Version updated: May 2018
PARENTS and GUARDIANS:
In our MissOandFriends.com website the HDGroup uses reasonable efforts to abide by and follow the requirements of the Children’s Online Privacy Protection Act of 1998 (COPPA). Parents, it is important that you spend time with your children to determine and monitor the appropriateness of the websites your child visits. Please also instruct your child to never provide personal information about themselves, their family or others on this site or any other site without your permission.
A CHILD UNDER THE AGE OF 13 MUST GET PARENTAL OR GUARDIAN CONSENT BEFORE GIVING OUT EMAIL ADDRESSES OR ANY PERSONAL INFORMATION TO THE HDGROUP. IF YOU ARE UNDER 18, PLEASE READ THIS POLICY WITH YOUR PARENTS. ASK YOUR PARENTS QUESTIONS ABOUT ANY WORDS AND CONCEPTS YOU DO NOT UNDERSTAND.
The HDGroup along with Miss O and Friends®and Girl2Girl Wall want you and your children’s experience with our website to be a fun, positive, learning experience. We urge you to instruct your children to follow common sense, family rules, and precautions whenever disclosing personal information on this site or, for that matter, anywhere on the Internet.
If I am over 18 or my child is 13 or over, does the HDGroup collect personal information about either of us?
The HDGroup never requires anyone on the Miss O and Friends® website/Girl2Girl Wall app to share any personal information about themselves in order to use the site. You can visit our site without registering with us. Nevertheless, our site contains special sections and privileges for members that register. If you do not wish to register, we do not collect any personal information from you or your child unless it is voluntarily provided, for instance when creating a story, writing on the Girl2Girl Wall or completing an online Smart Quiz. When registering or when specifically asked for personal information, we generally ask for first and last name, mailing address, phone number, an email address and sometimes age. See below for how we may use this information.
If my child is under 13, does the HDGroup collect any personal information about him or her?
We do not collect personal information online from children under 13 without first obtaining their parent’s consent except in special, limited circumstances. If your child is under 13 and wants to use portions of our site with special activities that require registration or require us to obtain personal information, such as to receive a Miss O & Friends® Newsletter, to join the Miss O® Club, to join the Girl2Girl Wall app or to claim a prize we might ask your child to “register.” A child can often register anonymously by just providing a user name (any “screenname” will do) and perhaps a password. When we ask your child for a first name, we encourage you to have your child enter a “screenname” (a made up name or nick name). Sometimes we may request a first name, state that the child lives in and age, for example when writing a story. Other times we will require your child’s first name, last name, home and email address and age; such personal information will only be requested after obtaining your verifiable consent. Only after receiving your consent, we may collect personal information from your child such as a last name, address, email address and age when the information is necessary for a particular activity such as receiving the Miss O & Friends® Newsletter, Email Newsletter; or when entering a contest so that the child and parent can be informed of winning. If we need more than just your child’s first name (or screenname), age and state of residence for your child to participate in a particular online activity, such as if your child signs up for the Miss O & Friends Newsletter, we will ask your child for your email address so that we can notify you and get your permission. When we ask for your permission, we will tell you what we will do with the information you or your child provides us, and we will tell you how you can review your child’s information and ask us to delete the information. We don’t keep your (or your child’s) email address any longer than is needed.
The HDGroup might collect an email address and first name (or screenname) from your child under 13 without your consent, but only in the following special case.
If a child under 13 sends a request to us, then we may keep their email address long enough to respond to them. The HDGroup deletes this information from our system soon after we answer their question or request.
If, at any time, you do not want your child to continue receiving an email newsletter, simply click on the link provided in the email newsletter for removal or contact us at [email protected]
Upon proper identification, parents may review the personal information we have collected about their child, request deletion, or refuse to allow further collection or use by writing to us at: HDGroup, LLC Consumer Relations, Attn: Children’s Online Privacy Protection Act, 3 Lockwood Avenue, Old Greenwich, CT 06870. However, if you ask us to delete your child’s information, we will not be able allow your child to participate in the portions of the Miss O and Friends® site or Girl2Girl Wall app that require registration or contain special activities or privileges.
Are all submissions, posts, photos, stories and comments screened prior to posting? Anything that is submitted on the Miss O & Friends® site or the Girl2Girl Wall app by our users, whether it’s a story, comment, quiz, poll, photo, contest entry, question, or answer, is screened by human eyes, regardless of a childs age. We screen out any personal/identifiable information, such as last names, schools, towns, camps, churches in addition to ensuring that the language is appropriate, no sexual inuendos, subjects are age appropriate for the 8-14 age group. Nothing gets posted without being reviewed first!
What does HDGroup do with collected information?
The HDGroup uses the personal information we collect for the purposes indicated at the time you or your teenager or child (with your consent) provides such information. For instance, if you Create a Story, we may use the information provided to post the story on our website and designate the first name (screenname), age and state of the person who wrote the story. Or, if you register in a contest, we will use the registration information to notify contest winners. Infrequently, and only after receiving consent prior to asking for information, we might email or mail you or your teenager or your child to provide information on upcoming Miss O and Friends® products, website updates and promotions. If, at any time, you want to stop receiving such updates and product information from the HDGroup, just email us at [email protected] Our mailings and emails will also include information or a link allowing you to ask to opt out of receiving such information in the future.
Occasionally we may ask your child what they like or do not like about the characters, the site, the games, etc. We do this to provide to your children more of what they want collectively. We may use and email address and user name to ban a user temporarily or permanently from our web site if that user engages in inappropriate conduct on the site.
We may also disclose collected information where we are required to do so by law, for example, in response to a court order or subpoena, or where we disclose information to service providers who provide support for the operations of our web site and do not use or disclose the information for any purpose. Furthermore, to the extent permitted by applicable law, we may disclose collected information to a law enforcement agency’s or other public agency’s (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our web site, protect the integrity or security of our website, or enable us to take precautions against liability.
If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or business transfer, we may transfer collected information to a third party as part of the transaction, to the extent permitted by law.
Does the HDGroup share or provide information about me with others?
From time to time, the HDGroup may provide your information to outside companies that offer products or services that may be of interest if your teenager 13 or older consents. Except as described in this policy, we never share personal information that we receive online from children under 13 with other companies outside of the HDGroup. We will remove your name from the list we provide to outside companies if you email us at [email protected], and we will do the same for your teenager’s name if they request removal from the list. In special circumstances, the HDGroup may allow other companies access to our personal information database. Such special circumstances may be necessary to allow access for providing maintenance to our database, software, servers or routers, for updating security, for helping to process and fill orders or requests, or for providing other necessary services to the HDGroup. When we provide access to the HDGroup’s personal information database, we require those other companies to sign confidentiality agreements promising to keep secret any information they see. If the HDGroup believes that anyone’s behavior on our site may damage us, our site or anyone else; we may disclose to the appropriate authorities the relevant personal information in order to prevent this harm. In that case, we might try to identify the wrongdoer, contact them or bring legal action against them. We may also disclose personal information if we believe that the disclosure is required by law, or in response to a proper legal request.
Does the HDGroup ever collect information without consent?
When visitors come to our site, certain non-personally identifiable computer information may be passively collected. Such information may include, the user’s IP address, the web browser (e.g., Internet Explorer, Firefox, Safari) being used, the frequency with which a visitor visits part of our web site, and information about the Internet Service Provider, in order to make our web site more interesting and useful to our users and for various reasons related to our business.
Are third-party advertisers used by the HDGroup?
We use third-party advertising companies to serve ads when you visit our Web site or app. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp
Cookies & 3rd Party Advertisements
We allow third-party companies to serve ads and/or collect certain anonymous information when you visit our web site or app. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, you can visit http://www.networkadvertising.org/managing/opt_out.asp.
HD Group, LLC is service provider, located outside the EU. Our only physical location is based in the United States of America. We provide Internet based services to customers outside the EU. Visitors to our internet services can use our services when they travel to other countries, including within the EU. Our company has always maintained (USA) COPPA compliance, never specifically targeting our services at individuals in the USA, EU, or anywhere in the world. We have always been and currently are COPPA compliant; thus we are compliant with the rules of the GDPR. We do not collect PII (Personally Identifiable Information) of any users. Our compliance to not collect any PII (personally identifiable information), includes, but is not limited to: No automatic email opt-ins. We only collect and use email addresses when users opt-in. Users must be at least 13 years old to participate. If users are younger than 13 years old, parental permission must be provided to participate. In this instance, we still do not possess any PII (no last name, no address). The only user information we hold is first name, state and age, and email address. For users opting-in, either age 13 or older, or, if younger than age 13, with parental permission, we hold a user volunteered reference email only. We do not share this referenced email information. We do not share non-PII information – it is only used to communicate with our members. Individuals’ requesting their email to be deleted are purged from our database with 24 hours and confirmed via our webmaster and hosting providers. We employee an outside hosting provider who updates, on-going, state-of-the-art technology and procedures to detect, report and investigate any data breach. Our Data Protection by Design and Data Protection Impact Assessments comply with the ICO’s code of practice on Privacy Impact Assessments, as well as the latest guidance from the Article 29 Working Party. All decision makers in our organization are aware of the GDPR law and appreciate its’ impact. Given our GDPR status, although not mandatory, our CEO continues to serve as our designated Data Protection Officer.
3 Lockwood Avenue
Old Greenwich, CT 06870