Privacy Policy

Last updated November 29, 2018

What is the PRIVO iD Platform

The PRIVO iD Platform, (aka PRIVO-Lock) is an identity and consent management platform owned and operated by Privacy Vaults Online, Inc. d/b/a PRIVO®. The PRIVO iD Platform (the Platform) is a third-party service provider for websites, apps and connected toys handling account creation and managing consent on their behalf. It also includes the PRIVO iD (PiD), a privacy enhanced single sign on for parents and families. This service is available at my.PRIVO.com. This policy covers the PRIVO iD Platform and my.PRIVO.com. It is not intended to, encompass the privacy practices of the sites and services that use the Platform. To understand how our clients, use your information, and that of your child, please review their privacy policy.

This Privacy Policy is part of the Terms of Service. When you use the Platform or my.PRIVO.com, you agree to the Terms of Service. They can be found here.  If you disagree with any part of the Terms of Service or Privacy Policy, please do not use the Platform or my.PRIVO.com. 

PRIVO is a leader in online privacy protection. The privacy solutions offered by PRIVO also include an FTC-approved COPPA (Children’s Online Privacy Protection Act) Safe Harbor Program, as well as GDPRkids™ Privacy Assured and Student Digital Privacy Programs. To find out more about these solutions visit privo.com and the privo.com privacy policy.

What is the PRIVO iD Platform?
The PRIVO iD Platform is a suite of online technology services that simplify the process of creating user accounts, logging into those accounts, and, where the user may be a child, securing verifiable parental consent.  The powered by PRIVO iD (PiD) symbol indicates that the site or service uses the technology, but it is not operated by PRIVO. 

What is a PRIVO iD (PiD) Account?
A PRIVO iD account (PiD) is part of the PRIVO iD Platform suite of services. A PiD account is a secure online log-in credential that can be used on sites and services in the PRIVO iD network. Only COPPA compliant services and those that have met the requirements of the PRIVO Privacy Assured Programs are included in this network.  PiD account holders have a dashboard that allows parents to manage consent and users to control their settings. Adults, teens and children can create their own PiD account on my.PRIVO.com.

What is my.PRIVO.com?
my.PRIVO.com is a website that hosts a direct PRIVO iD registration process and showcases information on members of PRIVO's FTC approved COPPA Safe Harbor and Kids Privacy Assured programs. Account holders can manage their PiD account on my.PRIVO.com.

Information we collect for PRIVO iD
When a parent or teen registers for a PiD on the my.PRIVO.com Site, we collect the following personal information to set up an account:

  • Full name
  • Email address
  • Optional cell phone number to further secure your account
  • Other optional non-personal information, such as occupation, age, gender, income range, education level, number of children, or hobbies.

Parents have the option to provide PRIVO with a minimum set of information about each of their children, including:

  • The device ID of any devices your child uses which PRIVO will use to create a PiD child account for each child;
  • A method of providing verifiable parental consent for your child’s use of any child account you create. To learn more about why parental consent is necessary, click here.

Parents have the option to verify by providing:

  • A credit card number
  • Partial social security number
  • A driver’s license number
  • Skype account information
  • Or other data that is reasonably designed to identify the user.

PRIVO uses third-party providers to verify this information and does not store or use it for any other purpose but verifying your identity. For more information on these third-party service providers see here.

Parents may also provide PRIVO with verifiable parental consent through an offline method, such mailing, faxing or emailing a signed form to PRIVO or calling the PRIVO Customer Service number.

When you have completed the registration process, parents and any child(ren) added will each receive a PiD account.  This iD allows parents and their child(ren) to log into any site or service that is using the PRIVO iD Platform more quickly and easily. 

Information We Collect for a Website or App that Uses The PRIVO iD Platform
A child may begin the registration process for an account on a site or service that uses the Platform such as a child-directed website or mobile app.  On behalf of the site or service, PRIVO collects the following from children:

  • First name
  • Date of birth
  • Username
  • Password
The following information may also be collected from time to time:
  • Gender
  • Grade
  • Display name
  • Child email address
  • Parent email to seek verifiable consent in the manner described above, for the child’s use of the site or service

PRIVO does not collect more information than reasonably necessary for a child to participate in a given activity.  The site or service using the Platform may collect additional information from your child and will disclose this to you in its privacy policy.

Third Party Service Providers
PRIVO works with a number of third-party service providers solely to support our services. Information shared with these third parties is not used for any other purposes. For more information on these providers please click here.

What We Do With The Information You Provide
PRIVO only uses information collected directly from you for the purposes stated.  The information is used to facilitate registration on sites and services and to process verifiable parental consent when required by law.

We will also use your information to update you about changes to our policies and to give you information about additional products and services we, or one of our clients, may offer. With your explicit consent, we may share your information with trusted third parties who offer products or services we believe you may find interesting. After opting in, if you do not want us to disclose your information in such a manner, you may opt out of disclosure by following the procedures described in the next section. At any time, you can opt-out of these communications and/or control your communications settings in your account profile.

PRIVO will disclose information about you or your child(ren), in a manner that is not aggregated or anonymous, if we believe it is legally necessary to do so, for example, in response to a court order or civil subpoena, or to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose PRIVO to legal liability. In addition, in the event of a merger, acquisition, reorganization, bankruptcy or other similar event, PRIVO customer information may be transferred to our successor or assigned but will remain governed by and protected in strict accordance with this Privacy Policy and no further use of customer information will be made without explicit consent.

Control Over Your Information and the Information of Your Child
When you provide us with consent for you and/or your child to participate at a site or service using the Platform we give you the option to agree to the collection and use by ourselves and our client of your child’s personal information for internal purposes, without having to agree to the disclosure of your child’s information by us or our client to unaffiliated third parties.

To manage your information, or the information we maintain about your child, sign in with your PiD and click “Manage Accounts”. There, you will be able to see all the permissions you have set for your child, access the personally identifiable information that PRIVO has collected from you or your child, correct factual errors in such information, can request to have this information deleted or request that we no longer collect or maintain such information. To protect your child’s privacy and security online, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.

We retain the personal information we collect as long as reasonably necessary to provide the service. If a parent or child requests to delete their information this request will be met within 30 days unless there is a legal requirement to retain the information.

If we are providing our service on behalf of another company, website or app then please review their privacy policy to understand your rights in relation to the personal information they have collected from you. If a parent or child requests to delete their information this request will be met within 30 days unless there is a legal requirement to retain the information.

If we are providing our service on behalf of another company, website or app then please review their privacy policy to understand your rights in relation to the personal information they have collected from you.

Passively Collected Data
We will sometimes passively collect information about visitors to my.PRIVO.com using the data transfer logs of the site or service or “cookies”.  The information we may collect through passive collection technologies, such as “cookies”, includes IP address and browser type, as well as time spent on my.PRIVO.com and areas visited.  Our logs are used only to improve the design, functionality, and content and to enable us to personalize your experience. PRIVO utilizes Google Analytics to assist in these efforts by providing general analytical data on use and functionality of for internal purposes. Data that is collected, processed, and stored is secure and kept confidential and PRIVO has opted not to share this data. For more information, visit their Privacy Policy.

PRIVO does not track you, that is, it does not collect personally identifiable information about your online activities over time and across third-party web sites or online services. my.PRIVO.com does not employ technology that responds to browser signals that permit users to limit tracking.

Security
PRIVO uses generally accepted security measures and safeguards and requires that the third parties it works with agree to do the same. The measures and safeguards include limiting access to the data to those persons who need it to complete their work for PRIVO.

PRIVO may host the registration pages of sites and services that use the Platform. All data is transmitted through an SSL transmission to ensure privacy and security of your family’s information. We have put in place industry standard physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while PRIVO uses reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

Third Party Links
my.PRIVO.com contains links to many of the site and services that use the PRIVO iD Platform or allows its users to sign in with the PiD. Sites and services displaying the PRIVO logo have made specific, legally–binding assurances to PRIVO about their practices, including a promise to maintain an accurate and up–to–date privacy policy of their own disclosing their data gathering and usage practices. However, apart from this legally binding promise, PRIVO cannot control these third parties, and is not responsible for the policies or practices of sites and services using the Platform. We encourage you to carefully review the privacy policies of sites that link to and from the PRIVO website or use the  PRIVO iD Platform, before providing such sites and services with any personally identifiable information, and to contact us at privacy@privo.com if you believe any sites or services using the Platform is engaged in practices that are inappropriate, or in any way inconsistent with their publicly posted privacy policies.

How to update or remove your information
PRIVO keeps your information/content for as long as necessary in providing the services. If you want to opt out of services, review your information, or delete your information, please contact us at privacy@privo.com.

Notice to California Residents
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of PRIVO to third parties for the third parties’ direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities within the State of California. To make such a request, please send an email to privacy@privo.com or write us:

Privacy Vaults Online, Inc., d/b/a PRIVO
17949 Main St., #1025
Dumfries, VA 22026-1025
703–569–0504 (telephone)
703–783–8752 (fax)
privacy@privo.com(email) 
Attn: Privacy Officer  

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

  • to correct the personal data we have about you;
  • to withdraw your consent to the processing of your personal data;
  • to obtain a copy of the personal data we hold about you;
  • to have your personal data deleted;
  • to transfer your personal data to another controller to provide you with services;
  • to restrict the personal data we have; 
  • to request we stop processing your personal data.

You can action any of these rights by contacting us at: privacy@privo.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 at privacy@privo.com. to find out more.