Privacy Policy

Effective Date: October 1, 2019
Welcome to cubbynews.com which is owned and operated by TMW LLC. We are committed to providing services to you and your children where you can feel confident that your children’s privacy is protected.
This Privacy Policy describes the ways in which TMW LLC, and its subsidiaries (collectively, we, our, us, or the Company) collect, use, and disclose information about you and the children who use your Account through cubbynewa, and any other websites, applications, and online services (Apps) that link to this policy (collectively, the Services).
Please read this Privacy Policy closely. By using the Services, you agree to the handling of your information in accordance with this Privacy Policy.
  • Child Safe Guarantee:

    The Services are backed by our Child Safe Guarantee. This means that Accounts will never include any pop-up ads or other advertisements directed to children. In addition, Child Users do not have external links included. External links will only be available to the Adult User in their content.
  • Types of Accounts, Services, and Users:

    How we collect, use, and disclose information depends on the type of Account and the type of user. We currently offer the following types of Accounts through the Services: Single Accounts, Family Accounts, and Community Accounts (collectively, Consumer and Other Accounts), which are described in our Terms & Conditions.
    Consumer and Other Accounts are collectively referred to as Accounts, and the provisions of this policy apply to all Accounts. Any difference in how the Consumer and Other Accounts are treated is identified below.
    Users of the Services include Child Users (any child under age 18 who uses the Services) and Adult Users (including parents and legal guardians of Child Users, Gift Account purchasers, and community administrators), collectively referred to as Users.
  • Content You Submit:

    As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Services, including when Adult Users create an Account, sign up for Services, or contact us with a question, comment, or request. However, we will only use or disclose this information in accordance with this policy and applicable law.
    Adult Users are asked to provide certain information about themselves when registering for any Account, including first and last name, email address, and telephone number (which is optional). The other information provided at registration depends on the type of Account or Adult User. For example:
    Payment information is collected from Adult Users who purchase a Single Account or a Family Account, including those who purchase a Gift Account for others. For your security, we do not store your complete credit card number in our databases but retain only the first and last four digits so that we can identify your Account and respond to your requests and questions.
    A parent or legal guardian email address is collected when the Adult User purchasing a Single or Family Account states that he or she is not the legal guardian.
    In addition, Adult Users can provide us with information through separate password-protected sections (i.e., the Parent Section or Teacher Dashboard) of the Services. These sections, accessible via the Menu or Settings link on the Services, allow Adult Users to administer their Accounts, including when they add Child Users, provide testimonials, seek customer support, or submit comments or questions.
    If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.
    We and our third-party service providers collect information directly from Users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from Adult Users, we may collect information about patterns of usage and order history; from Child Users, we may collect information about patterns of usage, which activities a child commences and completes, when a child starts and stops an activity, which areas of the Services the child frequents, the number of questions answered, and the child’s choice of Avatar and customization.
    We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, your geolocation, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
    We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including delivering content, tracking and enhancing our Users’ experience on the Services, and delivering advertising to visitors to our Sites when they visit other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. The information collected through these technical methods on the child-directed portions of the Services are used only to support the internal operations of the Services. We do not allow third-party advertising networks to collect information about Users who are logged in to their Accounts.
    If you do not want the Services to collect information through the use of cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s Help menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you will not be able to remain logged in to your Account, and therefore you would have to log in during each page transition.
    We may collect and store information about your location. The location information we have access to may include (1) your ZIP or postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is located in, as determined from your IP address. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information.
    Additionally, if you downloaded the App on your mobile device to access the Services, as part of your use of the Services we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. We may also ask if you would like to receive SMS text messages. Please note that your carrier may charge you for the text messages you receive.
  • How We Use Information:

    We will never sell or rent the PII of any User of the Services to a third party, except as described in this policy in the context of a sale of the Company.
    We and our third-party service providers may use the information collected from Users as follows:
    Information collected from Adult Users may be used:
    • To permit you to register and use the Services, including, for example, to send you communications about User progress or your Account, or to allow you to provide Feedback through the Parent Section.
    • For certain Consumer and Other Accounts, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
    • To respond to your inquiries and fulfill your requests, reset your password, or provide technical support.
    • For Consumer and Other Accounts to provide marketing communications that we believe may be of interest to you. You can always choose to stop receiving these marketing messages by simply following the instructions contained in the message or, if the communication is by phone, informing the caller of your desire not to receive further phone communications. For all Accounts, you may not opt out of receiving administrative messages from us regarding your Account, such as password reset emails, and customer support messages.
    • To deliver advertising to you based on your visits to the non-child-directed portions of the Services, for example when you visit third-party websites and applications or via postal mail. We will never use information collected in the child-directed portions of the Services for targeted advertising purposes. We do not currently respond to web browser “do not track” signals; however, you may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.org.
    • To measure the effectiveness of our advertising to adults.
    Information collected from Child Users may be used:
    • To measure a Child User’s activities.
    • To provide activity reports of a Child User’s performance to the Adult User on the Account.
    Information collected from both Adult and Child Users may be used:
    • To allow us to assess and improve the Services, its content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ efficacy; and to inform our understanding of the Services’ user base.
    • To customize, adapt, and personalize Users’ viewing and content-consumption experience, for example, by measuring a Child User’s activities and adapting the Child User’s learning path to his or her learning needs.
    • To maintain and analyze the functioning of the Services.
    • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
  • When We Disclose Information to Third Parties:

    Information collected from both Adult and Child Users will not be disclosed except as follows:
    • To third parties who perform certain services for us, such as process credit cards or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy.
    • Where parents or legal guardians have linked a Family Account to Friends Account, the Users of both Accounts will be able to review the Achievement Point Amount within both Accounts.
    • As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
    • Where legally required and in certain other cases, we may make such disclosures without first providing notice to Users.
    • Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law, information may be disclosed to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, transfer, or license all or a portion of our assets in bankruptcy or otherwise. This means that if some or all of our assets are acquired or otherwise transferred or licensed, including in bankruptcy, that such acquirer shall be subject to the same commitments stated under this Privacy Policy.
    In addition, with respect to Consumer and Other Accounts, we may use third-party advertising networks to collect cookie information about Adult Users’ visits to the non-child-directed portions of the Services and to (1) deliver interest-based advertising to those Adult Users, when those Adult Users visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies.
    We do not disclose the personally identifiable information of any Child User to third parties for any marketing or promotional purposes.
    We also may disclose de-identified and/or aggregated User information for any other purpose as permissible by applicable law—for example, the distribution of de-identified user records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns—provided that no individual Adult User or Child User or any specific end-user device can be readily identified.
  • How to Access, Change, or Delete Account Information:

    An Adult User can review or change the information they provided when they registered for the Services, including by adding or removing Child Users to or from the Account, by updating information through the Parent Section of the Services. In addition, Adult Users may contact us at any time to request that we provide for their review, or delete from our records, any PII they have provided about Child Users associated with their Accounts, or to cease collecting PII from those Child Users, as applicable. Please keep in mind that a request to delete PII may lead to cancellation of your Account or the inability to use certain Services.
    When we change or delete any PII at your request, we will make good faith efforts to make the changes in our then-active databases as soon as reasonably practicable, generally within 24–48 hours. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Please note that information may remain in backup or archive records, and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, Account recovery, or if required by law. All retained data will continue to be subject to the Privacy Policy in effect at that time.
  • Account Cancellation and Reactivation; Data Deletion:

    At any time, Adult Users may cancel their Accounts through the Parent Section of the Services.
    For Single User and Family Accounts that have been canceled, if the Account remains inactive for 24 months, we will delete all PII in our active databases associated with the Account (Account Information), unless otherwise stated in this Privacy Policy). The 24 months is provided so that you have the ability, following cancellation of an Account or inactivity, to reactivate your Account and potentially recover previous information and resume where the Child User left off. However, we provide no guarantee, and shall have no liability or obligation to ensure that all Account Information and Services-related progress will be available or accessible or all learning or personalization features will be able to be recovered or resumed. If a User requests that PII be deleted prior to the end of the 24-month period of inactivity, we will take commercially reasonable steps to satisfy that request.
    Upon Account cancellation, de-identified Adult and Child User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law.
    Please note that following a request to delete information or your Account, information including PII may remain in backup or archive records, and we may retain certain data if required by law, relevant to preventing fraud or future abuse, or for legitimate business purposes, such as account recovery and customer support, and all subject to our internal records retention periods. All retained data will continue to be subject to the Privacy Policy in effect at that time and applicable law.
  • Links to Other Services:

    In certain sections of the Services, we may include links to external websites or applications. However, in order to protect children from accessing these external websites, an Adult User will be required to enter a valid password. These websites and applications are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of any external websites and apps, as those parties’ practices would not be subject to this policy.
  • Location of Information Processing:

    The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be processed, under the laws of those countries.
  • Security:

    The security of your personal information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by the Services. We use industry standard SSL (secure socket layer technology) encryption to transfer PII. Other security safeguards include, but are not limited to, data encryption and firewalls.
    Account holders create a password in the registration process. You can help protect against unauthorized access to your Account and PII by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. At registration, we assign a Member ID to each Account and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.
    Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us.
  • Changes to Our Privacy Policy:

    We constantly try to provide the best services, and accordingly our Privacy Policy will change from time to time. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services, either display an alert next to the Privacy Policy, display an alert upon login to the Services, or directly communicate with you (e.g., via the email address associated with your Account).
  • Contact Us:

    TMW LLC is located in the United States of America. TMW LLC is the operator of all of the Services for Consumer and Other Accounts. Questions regarding this Privacy Policy and issues related to your or a Child User’s information for which you are responsible should be directed to us via any of the following methods:

    Mailing address:
    TMW LLC
    Attention: Legal Department
    P.O. Box 22623
    Beachwood, OH 44122
    USA
    Telephone Number: 440.682.0202
    Email address: This email address is being protected from spambots. You need JavaScript enabled to view it.

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