Clever Image PRIVACY POLICY

Clever Image is committed to providing quality online activities and information to parents of preschoolers. While we encourage the interactive nature of online media, we strive to promote the online safety and privacy of our users.


INFORMATION-COLLECTION POLICIES

Clever Image's target audience is parents of preschoolers (excluding the Games area, which is intended for preschoolers and their parents and which is governed by special information-collection policies--please see below for more on the Games area). Clever Image's design, content, and language, as well as our activities, target a parent audience. We do request personally identifiable information from parents who choose to participate in certain activities available on Clever Image.com, as described below. If we were to discover that a child submitted personally identifiable information, Clever Image would delete the information immediately.


CLUB MEMBERSHIP

Clever Image provides Club Membership for our parent audience. In order to participate in our Club Member activities, we ask users to submit personal information (e.g. full name, e-mail address, zip code, birthday.) All such personal information is collected for the purpose of providing our users access to Clever Image's Club Members activities. Once registered, users can participate in Club Member activities such as newsletters, message boards, Clever Image advisory board (where members will be contacted by Clever Image for feedback and opinions on various subjects), Club Member sweepstakes (refers to those sweepstakes that are open only to Club Members; for sweepstakes that are open to all grown-up users, please see "General Activities: Online Sweepstakes" section below) and "Third Party" offers (the opportunity for Club Members to receive information concerning special offers and promotions sent by either Clever Image on behalf of or in partnership with other third party businesses selected by Clever Image or directly by such third parties.) At any time after the registration process, Club Members can choose to discontinue participating in some of the Club Member activities (e.g. newsletters, Clever Image advisory board, "Third Party" offers) or altogether unregister by electing to unsubscribe to such activity, which option can be found at the end of every Clever Image correspondence sent to users.


USE OF CLUB MEMBERS INFORMATION

All information collected during the registration process is used for the purpose of providing our users access to Clever Image's Club Members activities. For instance, if the Club Member selected to receive newsletters, special announcements, offers and promotions from Clever Image, we use the information provided by such Club Member to send them the requested information which we may send by e-mail and occasionally, by postal mail, for those who have provided us with mailing addresses. The information provided by Club Members may also be shared with third parties as more fully described below in "Use of Information" and in the following manner. In connection with Club Members who have selected to opt into "Third Party" offers, Clever Image may sometimes share and transfer the personal information collected from our Club Members with and to third party business partners selected by Clever Image to promote, sponsor and/or fulfill our "Third Party" offers who will use such information to directly contact and send Club Members special offers and promotions provided by the third party business partner. Other times, we on behalf of the third party business partner may send Club Members third party special offers and promotions, but only if the Club Member has selected to opt into "Third Party" offers.


GENERAL ACTIVITIES


Online Contests and Sweepstakes

Clever Image may offer parents the opportunity to enter contests and sweepstakes. Clever Image may ask for information such as parent's first name, parent's e-mail address, parent's birth date, child's first name and birth date and in some instances, Clever Image may collect telephone numbers for certain types of contests. Clever Image uses this information for purpose of conducting the contests and sweepstakes and does not (except as set forth herein) disclose such information externally to third parties, except with a fulfillment house which Clever Image uses to help select winners and fulfill prizes and, in some cases, with third-party sponsors. From time to time, Clever Image may offer contests and sweepstakes sponsored by third party businesses and may share with such third party businesses entrant information collected by Clever Image. In these types of contests and sweepstakes, Clever Image will disclose to potential entrants that such information will be so supplied and the identity of the third party to whom such information will be supplied at the time entrant information is collected and will provide potential entrants with the opportunity to opt out of such third party sponsored contests and sweepstakes. However, any information supplied to a third party may be retained by such third party and will be out of the control of Clever Image. Entrants of Clever Image contests and sweepstakes have the opportunity to opt-in (by indicating so on the entry form) to become subscribers of the Clever Image newsletter and to receive other e-mail special announcements and promotions. Please see "Electronic Newsletter and Special Announcements Subscription" below. The personal information collected from those entrants who have chosen to opt-in to the Electronic Newsletter and Special Announcements Subscription shall be maintained by Clever Image. For those who elect not to opt-in, and/or entrants who have not been selected as winners, Clever Image will delete personal information collected on the online entry forms from its system, however, personal information collected online from contests and sweepstakes winners may be maintained by Clever Image and may be shared with third parties for fulfillment purposes, as described above, as well as internally. Entrant's decision not to opt-in will not affect eligibility for contests and sweepstakes and will not impact your chances of winning.


Electronic Newsletter and Special Announcements Subscription

Clever Image may provide parents the opportunity to receive e-mails containing the Clever Image Newsletter, along with other Special Announcements pertaining to Clever Image. These e-mails will provide subscribers with information updates, announcements, and promotions. We request no personally identifiable information from the parent except his/her e-mail address, which we use solely for the purpose of sending the e-mails. The e-mail address provided to Clever Image may be transferred, disclosed, or shared with third parties who may be engaged by us specifically to handle the preparation and delivery of the e-mails and perform other related technical and processing functions. At anytime after the signup process, parents can choose to discontinue their subscriptions to Clever Image's Newsletter and Special Announcements altogether by electing to unsubscribe, through the unsubscribe option found at the end of each Clever Image e-mail sent to users.


E-mail

Clever Image provides parents the opportunity to send e-mail to us. We request no personally identifiable information from the parent except his/her first name and e-mail address, which we use solely for the purpose of responding to questions. The grown-up's first name and e-mail address are deleted from our system periodically


Electronic Postcards & Games

Clever Image gives parents the opportunity to send "electronic postcards" to friends and family. We ask the user to submit the first name and e-mail addresses of their friends and family. Clever Image uses this information only for the purpose of sending the postcards. The friend's e-mail address is deleted immediately from our system.


Ordering from the Site and Opening An Account

When customers make purchases on Clever Image (e.g. games), we require them to provide us with their full name, billing and/or shipping addresses, e-mail address, and credit card number/expiration date. We also provide our customers the opportunity to send to family and friends gifts items purchased by the customer and will send, on behalf of customers who request it, e-mails to family or friends notifying them that someone has sent them a gift. To do this, we ask customers to provide us with their family or friend's first name and e-mail address. We use this information only to send the gift recipient the item(s) the customer has requested their family or friend receive. During the checkout process, we also provide customers the opportunity to receive newsletters, sales and promotions from Clever Image. To be removed from the contact list at any time, customers can elect to unsubscribe in the next e-mail they receive from Clever Image. If customers do not complete the order process (e.g., fail to enter a valid credit card number/expiration date or fail to complete a purchase transaction) the information customers submitted during the order process will not be captured by our systems. Once customers have successfully entered a valid credit card number/expiration date and completed the order process, an account will be created and maintained for customers. We use this information to process the customer's order and to send order confirmations via e-mail but we do not sell, transfer or share the information with third parties except, the information may be transferred, disclosed and shared with our third party agent who uses the information solely to handle and manage fulfillment and customer service, but can not use it for other purposes and has agreed to maintain the confidentiality of such information.


Customer Service

In addition to being able to call us, our customers may also e-mail us their questions. Other than an e-mail address, we do not request that users submit any personal information online for customer-service inquiries. We may however ask for additional non-personal information to better help us respond to customer service questions. We use the e-mail address to communicate directly with customers about technology-related questions, and provide them with answers that they may find helpful. We do not sell, transfer or share the e-mail address with third parties, with the exception that the information is transferred, disclosed and shared with our third party agent who uses the information solely to handle and manage customer service, but cannot use it for other purposes and has agreed to maintain the confidentiality of such information. Once we or our third party agent have had a chance to provide e-mail responses to customer service e-mail questions, the e-mail address is deleted from our system.


Clever Image’S GAMES AREA

Clever Image’s Games area is an area of our site where parents can enjoy quality online entertainment with their preschool-aged children. This area includes Games, Stories, Music, Art, Shows and other activities, the design, content and language of which are targeted to preschoolers. The Games area is fully compliant with the Children's Online Privacy Protection Act of 1998.

It is our policy in the Games area to require only the minimal collection of information from our visitors. Consistent with this policy, the Games area of Clever Image limits the collection of information from kids to what is known as non-personally identifiable information (e.g. first name). Other than the collection of such non-personally identifiable information, we do not collect personal information from our users in the Games area. As such, we do not share any personal information about our users in the Games area with any third parties. In addition, we do not condition a kid's participation in any games or other online activities contained in the Games area on the disclosure of more information than is reasonably necessary to participate in the activity. Lastly, we provide a "bumper page" at certain points in the Games area of our site to let users know when they are entering an area that is limited to parents and we also provide a "bumper page" when linking from the Games area to an advertiser's site or other websites, which may have their own information practices that are different from ours, in order to let users know they are going to an advertiser's site or other Web sites.


USE OF INFORMATION

At Clever Image, we may share non-individual, aggregate information (e.g. non-personally identifiable information) about our users internally within and externally with third parties, such as advertisers and business partners. We also use personal information collected on our site internally within, however, it is our policy to not disclose externally with third parties personal information collected on our site, except in the following instances:

Third Party Businesses
From time to time, we may partner with outside third parties to provide you with additional content, products, or services that we believe may be of interest. For example, we may partner with a greeting card company, software manufacturer, or telephone provider to offer you electronic cards, games, or telephone messaging. These partners operate Web sites that are separate and independent from Clever Image. We receive e-mail addresses from these sites of adults who request to receive information--including newsletters, sales, and special offers--from us. If you do not wish to receive such information, you can respond, at any time, to e-mail correspondence you receive from us by placing "REMOVE" in the subject line. You can also send an e-mail to Onlineprivacy@Clever Image.com or call us at 201-941-9652 and inform us that you no longer wish to receive correspondence from Clever Image and its affiliates.

Agents
The personal information provided to Clever Image may be transferred, disclosed or shared with third parties who may be engaged by us specifically to handle and deliver certain activities ( e.g., message boards, sweepstakes, e-cards, newsletters, advisory board) and perform other technical and processing functions, such as sending postal mail and e-mail, removing repetitive information from registration lists, programming, providing user services to our users, or otherwise operating our site. They have access to personal information needed to perform their functions, but may not use it for other purposes and have agreed to maintain the confidentiality of such information.

Business Transfers
In the event that all or substantially all of the assets relating to Clever Image are transferred or sold to another entity, personally identifiable information may be transferred to the acquiring entity.

Online Contests and Sweepstakes
In addition to the fulfillment houses to whom Clever Image may supply personal information collected from contests and sweepstakes entrants for the purpose of helping Clever Image select winners and fulfill prizes, Clever Image may supply third-party sponsors with personal information collected from contests and sweepstakes entrants in connection with certain online contests and sweepstakes. In each such case, Clever Image will disclose to potential entrants that such information will be supplied to a third party, and the identity of such third party, at the time entrant information is collected. Please see "General Activities: Online Contests and Sweepstakes" above.

Special Cases
We may also disclose personally identifiable information to third parties in order to comply with law or requests by law enforcement agencies, to enforce our Terms of Use or to protect the rights, property, or safety of our website, users of our website, and others.
Other than as set forth above, we do not at present intend to use your personal information for other purposes. However, in the future if we use your personal information in a manner different from that stated at the time of collection, we will provide notice to you and you will have a choice as to whether or not we use your information in such different manner.


COOKIES AND LOG DATA

Cookies are information files that your web browser places on the hard drive of your computer when you visit a website. Cookies cannot damage user files, nor can they read information from a user's hard drive. Cookies allow websites to "remember" users activities on a website as well as users visits to a site. At Clever Image, cookies are used to determine the number of unique visitors to our website over a given period. We do not store any personal information into cookies nor do we link or combine information collected through cookies to any personal information submitted by users when participating in our activities. Log data collected on web servers both within Clever Image's control and under the control of Clever Image's third party ad service provider, who is required to maintain such data on a confidential basis, supplies Clever Image with aggregate information about the number of visits to different pages on our site. Clever Image uses such aggregate information to improve access to our content based on our visitors' browsers and operating system types to make our content available to as many users as possible. We do not link the "log data" collected to personally identifiable information submitted by users when participating in our activities.

The ads appearing on Clever Image are delivered to you by us and/or a third party ad service provider. In the course of serving ads, the ad service provider may place or recognize their own unique cookie on your browser, and may use non-personally identifiable information about your visit to Clever Image, such as the number of times that you have viewed an ad.


SECURITY

Clever Image has taken steps to ensure that personally identifiable information collected is secure, including limiting the number of people who have physical access to our database servers as well as electronic security systems and password protections which guard against unauthorized access.

QUESTIONS/CONCERNS?

If you have any questions regarding Clever Image's privacy policy, please contact us at:

Renata Redondo
Clever Image Privacy Coordinator.
311 Fairview Avenue
Fairview, New Jersey 07022
(201) 941-9652
Onlineprivacy@Clever Image.com


Clever Image.com is intended for both domestic and international visitors, however, it is specifically directed towards residents of the United States and Brazil.

This policy, like the online medium itself, is subject to changes.