Wanderlight, A Pilgrim’s Adventure
Effective Date: August 15, 2020
Welcome to Wanderlight, A Pilgrim’s Adventure (Wanderlight), which is an experiential, faith based game produced by Loyola Press (LP), an Illinois not-for-profit corporation. We are committed to providing children with a faith based, learning environment where you can feel confident that your children’s privacy is protected.
Summary of Key Points
- When using your subscription license to access Wanderlight through LP, you will never be subjected to any pop-up ads or other advertisements directed to children.
- Personal Information, or PI, is defined in this policy to mirror the text of the California Consumer Privacy Act (CCPA) and means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
- We take your privacy very seriously, and we will never monetize your Personal Information; we may use it to enhance your experience with opportunities like special promotions and offers.
- During Wanderlight registration, the only information we may ask you to provide about a child who will be using your subscription license to access Wanderlight through LP is the child’s first name (or nickname),
- We do not ask for certain sensitive PI such as social security numbers, driver’s license numbers, or biometric data. However, paying subscribers are asked for payment information when they subscribe. Please see Section 3, (Information Collection) for more information about how we safeguard payment information.
- Because the security of your Personal Information is important to us, we only ask for PI where it serves a business purpose and try to limit the collection of PI to only what is necessary to accomplish those purposes. We also use commercially reasonable physical, technical, and administrative security measures designed to safeguard all information collected by Wanderlight and LP.
Adult Users (as defined below) may contact us, their parish or parish school, when applicable, at any time as described in Section 12 (Contact Us) to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their subscription license, or to cease collecting PI from those Child Users. For information about when we automatically delete PI due to Subscription License cancellation or inactivity, please see Section 7 (Account Cancellation and Reactivation; Data Deletion).
Additional Protections and Information for School Accounts
- If you have access to Wanderlight through a School or a Parish subscription license, additional privacy protections apply because either of those institutions may provide Wanderlight with student personally identifiable information (Student Data) as defined by the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g) and its implementing regulations (34 CFR Part 99) (collectively, FERPA).
- LP will delete, or if requested by the religious or educational institution, transfer to that religious or educational institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of LP’s agreement with the applicable Institution.
Student Privacy Pledge
LP is a signatory of the Student Privacy Pledge. The Future of Privacy Forum and the Software & Information Industry Association introduced the Student Privacy Pledge to safeguard student privacy regarding the collection, maintenance, and use of student personal information. Since 2014, more than 300 companies have signed on. Signing the pledge demonstrates our commitment to complying with the highest standards for safeguarding Student Data.
1. No Ads, No External Links Guarantee
When using your subscription license to access Wanderlight through LP, you will never be subjected to any pop-up ads or other advertisements directed to children.
In addition, Child Users are unable to access external links.
2. Types of Subscription Licenses, Services, and Users
How we collect, use, and disclose information depends on the type of subscription license and the type of user. We currently offer the following types of Wanderlight Subscription Licenses through LP: Consumer Licenses, Teacher Licenses, Classroom-Linked Licenses, Parish-Linked Licenses and Parish School Linked Licenses which are described in our Terms & Conditions.
The provisions of this policy apply to all Subscription Licenses. Any differences in how these licenses are treated, is identified below.
Users of the Subscription Licenses include Child Users (any child under age 18 utilizes a Subscription License to play Wanderlight) and Adult Users (including parents and legal guardians of Child Users, teachers, librarians, parish and parish school administrators), collectively referred to as Users.
3. Information Collection
There are two general categories of information that we collect.
A. Information Users Provide to Us As more fully set forth below, we and our third-party service providers collect information that Users provide when using the Subscription License, including when Adult Users purchase a Wanderlight subscription license from LP, or contact us with a question, comment, or request, and when Child Users participate in assessments. However, we will only use or disclose this information in accordance with this policy and applicable law. Please see Section 5 (When we Disclose Information to Third Parties) below for more information and how we limit disclosure of Child User information.
Adult Users are asked to provide certain Personal Information about themselves when purchasing a Subscription License, including first and last name, email address, and telephone number (which is optional). The other information provided at registration depends on the type of Subscription License or Adult User. For example:
Payment information is collected from Adult Users who purchase a Wanderlight Subscription License, including those who purchase a Subscription License as a gift for others. For your security, we do not store your complete credit card number in our databases but retain only the first six digits and last four digits so that we can identify your Subscription License and respond to your requests and questions.
The email address of a parent or legal guardian is collected when the Adult User purchasing a Wanderlight Subscription License states that he or she is not the legal guardian, or if a teacher or administrator provides such addresses in order for parents or legal guardians to connect to the Teacher Subscription License, Parish Subscription License, or Parish School Subscription License.
The Parish or Parish School name and address (state and ZIP code only) are collected from Adult Users who register for a Teacher, Librarian, Parish or Parish School Subscription License. Adult Users who purchase a Parish or Parish School Subscription License are asked to provide the first name (or nickname).
In addition, Adult Users can provide us with information through
separate password-protected sections (i.e., the Parent Section or Teacher
Dashboard) of the Services. These sections, accessible via the Menu
the Services, allow Adult Users to administer their Accounts, including when
they add Child Users, seek customer support,
B. Information We Collect from Users We and our third-party service providers collect Personal Information directly from subscription license users Users in the form of the actions they take and activities they complete when using the subscription license. For example, from Adult Users, we may collect information about patterns of usage and order history; from Child Users, we may collect information about patterns of usage, which activities a child commences and completes, when a child starts and stops an activity, which areas of the Wanderlight game the child frequents, which prayers the child likes, the number and kinds of quests the child undertook, how many eggs the child collects, and the child’s choice of Avatar.
We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address, your geolocation, and the websites you visited prior to visiting the Services. When you download and use one of our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
What Are Cookies?
Cookies are small text files placed on your device to collect standard internet log information and visitor behavior information. The cookies may transmit information via your browser with a purpose of authenticating or identifying the computer (via, e.g., the IP address) or the User. Cookies may contain information such as registration data and User preferences.
- automatically collect certain technical information from your computer or mobile device over time and across different websites, including when you use the Services, such as your browser type, operating system, device type, the page served, your IP address and your geolocation. When you download and use our App(s), we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;
- collect and store information about your location. The location information we have access to may include (1) your postal code, if you provide one to us; and (2) the approximate geographic region your computer or mobile device is located in, as determined from your IP address. However, we do not collect your street name and the name of your city/town. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such IP information. We also have access to your school or classroom location if you (as a teacher) provide it to us;
- we may collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your IP address, geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. In addition, if you choose to turn on your Bluetooth, wi-fi or other geolocation functionality when you use our App(s), we may collect and use your geolocation information; and
When a server receives a request from a device which stores a cookie from a website, the server is able to use the information stored in the cookie in combination with the information stored on the server to allow the website to respond to you as an individual and to tailor their operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. A cookie cannot collect information from your computer and cannot carry any viral or other damaging files.
Types of Cookies
We use the following cookies:
These cookies are essential to provide you with services available through Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow us to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information, and to monitor the level of activity on our Services.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
Except as otherwise provided in this policy, such as when a California resident has opted-out of our sharing Personal Information for valuable consideration, by continuing to use our Services, you are accepting our use of these cookies that make advertising and communications more relevant to you and your interests and further help us to improve our Services.
Pixel Tags and IFrames:
We also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of Users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on web pages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our Users’ Personal Data.
We and our third-party service providers may use the information
collected through these technical methods for a number of purposes, including
delivering content, tracking and enhancing our Users’ experience on the
. For example, when you return to the Services after logging in,
cookies help the Services recognize who you are without having to log back in.
For more information, see (What are Cookies) above. The information collected through these technical methods on the
child-directed portions of the Services are used only to support the internal
operations of the Services. We do not allow third-party advertising networks to
collect information about Child Users who are logged into their Accounts.
Push Notifications and SMS. Additionally, if you downloaded the App on your mobile device to access the Services, as part of your use of the Services we may ask if you would like to receive push notifications, which may include alerts and notifications, badges, banners, and sounds on your mobile device. You may choose to stop receiving push notifications at any time by changing the settings on your mobile device. We may also ask if you would like to receive SMS text messages. Please note that your carrier may charge you for the text messages you receive. To permanently stop receiving SMS text messages from us (if you are located in the U.S. or Canada) text STOP, CANCEL, or UNSUBSCRIBE in reply to any SMS text message sent by us.
4. How We Use Information
We will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money..
We and our third-party service providers may use the information collected from Users as follows:
Adult User Information Information collected from Adult Users may be used:
- To permit you to purchase a subscription license in order to access the Wanderlight game, including, for example, to send you communications about your subscription license For certain Consumer and Other Subscription licenses, to complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
- To respond to your inquiries and fulfill your requests, retrieve your password, or provide technical support. For all active subscription licenses, you may not opt out of receiving administrative messages from us regarding your subscription license, such as password reset emails and customer support messages.
Child User Information Information collected from Child Users may be used:
- To analyze, provide progress reports on, or provide an assessment of a Child User’s performance to the Adult User on the Account.
Both Adult and Child User Information Information collected from both Adult and Child Users may be used:
- To allow us to assess and improve Wanderlight, its educational and faith based content, and to inform our understanding of Wanderlight’s user base.
- To maintain and analyze the functioning of Wanderlight.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain (collectively, (a)-(g) are Other Uses and Disclosures).
5. When We Disclose Information to Third Parties
Information collected from both Adult and Child Users will not be disclosed except as follows:
- Where parents or legal guardians have linked a Consumer Subscription License to a Parish, a Parish School, or a Teacher Subscription License as described in the Terms & Conditions, the Adult Users of both subscription licenses will be able to review the progress and details of their Child Users within both subscription licenses.
- As we believe to be necessary or appropriate as set forth above in Other Uses and Disclosures and in other instances substantially similar to those listed in this Section.
- Where legally required and in certain other cases, we may make such disclosures without first providing notice to Users.
We do not disclose the Personal Information of any Child User to third parties for any marketing or promotional purposes. This also means that we do not share the Personal Information of children under the age of 16 for valuable consideration.
6. How to Access, Change, or Delete Account Information
Consumer Subscription Licenses: An Adult User can review or change the information they provided when they purchased the subscription license. In addition, Adult Users may contact us at any time as described in Section 12 (Contact Us) below to request that we provide for their review, or delete from our records, any PI they have provided about Child Users associated with their subscription license, or to cease collecting PI from those Child Users, as applicable. Please keep in mind that a request to delete PI may lead to cancellation of your subscription license or the inability to access Wanderlight, and if a Parish, a Parish school or a Teacher subscription license is linked to a Consumer subscription license, a request to delete PI in one of the subscription licenses may be reflected in your other subscription license.
Parish or Parish School Subscription Licenses: If you are accessing Wanderlight using a Parish or Parish School Subscription License that is integrated with a school student information system (SIS), unless otherwise required by law, any request to access or make changes to or delete PI including Student Data must be made by the religious or educational Institution within the SIS. Once the changes are made within the SIS, the changes will automatically appear within the Parish or Parish School Subscription License.
If you are using Wanderlight through a Parish or Parish School Subscription License and the religious or educational institution is not integrating its SIS with the Wanderlight, unless otherwise required by law, any request to access, make changes to, or delete PI including Student Data must be made by the religious or educational institution’s designated administrator for the Parish or Parish School Subscription License . The administrators will be provided access to the Parish or Parish School Subscription License User Profile pages in order to update, correct, or delete the information contained therein.
7. Account Cancellation and Reactivation; Data Deletion
At any time, Adult Users, with the exception of Parish or Parish School Subscription Licenses, may cancel their Subscription Licenses by________?. Parishes or Parish Schools may contact us as described in Section 12 (Contact Us) below to cancel such Subscription Licenses.
For Parish and Parish School Subscription Licenses, if you cancel your Subscription License, we will delete all Subscription License Information 48 hours after the cancellation, unless a Child User’s parent or legal guardian has linked to the Parish or Parish School Subscription License, in which case we will delete that Child User’s Subscription License Information as described in the previous paragraph. Please note that canceling an entire Parish or Parish School Subscription License will result in the loss of activities and progress data for every Child User, except for Child Users whose parents or legal guardians have linked to the Parish or Parish School Subscription License. If a Subscription License Information is not canceled, we will delete all Subscription License Information 24 months after the last activity on the Parish or Parish School Subscription License.
For Parish and Parish School Subscription Licenses, Adult Users should contact their respective religious or educational Institution for any questions regarding Subscription License cancellation and data deletion. If a religious or educational institution terminates its agreement with LP, LP will delete, or if requested by the religious or educational institution, transfer to the religious or educational institution all Student Data within 90 days (or a shorter time frame if required by applicable law) following the termination of the agreement with the applicable religious or educational institution.
Upon cancellation of a subscription license, de-identified Adult and Child User information may nonetheless persist internally in our archive files or similar databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics as permissible by applicable law
8. California Privacy Rights
Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. In this section “you” or “your” refers to California residents. Under the new law we are required to disclose the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:
- Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we hold.
- Right to data portability. You may be entitled to receive a copy of your electronic Personal Information in a readily-usable format.
- Right to disclosure. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request.
- Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. You can exercise such right to opt-out.
As stated in the Summary of Key Points above, we will never monetize the Personal Information of any User of the Services by providing it to a third party in exchange for money. The CCPA has a broader definition of the term “sell” which includes disclosing Personal Information to any third party for valuable consideration. You can exercise such right to opt-out..
In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your personal information.
We use and disclose the information we collect for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, and other activities to improve our service, and understand how users interact with our services.
In the preceding 12 months, we have also disclosed the following categories of personal information for one or more business purposes: identifiers, commercial information, internet or electronic network activity information, geolocation data, and inferences we draw or derive about users
Exercising Access, Disclosure, Data Portability, and Deletion Rights
To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us as set forth in in Section 12 (Contact Us) below.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your Child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.
9. Location of Information Processing
The Wanderlight game is controlled and operated by LP from the United States.
The security of your personal information is important to us, and we employ physical, technical, and administrative security measures designed to safeguard the information collected by Wanderlight. We use industry standard SSL (secure socket layer technology) encryption to transfer PI. Other security safeguards include, but are not limited to, data encryption, firewalls, and physical access controls to buildings and files.
Subscription License holders create a password in the registration process. You can help protect against unauthorized access to your Subscription License and PI by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Subscription License . At registration, we assign a Member ID to each Subscription License and use those Member IDs to authenticate logins, allow access to the subscription content, and monitor compliance. The Member ID is also used to authenticate users when requesting technical support. Access to information is limited (through user/password credentials and two-factor authentication) to those employees who require it to perform their job functions.
Parish and Parish School Accounts
We are committed to maintaining the security and confidentiality of your and your children’s information, including, but not limited to, any Student Data, which we receive through Parish or Parish School Subscription Licenses. Some of the precautions we take include (a) limiting employee access to your and your children’s PI to only those employees with a need to such access to fulfill their job responsibilities; (b) conducting background checks on our employees and, specifically, upon all employees that may have access to Student Data; (c) requiring employees to sign confidentiality agreements upon hiring; (d) conducting regular employee privacy and data security training and education; and (e) protecting PI with commercially reasonable technical, contractual, administrative, and physical security safeguards.
Please be aware, however, that no information system can be guaranteed to be 100 percent secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Subscription over networks that we do not control, including the internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 12 (Contact Us) below.
12. Contact Us
For All Subscription Licenses (Consumer, Parish and Parish School Subscription Licenses)
3441 N. Ashland Ave.
Chicago, IL 60657
Telephone Number: 800-803-3217
Email address: firstname.lastname@example.org
For questions or complaints about COPPA compliance, please contact iKeepSafe Safe Harbor at COPPAPrivacy@ikeepsafe.org.