CKT

Privacy Policy

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.

 

PURPOSE OF THIS PRIVACY POLICY:

This privacy policy addresses the online privacy practices of Cricket Media Services, Inc., formerly known as ePals, Inc., and its affiliated entities, including its subsidiaries, Cricket Media, Inc. and In2Books, Inc., for the website services, magazine apps, and/or products indicated herein (collectively, “Cricket”). The magazine apps developed by Carus Publishing which this privacy policy applies to include: ASK, BABYBUG, CLICK, COBBLESTONE, CRICKET, FACES, LADYBUG, MUSE, and SPIDER. Cricket is committed to protecting the privacy of children, students, parents, educators, and eMentors, while providing students and schools with a dynamic learning and teaching environment made possible by the Internet and made available through its ePals® global learning community (hereinafter “ePals”) and/or through its online student e-mentoring programs, CricketTogether™ and TryEngineering Together™ (the latter program is offered in conjunction with the Institute of Electrical and Electronics Engineers, Incorporated, “IEEE”), and its topic-based and language learning offerings, Cricket eLearning (including brand names NeuLingo and Fluent City).

This Privacy Policy explains how Cricket collects and uses information from users of its websites, Products, and services, including ePals, all versions of CricketTogether and TryEngineering Together, NeuLingo, Fluent City, Invent It Challenges and/or similar contests involving or related to ePals or Cricket’s magazines, and In2Books’ learning programs (individually and collectively, “Services”), and in connection with its sale of Cricket’s magazine subscriptions and related products (collectively “Products”), including our treatment of personally identifiable information.

If you are not of legal age to form a binding contract (in many jurisdictions, this age is 18), you may only use the Services, and disclose information to us with your parent’s (or guardian’s) consent. Review this Privacy Policy with your parent (or guardian). You may only order Products from any sites if you are 18 years of age or older or authorized to order, and have a valid credit card to purchase or where indicated on a particular site.

 

IF YOU USE THE SERVICES, THE PRIVACY POLICY APPLIES TO YOU.

As you will see from reviewing this Privacy Policy, we take your privacy seriously. By accessing or using the Services (including via mobile devices) or accessing shop.cricketmedia.com and ordering Products, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Remember that your use of the Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy; and for certain Services such as CricketTogether or TryEngineering Together, your use may be subject to participation guidelines and permissions that may be imposed by a child’s teacher or school administrator. Any capitalized terms we use here without defining them have the definitions provided in the Terms of Use.

If you have questions or concerns regarding the Privacy Policy, you should contact us at support@cricketmedia.com. Note if you are reading a hard copy of this Privacy Policy, the email address for Cricket Support is: support@cricketmedia.com.

TABLE OF CONTENTS

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

I. PRIVACY NOTICE FOR CHILDREN UNDER 16

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.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

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 support@cricketmedia.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.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.

This Privacy Policy covers all users and is applicable to all of the Services and Product purchases.

When we use the term “Personal Information” in this Privacy Policy, we are referring to personally identifiable information. When we refer to “Child Related Personal Information,” we mean personally identifiable information of minors (i.e. persons under the age of 18). General references to “information” are to information that does not and could not reasonably be used by us to identify an individual.

What Information Do We Collect From or About Children?

Personal Information (PI)

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:

CricketTogether and TryEngineering Together

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.

Challenges (Invent It)

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.

ePals Global Community

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.

NeuLingo

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.

Cricket eLearning (formerly Fluent City)

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. 

Non-Personally Identifiable Information

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.

How Do We Use the Information We Collect From or About Children?

Use of Personally Identifiable Information:

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.

Use of Non-Personally Identifiable Information:

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).

Will Cricket Share My Child’s Personal Information?

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 Parties Used in Relation to Children

Third-Party Service ProviderService Privacy PolicyIn Which Products is the Service UsedHow the Service is Used in Relation to Children
KalturaKaltura Privacy PolicyCricketTogether, 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.

AtlasAtlas Privacy PolicyCricketTogether, TryEngineering Together, ePals Global Community, and Invent It ChallengesServing as a User Database, hosting user information, and user-generated content.
SubmittableSubmittable Privacy PolicyInvent It ChallengesServing as a repository for entry submissions.
TypeformTypeform Privacy Policy > ‘Option C: Privacy Policy’CricketTogether, TryEngineering TogetherServing as a survey tool embedded into the platforms.
Amazon WebservicesAmazon Webservices Privacy PolicyCricketTogether, TryEngineering Together, Invent It Challenges, ePals Global CommunityStoring content viewed by users as well as storing permissions, consent forms, and content submitted by users.
Google AnalyticsGoogly Analytics Privacy PolicyCricketTogether, TryEngineering Together, Invent It Challenges, ePals Global CommunityUnderstanding how users are interacting with the products so as to improve experience.
ClassinClassin Privacy PolicyNeuLingoServing as the virtual classroom for language-learning sessions.
ZoomZoom Privacy PolicyeLearning (formerly Fluent City), NeuLingoProviding group and 1:1 online classes. Hosting recordings of group and 1:1 online classes that then get transferred to Kaltura.
HerokuHeroku Privacy PolicyeLearning (formerly Fluent City), NeuLingoProviding 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: support@cricketmedia.com.

Can I Review, Change, or Delete the Child-Related Personal Information Cricket has Collected from My Child?

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:

  • For ePals®: Teachers of ePals can review or edit, any Child-Related Personal Information related to their students (such as the students’ names, dates of birth, or usernames) by logging in to ePals and accessing the ‘Participants’ section of the collaboration. Parents/Guardians can request that a child’s account, including those set up by an authorized teacher, be deleted at any time by emailing support@cricketmedia.com.
  • For CricketTogether™ or TryEngineering Together™: Teachers can log into their accounts on https://crickettogether.com or https://tryengineeringtogether.com, click the “My Class” button in the navigation bar, and update information about a child. Alternately, Cricket support administration can also edit student information. For more information, or if you need assistance, send an email to support@crickettogether.com; or support@tryengineeringtogether.com.
  • For Invent It Challenges: Parents/Guardians can request that a child’s information and entry, including that supplied by an authorized teacher, be deleted at any time, by emailing support@cricketmedia.com; or invent@cricketmedia.com.
  • For NeuLingo: Parents/Guardians can review and edit information about their child in the NeuLingo Parent/Guardian portal as well as view recordings of their child’s language-learning sessions. To delete information about a child, parents/guardians can request that a child’s information be deleted at any time, by emailing neulingo-support@cricketmedia.com.
  • For Cricket eLearning (formerly Fluent City): Parents/Guardians can access recordings of their child’s online classes. Parent/Guardians can review, modify, or delete information about a child at any time, by emailing support@cricketmedia.com.

We will endeavor to respond to any requests for access to a child’s personal information within thirty (30) days.

A Note to EU Citizens

Cricket, complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:

  • the right to have your personal information updated to ensure it is up-to-date and accurate;
  • the right to withdraw your consent to any processing that is currently being done under your consent;
  • the right to receive a copy of the personal information we hold about you;
  • the right to request that we delete personal information in certain circumstances;
  • the right to have us transfer to another controller the personal information that you have provided us with;
  • the right to request a restriction on the processing of your data in some limited circumstances;
  • the right to request that we stop processing your data.

For more information how to action these rights, please contact us at: support@cricketmedia.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.

II. STUDENT DIGITAL PRIVACY

For some Cricket Services, including but not limited to ePals® or CricketTogether™, teachers and school administrators may provide consent on behalf of parents. As a parent, you should consult your school’s acceptable use policy for more information about your child’s school’s policies and practices for protecting children on the Internet. As a teacher or school administrator, you should confirm that you have authority to consent on behalf of your student’s parents, by reviewing your school’s acceptable use policy and any express consents provided by parents or guardians to students’ online activities, together with Cricket’s Privacy Policy and Terms of Use.

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.

If we need to make a material change to this privacy policy we will notify you before making any changes to seek your consent or allow you to opt out. If we are involved in a merger or sale this privacy policy will be maintained unless we contact you to notify you of a change, seek your consent or allow you to opt out.

Teachers, parents and eligible students can review, update or have their information deleted at any time by contacting us here: support@cricketmedia.com

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.

III. INFORMATION THAT WE COLLECT FROM INDIVIDUALS 16 YEARS OLD AND OVER

Our privacy practices for data that we collect online from individuals 16 years old and over are generally similar to those for information that we collect from users under 16 years old, with specific collection practices, if any, identified in the case of individuals ages 18 and up who may consider being mentors as part of the CricketTogether or TryEngineering Together online services; in the case of purchasers of Products in the e-commerce section, shop.cricketmedia.com, (who must be 18 years of age or older, with a valid credit card or otherwise authorized to submit electronic payment[s]); and in the case of purchasers of sessions of language-learning (e.g., NeuLingo), online correspondence (e.g., Cricket Together: Family & Friends), or Math 1:1 tutoring, which involve submitting payment-related information through third-party credit card payment services Stripe (Stripe’s Privacy Policy).

For individuals 16 years old and over on our Cricket eLearning platform, we collect personal Information for adults who are adult learner participants as follows: first name, last name, email address, city, and country. For all 1:1 tutoring sessions, you may upload attachments that include additional personal information solely about you—including but not limited to voice recordings, images, and videos (so long as these materials are owned by you or authorized for such sharing as contemplated). All 1:1 and group tutoring sessions are recorded (and retained for up to one year). You have the right to review and/or request the deletion of your  information, including uploaded attachments pertaining to 1:1 tutoring sessions. To delete your personal information, please email your request to support@cricketmedia.com. Recordings of tutoring sessions, notes, and in-session text chat are stored (and may be accessible by applicable parent/guardian) with Zoom or Kaltura or similar platforms engaged by Cricket for such purposes and are also accessible by Cricket. Data collected and stored on Zoom is subject to Zoom’s privacy policy https://explore.zoom.us/en/privacy/. Data collected and stored on Kaltura is subject to Kaltura’s privacy policy.

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.

What Information Do We Collect From Individuals 16 Years Old and Over? What Information Do We Collect from Individuals Ordering Products through shop.cricketmedia.com—those individuals 18 Years Old and Over?

For all Cricket Services or Products:

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.

For orders of Cricket Products:

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.

Non-Personally Identifiable Information:

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.

How Do We Use Information that We Collect From Individuals Ages 16 and Over? How Do We Use Information that We Collect from Individuals Ordering Products-those Individuals 18 and Over?

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.

What does Cricket use my information for?
Generally

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.

Your email address

If you provide us your email address, we may send you email communications. Web beacons may also be used in some of our emails to let us know which emails (and which links within those emails) have been opened by recipients. This allows us to gauge the effectiveness of our customer communications. If you are a student, we will only use your email address to send you Notifications. To opt out of receiving emails from us with regard to our Services or Products, please contact us at support@cricketmedia.com. Please note that your ability to opt-out from receiving marketing and promotional materials does not change our right to contact you regarding your use of our website. Please note that if you do not want to receive even legal notices from us via email, such as changes to this Privacy Policy, those legal notices will still govern your use of the Services and/or ordering Products, and you are responsible for visiting this Privacy Policy from time to time to review any changes.

Your friend’s email address

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 support@cricketmedia.com to request that we remove this information with regard to ePals and/or at support@crickettogether.com or support@tryengineeringtogether.com for CricketTogether.com or TryEngineeringTogether.com from our database.

Usage Information

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).

Mobile Usage Information

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.

IV. INFORMATION SHARED WITH THIRD PARTIES

We may disclose personally identifiable and/or non-personally identifiable information with third parties in certain limited circumstances, as set forth below:

Businesses We Do Not Control

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.

Agents

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

Service Provider, Sub-Processors / Onward Transfer

We may transfer such information to these third-party companies that help us provide our service (for example, in the case of Product purchases on the e-commerce portion of the Site). Transfers to subsequent third parties are covered by: (a) the provisions in this Privacy Policy, (b) our applicable service agreements with such third-party companies, and (c) our service providers’ respective privacy policies.

Business Transfers

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.

Protection of Cricket and Others

We may release Personal Information or Child Related Personal Information when we believe in good faith that such release is necessary to comply with the law (such as to comply with a court order or subpoena), enforce or apply our Terms of Use and other agreements, or protect the rights, property, or safety of Cricket, our employees, our users, or others. (For example, we may disclose such information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person). We will try to give you notice if we release information for these reasons, but please understand that we reserve the right not to, as it may not be practical, legal, or safe to do so.

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 support@cricketmedia.com or, as applicable, support@crickettogether.com or support@tryengineeringtogether.com

LINKS TO THIRD-PARTY WEBSITES

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.

COOKIES
Cookies and Website Information

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.

We may write “cookies” to your computer, primarily to personalize Services and to make our sites easier to use during each session, for example by keeping track of your preferences, such as what language you use. We may also use cookies to record session information, record user-specific information on what pages users access or visit, record past activity at our Site in order to provide better service when visitors return to our site, or to customize a Site view based on visitors’ browser type or other information that the visitor sends. Information gathered through cookies and by our web server logs may include the date and time of visits, the pages viewed, time spent on the Site, and the URL of websites visited just before and just after our Site in aggregate. If you choose to furnish personally identifiable information while using the Services, this information can be stored in or linked to other data stored in the cookies.

Certain of our partners and/or service providers may use cookies (to help us understand our users, to tailor what content is delivered, to help with shopping cart functionality, etc). The use of cookies by our partners, and service providers is covered by our privacy policy, but we do not necessarily have access to or control over these cookies.

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.

Our Site includes Social Media icons representing certain social media entities. These Social Media entities may collect your IP address, which page you are visiting on our Site, and may set a cookie to function properly. Social Media entities are hosted by a third party. In each case, your interactions with these social media entities are governed by the privacy policy of the respective social media entity providing such services, and not this Privacy Policy.

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.

V. DELETION OF ACCOUNTS AND RETENTION OF CERTAIN INFORMATION

You may revise or request deletion of your Cricket account, by sending a request to support@cricketmedia.com (for ePals); for CricketTogether: support@crickettogether.com; for TryEngineeringTogether: support@tryengineeringtogether.com; for Math 1:1 tutoring: support@cricketmedia.com; and for NeuLingo: neulingo-support@cricketmedia.com. Purchasers of Products utilizing our e-commerce section, shop.cricketmedia.com, should send a request to support@cricketmedia.com. 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.

Your California Privacy Rights

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 support@cricketmedia.com.

VI. SECURITY PRACTICES

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 support@cricketmedia.com.

The Services contain links to other sites. We are not responsible for security on other sites. (We recommend that you read all third parties’ privacy policies to ensure you understand them). This Privacy Policy only governs information collected by Cricket for the Services and Products.

VII. CHANGES TO THIS POLICY

We may make changes to this Privacy Policy from time to time for any reason. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

If we make changes to this Policy, we will post the revised Policy here with a new effective date at the top. Please check back to this page periodically. One way to know that the Policy has changed is to look at the effective date at the top of this privacy policy to see if it has changed.

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.

VIII. USERS OUTSIDE THE UNITED STATES

When you use the Services or order Products, the information we collect about you, including personal information, will be processed in the United States, as Cricket’s servers are all located in the United States. The data protection and other privacy laws of the United States may not afford the same level of protection as the laws of certain other countries. Cricket adheres to the rights of EU citizens. By providing personal information to Cricket from outside the United States, whether directly or indirectly through the Services or otherwise, your information will be transferred to the United States, in accordance with the measures of protection described in this Privacy Policy.

IX. FOR MORE INFORMATION

Please let us know if you have any questions or comments regarding our privacy policy. You can contact us at:

Cricket Legal Department
1751 Pinnacle Drive, #600
McLean, VA 22102
Phone: (703) 885-3400
support@cricketmedia.com

Cricket Logo

Cricket Media, Inc.
1751 Pinnacle Drive, Suite 600
McLean, Virginia 22102
(703) 885-3400

©2020 Cricket Media, Inc. All Rights Reserved.