CHILDREN’S 394f6l

PURPOSE:	We, at Kongregate Inc. (“Kongregate,” the “Company,” “we” or “us”), are committed to respecting your privacy and the integrity and security of your personal information, and especially the privacy of Children who use our Site and certain of our Apps which Kongregate has designated as directed to Children (collectively, our “Children-Appealing Games”). While almost all of our Services, Platform and 3rd Party Platform Games are generally designed for and directed at people 18 years of age or older, we have a handful of Children-Appealing Games, for which this Children’s applies. This Children’s explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 within the United States (or up to the age of 16 for children located in certain European countries)(each, a “Child,” or collectively, “Children”) and uses that are defined in our general . This Children’s is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), among other applicable privacy laws, and outlines our practices regarding children’s personal information in the United States and other applicable regions. As the data controller of certain of your personal information, through this , we want you to know how we handle it, how we use it, process it and/or share it, as well as the ways in which you can protect your own privacy.
SCOPE:	The Children’s applies to any and all end s of Kongregate’s Services who are Children. Each of kongregate.telechargertorrent.org, www.kartridge.com, and all other sites or online services that are owned or operated by Kongregate currently or in the future is a “Site,” and collectively, the “Sites.” Each mobile game published or operated by Kongregate currently or in the future is an “App,” and collectively, the “Apps,” (and together with the Sites, the “Platform”). Each Kongregate game that can be played through third party platforms, e.g., via consoles, PCs and/or social media sites such as Facebook is a “3rd Party Platform Games.” By visiting our Sites, using the Apps, playing 3rd Party Platform Games or otherwise access any of our other products, services or content through any of our Platform or through 3rd Party Platform Games (collectively, “Services”), you agree to and accept this , our Cookie Policy (which is incorporated into the ) and our of Service. (of which the is a part). Updates to Children’s . We reserve the right to amend this Children’s at our discretion and at any time. When any changes are made, we will try to provide reasonable notice and will post the updated version on the Platform. We may also send an email or provide notice within some or all of our Services when this changes. If we make a material change to the collection and use of personal information, we will post notice or send an email prior to making the change. Each time a accesses our Services, the Platform or 3rd Party Platform Games, the then current version of the applies, and you agree that the information we collect will be subject to the Children’s , as updated. Should you have any questions about the changes, you are welcome to us at please us at 1-800-678-2319 or at @kongregate.telechargertorrent.org. If you do not agree with the changes, then unfortunately, we must ask you to cease using our Platform and/or Services, as we must have all s under the same in order to provide equitable Services to all.
REFERENCE:	Certification Program. Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification Kongregate, Inc is a member of the PRIVO Kids Privacy Assured COPPA safe harbor certification Program (“the Program”). The Program certification applies to the following digital properties listed on the certification page that is viewable by clicking on the PRIVO Seal (Maleficent Free Fall, Inside Out Thought Bubbles, and Where’s My Water? 2). PRIVO is an independent, third-party organization committed to ing online services to safeguard children’s personal information collected online. The PRIVO COPPA safe harbor certification Seal posted on this page indicates Kongregate, Inc has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please us at @kongregate.telechargertorrent.org. If you have further concerns after you have ed us, you can PRIVO directly at [email protected].
EFFECTIVE DATE:	September 17, 2020
LAST UPDATED:	February 10, 2024
LAST REVIEWED:	February 10, 2024

TABLE OF CONTENTS 15b54

WHAT INFORMATION WE COLLECT FROM CHILDREN
HOW WE USE PERSONAL INFORMATION COLLECTED
WITH WHOM WE SHARE YOUR PERSONAL DATA FROM CHILDREN
PARENTAL CHOICES AND CONTROLS
HOW WE PROTECT YOUR INFORMATION
QUESTIONS, CONCERNS OR REQUESTS

1. WHAT INFORMATION WE COLLECT FROM CHILDREN 6v1d5

Children can, in many cases, with Children-Appealing Games to view content and play games, among other things. During the registration process, we may ask Children to provide certain information for notification and security purposes, including, the child’s age, the child’s name and . We also may ask for birth years from Children to validate their ages. x392g

We strongly advise Children never to provide any personal information in their names. Please note that Children can choose whether to share their information with us, but certain features cannot function without it. As a result, Children may not be able to access certain features if required information has not been provided.

In any instance that we collect personal information from Children, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow Children to continue to participate in the activity, and ensure the security of our s and our Services, or as required by law. In the event we discover we have collected information from Children in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

When ing or using the Children-Appealing Games, you or your Child may submit, or we may automatically collect, any or all of the following information:

Profile information such as name and to protect the ;
In any instance where we ask for age and determine the is under 13, we will provide parental notice and/or obtain parental consent as required by COPPA should we collect any additional information e.g. the email address of a parent or other legal guardian;
information if you or your child reaches out to us;
Postal address and limited and tokenized payment information may be collected when ing a game, or making a purchase;
Persistent identifiers, i.e., device and network identifiers such as IP address, mobile advertising ID, media access control (MAC) address, and identifiers associated with browser cookies, web beacons and similar technologies (which we further describe in our Cookie Policy);
Internet or other electronic network activity information, such as your Internet service provider (ISP), browser type and operating system version, language settings, access times, pages viewed, the routes by which you access the Services, and your use of any hyperlinks available within the Services.

2. HOW WE USE PERSONAL INFORMATION COLLECTED 3v66x

We collect and use information about you or your child for the following purposes, including to:

For the sake of our CONTRACTUAL RELATIONSHIP as necessary to perform and fulfill certain obligations under the of Service:
- For the provision of our Services to you or your Child, including to and manage the , provide or improve customer service, fulfill your requests, improve the experience of our Services and to ister our contractual relationship with you or your Child;
- To ensure that the content from our Services is transmitted to you or your Child and the device in the most efficient way;
- To handle payments for your Child’s ;
- To communicate with you regarding your Child’s or the purchase of our Services;
- To send mobile push notifications to your Child, to which you have consented;
- To notify you about changes to our Services;
- To provide offers, news, information, products or services that you request from us.
For our LEGITIMATE INTERESTS of developing, istering, protecting and marketing our Services as well as from a business and strategic management perspective:
- To operate, improve and optimize our Services for the benefit of our s;
- To provide technical and respond to inquiries;
- To better understand how s interact with our Platform and to personalize our Services;
- To use IP address, device identifiers or other information necessary to block disruptive use or services, for the reason of protecting our Services or otherwise enforcing or applying our of Service;
- For research, analyzing and statistical purposes;
- To enhance the security of our network and information systems;
- To protect against fraud, unauthorized transactions, claims and other liabilities;
- To manage exposure to risk from unauthorized s;
- To provide information in a change of control or mergers and acquisitions processes or for the reasons of business and strategic management; and/or
- For the establishment, exercise or defense of legal claims.
When we process data for our legitimate business purposes, we will always consider your personal data rights in high regard, take of your rights and proceed only when our interests are not overridden by your interests or rights. You have the right to object to this processing, but please bear in mind that if you object, this may affect our ability to carry out tasks above for your benefit.
We may also process or share your personal data if it is reasonably necessary for us to comply with a LEGAL OBLIGATION or in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

3. WITH WHOM WE MAY SHARE INFORMATION COLLECTED FROM CHILDREN 6ck6h

Kongregate does not sell personal information collected from Children or teens we know to be under the age of 16. We do not share email addresses with third parties for the purpose of sending their own emails to you without your consent. When we disclose personal information for a business purpose, we enter a data processing agreement that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the Services for which we have agreed upon.

We may share or disclose personal information collected from Children in a limited number of instances, including the following:

Service Providers. We share information with our service providers, who are und companies or individuals we hire or work with, that perform services on our behalf, including customer , payment processors, or others who assist us in fulfilling orders or transactions, web hosting, information technology, and analytics services.
Third Parties for Security or Other Legitimate Reasons. We may also disclose your personal data to third parties, if we reasonably believe that disclosure of such personal data is necessary: (i) to comply with valid legal obligations including subpoenas, court orders, governmental requests or search warrants, and as otherwise authorized by law; (ii) to protect our rights, property, or the safety of our customers, employees or the general public; (iii) to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of our Services and to protect our network, services, devices and s from such use; (iv) to advance or defend against complaints or legal claims; (v) to determine credit risk, for reporting purposes or to obtain payment for our Services; and (vi) to outside auditors and regulators.
Intra-Group Transfers. We may disclose your personal data to other companies within our parent company if it is necessary for istrative purposes or the provision of our Services to you. If you have agreed thereto, we may also disclose your personal data to companies owned or operated by our parent company for marketing purposes. The companies who may have access to your personal data follow practices consistent with this .
Corporate Transaction, Reorganization or Bankruptcy. In the event of a change of control, sale of some or all of our business or assets, corporate reorganization or bankruptcy, we would share the pertinent customer information (which may include your personal information) with the other business entity (or entities) involved in the transaction. In such an event, we would notify you via email and/or a prominent notice on our Platform of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Legal Compliance. We may disclose information upon governmental request, in response to a court order, or when required by law to do so. We may also share information with companies assisting in fraud protection, legal compliance or investigations. We do not provide information to these agencies or companies for marketing or commercial purposes.

In the event we collect (or allow others to collect) information from Children on our Site or Children-Appealing Games for other purposes that those identified above, we will notify parents and obtain consent prior to such collection.

Visit the Third Party Operators page to see the list of third-party operators who collect persistent identifiers on our sites and applications. This list may be amended at our discretion and at any time.

If you or your parent have any questions about our use of service providers and their collection and use practices in relation to children please us at @kongregate.telechargertorrent.org.

4. PARENTAL CHOICES AND CONTROLS 5b2r4p

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular , and can request that we delete from our records the personal information we have collected in connection with that . Please keep in mind that a request to delete records may lead to a termination of an , hip, or other service.

Parents can us at 1-800-678-2319 or at @kongregate.telechargertorrent.org to request access to, change, or delete their child’s personal information. A valid request to delete personal information will be accommodated within a reasonable time.

In any correspondence such as e-mail or mail, please include the child’s name and the parent’s email address and/or telephone number. To protect children’s privacy and security, we will take reasonable steps to help a parent’s identity before granting access to any personal information.

We do not sell personal information collected by or from any Service or portion of a Service that is directed to Children or where we know that the is a Child or a teen under 16 in certain countries within the EU. For the portions of our Services that are directed to audiences older than 13, we do not sell identifying information such as name, email address, phone number, or postal address, but we may share identifiers such as cookies and the advertising identifier associated with your mobile device with our advertising partners, and those partners may use and share those identifiers to show ads that are targeted to your interests.

5. HOW WE PROTECT YOUR INFORMATION 2l654d

We strive to maintain the security of your personal information through a variety of security measures. Safeguarding your personal data is a priority for us. Personal data that you provide to us is stored on secure servers, and we use rigorous procedures to protect against loss, misuse, unauthorized access, alteration, disclosure, or destruction of your personal data. Although we work hard to protect your personal data, please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal data, and we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information.

6. QUESTIONS, CONCERNS OR REQUESTS 2d6n2s

For questions, concerns or requests regarding the Children’s , please us at 1-800-678-2319 or at @kongregate.telechargertorrent.org or at:

Kongregate Inc.
10680 Treena St #155
San Diego, CA 92131