Last updated April 2004
This page may look boring, but it is important. Together
with the Terms and Conditions, it
sets out how SmileMiles handles all data on this site, especially YOURS. By
registering for the SmileMiles service and (hopefully!) joining, you will be
agreeing to it. N.B. We do not send random marketing emails to
personal email addresses (spam).
Fundamental to the success of SmileMiles is the trust you place in us to
safeguard any personal information which you place on the website. This
statement describes the privacy practices we apply for the SmileMiles services.
SMILEMILES is committed to protecting the privacy needs of children and we
encourage parents and guardians to take an active role in their children's
online activities and interests. Modern information and communication
technologies play a fundamental role in the activities of an organisation such
as SmileMiles. We are based in the United Kingdom. Our principal activities are
Online Entertainment and Education. Our privacy policy covers SmileMiles Ltd.
and its Web site:
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Organisation Name:
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SmileMiles
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Address:
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23 Grovelands Road
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City, Zip:
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London , N13 4RJ
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Country:
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United Kingdom
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Controller:
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G Faherty
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Web Sites(s):
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www.SmileMiles.com
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This document sets out how SmileMiles handles data that identifies you. You
should read it in conjunction with the SmileMiles Terms and Conditions, of
which this Privacy Policy forms a part. If you have questions regarding this
statement, you can contact SmileMiles via the “contact
us” page on our web site. We make every effort to respond to every
message within 48 hours.
Providing Visitors with Anonymous Access
You can access our Web site home page and browse our site without disclosing
your personal data.
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Registering with our Web site enables you, for an initial trial period, to
create an account for you as parent, and a junior “associate” member
(conversely, you, the junior member, and your parent). In addition to the
SmileMiles feature, Parent and junior members have the facility of a private
family messaging system, not accessible by any other party. When provided,
parents may communicate with other parent members in discussion forum and post
information to be accessed by others. If you do so, other members may collect
your data. This communication is entirely controlled by you. If you choose to
become a full member, in addition to the above facility, we allocate a
SmileMiles web page in the name of each associated junior member. This web page
allows junior members to post pictures, diary entries, achievements and other
material. Junior members may mark any or all of these items as private (only
the junior can see) or public. Furthermore, and entirely at parental
discretion, this web page may be published to (a) named persons (e.g.
relatives), (b) other SmileMiles community members, or (c) the entire Internet.
Only items marked "public" may be seen.
Our Web site also contains educational and entertainment links to third party
Web sites. While we make every effort to select links wisely, we have no
control over the privacy policies of those web sites.
Profile
We store information that we collect through cookies to create a “profile” of
your preferences. We tie your personally identifiable information, or your
membership history, to information in the profile, in order to improve the
content of the site for you, including your opt-out choices. We do not share
your profile or other personally identifiable information with other third
parties.
Log Files
As is true of most Web sites, we gather certain information automatically and
store it in log files. This information includes internet protocol (IP)
addresses, browser type, internet service provider (ISP), referring/exit pages,
operating system, date/time stamp, and clickstream data. We use this
information, to analyze trends, to administer the site, to track users’
movements around the site and to gather demographic information about our user
base as a whole, in order to improve the service to the membership as a whole.
We do not link this automatically-collected data to personally identifiable
information. You should be aware that your IP addresses are traceable to
personally identifiable information via your Internet Service Provider.
Cookies
We set a persistent cookie to store your name and email address, so you don't
have to enter them again when you visit our site. Even if you allow this
cookie, you have the choice of whether to have your login name "remembered" by
our site. In order to work with our web-site, the highest level of security can
be set in your browser (Tools -> Internet Options... -> Security ), but
cookies must be enabled (Tools -> Internet Options... -> Privacy ).
Clear Gifs (Web Beacons/Web Bugs)
Clear gifs are tiny graphics with a unique identifier, similar in function to
cookies, and are used to track the online movements of Web users. In contrast
to cookies, which are stored on a user’s computer hard drive, clear gifs are
embedded invisibly on Web pages and are about the size of the period at the end
of this sentence . We DO NOT at this time employ clear gifs (a.k.a. Web
Beacons/Web Bugs). If this policy were to change, then we would inform you on
the site home page, in this document or by email.
Links to Other Sites
This Web site contains links to other sites that are not owned or controlled by
SmileMiles. Please be aware that we, SmileMiles, are not responsible for the
privacy practices of such other sites. We encourage you to be aware when you
leave our site and to read the privacy statements of each and every Web site
that collects personally identifiable information. This privacy statement
applies only to information collected by this Web site.
In order to use this Web site, you must first complete the registration form and
create a user name. During registration you are required to give contact
information such as name, country and email address, as well as some optional
data such as gender. We use this information to send you your password, to
notify you of any changes to your family member accounts, and to personalize
your experience of our site. Your optional information, if you choose to supply
it, will be used to help us understand our membership, enabling us to further
enhance the site for the benefit of all members. We appreciate your openness.
When we do this, we will not link the information to you personally. The
information you supply is available to you, and capable of being modified,
through your personal “My Account” page. We do not collect information about
our visitors or members from other sources, such as public records or bodies,
or private organisations.
Orders and applications
Whenever you purchase a product or service from us, we request certain
personally identifiable information from you on our order form. You must
provide contact information such as name, email, and billing or shipping
address. Your financial information (such as credit card number, expiration
date) is supplied by you direct to HSBC (and on to your bank) only through the
secure payment gateway. We retain your address details for authentication
purposes. We do not retain your financial information. We retain a transaction
reference associated with any purchase or membership application. If we have
trouble processing an order, we will use this information to contact you. If
you are a winner in our monthly (non-financial) draws, then you will be asked
to supply your address in order to send promotional items (e.g. T-Shirt). You
may decline this.
Charitable Giving
When you join SmileMiles, we donate a sum of money to a charity. As well as a
pre-determined list, which we supply, you can elect a school of your choice to
receive the funds. If you do so, then you are required to give the school name
and address including zip code. Without this information, we cannot process the
election and send a check. This information is linked to your membership, and
constitutes a part of your personal data. At no time will this information be
used to contact the school for any other reason. We will make basic checks to
ensure the validity of the school prior to sending a donation. All donations
are listed on the web site twice a year, by name of charity and amount given.
Zip codes are not posted. Our accounting system is regulated and public.
Surveys or Contests
From time-to-time we may provide you the opportunity to participate in contests
or surveys on our site. If you participate, we will request certain personally
identifiable information from you. Participation in these surveys or contests
is completely voluntary and you therefore have a choice whether or not to
disclose this information. The requested information typically includes contact
information (such as name and shipping address), and demographic information
(such as zip/postal code).
We may decide to use a third party service provider to conduct these surveys or
contests; any such company will be prohibited from using our users’ personally
identifiable information for any other purpose unless you give your consent.
The name of any such company will be visible on any page where you are invited
to part with your information or views. We will never share the personally
identifiable information you provide through a contest or survey with other
third parties unless we give you prior notice and choice.
Tell-A-Friend
If you choose to use our referral service to tell a friend about our site, we
will ask you for your friend’s name and email address. We will automatically
send your friend a one-time email inviting him or her to visit the site.
SmileMiles stores this information for the purpose of sending this one-time
email and tracking the success of our referral program.
We will use this address once only, and your friend may contact us at the
address supplied in the email, or via the “contact
us” page on our site, to request that we remove this information from
our database.
Customer Service
Based upon the personally identifiable information you provide us, we will send
you a welcoming email to verify your username and password. We will also
communicate with you in response to your inquiries, to provide the services you
request, and to manage your account. We will communicate with you by email or
telephone at your request.
Special Offers and Updates
We may occasionally send you information on items we feel are of interest to the
membership, and on products, services, and promotions. You can sign up for
these emails from us on your registration page and My Account page. Out of
respect for your privacy, we present the option not to receive these types of
communications.
Newsletters
If you wish to subscribe to our newsletter(s), we will use your name and email
address to send the newsletter to you. Out of respect for your privacy, we
provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.
Service-related Announcements
We may send you strictly service-related announcements on rare occasions when it
is necessary to do so. For instance, if our service is temporarily suspended
for maintenance, we might send you an email. Generally, 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.
Acceptable Use
If we receive a complaint from another member with regard to any content which
you or your child have posted in our forum or on your SmileSpace, then we will
remove it from public view. We will then contact you by email to advise of our
action. The offending item will be removed in forum by deletion, and on
SmileSpace by removing from publication. You will still be allowed to modify or
delete the offending item. Once you have done so, you can contact us to make
the SmileSpace available again. Your SmileSpace represents your personal data.
You have the right to maintain your data. We have the right to withdraw from
publication any material that contravenes SmileMiles’ Acceptable Use Policy. We
will not delete a SmileSpace except by your request.
Children are our most important members. Alongside all of our other safeguards,
we take specific steps to protect the privacy of children by:
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Making all reasonable efforts to ensure that a parent has authorised the
collection of the child's personal data.
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Giving parents the option to consent to the collection and use of the child's
personal data for our internal use
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Notifying parents of activity on the child’s account.
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Providing information about our personal data practices in relation to children
on our public pages and wherever we knowingly collect personal data from
children on our Web site.
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Submitting to independent, third-party scrutiny of our data practices
Types of personal information collected
The Children's Online Privacy Protection Act, (COPPA) defines "personal
information" as individually identifiable information such as a first and last
name, a home or other physical address including street name and city or town,
an e-mail address, a telephone number, a Social Security number, or persistent
identifiers such as customer or processor serial numbers held in a cookie,
where the identifier is associated with individually identifiable information.
We collect and use only as much information about children required for the
activity, and do not condition participation in any on-line activity on the
disclosure of more personal information. We ensure that only minimum
information is collected before gaining parental consent. The required
information is a name, an email address, a birth date and a country. The birth
date is used to display age-related pages. Country allows us to provide
relevant technical and membership data. Name data allows us to personalise the
introductory email.
Use of personal information
We use the information we collect from children only for internal business
purposes, and/or to give credit to children for work they have created. Aside
from email updates associated with the SmileMiles Game, we contact children by
e-mail only in response to their requests for information or assistance. We do
not monitor or collect for any internal use, any data which either parents or
children submit to their SmileMail or SmileSpace.
Involvement of parents
In compliance with COPPA, we always notify parents when collecting personal
information from children, and will seek parental consent before collecting,
using and/or disclosing that information. A parent may review - and have
deleted - their child's personal information, and may refuse to permit further
collection or use of their child's information by contacting us. Parents may
consent to our collection and use of their child's personal information without
consenting to the disclosure of that information to others. Additionally,
parents can determine the method of routing SmileMiles game-related
notifications either externally or internally.
Furthermore, before being allowed to use the extended features of the site, we
gain secondary authentication from the parent in the form of a credit card or
check payment. Without this, participation is limited to 15 days and all data
is deleted after 45 days.
Parents have full control over the publication of their child(ren)’s SmileSpace
web pages. Parents also have the ability to give to their children graduated
control over their own data. Any changes made by a child to any publicly
viewable data is notified to the parent unless the parent chooses not to be
notified.
We may share aggregated demographic information (country, city, gender (where
provided)) about our user base with our site development team and web hosting
provider. This information does not identify you as an individual user. We do
not link such aggregate user data with personally identifiable information.
We DO NOT Share Personally Identifiable Information with Third Parties. If we
should want to disclose your personal data for any purposes that are different
from those indicated here, we will offer you the opportunity to consent to
disclosure by indicating in a box at the point on the site where such personal
data is collected.
We use an outside shipping company to fulfill any orders, and use a credit card
processing company to bill you for goods and services. These companies do not
retain, share, store or use personally identifiable information for any other
purposes.
We must reserve the right to disclose your personally identifiable information
as required by law and when we believe that disclosure is necessary to protect
our rights and/or to comply with a judicial proceeding, court order, or legal
process served on our Web site. We would strongly resist such a measure until
strong proof was supplied.
We provide you the opportunity to ‘opt-out’ of having your personally
identifiable information used for certain purposes, when we ask for this
information. For example, if you purchase a product/service but do not wish to
receive any additional marketing material from us, you can indicate your
preference on our order form. If you no longer wish to receive our newsletter,
you may opt-out of receiving it by following the instructions included in each
newsletter or communication or via the “contact
us” page on our web site. We also offer an opportunity to opt in or out
of certain routine communications on your Membership Details page.
When you enter sensitive information on our registration or order forms, we
encrypt that information using secure socket layer technology (SSL). We give
you a secure transmission method to send the following types of personal data:
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primary personal data (such as name and contact details)
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identifiers (such as credit card details, Web site password)
We have implemented security policies, rules and technical measures to protect
the personal data that we have under our control from:
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unauthorised access
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improper use or disclosure
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unauthorised modification
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unlawful destruction or accidental loss
We follow generally accepted industry standards to protect the personal
information submitted to us, both during transmission and once we receive it.
No method of transmission over the Internet, or method of electronic storage,
is 100% secure, however. Therefore, while we strive to use commercially
acceptable means to protect your personal information, we cannot guarantee its
absolute security. SmileMiles is not a bank however, and we do not store any
financial information beyond your subscription payment and renewal data.
While we use SSL encryption to protect sensitive information online, we also do
everything in our power to protect user-information off-line. Access to all of
our users’ information, not just the sensitive information mentioned above, is
restricted in our offices. All personnel, who have access to, and are
associated with the processing of personal data, are obliged to respect the
confidentiality of our visitors' personal data. Only staff who need the
information to perform a specific job (for example, Forum moderator, Editorial,
MemberAdmin, security) are granted access to information, either personal or
non-personal. This access does not extend to include member communications and
account details, which are personal to the members themselves. All staff and
suppliers are kept up-to-date on our security and privacy practices. Finally,
the servers that we store personally identifiable information on are kept in a
secure environment, operated under a contract of confidentiality.
We ensure that your personal data will not be disclosed to State institutions
and authorities except if required by law or other regulation.
If you use a bulletin board or discussion forum on this site, you should be
aware that any personally identifiable information you submit there can be
read, collected, or used by other users of these forums, and could be used to
send you unsolicited messages. We are not responsible for the personally
identifiable information you choose to submit in these forums. Furthermore,
please review the Acceptable Use section of our Terms & Conditions document for
guidelines on use of the Discussion Forum.
If your personally identifiable information changes, or if you no longer need
our service, you may correct, update, delete or deactivate it by making the
change on your member information page; by using the “contact
us” page on the web site, or by contacting us by postal mail at
SmileMiles, 23 Grovelands Road, London, England N13 4RJ. We allow you to challenge
the data that we hold about you and, where appropriate, you may have the data
erased, amended or completed. Alternatively, upon request, we will provide you
with a readable copy of the personal data we keep about you, within a month -
although we may first request further proof of your identity. We will provide
the information at a charge of 12GBP.
Our privacy policy is compliant with the UK Data Protection Act, and has been
drawn up under guidelines provided by the OECD, COPPA and Truste. At this time,
there are no formalised global or regional regulatory or self-regulatory
schemes applicable to our web site or organisation. In order to demonstrate
that our privacy policy accords with the above privacy instruments, we are:
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voluntarily committed to a Self Assessment procedure
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voluntarily committed to a Third Party Organisation certification
SmileMiles may update this Statement from time to time as our privacy
enforcement practices are modified or changed. We will post any changes here in
this privacy statement, on the homepage, and other places we deem appropriate,
so that you are aware of the information we collect, how we use it, and under
what circumstances, if any, we disclose it. We will notify you about
significant changes in the way we treat Your Information by way of the e-mail
address specified in your account or by placing a prominent notice on the Site
for a period of not less than thirty days prior to the change. We encourage you
to periodically review this page for the latest information on our privacy
practices.
If you have an enquiry or concern about our privacy policy, please contact our
privacy office using the address supplied in your joining email, or via the “contact
us” page on our web site. We do not recommend another means by which
visitors' concerns may be addressed.
Copyright SmileMiles Ltd.
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