Safety and Privacy at iTwixie.com
Last Updated: May, 2018
iTwixie.com is managed via a team of writers and designers in the culturally-rich city of Pittsburgh, PA and New York City, NY. At iTwixie, we believe in the power of every girl as well as the collective power of girls who stand together.
If you have questions or concerns regarding this statement, you should contact Rebecca Gaynier at firstname.lastname@example.org, who will ensure your concerns will be addressed swiftly and to your satisfaction. Everyone at iTwixie shares your child’s safety as our top priority.
Safety on iTwixie
What Information We Collect
During registration, girls create a username, password, and provide a parent’s email address, zip code, country, birthday, and the username by whom they were invited, if there is one. We also ask for a parent’s email address, when she utilizes the tell-a-friend feature, as well as the email address of a friend. We will automatically send this friend a one-time email inviting her to visit the site. We delete the friend’s email address once the invitation has been sent.
If a girl wishes to contact us, we will ask for her first name and email address. We use this information to respond to her inquiry. This information is deleted once the response has been sent.
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, which does not identify individual users, 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.
We use both session ID cookies and persistent cookies. We use session cookies to make it easier for the user to navigate our site. A session ID cookie expires when the user closes her browser. A persistent cookie remains on her hard drive for an extended period of time.
We set a persistent cookie to store user passwords, so the user doesn’t have to enter them more than once. Persistent cookies also enable us to track and target the interests of our users thus enhancing the users’ experience on iTwixie.
If a user rejects cookies, she may still use our site, but her ability to use some areas of iTwixie, such as contests or surveys, will be limited.
Third Party Tracking Technology
Some of our third party business partners employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs) and cookies, that help us better manage content on our site by informing us what content is effective. 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 have no access or control to these third party tracking technologies.
How We Use the Information We Collect
We only use the information we collect for the purpose that it was requested. A child’s participation in or access to an activity will not be conditioned on her providing more personal information than is reasonably necessary for that activity.
Girls are able to post content as well as comments on our monitored blog, tell-a-friend about the site, post monitored videos, photographs, podcasts and contact us.
It’s an iTwixie World
The iTwixie dynamic invites participation, not personal information! We believe that this is a great way to help keep our kids safe and inspired online. So we do four things to help make the iTwixie World safe for our girls:
- We ask girls to make up a username – and not to use their real first and last names-when they sign up to join iTwixie. We moderate posts and do not allow any Personally Identifiable Information to be posted. If at any time you would like any information about your daughter to be deleted, just contact us and we will delete that information as quickly as possible.
- We set up several reminders for the girls to use this username throughout the site on posts, in videos and even when posting comments, and to refrain from sharing information such as addresses, phone numbers or even their school name. We also employ monitoring tools to ensure that no Personally Identifiable Information is posted by any means.
- iTwixie’s trained editorial team searches and removes those accidental references to addresses, towns, phone numbers or school districts, from input before it’s posted to iTwixie. iTwixie will not hesitate to block any account if our trained editorial staff observes continued, persistent or obvious abuse against the iTwixie Pledge.
- If we cannot remove Personally Identifiable Information from a post without dramatically altering its composition, we will not allow its posting. We will send back an email to the parent explaining the problem so that the member is able to create another posting without personal information in it. We will delete any personal information of those under 13.
The iTwixie Pledge
When girls join iTwixie, we ask them to read through and sign, with their parents, the iTwixie Pledge. It’s here that we set up the positive and empowering tone of iTwixie, which we also use consistently to monitor throughout the site. iTwixie will only allow respectful, empowering comments, that do not disclose full names, addresses, phone numbers or the name of a child’s school.
Check out the iTwixie Pledge.
Agents/Service Providers We use other third parties such as a Web hosting company to host our Web site and a shipping company to send out prizes on our behalf. These third parties are prohibited from collecting or using your personal information for their own promotional purposes.
Business Transitions In the event iTwixie, Inc. goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personally Identifiable Information will likely be among the assets transferred. You will be notified via prominent notice on our home page.
iTwixie.com is managed 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. Parental permission must be provided to participate. We 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, we hold a parental 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.
We 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.
To receive earned iTwixie gear, or participate in a challenge where something would be mailed to her home, an iTwixie parent is asked to provide a mailing address for the gear/prize.
iTwixie seeks parental involvement as a means to fulfill the iTwixie vision of building character in today’s tween girl: to strengthen her mind, body, spirit, the bond between girls and their community-her iTwixie World!
iTwixie Tween Trends
Tween Trends is iTwixie’s research arm, which we use to continually look for ways to make iTwixie and all of our messages for girls, even those on behalf of sponsors and partners, better. So we monitor the site’s activity in aggregate. We never analyze the activity of one girl. By looking at the trends of activities on the site, we can gain insight into what’s most interesting to today’s savvier tween girl and what’s less appealing. This allows us to keep iTwixie fresh and meet its members needs, and offer articles and activities that are exciting to tween girls.
What Is COPPA?
The Children’s Online Privacy Protection Act is a United States federal law that regulates the online collection, use and disclosure of personal information from children under the age of 13. It requires that parents or guardians provide consent before personal information is collected online or is publicly disclosed online, from or by children under 13 years old. The law also sets out the acceptable ways of determining consent and providing transparency online.
iTwixie firmly enforces its policy to never disclose (and to remove if necessary) any Personally Identifiable Information on iTwixie. iTwixie reaches out to parents and caregivers to engage adults in learning about iTwixie and becoming part of the iTwixie Nation. That’s why we send an email to parents and caregivers to let them know of their child’s interest in iTwixie and to give a little information about us and our site. We ask parents and caregivers to review our policies and sign the iTwixie Pledge before their child can participate on iTwixie. And we invite parents and caregivers can subscribe to iTwixie’s Parent Circle section to keep up on what’s new in the iTwixie World. We are committed to doing all we can to foster the safest online experience possible, and welcome input from parents, caregivers, educators and adults who want to help advance character building and safety of tween girls.
Submissions to iTwixie
All articles, opinions, pictures, videos and podcasts submitted to iTwixie will correspond to that girl’s username, not her real name. A girl’s username, age, country and state will appear with the submission if it is provided. We monitor all postings to the site prior to posting it publicly in order to remove any Personally Identifiable Information.
If your daughter creates a blog, submits videos, podcasts, or photos on this web site, you should be aware that iTwixie will monitor these submissions and will not post any Personally Identifiable Information or inappropriate content.
How to Delete Information From iTwixie
Parents may remove, delete or update an account or any information posted on iTwixie by contacting us at email@example.com. If your child is not a member of this site but her photo or video appears on iTwixie you may also contact us at firstname.lastname@example.org if you wish to have us remove your child’s photo or video.
Please feel free to contact iTwixie, Inc., at:
Please send all submissions and correspondences to:
4551 Forbes Avenue
Pittsburgh, PA 15213
Please visit GetNetWise.org and discuss the “Kids Safety” section with your child. If at any time you or your child experiences questionable activity on iTwixie, your immediate communication of the matter would be appreciated and urgently attended to by our staff.
Together, we can ensure that our tween girls enjoy positive and character-building experiences in the vast and wonderful world of opportunity that today’s internet offers.
Bulletin Boards/Chat Rooms/Blogs/Forums
When a girl uses our monitored blog feature on iTwixie, you should be aware that any attempts to post Personally Identifiable Information or anything deemed inappropriate by our editorial staff, will be deleted prior to posting the blog entry. In addition, girls are able to submit videos, photographs and podcasts to iTwixie for broadcasting on the site. We take reasonable measures to ensure that no personal information including full name, phone number, geographical information, school information, family information or third party information is shared on the site in any manner.
iTwixie offers an instant messaging/chat feature on iTwixie.com called Twixing. In order to join iTwixie’s Twixing, a girl must subscribe to a special Twixing membership that requires a nominal fee. This fee collection allows iTwixie to know that parents/caregivers are aware that their daughter has joined iTwixie’s Twixing, which is important to ensure the safety of our girls.
In addition, COPPA requires that we obtain “verifiable parental consent” in order to allow a child to engage in activities where they might share their personal information with others participating in an online activity. COPPA allows a website operator to process a credit card transaction in order to obtain verifiable parental consent. Since Twixing membership requires a paid subscription, the successful credit-card transaction provides for the verifiable component needed to process parental consent.
At iTwixie, we recognize the need to keep our daughters safe from inappropriate content as well. That’s why iTwixieAdmin, an specially-trained adult moderator, participates in every Twixing session on iTwixie. iTwixieAdmin keeps the conversation on iTwixie positive, respectful and appropriate.
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.
In order to make a purchase from us, you must use our shopping cart provider to finalize and pay for your order. Its privacy statement and security practices will also apply to your information. We encourage you to read that privacy statement before providing your information.
If you have any questions about security on iTwixie, you can send email us at email@example.com
Changes in this Privacy Statement
If we decide to change our privacy practices, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify, by email, and/ or by means of a notice on our Web site. If we make material changes to how we collect and use Personal Information from children under age 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child’s Personal Information.
4551 Forbes Avenue
Pittsburgh, PA 15213