’s project or submits a project to the Join Project listing.
It is our policy not to create profiles for any user identified by our system as being under 16 years old or identified as a student.
We may collect personally identifiable and non-personally identification information in connection with such purchases. We need to collect and share some personally identifiable information from you in order for us, or our third party support and distributor vendor, CDS, acting as our agent or other payment account vendors as may be listed in the purchasing page, to process your order and which hosts the ecommerce portion of our site—shop.cricketmedia.com . When an individual puts an item in a shopping cart or places an order, we collect information associated with the transaction, may include the customer’s name, email, mailing address, products ordered, shipping address, and credit card information, as well as ship-to information (if Products are intended for someone other than the purchasing customer.) Customers have the option of registering certain information for future orders while completing the online order at shop.cricketmedia.com. For customers who choose to register, we will capture login name, password, name and mailing address, billing address, alternate ship-to addresses, and credit card information. We, or our trusted service provider, CDS, will retain your registration information, including your credit card information, so we can process your request.
For more information on CDS click here http://www.cds-global.com/about/privacy-policy/.
When registered customers return to shop.cricketmedia.com to place subsequent orders, they can identify themselves with their login name and passwords.
When a customer places an order online, we will send a confirming email message. We may also send an occasional email featuring a special promotion or product that may be of interest to Product customers. Any customer who prefers not to receive an online order confirmation or promotional email may indicate this preference on the online store order form. If you do receive commercial emails from us that you would rather not receive, simply follow the “unsubscribe” instructions included in each message.
We may use non-personally identifiable information that we collect from users at least 16 years old to improve the design and content of our site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze site usage.
We may also collect non-personally identifiable information from registered users (such as the member’s music tastes or hobbies) and match it to personally identifiable information (such as the member’s name) in our database for a particular Service. Such combined information is kept in our internal database under the member’s user name. We do not share such information with third parties, but we may use it for statistical purposes.
We may use the personally identifiable information that we collect online from Users who are at least 16 years old to obtain parental, teacher or school administrator consent, as applicable, for children to use the Service, to provide an interactive online experience to send newsletters, to make reading recommendations, to facilitate collaborative projects, to obtain User-generated content in response to Challenges or other submissions provided by users 16+, to provide educational content that we believe that the child may be interested in or would benefit from, to collect, fulfill, and bill for books, products or services, and, with permission from the applicable User, to post testimonials.
As indicated previously, personally identifiable information collected for customers ordering Products is used by CDS, our service provider for order fulfillment (and the entity hosting shop.cricketmedia.com), to process and fulfill Product orders, and information for a purchase for that product may be collected by CDS or such other payment vendor as may appear on the site-by way of example only, PayPal. We ask such service providers to maintain the confidentiality of your personally identifiable information and not to use for any reason except to carry out the purpose(s) for which we hired them. In addition, if you, an individual 18+ initiates a purchase of a Product but do not complete the transaction, we may use the email address you provide to send you email for the purpose of requesting feedback on your purchase experience. You are not obligated to respond to such email, but if you do, we may use your feedback to improve the ordering experience.
When you use certain of the Services, you may set up your personal profile, send messages, perform searches and queries, and transmit information through various channels, depending upon what category of User you are registered as within ePals (e.g., student, parent or teacher, or for CricketTogether or TryEngineering Together mentor) (“User Category”), and as permitted by the functionality of the Services. The information we gather from users enables us to personalize and improve the Services, and allows Users to set up a User account and profile through particular Services, such as ePals.
If you are a teacher and you provide us with another teacher’s name and email address, we may send that teacher an email inviting him or her to visit the Services. We store this information for the sole purpose of sending such email (and, if applicable, subsequent “reminder” emails) and tracking the success of our referral program. The referred teacher may contact us at email@example.com to request that we remove this information with regard to ePals and/or at firstname.lastname@example.org or email@example.com for CricketTogether.com or TryEngineeringTogether.com from our database.
Cricket uses certain aggregate data, standard web traffic and behavior analytics, to enable us to figure out how often users use parts of the Services, so that we can make the Services more appealing and relevant to users, and customize and improve the Services and/or Products. As part of our use of information, we may provide aggregate information to our partners (in a non-personally-identifiable format) about how our users use our site. We may share this type of statistical data so that our partners also understand how often people use our partners’ services and the Services — to help us improve the Services (including by having great partner content and services). We may link usage information to Personal Information and Child Related Personal Information that we collect through the Services, but we will only use this linked information internally (for example, to customize your experience), and will not disclose it in linked format to third parties (unless such third parties are acting solely as our agents). Additionally, certain usage-related information may be viewable in your user profile that may be displayed to other users, depending on your User Category; for example, certain “badges” may displayed in your profile (indicating successful completion of certain activities).
The type of usage data described above, when collected from a mobile device is used to determine the device capabilities and usage trends which allows us to better understand which devices we should support and what features are most frequently used.
We may disclose personally identifiable and/or non-personally identifiable information with third parties in certain limited circumstances, as set forth below:
In certain situations, we may share such information with affiliates, partners, and third-party vendors who may offer or sell items or provide services to you through the Services (either alone or jointly with us). We may, for example, work jointly with other businesses to offer or sell products or provide services, or we may work with third party websites to enhance your online experience. These transactions or services may or may not be commercial in nature. We will share your Personal Information or Child Related Personal Information that you provide with that business only to the extent that it is related to such transaction or service. Such services may include the ability for you to automatically transmit information you input on the Services to your profile or account on a third-party website, or to automatically transmit information you input on a third-party website to your Services profile. These third parties have agreed to maintain the confidentiality, security and integrity of any personally identifiable information provided to them through the Services. However, as we noted above, we have no control over the policies and practices of third-party websites (or other offerings) as to privacy or anything else, so please review all third-party websites’ policies before disclosing any Personal Information or Child Related Personal Information or other content on the Services or on any third-party website (via the automatic transmissions discussed above or otherwise). Cricket is not in a position to, and is not responsible for, reviewing or verifying the accuracy of any third party’s data collection or use policies, or their compliance with such policies. If you have any concerns regarding any third party (e.g., if you would like a third party to cease contacting you or delete any of your information), please contact such third party directly. We sometimes make our list of the names and addresses of customers purchasing Products available to other carefully selected companies whose products and services we believe might be of interest to you. Be assured this does not involve sharing Children’s Personal Information for marketing. If you do not want to receive offers from these other companies, you, the purchaser of a Cricket Product, can opt out of these third party offers at any time in your account management section of the e-commerce portion of the Site, at shop.cricketmedia.com.
We engage certain other companies and people to perform tasks on our behalf and sometimes need to share your information with them to provide communications, products or services to you. Examples may include sending email, analyzing data, processing payments, providing user services, providing customer service, processing parental consents, and/or monitoring online forums and chatrooms. These third parties: (a) have agreed to maintain the confidentiality, security and integrity of personally identifiable information; and (b) do not have any right to use the Personal Information or Child Related Personal Information we share with them except as necessary to assist us.
In connection with certain online contests or similar Challenges involving submissions of user-generated content, we capture registration information that contains personal information from parents and/or teachers or students age 16 or older through the establishment of an account with our trusted service provider, Submittable, so that we can process your request, if not directly collected by Cricket, or for submissions for content by those 18 and over for potential contributors to our publications. For more information on Submittable click here: http://www.submittable.com/privacy
If Cricket, or some or all of its assets, were acquired or otherwise transferred, or in the unlikely event that Cricket goes out of business or enters bankruptcy, user information may be transferred to or acquired by a third party.
If you have any inquiries regarding our partner’s privacy practices or how they use your child’s personal information, please contact us directly at firstname.lastname@example.org or, as applicable, email@example.com or firstname.lastname@example.org
For the benefit of our members, our sites link to other websites. We are not responsible for the data collection practices on those other sites. This policy does not apply to websites, offerings or practices of companies that Cricket does not own or control.
We recommend that you to carefully review those sites’ privacy policies before submitting personal information there.
Like most commercial websites, we use “cookie” technology and web server logs to collect information about how our website is used.
Cookies are small data files that a Website writes to your computer hard drive for record-keeping purposes. Cookies identify you as a unique customer and store your personal preferences, as well as technical information (including click through and click stream data). Cookies can either be permanent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).
The cookies allow our web servers to recognize the computers used to access our websites. Cookies facilitate delivery of certain content to users as they move from page to page on our websites, including by remembering the information about the session.
You may adjust your browser to reject cookies from us or from any other Web site. If you just wish to browse our site without logging in or registering as a member, you can set your browser not to accept cookies. Please consult the “Help” section of your browser for more information. There are, however, certain features of the Services that can be accessed only in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of those features.
In addition, we also use technology to collect information automatically, like your Internet Protocol (“IP”) address (which is the automatic number assigned to your computer by your Internet service provider when you surf the Web, or unique device identifier (“UDID”), international mobile equipment identity (“IMEI”), mobile equipment identifier (“MEID”) or media access control (“MAC”) address; computer operating system (e.g. Microsoft Windows, MAC OS); your browser (e.g. Internet Explorer, Firefox); websites visited before or after your visit our site; and pages viewed and activities at our site.
You may revise or request deletion of your Cricket account, by sending a request to email@example.com (for ePals); for CricketTogether: firstname.lastname@example.org; for TryEngineeringTogether: email@example.com; for Math 1:1 tutoring: firstname.lastname@example.org; and for NeuLingo: email@example.com. Purchasers of Products utilizing our e-commerce section, shop.cricketmedia.com, should send a request to firstname.lastname@example.org. Such request should clearly identify your Account and specify that you are requesting deletion of your Account. You should also provide contact information so that we may, if we deem appropriate, verify the authenticity of your request. Please note that some unrevised information may remain in our records after revision of such information, and some information may remain after deletion of your account, or in cached and archived pages. Deletion of your Account will not affect our use of any aggregated data derived from or incorporating the Personal Information you previously provided to us.
We will retain your Personal Information or Child Related Personal Information for as long as your account is active or as long as needed to provide you the Services; we also may retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.
California Civil Code Section 1798.83 permits a user that resides in California to request certain information regarding Cricket’s disclosures of personally identifiable information to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email Cricket at email@example.com.
We strive to protect the confidentiality, security and integrity of the personal information we collect from children and adults. We have put in place physical, electronic and administrative procedures to safeguard and to help prevent unauthorized access to and maintain the security of personally identifiable information collected through this site. This information is maintained on secure servers and is accessible to authorized personnel only on a “need to know” basis.
Your Cricket account Personal Information or Child Related Personal Information is protected by a password for your privacy and security. We also use coding practices which take steps to prevent attack on our Services from web browsers and malicious scripts.
You may help protect against unauthorized access to your account and Personal Information or Child Related Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
When you enter sensitive information (such as a credit card number) in our Credit purchasing process, we or in the case of Product orders utilizing shop.cricketmedia.com or CDS, encrypt the transmission of that information using secure socket layer technology (SSL).
Cricket endeavors to keep your information private; however, we cannot guarantee security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information. For additional information about the security measures we use in connection with the Services, please contact us at firstname.lastname@example.org.
If we make material changes in the way we collect, use or disclose Personal Information or Child Related Personal Information, we will notify you either: (i) via email prior to the effective date of the change; or (ii) by posting an announcement on the Services with two (2) weeks’ notice prior to the effective date of the change.
Cricket Legal Department
1751 Pinnacle Drive, #600
McLean, VA 22102
Phone: (703) 885-3400
Cricket Media, Inc.
1751 Pinnacle Drive, Suite 600
McLean, Virginia 22102
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