The Internet Gateway For Kids

KoiniSecure PRIVACY POLICY



I. Our Privacy Philosophy


Networking Partners, Inc. ("Networking Partners") is committed to protecting your and your children's online privacy on our websites and services.  We created the KoiniSecure children's online safety platform and its related social networks, including, without limitation, Koini.com website (collectively, as we may add websites from time to time, "Our Websites") to bring you and your children a more secure interactive on-line experience.  We therefore take your privacy very seriously and strive to only collect, handle and secure your and your children's personal information appropriately and in accordance with applicable law, including the Children's Online Privacy Protection Act of 1998, a United States law that gives you as parents control over what information is collected online from your children aged 13 and under and how such information is used, maintained and disclosed to third parties (we'll refer to children aged 13 and under in this Privacy Policy as your "COPPA Kids"), Canadian federal and provincial privacy legislation and all other applicable law.

We urge you to monitor your children's activities online and to discuss with your children appropriate restrictions relating to the online communication of personal information. Please take a moment to review the following resources to learn about how to appropriately safeguard your and your children's privacy when surfing the Internet:

Visit www.ftc.gov/privacy

for information from the Federal Trade Commission about protecting children's privacy online.Visit www.OnGuardOnline.gov for social networking tips for parents and youth

Visit www.wiredsafety.org for animations and printable educational materials relating to a wide variety of Internet risks and safety issues concerning tweens and teens.

This Privacy Policy describes the information that we may collect on Our Websites, the purposes for which the information collected is used, the rights you have regarding personal information collected from you and your children, and to whom and under what circumstances we may disclose your and your children's personal information. If at any time you have a question about anything contained in this Privacy Policy, please contact us here

II. What This Privacy Policy Covers


This Privacy Policy applies only to personally identifiable information ("PII") that Networking Partners collects from you and your children on or through Our Websites and describes how we collect, maintain and use this PII.  For the purpose of this Privacy Policy, PII means any individually identifiable information about you or your children collected online that can identify or be used to contact, or locate you or your children, including, without limitation: 

(a) your or your children's first and last name;
(b) a home or other physical address for you or your children (including street name and name of a city or town);
(c) your or your children's e-mail address or other online contact information, including, without limitation, an instant messaging user identifier or a screen name that reveals an individual's e-mail address or other PII;
(d) your or your children's telephone number;
(e) your or your children's Social Security number;
(f) a persistent identifier (such as a customer number) relating to you or your children held in a "cookie" (explained in more detail below) where such identifier is associated with PII;
(g) a combination of your  or your children's last name or a photograph with other information such that the combination permits physical or online contacting; or
(h) non-personally identifiable information ("NPI") concerning you or your children that we collect online when it is combined with your or your children's PII.
For the purpose of this Agreement, NPI might include certain data that does not by itself individually identify you or your children – for example, web usage information (e.g., browser type) and demographic information (e.g., age range, gender, certain preferences, etc.).
When we refer to "aggregate information" in this Privacy Policy, we mean NPI about you and your children that is combined with other individuals information for statistical evaluation.
Please note that this policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage.


III. What Information We May Collect From You


A. What information we do not collect

We do not collect PII from casual visitors to publicly available pages of Our Websites unless such visitors contact us. When visitors do contact us, we collect and store their communications in order to respond to their requests and may use their PII again (except in the case of your COPPA Kids, where we must obtain your consent) to send newsletters and/or promotional messages, unless they choose to opt out of receiving any further correspondence from us by following the opt-out instructions contained in each communication.

We do not collect any PII from your COPPA Kids without first obtaining your verifiable consent (such as when you register your children for a KoiniSecure account using your credit card), except in certain limited circumstances described below in the Section entitled "Children's Privacy." Only you as a parent or legal guardian may register your COPPA Kids for membership subscriptions on Our Websites and/or authorize the collection of PII from them in connection with games, activities, contests, surveys, promotions, etc. in which they may wish to participate on Our Websites.

B. What information we do collect

In order to access the enhanced subscription services and community features offered by Our Websites, you must first register with us and create an account for you and for at least one of your children. When you register, we will ask you for certain of your PII including, without limitation, your full name, mailing address, e-mail address, phone number, birth date and credit card number and/or other payment information. As part of the registration process, we may also ask you for certain NPI, including, without limitation, your communication and marketing preferences.

We will also ask for PII about the children you wish to have listed on your account, including, without limitation, their full name, and certain NPI, such as their age and gender in order to better personalize our service.

At the time you register your children for an account with us, you will need to create a user name and password for each child. PLEASE DO NOT USE ANY PII IN OR AS YOUR CHILDREN'S USER NAMES AS THIS INFORMATION WILL BE VISIBLE TO OTHERS ON OUR WEBSITES.

Please note that when you and your children register as members of Our Websites and sign in to use our services, you are not anonymous to us.

We may also collect PII from you and your children (including your COPPA Kids, subject to obtaining your verifiable consent) when you or your children use Our Websites to interact with others in the community (e.g. by posting comments, photos and/or video) and when you or your children participate in certain promotions, contests, surveys or sweepstakes where collection of such information is reasonably required in order to participate in such activities, or if you or your children send us an e-mail. We cannot guarantee that only your and your children's friends known to them will have access to information shared by you and your children when using interactive and sharing features of our websites. AS SUCH, PLEASE DO NOT, AND  INSTRUCT YOUR CHILDREN TO NEVER, SHARE OR POST PII ON PROFILE PAGES, MESSAGE BOARDS OR IN CHAT ROOMS.

We may combine PII and/or NPI we have about you with information we may obtain from our business partners or other companies.

C. Web analytics information and other NPI we may collect

As is the case with most commercial websites, when you browse Our Websites, we automatically receive and record certain NPI from your browser on our server logs, including, without limitation, your internet protocol (IP) address, browser type, internet service provider (ISP), referring and exit pages, operating system, date and time stamp, "cookie" information, etc.
We may collect the e-mail address of the sender and the recipient(s) of communications you ask us to make to people you know on your behalf through our "Tell-a-Friend" service (described in greater detail in the section below entitled "Tell-A-Friend.")
We collect text postings (e.g. blog or message board comments), photos, video or audio recordings you and your children may submit as part of your use of Our Websites. We also collect and store your children's IM and live chat history to better protect your and your children's safety.

D. Information We Collect Through "Cookies" and "Clear GIFs"

We use so-called "cookies" and "clear GIFs" to enhance your experience on our websites. These cookies and clear GIFs provide us with statistical and usage data that allows us to remember your preferences and customizations, personalize and update our content and improve navigation of our websites.

A cookie is a small information file that we place on your computer to help us to keep track of your visits to our websites and to remember your activities. For instance, we use cookies to remember user customizations and user screen names to avoid the need for multiple log-ins. We do not store any PII into our cookies nor do we link or combine information collected through cookies to any PII that you or your children submit to us when using Our Websites.

A clear GIF (also known as a "web beacon" or "web bug") is an electronic file placed on a web page, usually in the form of a transparent one pixel by one pixel GIF (Graphics Interchange Format file, a common file format for images used on the internet) that allows our websites to collect anonymous and aggregate metrics such as counting users who have visited certain pages, advertising responses or to deliver or access our cookies.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set (each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences). However, certain areas of Our Websites can only be accessed in conjunction with cookies and you should be aware that disabling cookies might prevent you from using some or all of our features and content.  Third party companies other than Networking Partners may show advertisements on Our Websites.  If you or your children click on a third party advertisement, the third party may set and access its own cookies on your computer. Please be aware that this Privacy Policy does NOT cover these other companies' cookies, which are subject to their own privacy policies.  Advertisers do not have access to our cookies.  For more information on third party ad servers, please see http://www.networkadvertising.org and the section entitled "Collection of Information by Third Party Sites and Sponsors."

E. Information collected through surveys or contests

From time to time we may provide you and your children the opportunity to participate in surveys or contests that may be entered into online.  If you or your children choose to participate, we may use the PII we already have on file as part of your children's registration profile or, if reasonably necessary for your child to participate in the survey or contest, request certain additional PII from you or from them. In the case of your COPPA Kids, we will first obtain your verifiable consent before using your COPPA Kids PII for such purposes. Participation in our surveys or contests is completely voluntary. We may use this PII to communicate with participants as part of the survey or contest, and to notify contest winners and award prizes. We may use a third party service provider or fulfillment house to conduct these surveys or contests. Any such third party will be prohibited by contract from using your PII for any other purpose than to run the contest or survey and must agree in writing with us to maintain the confidentiality and security of your information.

F. Information collected through our "Tell-A-Friend" service

If you choose to use our referral service to tell a friend about Our Websites, you can provide us with the names and e-mail addresses of one or more of your friends for the purpose of processing your  Tell-A-Friend request only.  We will automatically send your friend a one-time e-mail in your name and on your behalf inviting him or her to visit our home page. We store this information for the sole purpose of sending this one-time e-mail and tracking the success of our referral program.  Your friend may contact us at <e-mail> to request that we delete or destroy this information.

IV. How We Use Your and Your Children's PII


A. General information use practices

We use your and your children's PII for the following general internal purposes:
to customize the content and advertising on Our Websites;
to fulfill your and your children's requests for products and services, including processing your payments;
to improve our services though enhanced products, customer service and promotions;
to communicate with you and your children in accordance with your communication preferences;
to investigate and respond to complaints, questions or concerns you or your children may have about Our Websites; and
to determine your and your children's eligibility for our services.

We may share your and your children's PII with other members of the Networking Partners corporate group, but only to the extent necessary to fulfill the general internal purposes listed above.

We are not in the business of, and do not, without your consent and in accordance with applicable law, share, sell, rent or otherwise provide your or your children's PII to any third party, except that we may disclose your PII to certain third parties in the limited circumstances set forth below:

We provide your and your children's PII to trusted third parties who provide support for the internal operations of Our Websites under written confidentiality agreements. For instance, we may use third parties such as a credit card processing company to bill you for goods and services, or a fulfillment house to fulfill requests by you and your children. These third parties are prohibited by contract from using your PII for any other purpose.

In the good faith belief that we are required to do so by law, we may respond to subpoenas, court orders, or legal process, or establish or exercise our legal rights or defend against legal claims.
We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of service, or as otherwise required by law.

We transfer your and your children's PII if we are acquired by or merged with another company. In this event, we will notify you before PII is transferred and may become subject to a different privacy policy.

Except with respect to the limited exceptions above, you have the option of allowing us to collect and use your PII or that of your children for our own general internal purposes, without giving your consent to the sharing of this information with third parties. You can change your preferences in this regard by visiting your account dashboard at any time.

We may share aggregate information about our user base with our partners and advertisers. This information does not identify individual users. We do not link aggregate information with PII.
We use the information collected in log files, which does not contain PII, to analyze use trends, to administer Our Websites, to track users' movements and to gather demographic and statistical information about our user base as a whole so we can constantly improve and tailor our websites to better correspond to the needs and desires of our users. 

B. Communications from Us

Based upon the PII you provide us when you register for our websites, we will send you a welcome e-mail to verify the usernames and passwords you have selected for yourself and for your children.  We also will communicate with you by email in response to your inquiries, to provide the services you request, and to manage your account. We will send you service-related announcements when it is necessary to do so.  For instance, if our service is temporarily suspended for maintenance, we might send you an e-mail to inform you of this situation. You may not opt-out of these communications, which are not promotional in nature.  If you do not wish to receive them, you have the option to deactivate your account. 

With your permission, we may occasionally e-mail you information on our products, services, special deals and other promotions. If you wish to subscribe to our newsletter(s), we will use your name and e-mail address to send these newsletters to you. When you register for an account with us, you will be asked for your preference for receiving these marketing and promotional communications and newsletters from us and will have the opportunity at that time to opt out. 

V. Updating and Modifying Your Information and Removing Children from Your Account

We take steps to ensure that the PII we collect and process is accurate, complete, and current.  Nonetheless, we depend on you to update or correct your PII. For instance:

You can review and edit your Registration Data at any time by visiting your account dashboard.
You can review and edit your marketing preferences at any time by visiting your account dashboard .

You can request deactivation of your account with us or remove a child from your account by visiting your account dashboard.   If you ask us to delete your or one of your children's accounts, it will be deactivated. We may, however, store your or your children's PII for a certain period of time prior to deletion in order to discourage fraudulent activity.

Please note that any information that we have copied, including your Registration Data, may remain in back-up storage for some period of time after your deletion request. This may be the case even though no information about your account remains in our active user databases. Data in back-up storage cannot be retrieved in the ordinary course of business.

When a member turns 21 years of age, his or her account is converted to a Koini adult account. This means that the adult member will no longer be permitted to add new friends under the age of 21 on Our Websites, but may still communicate with friends under the age of 19 already listed as friends in such member's account as of his or her 21st birthday.

VI. How We Protect The Confidentiality and Security of Your and Your Children's Information

We limit access to PII about you and your children to our employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs and who are bound to protect the confidentiality of your and your children's PII.  We have physical, electronic, and procedural safeguards that comply with generally accepted industry standards to protect your personal information.

To help to protect the confidentiality of your and your children's PII, we span class="black"ly encourage you to keep your password confidential and not to disclose it to any other person.  We recommend you build a "span class="black" password" (see: www.microsoft.com/protect/yourself/password/create.mspx for information on creating span class="black" passwords) and to change it frequently.  We will not be liable for any loss that you may incur because of someone else using your password or account, either with or without your knowledge. If you suspect your password has been misused then please contact us here.

If you forget your password, contact us for assistance or follow the "Forgot your password?" link provided on the member log-in page.

When you enter sensitive information (such as credit card information) on our registration forms or other checkout pages we encrypt the transmission of that information using secure sockets layer technology (SSL).   

PLEASE KEEP IN MIND THAT NO METHOD OF TRANSMISSION OVER THE INTERNET, OR METHOD OF ELECTRONIC STORAGE, IS 100% SECURE.  THEREFORE, WHILE WE STRIVE TO USE COMMERCIALLY ACCEPTABLE MEANS TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE ITS ABSOLUTE SECURITY.

VII. Children's Privacy

Enabling parents to understand and control the scope of their children's activities on the Internet is why we created KoiniSecure.  Your account dashboard is where you can create, review, update or delete your children's profiles, review and approve friends they can communicate with and the websites they will be permitted to visit. Social networking websites typically encourage a great deal of personal information to be shared and exchanged so it is important that parents and children understand the risks inherent in sharing this information online.  We encourage parents to learn about and to discuss online safety with their children and to advise them never to share their PII online in screen names, blogs, on message boards, in IM, chat rooms or otherwise We comply with the Children's Online Privacy Protection Act (COPPA). COPPA is a United States law aimed at protecting the privacy of your COPPA Kids (those aged 13 and under) online.  Generally, COPPA requires us to:

Post a privacy policy on the homepage of our Websites and link to the privacy policy on every page where PII is collected from or about COPPA Kids.
Provide notice about Our Websites' information collection practices to you and obtain verifiable parental consent before collecting, using or disclosing PII from your COPPA Kids.
Give you a choice as to whether your child's PII will be disclosed to third parties.
Provide you access to your children's PII and the opportunity to request deletion of such PII and opt-out of future collection or use of the information.
Not condition a child's participation in a game, contest or other activity on your children's disclosing more PII than is reasonably necessary to participate in that activity.
Maintain the confidentiality, security and integrity of PII collected from children.

We collect and maintain PII about your COPPA Kids only from you, in connection with your registration of that child with us and/or from your COPPA Kids with your verifiable consent (unless previously obtained) in connection with other activities on our websites when reasonably necessary for participation in such activities.

We may collect your COPPA Kids' name and your and your children's online contact (e.g. email address) information without your prior consent under the following circumstances:

We may collect your COPPA Kids' name and your or your children's online contact information for the sole purpose of obtaining your consent or providing you with notice of our Privacy Policy, which information we will delete if we do not obtain your consent.
We may collect your COPPA Kids' online contact information to be used for the sole purpose of responding directly on a one-time basis to a specific request from the child, after which we will delete this information.
We may collect your COPPA Kid's online contact information to be used for the sole purpose of responding directly more than once to a specific request from the child (e.g., in the case of a request for a newsletter, or to announce the winner of a contest). In this case, we will notify you immediately after our initial response to the child and before contacting the child a second time in order to provide you with the opportunity to request that we do not make any further use of the information provided by your COPPA Kid.
We may collect your COPPA Kid's name and online contact information to the extent reasonably necessary to protect the safety of the child, so long as it is not used for any other purpose, in which case we will notify you as soon as possible after the collection.
We may collect your COPPA Kid's name and online contact information, so long as not used for any other purpose, to the extent reasonably necessary to (i) protect the security or integrity of Our Websites; (ii) to take precautions against liability; (iii) to respond to judicial process; or (iv) to the extent permitted under other provisions of law, to provide information to law enforcement agencies or for an investigation on a matter related to public safety.

Each time your COPPA Kids wish to log into our websites, we collect from them their user name and password (if you have chosen to subscribe them for membership on Koini.com).  We do not directly or actively collect any other PII from your COPPA Kids while they are visiting our websites.  However, please note that if your COPPA Kids participate in instant messaging, internal mail, live chatting, sending e-mails from our site, posting messages, photos or videos, etc., they may also provide others with additional information about themselves contained in their communications, including PII. Please discuss this risk with your COPPA Kids and make sure they understand the dangers of sharing PII online. 

We only share or disclose your COPPA Kids' PII to third parties in the manner described the Section entitled "How We Use Your and Your Children's PII" above.

You may, at any time, even after you have given us permission to collect and use your COPPA Kids' PII: (a) review, correct or request that your COPPA Kids' PII be deleted and/or; (b) revoke your consent to our continuing collection or use of your COPPA Kids' PII. See the section above entitled "Updating and Modifying Your Information and Removing Children from Your Account," for how to access, change, or request deletion the PII of your COPPA Kids. We reserve the right, subject to applicable law, to terminate any service provided to you and your children where you have refused to permit our further collection or use of your children's PII or have instructed us to delete your children's PII.

If we learn that the PII of your COPPA Kids has been collected without verified parental consent, we will take the appropriate steps to delete this information as soon as practicable.


VIII. IM, Chat Rooms, Forums

If you or your child/children use IM, chat rooms, discussion forums or message boards ("Public Forums") on Our Websites, you should be aware that any PII submitted in such Public Forums can be read, collected, or used by other users, and could be used to send you unsolicited messages or for other purposes.  As Public Forums are for public and not private communications, you should have no expectation of privacy with regard to any submissions made therein. We are not responsible for, and we cannot guarantee the security of, the PII you or your children choose to submit when using these features.  We reserve the right to terminate the accounts of users who use chat rooms or discussion forums in violation of this policy or of our Terms of Service

If your children (including COPPA Kids) engage in Public Forums communications with another member, then both members PII, if any, disclosed in the course of communications may be stored with the log of such communications, which we maintain only for the purpose of protecting our users (i.e. these logs are not associated with your or your Children's PII for marketing or other commercial purposes).

VIV. E-mail Service

Our Websites may offer the option of allowing your children to use our interface to send and receive e-mails through their registered e-mail service providers (e.g. AOL, Google, Yahoo, MSN etc.). In this way your children can check their e-mail and send and receive e-mail messages without having to, or trying to, leave our secure on-line environment. When your children use their e-mail accounts through Our Websites, we do not collect any information from incoming or outgoing mail or from your or your children's email accounts, calendars or address books. Our Websites, in the case of third party e-mail, only serve as a "viewing window" in which you may see and use registered e-mail accounts. All e-mail functionality is supplied by your registered e-mail providers and all e-mail correspondence and related account information contained in your account with such third party providers remains on their servers only. We do not collect or store any such information.   We do not guarantee the security of third party e-mail services. We do not monitor e-mails sent or received using Our Websites' interface.


X. Countries in Which Data is Processed

Our Websites and the servers that make them available are located in the United States and personal data you submit to us may be further transferred by us outside the U.S. or your country of residence. Most countries, including the United States, have not formally been determined to operate under specific laws deemed "adequate" by the European Union (EU) for the transfer of personal data. Networking Partners however, respects your privacy, and will handle your personal data in accordance with this privacy policy. By accepting this privacy policy, you specifically acknowledge and consent to the collection, processing, transfer and use of your personal data as indicated in this privacy policy.

XI. Links to Other Sites

This privacy statement applies only to information collected by Our Websites. Our Websites may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site (we will notify you and your children when you are leaving Our Websites) and to read the privacy statements of each and every website that collects PII. 

XII. Changes to this Privacy Policy

We may update this policy. We will notify you about material changes in the way we treat your and your children's PII by sending a notice to the primary e-mail address specified in your account or by placing a prominent notice on our websites. We may also make non-material changes to this Privacy Policy from time to, which changes may be made without notice to you and shall take effect as of the date such changes are posted. Continued use of our Websites following the effective date of any changes to our Privacy Policy constitutes your acceptance of such changes.

XIII. Redress/Enforcement

We will make every attempt to ensure subscriber satisfaction. If you have an issue or concern with Our Websites, you may contact us directly by one of the methods shown in the Contact Us section of this Privacy Policy. We typically will contact you within 30 days of the date of your message with a resolution or answer to your question.

From time to time, we review our information collection, use, and disclosure practices in order to ensure that we are complying with our Privacy Policy and applicable laws and regulations.  If you have any concerns about the privacy or security of your PII, please contact us.

XIV. Your California Privacy Rights

Beginning on January 1, 2005, California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding disclosure of personal information to third parties for direct marketing purposes. To make such a request, please send an e-mail to privacy@koini.com

XV. A Final Note to Parents

The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit The Direct Marketing Association's Web site (http://www.the-dma.org) and explore the Get CyberSavvy! program at http://www.cybersavvy.org/cybersavvy/index.html. Get CyberSavvy! helps families learn how information flows online so they can use the Internet in ways that protect their privacy and well-being. It also contains a number of valuable resources to help parents and children be aware of and express their preferences about information that is collected online and how it is used. Your efforts to instill responsible information practices will help steer your children to age-appropriate sites and will go a long way toward ensuring that your children have enriching experiences online.


XVI. Contact Us

If you have questions or suggestions regarding our privacy policy, please complete a feedback form

Effective Date: 03 March, 2009

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