VTech Privacy Policy

LAST UPDATED May 18, 2021

For specific information practices with respect to children, please see Section 7 below.
VTech Electronics North America, L.L.C. ("VTech") appreciates your interest in our company and your visit to our website, web-connected software applications or other online service (collectively, the "Web Services"). If you do not live in the U.S., please visit www.VTech.com to find the appropriate privacy policy for your use. If you are a resident of California, please see Section 9, “California Residents - Your California Privacy Rights,” below. All terms used in the “California residents - your California privacy rights” section have the same meaning as defined in Cal. Civ. Code 1798.140 and the California Attorney General’s regulations under the California Consumer Privacy Act (“CCPA”). By using our Sites and Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use, and sharing your information as described herein.

Remember that your use of the Web Services is also subject to the Terms and Conditions applicable to each service, which incorporate this Privacy Policy.

This Privacy Policy ("Policy") reflects VTech's commitment to protect your and your children's privacy and personal information. In this Policy, VTech may be referred to as "VTech," "we," "us" or "our." Although VTech sells and promotes children's products, VTech collects information primarily from adults (with the exception of information collected from children through Kid Connect/KidiConnect/KidiCom Chat, VTech educational games and other software used by children, and children’s “Wish Lists,” discussed below). Therefore, unless otherwise specified, all references to "you" or "your" in this Policy refer to adult users.

1. Agreement; Modification.

Your use of the Web Services constitutes your acceptance of this Policy. If you do not accept this Policy, please do not visit or use the Web Services. VTech may change this Policy from time to time. Each time you visit or use the Web Services, the current version of this Policy will apply. Accordingly, when you visit or use any of the Web Services, you should check the date of this Policy (which appears at the beginning of this Policy) and review any changes since the last version.

If VTech makes any material changes to this policy regarding the use or disclosure of previously collected information about you, we will notify you by email (if you have registered an account with us) and/or by means of posting a notice on the Web Services prior to the changes becoming effective, and seek your consent to those changes. In addition, if VTech makes any changes to its policy regarding the collection, use, or disclosure of personal information collected from your child, it will notify you and seek your consent.

2. Information VTech Collects.

2.1 Information that You Provide.

To access certain features of the Web Services, you may be asked to provide certain information about yourself and/or your child or children. The types of information that you would need to provide are described below. You may choose not to provide such information when requested, but doing this could limit or completely prevent you from being able to use or access certain features of the Web Services.

· Purchases: When making purchases on our Web Services, you may be required to provide your first and last name, e-mail address, billing address, shipping address, phone number, and credit card information.

· Learning Lodge: If you register for a Learning Lodge Parent Account, during registration we will collect certain information from you, the parent, including your email address, password, country, state, city, and zip code. During your use of Learning Lodge, we may also collect information about your recent firmware upgrades, purchased devices, downloads and purchases. You may also create a Learning Lodge Child Profile for your child. For this Learning Lodge Child Profile, we will ask you for your child’s name.

Certain VTech devices may also allow your child to view applications that are available in our Learning Lodge library and create a “Wish List” of applications they like, which is then sent to you. As discussed in Section 7, below, the creation of a Wish List results in the transmission to VTech of the applications selected by your child for inclusion on the Wish List as well as identifying information about your child’s device and console, country and language information, and date and time.

· Kid Connect/KidiConnect/KidiCom Chat: To sign up for Kid Connect/KidiConnect/KidiCom Chat as a parent of a child, you will first create a Learning Lodge Parent Account and Learning Lodge Child Profile, as described above. Then, through your Learning Lodge Account you can complete the Kid Connect/KidiConnect/KidiCom Chat registration. The Kid Connect/KidiConnect/KidiCom Chat registration will use your Learning Lodge username as your Kid Connect/KidiConnect/KidiCom Chat username. During your first use of the Kid Connect/KidiConnect/KidiCom Chat application (for example, on your smartphone), you will set up your Kid Connect/KidiConnect/KidiCom Chat profile by providing a “nickname” (which is the display name shown to other Kid Connect/KidiConnect/KidiCom Chat users), and a profile photo for Kid Connect/KidiConnect/KidiCom Chat (at your option).

Additionally, under your Learning Lodge Child Profile, you may create a Kid Connect/KidiConnect/KidiCom Chat Child Profile (for example, through the Kid Connect/KidiConnect/KidiCom Chat app on your smartphone). You can enter your child’s information, including the Kid Connect/KidiConnect/KidiCom Chat ”nickname” for your child (which is the display name shown to other Kid Connect/KidiConnect/KidiCom Chat users) as well as provide a Kid Connect/KidiConnect/KidiCom Chat profile photo for your child (at your option).

During your or your child’s use of Kid Connect/KidiConnect/KidiCom Chat, other limited forms of information may be collected by us, including text, chat and voice messages, photos and videos that you or your child send or receive. Information practices regarding information collected from children, and the processes for providing consent to your child’s use of Kid Connect/KidiConnect/KidiCom Chat, are discussed more fully in Section 7, below. .

Other activities: If you engage in other activities on our Web Services and contacting VTech with questions, you may be required to submit certain identifying information to VTech, such as your name and email address. In addition, certain Web Services may ask for or collect additional information about you and/or your children.

Note for Login Information.As described above, to set up or access your user account through any of the Web Services, you will be required to enter your username and your password. This is considered "Login Information," which allows us to identify your account and authenticate you as the user of the account.

2.2 Information Passively Collected.

VTech uses the web technologies described below to passively collect information about your visit to a Web Service. This information may include information about your computer, such as its operating system, internet protocol address ("IP Address"), and web browser. It may also include information about your VTech web-connected device and your browsing data. VTech may also collect information about your or your children's use of certain Web Services, as discussed in Section 2.4 and Section 7, below.

(a) Cookies. Some of the pages on the Web Services use "cookies" to help us better serve you and other visitors to the Web Services. Cookies are brief text files transmitted by websites to the hard drive of visitors' computers when they click on a website page. Should the visitor return to that page at a later time, the visitor's computer will transmit the text file back to the website server to permit the server to recall previous visits to that page or website or to keep track of a transaction in progress. Cookies retain the user preference like number of selected items per page, and payment gateway source to go to payment gateway and encrypted order ID, but are not linked to any personally identifiable information about you or your child that is referred to in Section 2.1.

(b) Action Tags. Some of the pages of the Web Services use "action tags," which are also known as "clear GIF" or "web beacons." An action tag is an invisible tag that may be placed on certain pages of a website but not the visitor's computer. When you access pages with action tags, those action tags generate a generic notice of that visit. Action tags are not linked to any personally identifiable information about your or your children but may be linked to your IP address.

(c) Log Files and Google Analytics. Like many companies with websites, VTech uses log files and Google Analytics to analyze trends, administer the Web Services, track user movement and gather other information. The log files contain information such as your IP Address, browser type used, internet service provider information, referring/exit pages, platform type, date/time, and number of clicks.

Do Not Track Signals: Our systems do not currently recognize or respond to browser “Do Not Track” signals.

Web Site Data Collection: Third-party analytics providers may collect information about an individual consumer’s online activity over time and across different websites when a consumer uses our Web Services.

2.3 When VTech Collects Information.

VTech collects the passively collected information described in section 2.2 while a user is visiting or using the Web Services. VTech may request or require the information described in section 2.1 if you choose to participate in any of the following Web Services features:

· Create, log in to, use, or manage a Web Services account

· Purchase a product or download a software application

· · Upload play or activity data from a VTech web-connected product (Note: additional details about this feature are provided below)

· Register products

· Participate in promotions<

· Contact VTech Customer Support

· Send messages about VTech products or services

2.4 More Information about Play or Activity Data from VTech Web-Connected Products and Learning Lodge.

A parent or guardian must set up an account to access Learning Lodge, and the parent or guardian will be asked to provide certain information about his or her child or children that will be using the VTech web-connected product, such as the child's name. Certain VTech devices may also passively record information from children’s play on VTech’s educational games for parent or guardian reference. To access the Learning Lodge features, the parent or guardian must first be logged in to his or her account.

3. VTech's Use of Your Information.

3.1 General Use of Information.

VTech uses the information collected through the Web Services to: (a) provide products, services, and information that you request; (b) manage user accounts; (c) improve our products and services; (d) enhance and customize the playing experience for users of our web-connected products; (e) provide you with a personalized assessment of your child's learning progress while using our web-connected products; (f) allow VTech to improve the Web Services' content; (g) analyze and monitor consumer activity; (h) promote and support VTech's products; and (i) verify product reviews.

3.2 Information about Other Products and Services.

If you choose to provide the personal information described in section 2.2, we may use it to identify our products or services that we think you may be interested in purchasing, and unless you opted-out of receiving communications about new products and special offers, we will send you information about those other products or services.

3.3 Communications with You.

From time to time, VTech may use your personal information to send email messages to you regarding your account(s), to respond to any emails or other communications you send to us, and/or to advise you of any problems with the Web Services. In addition, if you registered for a Web Services account and you have not opted-out of receiving promotional emails.

4. Disclosure of Your Information.

VTech may disclose your information to its affiliated companies, and to unrelated persons in the following circumstances:

4.1 Third Parties that Provide Services to VTech.

(a) In responding to your inquiries or providing you with the products or services you request, we may employ third-party companies to perform functions on our behalf. These functions may include order fulfillment, package delivery, marketing assistance, postal and email delivery, customer service, data analysis, data storage, billing services and credit processing. The third parties we contract for these purposes have limited access to your personally identifiable information in order to perform these functions on our behalf, and may not use or disclose it for other purposes.

(b) VTech may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is not linked to any personally identifiable information about you or your children, as described in section 2.1, but it may be linked to other passively collected information described in section 2.2.

(c) VTech ensures that any third parties with which it shares your information have adequate policies and procedures in place to protect that information, that they will securely handle, delete or destroy the information when it is no longer needed to serve the third party’s function for us, and that they do not use or disclose the information for any other purpose.

4.2 VTech Affiliates

In order to provide the Web Services, VTech may share, transfer, or store your information with its affiliates located in the United States, the European Union (EU), the United Kingdom and Hong Kong. All companies in question will handle your information with the same care VTech does, will not share your information with other parties or use it for other purposes, and have privacy policies as strict as our own.

4.3 Investigations.

VTech may disclose your information to unrelated persons in the investigation of any actual or suspected: (a) breach of this Policy or our Terms and Conditions, (b) illegal activity, (c) fraud, (d) intellectual property infringement, or (e) threats of violence or other harm.

4.4 Merger and Acquisition Activity.

If we are bought or acquired by another company, in whole or in part; merged with another company; or go through reorganization or bankruptcy, your information may be disclosed to prospective investors, buyers, or other acquirers or successors of VTech in connection with the applicable transaction (and in the case of an acquisition or merger, we may transfer the information collected through the Web Services to the purchaser or merged company as part of the sale).

4.5 Other Cases.

VTech may disclose your information if we in good faith believe we are required to do so: (a) to comply with applicable law or legal proceedings, including court orders, subpoenas, statutes and regulations; (b) to protect, enforce and defend VTech's rights or property; or (c) in an emergency to protect the personal safety of VTech's customers, visitors or the public.

4.6 With Your Permission.

VTech may disclose your information to unrelated persons when you have given us permission to do so.

5. Protection of Your Information.

5.1 Transmission and Storage of Your Information.

The security of your and your child’s personal information is important to VTech, and VTech is committed to handling your personal information carefully. If you submit your information to VTech directly through the Web Services it will be transmitted over a secure HTTPS connection using TLS technology. Further, VTech stores your personal information, described in section 2.1 and section 2.2, in servers with restricted access. Voice messages, photos and videos are encrypted while in storage. The information that VTech collects from you will be transferred to, and stored at, servers in the United States and Hong Kong.

VTech will retain your personal information only for as long as is reasonably necessary to fulfill the purposes for which it was collected unless a longer retention period is required by law. For example, VTech will usually store Learning Lodge and Kid Connect/KidiConnect/KidiCom Chat account and/or profile information only for as long as the parent maintains an active account. VTech does not store one-to-one text messages once the messages have been delivered. In addition, VTech will ordinarily store undelivered Kid Connect/KidiConnect/KidiCom Chat chat and delivered and undelivered voice messages, photos and videos sent through Kid Connect/KidiConnect/KidiCom Chat for only 30 days, to ensure they are delivered to their recipients. VTech also will store only the last three hundred (300) delivered and undelivered messages in a Group Chat for 30 days.

5.2 Login and Authentication.

VTech also protects your information by requiring users of the Web Services to verify their identities with unique login information before they can access or edit their account information or settings. If you select and establish Login Information in connection with your use of the Web Services, or any other interaction with the Web Services, you are responsible for keeping that Login Information confidential. Do not share your Login Information with anyone else.

6. Links to Other Websites.

The Web Services may include access or links to other, third-party websites. If you choose to visit those other sites from the Web Services, VTech is not responsible for the privacy practices or content of those websites. Those third-party websites are beyond VTech's control and may not have privacy policies and security protections, or their privacy policies or security protections may not be as protective of your personal information as VTech's policies and protections. Those other websites may send their own cookies to visitors, collect data or solicit personal information. We recommend that you review and understand the privacy policies of the websites you visit, whether you visit those websites directly or through a link from a page on the Web Services. VTech does not have access to or control over information collected by third-party websites.

7. Information Practices Regarding Children.

VTech is concerned about the safety and privacy of children when they use the Internet. We encourage parents and guardians to spend time with their children online and to be familiar with the sites their children visit. We also urge children to check with their parents or guardians before entering information on any website, or on any VTech Web Services. Our information practices regarding the collection of information from children are in accordance with the U.S. Children's Online Privacy Protection Act ("COPPA") and are outlined below.

7.1 Web Purchases.

Although VTech sells and promotes children's products, all of our products are intended to be purchased by adults. If you are under 18 years old and you want to buy something on the Web Services, you must have an adult buy it for you.

7.2 Operators Collecting Personal Information from Children

VTech Electronics Limited, a Hong Kong company, and VTech Electronics North America, LLC collect personal information from children, as outlined below. For any inquiries about this Privacy Policy or the companies' information practices regarding children, contact VTech Electronics North America, LLC at:

1156 W. Shure Drive Suite 200
Arlington Heights, Illinois 60004
1-800-521-2010
VTechkids@VTechkids.com

7.3 Information VTech Collects from Children.

VTech collects the following information from children as part of the Kid Connect/KidiConnect/KidiCom Chat service: chat and voice messages, photos and videos that the children send to their parents and other users approved by their parents.

Certain VTech services may collect information about the child’s device (for push notifications, such as to notify the child that his or her parent has purchased a new downloadable application from Learning Lodge).

Certain VTech devices may also passively record information from children’s play on VTech’s educational games for parent or guardian reference.

Certain VTech devices may also allow your child to view applications that are available in our Learning Lodge library and create a “Wish List” of applications they like. The creation of a Wish List results in the transmission to VTech of the applications selected by your child for inclusion on the Wish List, as well as identifying information about your child’s device and console, country and language information, and date and time. If your Learning Lodge Parent Account settings are set to receive notification emails when your child makes a “wish,” VTech will send your child’s Wish List to your contact email address.

7.4 Obtaining Verifiable Parental Consent Prior to Use of Kid Connect/KidiConnect/KidiCom Chat.

VTech will only collect, use, or disclose information from your child’s use of Kid Connect/KidiConnect/KidiCom Chat after receiving the verifiable consent of the child’s parent. Parental consent must be provided before a child profile can use Kid Connect/KidiConnect/KidiCom Chat. To provide this consent, you must have first created a Kid Connect/KidiConnect/KidiCom Chat Child Profile for your child, which in turn requires a Learning Lodge Parent Account. The process for creating these parent accounts and child profiles, and the information that will be collected from you, the parent, as part of the account creation process, is described above in Section 2.1.

Once you have created these accounts, through your Learning Lodge Parent Account, you can access the portal for managing COPPA consent. Access to this consent portal may be different for different devices. For example, while parents of KidiBuzz users will access this portal through the Learning Lodge web application on a computer, parents of KidiBuzz users may access this portal through the Parental Controls, Privacy Policy Content tab directly on the KidiBuzz or through the “Privacy Policy” consent link at the bottom of the parent’s “friends” list on the smartphone application. Once in that portal, you can select your child’s name from the list of child profiles associated with your account. Then, you can press the “Set COPPA Consent” (or similar) button. This will bring you to a third-party payment gateway to make a 50-cent payment. In addition, at that time you will see a pop-up screen providing you with direct notice of VTech’s practices concerning information collected from children, as described in this Section. This process helps to ensure that a parent is in fact providing the consent to VTech’s collection of personal information from children, because the small payment will appear on the parent’s next account statement. After the payment is received, and VTech has confirmed that the payment has been successfully processed, you will receive a message on the screen that consent is complete. At this point, your child will be able to use the Kid Connect/KidiConnect/KidiCom Chat service. If VTech later determines the payment was not authorized by the parent, it will revoke the consent from the associated Child Profile, and that profile will not be able to use Kid Connect/KidiConnect/KidiCom Chat.

7.5 Use and Sharing of Information Collected from Children.

The information listed in Section 7.3 is generated by children when they use the Kid Connect/KidiConnect/KidiCom Chat service, which allows children to exchange messages with their parents and with other “friends” approved by their parents, or when they play VTech's educational games. In order to provide the Kid Connect/KidiConnect/KidiCom Chat Software and Services, VTech may share, transfer, or store the information from your child with its affiliates located in the European Union (EU) and Hong Kong. All companies in question will handle your information with the same care VTech does, will not share your information with other parties or use it for other purposes, and have privacy policies as strict as our own. VTech does not otherwise disclose this information to third parties (except when a child shares Kid Connect/KidiConnect/KidiCom Chat voice and chat messages, photos and videos with other Kid Connect/KidiConnect/KidiCom Chat users that have been approved by you) or make it publicly available. VTech also does not enable children to make their personal information publicly available. VTech does not otherwise use the information collected from children for any purpose other than to allow children to share messages on Kid Connect/KidiConnect/KidiCom Chat, and to allow children to create their “Wish Lists”. Except as otherwise described in this Section 7, any information we collect from you about your children is treated and handled in the same manner as the information we collect about you.

Since Kid Connect/KidiConnect/KidiCom Chat allows children to exchange messages, information from your child will be shared with the Kid Connect/KidiConnect/KidiCom Chat “friends” with whom your child communicates. Before an individual can become a Kid Connect/KidiConnect/KidiCom Chat “friend” with whom your child can exchange messages, photos or videos, however, he or she must first be approved by you through your Kid Connect/KidiConnect/KidiCom Chat Parent Account. For example, your child cannot initiate a “friend” request on his or her own; only you can initiate a “friend” request on behalf of your child. Similarly, if you receive a “friend” request initiated by another Kid Connect/KidiConnect/KidiCom Chat user, only you can receive and approve that “friend” request to add that user as your child’s “friend.” Kid Connect/KidiConnect/KidiCom Chat users cannot contact your child until they have been placed on your child’s approved “friends” list.

Once an individual is approved by you, and becomes your child’s Kid Connect/KidiConnect/KidiCom Chat “friend,” he or she will be placed on your child’s “friends” list. Then, when your child exchanges a voice or chat message, a photo or video with that Kid Connect/KidiConnect/KidiCom Chat “friend,” VTech will deliver that message, photo or video to the Kid Connect/KidiConnect/KidiCom Chat “friend,” along with your child’s nickname and profile photo (previously provided by you).

7.6 Your Parental Rights Regarding Children's Personal Information

VTech does not require your child to disclose more information than reasonably necessary to participate in an activity. You have the right to review your child's personal information; direct VTech to delete it; revoke your consent for VTech to collect, use, and disclose information from your child; and refuse to allow any further collection, use, or disclosure of the child's information. Before processing a request to review or delete information collected from your child or to cease collecting, using, or disclosing that information, VTech will verify that you are the parent of the child. For example, to revoke consent, a parent must sign into their Learning Lodge Parent Account.

As noted above, VTech will not share information collected from your child with any third parties, except as is inherent in the Kid Connect/KidiConnect/KidiCom Chat service, such as when your child’s messages are shared with your child’s Kid Connect/KidiConnect/KidiCom Chat “friends” who have been pre-approved by you. However, even after you have approved a “friend,” you retain control over your child’s Kid Connect/KidiConnect/KidiCom Chat “friends” list. If you determine that you would no longer like your child to be able to share information with previously approved Kid Connect/KidiConnect/KidiCom Chat users, you can remove a user from your child’s “friend” list by accessing your child’s “friends” list through your Kid Connect/KidiConnect/KidiCom Chat Parent Account.

Moreover, consent to VTech’s collection, use, and disclosure of your child’s information related to the Kid Connect/KidiConnect/KidiCom Chat service can be revoked through the portal for managing COPPA consent in your Learning Lodge Parent Account. However, revoking your consent will mean that your child will no longer be able to use the Kid Connect/KidiConnect/KidiCom Chat service, since the transmission of messages on Kid Connect/KidiConnect/KidiCom Chat requires VTech’s collection and disclosure of your child’s information to other approved Kid Connect/KidiConnect/KidiCom Chat users.

If you wish to exercise any of these parental rights, you may contact VTech as described in Sections 8 and 9 below.

8. Notices.

If you wish to contact VTech, please (a) email us by using the "Contact Us" web page located in the Support Link on our website; or (b) telephone VTech's Customer Services Department at 800-521-2010 on Monday through Friday. 8:00 AM to 4:30 PM Central Time.

9. California Residents - Your California Privacy Rights.


California Consumer Privacy Act.The California Consumer Privacy Act (the “CCPA”) provides California residents with certain rights regarding their personal information that is collected by businesses, including the right to request that a business disclose what personal information it has collected about them, the right to request the deletion of personal information collected from them, the right to opt-out of the sale of their personal information (if the business sells personal information), and the right not to receive discriminatory treatment for exercising any of their privacy rights under the CCPA. These rights only apply to California residents. Any terms defined in the CCPA (Cal. Civ. Code Section 1798.140) have the same meaning when used in this section.

RIGHT TO KNOW

You may request that we disclose to you the following information covering the preceding 12 months:

(1) The categories of personal information we have collected about you;

(2) The categories of sources from which the personal information was collected;

(3) The business or commercial purpose for collecting or selling personal information;

(4) The categories of third parties with which we share personal information;

(5) The categories of personal information about you that we have sold and the categories of third parties to which the personal information was sold;

(6) The categories of personal information about you that we have disclosed for a business purpose and the categories of third parties to which the personal information was disclosed;

(7) The specific pieces of personal information we have collected about you.

You may request the disclosure of the information listed above by calling our toll-free number at 1-800-521-2010 or submitting a request to ccpa@vtechkids.com. Such a request may be referred to as a right to know request. In the request, please specify whether you are seeking information about categories of personal information and/or specific pieces of personal information. Pursuant to California law, we will verify your identity before complying with any such request. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number. For requests to know specific pieces of information that we have collected, we may also ask for information about a product you purchased, and we may ask you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

You also have the right to be informed, at or before the point of collection, as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. VTech will not collect additional categories of personal information or use personal information collected for additional purposes without providing you with notice consistent with this section.

RIGHT TO DELETE

You have the right to request that we delete any personal information about you that we have collected from you, and that we direct any service provider to delete such personal information from its records. Such a request may be referred to as a request to delete. However, pursuant to the CCPA, your information may not be deleted under certain circumstances, including where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with us, or to otherwise perform a contract between us and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; to comply with a legal obligation; or to otherwise use your information internally in a lawful manner that is compatible with the context in which you provided the information. For more information about these and other situations in which we may not delete your information, please see Cal. Civ. Code Section 1798.105(d).

You may request the deletion of such person information by calling our toll free number at 1 800-521-2010 or submitting a request to ccpa@vtechkids.com. In the request, please specify that you are requesting the deletion of personal information. Before deleting such personal information, we will verify your identity, as required by the CCPA. We will require you to provide personal information in order to verify your identity, such as your name, email address, and telephone number.

AUTHORIZED AGENT

You may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent, you must provide the agent with signed permission. In addition, you may be required to verify your own identity with us and confirm you provided the agent with permission to submit the request. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

SALE OF PERSONAL INFORMATION

California residents have the right to know whether a business sells personal information. If a business sells personal information, California residents have the right to “opt-out” of such sales by directing the business not to sell their personal information. VTech does not sell personal information, and has not sold personal information in the preceding 12 months. We also do not have actual knowledge that we sell the personal information of minors under 16 years of age.

RIGHT TO NON-DISCRIMINATION

California residents have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

NOTICE OF COLLECTION

In the preceding 12 months, we have collected the following categories of personal information about California residents:

· Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers. This category includes information such as real names, IP addresses, online identifiers, email addresses, postal addresses, and account and user names.

· Categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80. This category includes information such as names, telephone numbers, addresses, and credit card information.

· Characteristics of protected classifications under California or federal law. This category includes people’s age group.

· Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category includes products purchased, obtained, or considered.

· Biometric information. This category includes facial images and voice recordings.

· Internet or other electronic network activity information. This category includes analytic cookies, action tags, browsing and search histories, and logs of use of the Web Services.

· Geolocation data. This category includes location cookies and IP addresses.

· Audio, electronic, visual, thermal, olfactory, or similar information. This category includes image and audio files.

· Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. This category includes information about customers’ previous purchases and preferences.

We collect this personal information from the following categories of sources:

· You.

· Your child.

· Other users of the Web Services (such as people on Kid Connect/Kidi Connect/KidiCom Chat who communicate with you or your child).

· Customer service and call center.

· Our affiliates.

· Cookies, active tags, and tracking technology.

We collect this information for the following business or commercial purposes:

· Provide the services.

· Marketing and advertising.

· To communicate with you and provide customer service.

· To improve the services and products.

· To personalize your experience.

· To complete a purchase.

In the preceding 12 months, we have disclosed for a business purpose the following categories of personal information about California residents, and we have disclosed this information to the following third parties.

· Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Information in this category was disclosed to payment processors, marketing agency, customer service and call centers, logistic services providers, data analysis providers, our affiliates, and other users of the Web Services (such as people with whom you or your child communicates on Kid Connect/Kidi Connect/KidiCom Chat).

· Categories of personal information described in subdivision (e) of Cal. Civ. Code Section 1798.80. Information in this category was disclosed to logistic services providers, payment processors, and our affiliates.

· Characteristics of protected classifications under California or federal law. This category includes people’s age group. Information in this category was disclosed to our affiliates.

· Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Information in this category was disclosed to payment processors, logistics services providers, and our affiliates.

· Biometric information. Information in this category was disclosed to our affiliates.

· Internet or other electronic network activity information. Information in this category was disclosed to marketing providers, analytic providers, and our affiliates.

· Geolocation data. Information in this category was disclosed to payment processors, logistics services providers, data analytics providers, and our affiliates.

· Audio, electronic, visual, thermal, olfactory, or similar information. Information in this category was disclosed to our affiliates.

· Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Information in this category was disclosed to our affiliates.

California Shine the Light Law. California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding the disclosure of personal information to third parties for their direct marketing purpose. To make such a request please email us by using the " Contact Us " web page located in the Support Link on our website.

10. Update or Edit Your Information.

If your name, email address, mailing address, or telephone number changes, you should update or correct the relevant information by logging into your Web Services account(s) and editing your information, or by contacting us as described in Section 9.

11. Disputes; Choice of Law and Forum.

If you choose to visit the Web Services, your visit and any dispute over privacy are subject to this Policy and the relevant Terms and Conditions for that service (e.g., the Terms and Conditions for vtechkids.com, Learning Lodge, or Kid Connect/KidiConnect/KidiCom Chat). This Policy shall be governed and construed in accordance with the laws of the State of Illinois, excluding its conflicts of law rules. Any dispute arising out of or relating to this Policy or information VTech receives through the Web Services will be subject to the dispute resolution procedures and provisions set forth in our Terms and Conditions.

If you have any inquiries or complaints regarding this privacy policy you should first contact VTech at:

VTech Electronics North America, L.L.C.
1156 W Shure Drive, Suite 200,
Arlington Heights, IL 60004
ATTN: Privacy Matters
Or via email at vtechkids@vtechkids.com

12. Separate Agreements.

If any provision of this Policy is held to be unlawful, void or unenforceable for any reason, then that provision will be deemed to be deleted from this Policy and that deletion will not affect in any way the remaining provisions in this Policy.

13. Force Majeure.

VTech will not be liable in any way for its failure or delay to comply with this Policy if that performance becomes commercially impracticable as a result of any existing or future law, rule or regulation, whether valid or invalid, or any cause beyond VTech's reasonable control, including war, mobilization, insurrection, accident, natural disaster, explosion, rebellion, civil commotion, riot, act of an extremist, terrorist or public enemy, sabotage, labor dispute, lockout, strike, explosion, fire, flood, storm, accident, drought, power failure, inability to obtain suitable and sufficient energy, labor or material, delay of carriers or embargo. VTech also is not responsible for harm, damage, or injury caused by the actions of others.

14. Entire Agreement.

This Policy constitutes your entire understanding related to information about you or your children received in connection with your use of the Web Services, and it supersedes any prior agreements or understandings about that topic not incorporated in this Policy. If more than one version of this Policy applies to any dispute related to that information or the Web Services, the latest version of this Policy will control.