Last modified on May 25, 2018

The PopJam Platform Privacy Policy

This privacy policy ("Privacy Policy") describes how SuperAwesome Trading Limited, a private limited company incorporated in England (Company Number: 09769338), having its registered office at 22 Long Acre, London, WC2E 9LY and its affiliate companies, including Awesome Content Limited and SuperAwesome Limited (collectively referred to herein as "SuperAwesome," "us" or "we") collects, uses and shares the personal and non-personal information you and our other users (who we refer to as PopJammers) provide to SuperAwesome across the PopJam platform, including but not limited to the website located at www.popjam.com, the affiliated mobile application known as "PopJam," and any of the PopJam platform services and features (collectively referred to herein as the "PopJam Platform"). For users in Europe, we are the data controller in respect of such personal information for the purposes of the General Data Protection Regulation (GDPR) (EU) 2016/679. The Privacy Policy applies only to the PopJam Platform; it does not apply to any third-party websites or mobile applications to which we may link. Additionally, it does not apply to any non-PopJam services provided by SuperAwesome, such as our advertising platform, AwesomeAds. If you are looking for the Privacy Policy that governs AwesomeAds, please consult our AwesomeAds Platform Privacy Policy.

By using the PopJam Platform, you accept our Terms of Service https://www.popjam.com/tosfull and that you have read and understood our Privacy Policy. Younger visitors should check with their parents or guardians before using the PopJam Platform. If you are a parent or legal guardian, by allowing your child to use the PopJam Platform, you are confirming that you have read and understood the terms of this Privacy Policy on your child's behalf. It is important that you read and understand this Privacy Policy before allowing your child to use the PopJam Platform.

This Privacy Policy and the certification seal shown above and on the PopJam Platform confirm that SuperAwesome is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). ESRB Privacy Certified is designed to ensure that our information collection, use and disclosure practices are responsible and appropriate. To protect your privacy, we have voluntarily undertaken this privacy initiative, and the PopJam Platform where this Privacy Policy is posted has been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, we are subject to audits of the PopJam Platform and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

The PopJam Platform is also certified as COPPA-compliant by the kidSAFE Seal Program. The kidSAFE Seal Program is an independent safety certification service and seal-of-approval program designed exclusively for children-friendly websites and technologies, including child-targeted game sites, educational services, virtual worlds, social networks, mobile apps, connected products, and other similar interactive services and technologies. kidSAFE is also an FTC-Approved COPPA Safe Harbor Program. Click on the seal or go to www.kidsafeseal.com for more information.

TABLE OF CONTENTS

  1. What we collect on the PopJam Platform
  2. Why We Collect Information on the PopJam Platform
  3. How long we keep your Information
  4. How We Protect User Information
  5. Sharing Users’ Personal Information
  6. International Data Transfers
  7. Advertisements
  8. Your Rights and Choices
  9. Change of Mind or Objection
  10. Notice to California Residents / Your California Privacy Rights
  11. Contact Us
  12. Revisions to Privacy Policy

1. What We Collect on the PopJam Platform

We do not purposely or knowingly collect personal information from you, except under limited exceptions set forth below. All information and content provided by users goes through our industry-standard moderation process, which includes technical analysis, automated text and image detection, and trained, certified human moderators. The purpose of the moderation process is to remove any personal information or inappropriate content entered by users before it is posted on the PopJam Platform or shared with other users.

User Profile

Creating a profile on the PopJam Platform does not require, or permit, the use of any personal information. When you sign up for the PopJam Platform, you create an anonymous profile, which is then publicly available inside the PopJam Platform. You may not use your real name, a photo showing your face or another child’s image, or any other information that could identify you or your location (such as a school uniform) in the creation of your profile or in posting content to PopJam. Your PopJam profile shows:

  • Username, which may not contain your real name;
  • Profile picture or avatar, which may not contain any personal information, including your face or the face of another child;
  • Profile description, which may not contain any personal information;
  • Pictures you make and share, as long as such pictures do not contain any personal information, including your face or the face of another child;
  • The users you follow, your followers and your Top Friends in the PopJam Platform;
  • Quizzes, tests and games in which you have taken part; and
  • Badges or stickers you have collected.

There are users of PopJam whose personal information, including photographs of their faces, are visible to other users and the public. In those instances, the PopJam user whose personal information is visible has a business arrangement with us or with an advertiser on the PopJam Platform pursuant to which the user or his/her legal guardian has consented to posting that user’s personal information on the PopJam Platform.

Sharing and Search

Users’ creations and comments are accessible and visible to all users of the PopJam Platform. There are no private channels or personal chat areas on the PopJam Platform. Pictures, quizzes, tests, games, comments, designs, artwork, and other content users post, upload, provide to, or share through the PopJam Platform (“User Content”) can also be shared via URL or "rejammed" (as we call it) by other users. Users can search for each other on the PopJam Platform with a username or profile picture using the search and browsing tools on the PopJam Platform.

Communicating with Us

Users may also provide us with personal information by communicating directly with us. For example, if you choose, you may use one of our public email addresses to contact us. If you write to us (or otherwise contacts us), we will ask you to put us in contact with a parent or guardian, through whom we can then provide support.

Consistent with the one-time use exception under the Children’s Online Privacy Protection Act, we only use your contact information to respond to your inquiry, and we then delete your and your parent’s email addresses from our servers.

Password Recovery

You have the option of providing an email address to enable us to recover your password if you forget it. When requesting a password reset, we will ask you for your email address. We will then anonymize your email address by ‘hashing’ it, compare the anonymized hashes of your email address to confirm your identity, and then send you a password reset link using (but not storing) your email. Your email address is never stored in a format that could be used to identify you, and it is deleted from our servers after the password reset is complete.

Other Non-personal information

We collect non-personal information about users whenever they interact with the PopJam Platform. Non-personal information includes the number and frequency of visitors to the PopJam Platform and the length of their stays, browser name, the type of computer, and technical information about the means of connection, such as the operating system. We also collect your IP address solely for the internal support of the PopJam Platform, such as system administration, and in case requested by law enforcement. We encrypt the IP address and adopt and implement appropriate and reasonable security practices regarding access to it. We delete all IP addresses after one year.

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2. Why We Collect Information on the PopJam Platform

We use the information you give us to provide you with the PopJam Platform. This may involve using the information we collect on how you use the PopJam Platform and the content you interact with to tailor your view of a service or personalise the content and features made available to you. We may also send you service-related mobile app push-notifications, including announcements and administrative messages. We will also use your information to provide you with any technical and other customer support you need. We will use your information for these purposes because it is in our legitimate interests to ensure that service is being offered to you at a high standard and to your satisfaction.

Provide the PopJam Platform

We collect non-personal information from your use of the PopJam Platform to understand how our customers interact with the PopJam Platform, so we can improve it and develop new services to meet our customers’ needs. We may also use this information to conduct statistical analysis and for business planning. For example, we will use the information to identify which aspects of the PopJam Platform are the most popular, so we can ensure that our IT infrastructure is sufficient to meet demand. We will also use the information to identify less popular aspects of the PopJam Platform to ensure that we are reaching our target audience and promoting our services effectively. We will typically use information in this way because it is in our legitimate interests to ensure that the PopJam Platform offers customers the best experience.

Improve our Services and Product Offerings

We collect non-personal information about users whenever they interact with the PopJam Platform. Non-personal information includes the number and frequency of visitors to the PopJam Platform and the length of their stays, browser name, the type of computer, and technical information about the means of connection, such as the operating system. We also collect your IP address solely for the internal support of the PopJam Platform, such as system administration, and in case requested by law enforcement. We encrypt the IP address and adopt and implement appropriate and reasonable security practices regarding access to it. We delete all IP addresses after one year.

Defend our Legal Rights

We may also use your information to prevent potentially illegal activities, protect the safety of our users and others, enforce our terms of service and comply with our legal and regulatory obligations, requests from government bodies or courts, or respond to litigation. Typically, we will do this because it is necessary in order to comply with a legal or regulatory obligation to which we are subject (e.g. complying with subpoenas, search warrants and court orders).

We may combine all the information we collect from or receive about you for any of the foregoing purposes. Please see Your Rights and Choices section for further information. Further, we may aggregate your information with other users’ information and use it for statistical analysis, research and reporting purposes. We may also share this information with our business partners. This aggregated information cannot be used to identify you or otherwise be traced back to you.

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3. How Long We Keep Your Information

We will keep your information only for long as it is necessary for the purposes described above (to provide you with the PopJam Platform, for our legitimate interests as described above and in order to comply with our legal and regulatory obligations). This period will vary depending on your interactions with the PopJam Platform. For example, we may retain your account data for a reasonable period of time after your last activity. This is to enable you to easily come back and start using the service again. We may also keep a record of correspondence with you relating to the PopJam Platform, for example, if you have made a complaint, for as long as is necessary to protect us from a legal claim. In all cases, where we no longer have a need to keep your information, we will delete it.

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4. How We Protect User Information

SuperAwesome takes reasonable steps to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide via the PopJam Platform. We adopt and implement appropriate and reasonable security practices regarding the collection, storage and processing of the information we collect, such as encryption. We also put in place physical safeguards such as limited employee access and confidentiality agreements with employees and contractors. Despite our best efforts, no security measure is ever perfect or impenetrable. In the event we experience a data breach involving unencrypted personal information, we will notify users by posting notice on the affected PopJam website or app.

5. Sharing Users’ Personal Information

We do not sell, trade, or rent your personal information to others, and will not do so except as required by law or in connection with a merger, asset sale or similar business transaction (as described below). We may share aggregated demographic or non-personal information not linked to any personal information regarding visitors and users with our business partners, company affiliates and advertisers. We use third-party service providers (as set out below) to help us operate our business and the PopJam Platform or administer activities on our behalf.

Group companies

We may share your information with our affiliate companies in order to provide you with the PopJam Platform and to help better tailor our services to you.

Service providers

SuperAwesome, like many other website and app operators, uses analytics for the purpose of analyzing our user base and improving the performance of our online services. PopJam uses Google Analytics for this purpose:

We may also engage other third parties to perform services in connection with the operation of the PopJam Platform, some of whom may process personal information. Each of these third parties is contractually obliged to protect the security of any information we share with them, and limited in their use of the information to the services being provided solely to SuperAwesome:

  • Amazon (AWS): Your User ID is shared with AWS in connection with User ID searches and storing posted images.
  • TwoHat Security (Community Sift): Your username is shared with Community Sift in connection with our moderation process.
  • Zendesk: your username is shared to assist with password reset queries.
  • Google Android: Your Android input method editor is shared with Google Android in connection with performance of network communications.
  • Apple: Your iOS identifier is shared with Apple in connection with performance of network communications.
  • Internet service provider (ISPs): Your IP address is shared with ISPs to ensure legal or regulatory compliance.

For more information on the processing of your data by our third-party service providers, please contact us at hi@popjam.com.

Law enforcement requests

We may disclose your personal information: (a) in the good faith belief that we are required to do so by law; (b) if doing so is reasonably necessary to comply with legal process; (c) to permit us to pursue available remedies, including commencing or responding to any claims; (d) to enforce the terms and conditions of the PopJam Platform; (e) to protect the rights, property, or personal safety of SuperAwesome, its users or the public; or (f) or other illegal activity or for risk management purposes.

Corporate Transaction

In addition, your personal data may be disclosed as part of any proposed or actual merger, sale, and transfer of SuperAwesome assets, acquisition, bankruptcy, or similar event.

Do Not Track disclosure

Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support and does not act on DNT signal headers that we may receive.

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6. International Data Transfers

We operate globally and may need to transfer your personal information outside the European Economic Area to our affiliate companies, partners or third party service providers in locations around the world for the purposes described in this Privacy Policy. We do so in order to provide you with our services and for the other purposes outlined above. Please be aware that the data protection laws in some of these countries may not offer the same level of protection as those in your country of residence. Before transferring your information in this way, we will take reasonable steps to ensure that suitable safeguards are put in place aimed at ensuring that an appropriate level of protection applies to the privacy of your personal information and we will comply with all applicable laws. For further information on these safeguards, please contact us at hi@popjam.com, or Privacy, PopJam, 22 Long Acre, London WC2E 9LY, UK.

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7. Advertisements

We may serve advertising on the site from child-friendly brands. Advertising enables us to keep the PopJam Platform free to use. Any ads we serve will be delivered by our own ad serving technology, which has been designed to be compliant with COPPA and is certified as such by the ESRB Privacy Certified and kidSAFE COPPA Certified programs. Such advertisements will only be targeted based on the context or content you are viewing on the PopJam Platform, and not on your browsing behavior. All ads served in the PopJam Platform will carry the SuperAwesome SafeAd watermark, which indicates that: (a) the ad is not collecting personal information in contravention of COPPA; (b) its content has been reviewed for compliance with best practice and the CARU self-regulatory principles to be appropriate for children, and (c) it is age-appropriate for the PopJam Platform. If you have any questions about advertising on the PopJam Platform or concerns about specific ads that you see, please contact us on hi@popjam.com.

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8. Access, Modify, Delete and Other User Rights

Notwithstanding the limited nature of the personal information we collect from or about the users of our PopJam Platform, users or their parents have the right to request access to review, modify and correct personal information about a user. We will take reasonable steps to verify your identity, such as requiring a password and user ID. Users or their parents may also contact us to request certain information regarding our disclosures to third parties for their direct marketing purposes. However, we do not share information with third parties for this purpose.

Depending on the country from which you are using the PopJam Platform, you may have the right to have the information you have provided to us and which we use to provide the PopJam Platform to you in a machine-readable format. This right enables you to move your information from one provider to another, for example, so that the other provider can continue to service your needs effectively.

If you would like to delete the information that we have collected from your use of the PopJam Platform, please use the settings of the mobile app or contact us. We may be required to retain some or all of this information in order to enable you to use the PopJam Platform and features, and to ensure that these function properly. We may also retain such information where required by law, to resolve disputes, troubleshoot problems, enforce our terms and conditions of use and enable us to defend our legal rights. We may only be able to provide the PopJam Platform if we have your information, so deletion of your information will require deletion of your account and termination of your ability to use the PopJam Platform.

If a user or parent wishes to exercise any of the above rights, please contact us at hi@popjam.com or using the information within Section 11 of this Privacy Policy.

Any User Content posted in the PopJam Platform is publicly viewable. You are prohibited from posting personal or inappropriate information at any time, and we take reasonable steps to prescreen all posts to remove any such information. Should you wish to edit or remove any User Content after it has been posted, you may contact us at hi@popjam.com or using the information within Section 11 of this Privacy Policy. Removal of the information from public view does not guarantee complete or comprehensive removal, however. After the removal request has been honored, we may retain copies of the User Content or information previously posted on our servers. We are not required to remove the posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted this information.

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9. Change of Mind or Objection

Where you have given us consent to use your information for any of the above purposes, you have the right to withdraw that consent at any time. You may also have a right to object to our use of your information where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to our processing on this ground. Please contact us at hi@popjam.com or using the information within Section 11 of this Privacy Policy for more information about exercising these rights.

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10. Notice to California Residents / Your California Privacy Rights

Under California Civil Code § 1798.83, California residents are entitled once a year to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes during the immediately prior calendar year. We do not share your personal information with any unaffiliated third parties for their own marketing purposes. Nonetheless, you may make one request per year if you are a California resident. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request this information in writing by contacting us at hi@popjam.com or by regular mail at: Privacy, PopJam, SuperAwesome Trading Ltd., 40 Long Acre, London WC2E 9LG, United Kingdom. Please allow up to thirty (30) days for a response.

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11. Contact us

If you have any questions, need information or require assistance, please do not hesitate to reach out to us either by sending us an email at hi@popjam.com or send us a post at:

Attn: Privacy, PopJam
SuperAwesome Trading Ltd.
22 Long Acre
London WC2E 9LY
United Kingdom
Email address: hi@popjam.com
Telephone: +44 203 668 6677

As previously mentioned, we are a licensee of ESRB’s Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at https://www.esrb.org/privacy/contact.aspx, or:

ESRB
Attn: VP, Privacy Certified Program
420 Lexington Avenue, Suite 2240
New York, NY 10170 USA
privacy@esrb.org

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12. Revisions to Privacy Policy

SuperAwesome has the discretion to update this Privacy Policy at any time. When we do, we will update the “last modified” date at the top of the Privacy Policy. If the change is material, we will place a notice on the PopJam website (www.popjam.com) and app by revising the link to read substantially as "Updated Privacy Policy" for a reasonable amount of time, and if necessary, will obtain your prior consent or the prior consent of a parent or legal guardian. The most current version of this Privacy Policy will be available on the PopJam website and app and will supersede all previous versions of this Privacy Policy.

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