Privacy Policy

Last Updated: June 11, 2010

To help ensure a positive experience for our visitors, we provide you with this Privacy Policy.

The Privacy Policy describes what information we collect, how we collect it, how we use it, how we store and protect it, and how we disclose personal information that may be collected by Smarty Education anytime you interact with Smarty Education, such as when you visit our website (www.fishsmarty.com), when you purchase Smarty Education products and services, or when you call our sales, marketing, or support associates.

We ensure that our Privacy Policy and our information practices adhere to applicable European Union Data Protection legislation, the United States Children's Online Privacy Protection Act (COPPA, http://www.ftc.gov/bcp/conline/edcams/kidzprivacy/index.html), Canadian federal and provincial privacy legislation, other applicable data privacy laws and all other applicable legislation.

Please take a moment to read the following to learn more about our information practices, including how we collect, use, store, disclose, and how we safeguard your personal information.

Smarty Education is fully dedicated to safeguarding any personal information collected. Your privacy is a priority at Smarty Education.

1. What Information We Collect

In order to become a Fish Smarty member (required to get a full access to Fish Smarty content), we request certain personally identifiable information (PII) from you during a membership subscription process. You are required to provide a parent’s account name (username), parent’s password, parent's email address, parent’s residence country, child's account name (username),  child's password, and financial information (such as credit card information and expiration date) required for online payment (described in Section 2). In the parent’s account management page you can provide Parent Name and Surname information; however, this information is optional.

The Fish Smarty website requires you to provide a parent's valid email address as stated above. This email address is correlated with the parent’s account username. We use this information to send you a message confirming membership account creation, to notify you about our privacy practices, to notify you about the services offered by Fish Smarty and features of our Web site, or to send the parent communications, and for the other purposes described in this Privacy Policy. We also need to contact you regarding any Customer Service matters, such as password retrieval or subscription extension.

We may also request a Fish Smarty name (username or name) and email address when a user submits a form through the "Contact Us" section of the Fish Smarty website so that we may respond to the inquiry. We collect the email address for the sole purpose of responding directly on a one-time basis to a specific inquiry.

The Fish Smarty website does not condition a child's or parent’s participation in an online activity on the child or parent providing more personal information than is reasonably necessary for that activity.

Fish Smarty games (concerns only the full versions of games accessible to Fish Smarty members) save games scoring for each played game level by a child on the parent’s account. The games scoring information is associated with a particular child playing the games and is enabled by default for each Fish Smarty account. Parents can disable the option of saving scoring information from the parent’s account page. Games accessible to non-members does not save games scoring.

Additionally, when visitors come to our website, we may passively collect certain non-personally identifiable computer information, such as the type of computer operating system (e.g. Windows XP or Mac OS X), the user's IP Address, the web browser (e.g. Firefox or Internet Explorer) being used, the frequency with which guests visit various parts of our sites, search keywords, conversion information, and information regarding the Internet service provider, in order to make our sites more interesting and useful to you and for various purposes related to our business. We may collect this non-personally identifiable information through the use of software technologies such as analytical solutions, unique identifiers or "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your Web experience smoother, and some of our services may not function properly.

Finally, we collect financial information (such as credit card information and expiration date) as described in Section 2 of this Privacy Policy. We do not use this financial information for any purpose other than processing payments to Fish Smarty. The financial information that you enter to purchase a membership is not stored by Fish Smarty, but, instead, is retained by our payments processing vendor for the purpose of processing credit card payments made to Fish Smarty.

If personal information is not provided to us, then Fish Smarty may not agree to Fish Smarty membership and may not be able to provide access to certain content and functionality on the Fish Smarty website, or to provide other information, products or services which may be requested.

Smarty Education Limited is the sole owner of the information collected on www.fishsmarty.com. Smarty Education Limited collects personally identifiable information from our users at several different points on our Website including registration and Customer Service contact queries.

2. Financial Information

As mentioned in Section 1, if you decide to purchase or extend a membership, the cardholder name and financial information such as credit card number, card verification code, and expiration date will be required at the time of purchase. That information is not stored by Fish Smarty, and, instead, is collected and stored by our payments processing vendor for the purpose of processing payments made to Fish Smarty. That information is safeguarded with appropriate security, and it will not be used for other purposes. Furthermore, our payments processing vendor has agreed to maintain the confidentiality, security, and integrity of the personal and financial information it obtains from the Fish Smarty website, and only to use this information on our behalf. The financial institution used is well recognized on the market and bound by all applicable privacy laws relating to the provision of financial services.

3. How We Use the Information We Collect

In addition to the purposes described in Section 1, Smarty Education uses the parent’s email address provided during membership subscription process to deliver notification regarding the site, such as any future amendments to this Privacy Policy. We also may use this information to offer products, programs, or services offered by Smarty Education.

The information submitted during the membership subscription process will be used by Smarty Education to create personalized accounts for parents and children, which will allow them to participate on the Fish Smarty (www.fishsmarty.com) website. An additional information collected on parent’s account management pages (such as Parent Name and Surname) is used to facilitate and speed up Customer Service process. The child and parent accounts can be managed by parents via the parent’s account management pages.

The games scoring information collected from the games played by children (concerns only the full versions of games accessible to Fish Smarty members) are associated with the particular children accounts and presented on the parents’ accounts pages as reports, so parents can closely interact with and guide their children’s development. Moreover, parents can disable saving games scoring option or remove permanently all associated games scoring information. Games scoring information marked before removal as “Remove scoring and use it for anonymous educational reporting.” is removed from the associated account, becomes anonymous (not associated to any account) and might be used for anonymous educational reporting purposes.

4. How We Disclose the Information We Collect

Smarty Education does not share, rent or trade personally identifying information about our registered users, including kids under 13, with non-affiliated third parties (i.e. companies who are not one of our corporate affiliates or who are not providing support to the internal operations of our company) for their promotional purposes.

With our service providers, strategic partners, and third-parties
We use other third-parties such as a shipping company to fulfill orders, and a credit card processing company to bill you for goods and services. We use email and the telephone to assist you if you have questions while using our site or regarding your order. We might share PII as necessary for the third party to provide the service. We do not allow third-party companies to solicit or advertise to our users. Our intention is to keep Fish Smarty free from any of this sort of direct advertising. These third parties are prohibited from using your personally identifiable information for promotional purposes.

We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena, or where we disclose information to service providers or other group companies who provide support for the operations of our website and who do not use or disclose the information for any other purpose. To the extent permitted by applicable law, we also may disclose PII in response 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 website, protect the security or integrity 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 PII to a third party as part of that transaction, to the extent permitted by applicable law.

5. How We Store the Information We Collect

We may transfer PII and store it outside of the jurisdiction in which a member of Fish Smarty is located. Fish Smarty website (www.fishsmarty.com) is hosted in Canada, which was recognized as a country providing an adequate level of protection by European Commission, so that the information we collect will be mainly processed and stored there.

6. How We Protect the Information We Collect

The security of your personal information is a high priority at Smarty Education. We have put in place appropriate administrative, technical, physical, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. When you enter sensitive information, such as your credit card number, or use our membership subscription form, we encrypt that information using secure socket layer technology (SSL).

The information a parent or child submits to www.fishsmarty.com that relates to his or her account is password-protected. No employee of Smarty Education nor any automated system will contact a parent by email or messaging systems asking for a parent or child’s login details, password or any other personal information related or unrelated to a Smarty Education service or product. If any message claiming or appearing to come from Smarty Education or any of its related websites is sent to you asking for such information, please report it immediately to us using the Contact Us form on the Help page.

We follow generally accepted industry standards to protect the personally identifiable 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.

You can help us by also taking precautions to protect your personal data when you are on the Internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser like Firefox or Safari.

If you have any questions about security on our Web site, you can contact us using the Contact Us form on the Help page.

7. Accessing/Updating/Correcting the Information, and Objection to Information Collection and Retention

If your personally identifiable information (PII) changes, or if you no longer desire our service, you may correct, view, update, amend, delete/remove or deactivate it using the parent’s account pages or by emailing our Customer Support using Contact Us form on the Help page.

Please be sure to include your parent’s email address and a telephone number where we can reach you. To protect you and your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.

8. Privacy Questions and Suggestions

If you have questions or concerns about Smarty Education’s Privacy Policy or data processing, please use the Contact Us form on the Help page or write us:

Smarty Education Limited,
Unit 9A, Plato Business Park,
Damastown Way,
Damastown,
Dublin 15,
Ireland

9. A Final Comment 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.

10. Effective Date and Changes to this Privacy Policy

The Privacy Policy set out above is effective as of 11 June 2010, and applies to all information previously obtained by Fish Smarty. Smarty Education may update its Privacy Policy from time to time. Fish Smarty members will be informed of any such change by us posting a new Privacy Policy on the Fish Smarty website and the effective date of any change of Privacy Policy will be clearly marked.

If we make material changes to how we collect and use Personal Information, we will notify parents here, by email, or by means of a notice on our home page in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.

We reserve the right to modify this privacy statement at any time, so please review it frequently.