document: title: privacy policy
text: Last updated February 12, 2013

Welcome to Pokémon!

Our Privacy Commitment

Pokémon respects the privacy rights of our online visitors and recognizes the importance of protecting all information that you may choose to share with us. The policies below are applicable to the Pokémon network of sites, including pokemon.com (including any versions optimized for viewing on a wireless or policy_textst device); all email newsletters published or distributed by Pokémon; all apps published by Pokémon, whether for policy_textsts, smart TVs, video game consoles, social media platforms, mobile devices or other platforms; and all other interactive features, services, and communications provided by Pokémon (“Sites”), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by Pokémon (collectively “Pokémon” or “we”, “us”, or “our”). We have established this privacy policy (“Privacy Policy”) to let you know the kinds of personal information we may gather during your visit to these Sites, why we gather your information, what we use your personal information for, when we might disclose your personal information, and how you can manage your personal information. 

We also recognize the need to provide additional protections for children who visit our Sites. To learn about our supplemental privacy protections for kids under the age of 13, click here to read Pokémon's Kids Privacy Policy.

This Privacy Policy and the certification seal shown on this page confirms that Pokémon is a member in good standing of ESRB's Privacy Online Program. The ESRB's Privacy Online Program is designed to ensure that our pokemon.com website information disclosure practices are responsible and appropriate. To protect your privacy, we have voluntarily undertaken this privacy initiative and all of our pokemon.com website have been reviewed and certified by ESRB Privacy Online to meet established online information collection and use practices. As part of this privacy program, we are subject to frequent audits of our pokemon.com website and other enforcement and accountability mechanisms administered independently by the ESRB.

Pokémon is a self-certified member of the U.S. Department of Commerce's EU Safe Harbor privacy program jointly established to comply with the European Commission's 1998 Directive on Data Protection and The U.S. Department of Commerce’s Swiss Safe Harbor privacy program jointly established to comply with the Swiss Federal Act on Data Protection. For more information about this privacy initiative, visit the Department of Commerce's website at http://www.export.gov/safeHarbor/.

Table of Contents

  1. What information does this Privacy Policy cover?
  2. What types of personally identifiable information do we collect about our guests?
  3. How is your personally identifiable information used and shared?
  4. How long does Pokémon keep your personally identifiable information?
  5. What choices do you have about the collection, use, and sharing of your personally identifiable information?
  6. What kinds of security measures do we take to safeguard your personally identifiable information?
  7. How can you update your personal information and profile?
  8. How can you ask questions, or send us comments, about this Privacy Policy?
  9. How will you know if we amend this Privacy Policy?



1\. What information does this Privacy Policy cover?

This Privacy Policy applies only to personal information collected on the Sites where this Privacy Policy is posted, and, unless Pokémon specifies otherwise in writing, does not apply to any other information collected by Pokémon through any other means.

Please note that this Privacy Policy applies only to information submitted and collected online, and does not apply to information that may be collected by Pokémon offline. This Privacy Policy applies only to Sites maintained by Pokémon, and not to our international affiliates, or any website maintained by other companies or organizations to which we link. Pokémon is therefore not responsible for the content or activities provided on those website websites.

This Privacy Policy applies to use and sharing of personal information collected as of the date this Privacy Policy is posted. Finally, the terms of this Privacy Policy are subject to all applicable laws.

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2\. What types of personally identifiable information do we collect about our guests?

We don't require personal information to access our Sites. However, if you prefer not to disclose personal information, you will not be able to enjoy certain features of our Sites. Personal information is information that identifies you and may be used to contact you.

Information You Provide to Us

We receive information from our guests and, with our guests' consent, from third parties such as Pokémon Organized Play ("POP") tournament organizers. We collect personal information directly from our guests when they:

  1. create an account for Pokémon's Sites

  2. link an account from one of Pokémon’s Sites with an account from another site operated by Pokémon or an affiliate of Pokémon

  3. participate in games, reward programs, contests, sweepstakes, events, or promotions

  4. send questions, correspond with us via e-mail concerning their participation in POP or request customer support

  5. participate in polls, surveys, or questionnaires

  6. use our Email-a-Friend feature

  7. provide us with business information, such as when they apply for or have a special role in POP (such as Pokémon professors or league or tournament organizers) or seek employment




Typically, this information includes:

  1. personal first and last name

  2. email address

  3. telephone number

  4. address and location based information (where necessary for the provision of services)




Additionally, we may also collect other types of non-personal information (known as demographic information) such as your age, gender, the country where you live, dates of birth, hobbies, and toy and game ownership preferences. This demographic information may be associated with your personal information.

Business Information (Including Pokémon Professor, League or Tournament Organizer Applications)

When you apply to be or serve as a POP organizer, you agree that we may use any personal information submitted to or collected by us may be used for any lawful business purpose. We may share this personal information with independent third parties who run POP events so that they can contact the POP organizers about participating in those events and other POP matters. These independent third parties may not have agreed to abide by the terms of this Privacy Policy. You should ask about such third parties’ privacy policies.

Any personal information submitted to us on-line by job applicants, and by persons specifying that they are submitting personal information in a business capacity, will be used solely for its intended purpose.

Information Collected Through Technology

We collect information through technology to make our Sites more interesting and useful to you. For example, when you come to one of our Sites, we collect your IP address. An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet Service Provider), your company, or your university. At times, we also use IP addresses to collect information regarding the frequency with which our guests visit various parts of our Sites. We may combine this information with personally identifiable information.

Location Based Information

We may collect and store your device’s source IP address which may disclose the location of your device at the time you access the Sites. Advertisements and certain content could be directed to you as a result of this data. In addition, in some cases the Sites can deliver content based on your current location if you choose to enable that feature. If you enable that feature, your current location will be stored locally on your device which will be used by the Sites to serve you certain content tied to your location. If you elect to have your location-based searches saved to your history, we will store such information on our servers (collectively, all location based information collected by Pokémon is “Location Information”). You always may disable these features or withdraw your consent to providing your Location Information. However, if you prefer not to disclose Location Information, you will not be able to enjoy certain features of our Sites.

Cookies

Our Sites also use cookies. Cookies are pieces of information that a Site sends to your computer while you are viewing the Site. We and other companies use cookies for a variety of purposes. For example, when you return to one of our Sites after logging in, cookies provide information to the Site so that the Site will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser (like Mozilla Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your experience smoother, like the features mentioned above, and some of our services may not function properly.

Web Beacons and Log Files

Our Sites use a variety of technical methods for tracking purposes, including Web beacons. Web beacons are small pieces of data that are embedded in images on the pages of various sites. We also use these technical methods to analyze the traffic patterns on our Sites, such as the frequency with which our users visit various parts of our Sites. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. Our Sites use log files to record which pages visitors to our site accessed, how long they stayed on the site, where they came from and other data. We also use these technical methods in HTML e-mails that we send our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is personally identifiable.

Finally, once you've clicked on an advertisement or other link and have left our Sites, our Privacy Policy no longer applies and you must read the privacy policy of the host of that site to see how your personal information will be handled on their site.

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3\. How is your personally identifiable information used and shared?

We don't share, sell, or rent your personal information to third parties without your prior consent. We don't require personal information to access our Sites. However, if you prefer not to disclose personal information, you will not be able to enjoy certain features of our Sites.

Whatever the purpose may be, we will only collect information to the extent reasonably necessary to fulfill your requests and our legitimate business objectives.

Pokémon Online Tools and Events

For example, if you register on our Sites, your information will be used to provide you the benefits associated with registration, including the ability to create a Trainer Image and to earn Trainer Tokens. In addition, if you participate in a game, contest, sweepstakes, or other similar event ("promotion"), the information provided in connection with the promotion will be used to determine your entry eligibility, to contact you with the results, and for prize fulfillment purposes.

POP Participants

If you chose to participate in the POP tournament ratings and rankings portion of our site, www.pokemon.com, then we will use your personal information about you to track your tournament results, Player Ranking, rating, player status (e.g., active, terminated, winner etc.). If you are 13 and older, we will post your full name or first name and last initial (as you direct us) and your state and country on the appropriate Site(s) with your Player Ranking. If you are under 13, then your parent or guardian can choose to post your username, full name, or first name and last initial in the Player Rankings.

Also if you chose to participate in the POP tournament ratings and rankings portion of our site, www.pokemon.com, we will share your personal information with independent third parties who run POP events (such as league leaders and tournament organizers) so that they can run POP events that you may participate in. In most cases, these are independent third parties and not Pokémon employees. They've agreed to abide by the terms of this Privacy Policy, but Pokémon cannot guarantee that these independent third parties will safeguard your personal information. If you don't want your personal information shared with independent third parties who run offline POP events, then don't apply to participate in the POP tournament ratings and rankings portion of our site.

Message Boards

If you register for access to our message boards or chat rooms, we will use your personal information to enable you to view and post messages on the boards. However, you should understand that community forums and message boards are tools that allow you to communicate with members of the online community. That's why whenever you give out personal information online in public areas, that information can be collected and used by people you don't know.

Operational Uses

We may also use your personal information for other purposes such as "Operational Uses." For example, we may use your information to send you administrative communications either about your account with us or about features of our Sites, including any future changes to this Privacy Policy. If you have selected to receive online marketing communications from our site, your personal information may be used to send you marketing material about our products and services.

Outside Vendors

Pokémon may share your personal information with outside entities hired to assist with internal Site support operations (e.g., online product fulfillment, email services, or technical support). We also provide postal addresses to delivery service companies for delivery purposes. In the course of providing such services, these companies may have access to your personally identifying information. These entities have agreed to maintain the confidentiality, security, and integrity of all the personal information they obtain from us.

Transfer of Personal Information from Application to Pokémon

To the extent that you have installed a Pokémon application on your device, except as disclosed below, the personal information collected by the application remains on the application and is not provided to Pokémon. Pokémon will have access to your personal information or your personal information will be transferred to Pokémon’s servers in any of the following circumstances:

  * Pokémon may also access certain data from the application, including without limitation the user supplied information and device information, for statistical analysis. All such data has been anonymized prior to Pokémon’s collection and storage.



Use of Your Location Information

We may only use and share your Location Information in conjunction with our right described in “Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Sites and Others” below and to:

  * Customize the default country and default language to show you the products and services in your chosen language and country.

  * Provide you with the products and services you request.

  * Personalize content and experiences on our Sites, including providing you recommendations based on your preferences.

  * Personalize your newsletters, offers and promotions for our products and services, third party products and services, or special events.

  * Personalize the advertising you receive, including advertising based on your activity on our Sites or activity on third party sites and applications.

  * Optimize or improve our products, services and operations.

  * Detect, investigate, and prevent activities that may violate our policies or be illegal.

  * Perform statistical, demographic, and marketing analyses of users of the Sites and their purchasing patterns.




Aggregate Information

Finally, we may take your personally identifiable information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, no restrictions apply under this Privacy Policy on our right to aggregate or de-personalize your personal information, and we may use and share in any way with third parties the resulting non-personally identifiable information.

Purchase or Sale of Businesses

In the event of a merger, sale of assets, acquisition, dissolution, reorganization, bankruptcy, change of control or other similar event, your personally identifiable information may be transferred to our successor or assign, if permitted by and done in accordance with applicable law, or if we sell one or more of our businesses, your personally identifiable information may be transferred as a part of the sale. If we purchase a business, the personally identifiable information received with that business would be treated in accordance with this Privacy Policy, if it is practicable and permissible to do so.

Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Sites and Others

We will disclose personal information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our Terms of Use; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Sites or third parties.

4\. How Long Does Company Keep Your Personally Identifiable Information?

Pokémon will keep your personal information so long as you have an account with Pokémon, provided, however, that Pokémon will use commercially reasonable efforts to delete any personal information collected by Pokémon that is no longer relevant to your use of the Sites or the Services offered by Pokémon. To the extent that you have installed a Pokémon application on your device, Pokémon will keep your personal information within such application for so long as you keep the application on your device.

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5\. What choices do you have about the collection, use, and sharing of your personally identifiable information?

As mentioned above, you have control over the personal information you submit to us. If at any time you decide to remove your personal information from our database, you may do so by doing the following:

  * To remove your name from the Sites, log into the www.pokemon.com site and follow the instructions to unregister or contact us at The Pokémon Company International, Inc., Attention: Privacy Policy Administrator, 333 108th Avenue, NE, Suite 1900, Bellevue, WA 98004, Fax: +1 (425) 274-1041.




If you contact us, please include the name of the Sites you used to register and the email address you used to register with us so we can verify your request.

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6\. What kinds of security measures do we take to safeguard your personally identifiable information?

The security and confidentiality of your personal information is extremely important to us. We have implemented technical, administrative, and physical security measures to protect your personal information from unauthorized access and improper use. To prevent unauthorized electronic access to personal information, we limit access to only those employees performing a legitimate business function; maintain information collected online behind a firewall-protected server; verify your identity by asking you for an email address or by other means; store your personal information on servers separate from other corporate information and systems; and notify you by email if we learn that a breach has occurred. We also collect personal information from you only on SSL-protected (encrypted) web pages and it is transmitted over the Internet only through an SSL-protected (encrypted) channel. From time to time, we review our security procedures to consider appropriate new technology and methods. However, please understand that, despite our best efforts, no security measure is perfect or impenetrable.

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7\. How can you update your personal information and profile?

You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), as follows:

  * Please visit the "Edit Profile" section on the www.pokemon.com site (where you can modify your contact information and preferences after logging in) or contact us at The Pokémon Company International, Inc., Attention: Privacy Policy Administrator, 333 108th Avenue, NE, Suite 1900, Bellevue, WA 98004, Fax: +1 (425) 274-1041.



If you contact us, please include the name of the Sites you used to register and the email address you used to register with us so we can verify your request.

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8\. How can you ask questions, or send us comments, about this Privacy Policy?

If you have questions or wish to send us comments about a Privacy Policy posted on one of our Sites, you can contact us as follows:

Sites | Contact Information  
---|---  
www.pokemon.com | The Pokémon Company International  
Attn.: Privacy Policy Administrator   
333 108th Avenue, NE   
Suite 1900   
Bellevue, WA 98004   
fax your inquiry to +1(425)274-1041.  
  
Pokémon is a licensee of the ESRB's Privacy Online Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at http://www.esrb.org/privacy_wc_hotline.asp. Please note that the ESRB is not affiliated with Pokémon and cannot help you with non-privacy-related issues.

ESRB   
Attn.: Privacy Online Program   
317 Madison Avenue, 22nd Floor   
New York, NY 10017   
privacy@esrb.org

Your California Privacy Rights   
Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please send us an e-mail or write us at the address above.

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9\. How will you know if we amend this Privacy Policy?

We may amend this Privacy Policy at any time. If we make any material changes in the way we collect, use, or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the Sites covered by this Privacy Policy. Any material changes to this Privacy Policy will be effective 30 days following our dispatch of an email notice to you or 30 days following our posting of notice of the changes on the Sites covered by this Privacy Policy.

Please note that, at all times, you are responsible for updating your personal information to provide us your current email address. If the last email address that you have provided us is not valid, or for any other reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice.

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* * *

Supplemental Kids Privacy Policy

Last updated February 12, 2013

OUR ADDITIONAL PRIVACY COMMITMENT TO KIDS AND THEIR PARENTS

Pokémon has developed its Sites with the goal of creating an enjoyable experience for all users. This Kids Privacy Policy is designed to answer your questions regarding our privacy policies and principles with respect to children under the age of 13.

Building on our general Privacy Policy, we recognize the need to provide additional privacy protections when children visit the Sites on which this Kids' Privacy Policy is posted. We explain those additional protections in this Kids' Privacy Policy.

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age; and that we obtain the consent of parents and guardians in order for children under 13 years of age to use certain features of our Sites. Below we explain how we do that for these "kids." Also, when we use the term "parent" below, we mean to include legal guardians.

TABLE OF CONTENTS

  1. What types of information do we collect about kids?
  2. How do we use and share the personally identifiable information that we collect from kids?
  3. How do we notify and obtain consent from parents for the collection of personal information from their kids?
  4. How can parents access, change or delete personally identifiable information about their kids?
  5. How will we notify parents if our Kids' Privacy Policy changes?



1\. What types of information do we collect about kids?

Kids can surf Pokémon's Sites, view content, and enjoy many features without any personal information being collected. We don't collect personal information from kids while they use our Sites unless they register on Pokémon's Sites.

We receive information from our guests and, with our guests' consent, from third parties such as Pokémon Organized Play ("POP") tournament organizers. We collect personal information directly from kids to:

  1. create an account for Pokémon's Sites

  2. link an account from one of Pokémon’s Sites with an account from another website operated by Pokémon or an affiliate of Pokémon

  3. participate in games, reward programs, contests, sweepstakes, events, or promotions

  4. send questions, correspond with us via e-mail concerning their participation in POP or request customer support

  5. participate in polls, surveys, or questionnaires

  6. use our Email-a-Friend feature




Typically, this information includes:

  1. personal first and last name

  2. email address

  3. telephone number

  4. address and location based information (where necessary for the provision of services)




We may collect demographic information (date of birth, gender, and preferences) and combine it with the child's personal information. Pokémon will only collect this information if this information is provided by the parent or with the parent’s consent.

Note that all commercial sites directed to children under 13 are prohibited by U.S. law from conditioning a kid's participation in an online activity on the kid's providing more personal information than is reasonably necessary. As a result, Pokemon will not collect more personal information than is reasonably necessary.

Finally, we may collect demographic information about a kid. For example, if a kid participates in a survey, we may collect those responses. Among them, we may collect age, gender, hobbies, interests or other demographic information about gaming and preferences, and the country where a kid lives. We also use some passive technologies, including cookies and web beacons, to monitor traffic on our Sites. This demographic information may be associated with a kid’s personal information that Pokemon has collected in accordance with law.

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2\. How do we use and share the personally identifiable information that we collect from kids?

We may collect personal information from parents to allow kids to participate in certain activities offered on our Sites and within our kids' subscription products. These activities may include participating in games, reward programs, contests, sweepstakes, events or other promotions.

We may use your child's information provided by the parent or with the parent’s consent to allow your child to send questions or request customer support. We may also use that information to participate in polls, surveys or questionnaires. We may also use that information to send your child email and messages with promotional information about new products and features, special offers, contests and sweepstakes and other interesting events concerning new products, events and other information about Pokémon. You may always opt-out of having your child receive these promotional messages.

We may also use your child’s information provided by the parent or with the parent’s consent to allow use of other website features including sending e-mail message to "tell-a-friend" and may in the future permit “canned chat” where a kid is able to select words from a list prepared by Pokémon to send messages to other site users. If a parent allows us to collect personal information about their kid, we may link certain information collected through technology (see the "Information Collected Through Technology" section of A2 of our General Privacy Policy) to that personal information.

Until we receive verifiable parental consent, the contact information gathered from a kid is used only to obtain consent to our information collection practices from their parents.

Finally, so long as we have received parental consent, we may use a kid’s personal and demographic information for our other business purposes, such as record keeping, transaction fulfillment, and to study ways to better improve our services.

If a child wins a sweepstakes, contest or other promotional event, we notify the parent at the email address provided to us during the registration process, and request that the parent provide his or her postal address for purposes of delivering the prize. So long as we have obtained the appropriate consent, we may publish a winner's first name, city, and state of residence on our Sites.

Also if you chose to allow your child to participate in the POP tournament ratings and rankings portion of our site, www.pokemon.com, then we will use personal information about your child to track your child's tournament results, Player Ranking, rating, player status (e.g., active, terminated, winner etc.). As parent or guardian, you can choose to post your child's username, full name, or first name and last initial, in the Player Rankings.

Also if you chose to allow your child to participate in the POP tournament ratings and rankings portion of our site, www.pokemon.com, we will share your personal information with independent third parties who run POP events (such as league leaders and tournament organizers) so that they can run POP events that your child may participate in. In most cases, these are independent third parties and not Pokémon employees. They've agreed to abide by the terms of this Privacy Policy, but Pokémon cannot guarantee that these independent third parties will safeguard your child’s personal information. If you don't want your child’s personal information shared with independent third parties who run offline POP events, then don't allow your child to participate in the POP tournament ratings and rankings portion of our Sites.

With parental consent, Pokémon may share kids' personal information as necessary with outside entities hired to assist with internal website and support operations (e.g., online product fulfillment, email services, or technical support). These entities have agreed to maintain confidentiality, security, and integrity of all the personal information they obtain from us and will abide by this privacy policy. We do not share any information about a child with any third parties unless the disclosure is reasonably necessary to:

  * comply with law, including, for example, to comply with a court order or subpoena;

  * enforce our Terms of Service, or Sites or game/promotion rules;

  * in connection with the purchase or sale of assets, a merger, reorganization, bankruptcy or similar corporate transaction; or

  * protect the safety and security of our Guests and our Sites.




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3\. How do we notify and obtain consent from parents for the collection of personal information from their kids?

When a child under the age of 13 attempts to register with our Sites, we send their parent an e-mail notifying them that their child would like to register, and asking them to visit our Sites to grant consent for their child to register. If the parent ignores or refuses to register their child, we will delete all contact information from our database within 14 days of such notice. If the parent permits the registration, their child will be granted access to the features described in the notification e-mail.

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4\. How can parents access, change or delete personally identifiable information about their kids?

At any time, a parent can contact our customer service department to access, change or delete the personal information that we have collected from his or her kid as follows:

  * To access, change or delete the personal information about your child on the Sites, log into the www.pokemon.com site and follow the instructions to unregister or contact us at The Pokémon Company International, Attention: Privacy Policy Administrator, 333 108th Avenue, NE, Suite 1900, Bellevue, WA 98004, Fax: +1 (425) 274-1041.



Please include the kid-member's name and the parent's e-mail address in the e-mail so that we can better assist you with your inquiry or request.

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5\. How will we notify parents if our Kids' Privacy Policy changes?

We may amend our Kids' Privacy Policy at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, or share kids' personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Kids' Privacy Policy only in conformance with applicable law, including any parental consent requirements.

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