Privacy Policy

HIGHLIGHTS FOR CHILDREN, INC. PRIVACY NOTICE

Last revised: January 4, 2024

Your privacy is important to us. This Privacy Notice (the “Privacy Notice”) governs the use of your Personal Information (as defined below) by Highlights for Children, Inc. and/or its affiliates except Highlights for Children International, Inc. (collectively, “we,” “us,” or “our”), including, without limitation:

• the websites currently located at www.highlights.com and www.highlightskids.com (collectively, the “Website(s)”);
• the mobile applications Highlights Hidden Pictures Puzzle Town, Highlights Hidden Pictures Puzzles, Highlights Shapes, Highlights Monster Day, Highlights Digital Magazine, Highlights Everyday, Highlights All About, and Highlights Magazine Amazon Alexa Skill (collectively, the “Mobile Applications”); and
• any other products, services, interactive features, widgets, and resources we offer, and all other content included within the Website(s) and/or Mobile Applications (all of which are collectively referred to as the “Services”).

This Privacy Notice explains what information we collect about you, how we use or share such information, how to exercise any rights you may have with respect to your Personal Information, and the safeguards we have in place to reduce the risk of unauthorized access and use.

Please carefully read this Privacy Notice, which is part of our Terms of Use, before using our Website(s), Mobile Applications, and/or Services. If you do not agree with the Terms of Use and/or the Privacy Notice, please refrain from using our Website(s), Mobile Applications, and/or Services. By accessing or using our Website(s) and/or Mobile Applications you agree to our use of your information consistent with the Terms of Use and this Privacy Notice.

PRIVACY NOTICE CHANGES

This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Such changes to this Privacy Notice will be posted on the Website(s) and within the Mobile Applications and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of the Website(s), Mobile Applications, or Services.

TABLE OF CONTENTS

1. Children’s Privacy
2. Information We Collect 
   a.    Personal Information
   b.    Business Information
   c.    Usage Data and Site Activity
   d.    Communication Recordings
3. How We Collect Information
   a.    Personal Information You Provide
   b.    Third-Party Data Sources
   c.    Cookies and Internet-Based Advertising
   d.    Third Parties that Collect Information on Our Sites
        i.    Automatic Data Collection
        ii.    Social Media
4. How We Use and Share Information
   a.    Generally
   b.    Opt-Outs
   c.    Reviews and Testimonials
   d.    Gifts
   e.    Service Providers
   f.    Sharing and Selling Information with Third Parties
5. How Long We Retain Your Data 
   a.    Access and Correction
6. Other Privacy Provisions 
   a.    Security 
   b.    Links and Other Websites 
   c.    Compliance with Laws and Law Enforcement
   d.    Other Transfers
7. California Consumer Rights
   a.    California Privacy Rights for Minor Users
   b.    Right to Opt-Out of the Sale or Sharing of Personal Information
   c.    Right to Know
   d.    Right to Deletion
   e.    Submitting a Request
   f.    Authorized Agent
   g.    Non-Discrimination Notice
   h.    Do Not Track (DNT)
8. Contact Us

CHILDREN’S PRIVACY

Except as provided below, the Website(s) are not intended for children under the age of 13 and we do not knowingly collect Personal Information (as defined below in “Information We Collect”) from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records. A parent may review or have deleted a child’s personal information, and refuse to permit further collection or use of such information, by contacting us at the email or mailing address below.

The website www.highlightskids.com allows children under the age of 13 to submit questions and comments via surveys and comment forms. We take steps to limit the information we obtain from children through such surveys and forms to prevent the information from being Personal Information. For example, we sometimes ask for the child’s first name, age, and state of residence, but we will not ask for last name, email address, or other information that would allow us to personally identify the child. If we become aware that we have inadvertently received Personal Information from a child under the age of 13 via such surveys and forms, we will delete such information from our records.

All of our Mobile Applications are certified by the Children’s Advertising Review Unit (CARU, operated by the Council of Better Business Bureaus) under its Safe Harbor program. As such, our Mobile Applications comply with the Children’s Online Privacy Protection Act as well as with CARU’s Self-Regulatory Guidelines for Children’s Advertising, including the Guidelines for Interactive Electronic Media. We do not collect Personal Information about a child via Mobile Applications. We do allow adults to provide an email address to receive product information and special offers but the submission form is behind a parental gate. We use Mixpanel Analytics, which gives us information about how our Mobile Applications are being used but this information is anonymized and is not Personal Information. More information about CARU and the Safe Harbor program can be found here.

We receive Personal Information about a child if a consumer purchases a product or service from us and provides us with a child’s Personal Information in order to facilitate shipping or delivery of the product or service to the child. Generally, the Personal Information we receive in such instances is limited to the child’s name and address.

California Privacy Rights for Minor Users

If you are a California resident under the age of 18, you have the right under California Business and Professions Code Section 22581 to view, correct, or remove certain information provided by you or publicly posted by you, by accessing your Highlights for Children account through www.highlights.com, www.highlightskids.com, or another product or service as applicable and editing/removing your information. You will need your password to access your personal account. You may also send us an email asking us to remove your posted information or content at privacyteam@highlights.com. 
Alternatively, you may write to us at: 
Highlights for Children, Inc.
Attn: Privacy Team
1800 Watermark Drive, 
Columbus, Ohio 43215 

Please be specific in your request. We will be happy to review, update, or remove your posted information and/or content as appropriate. Residual copies of your posted information and/or content that have been removed from your account may remain in our backup systems for approximately one month. We may still retain your posted information or content to resolve disputes, enforce our agreements with you, or comply with legal requirements; however, we will take steps to limit use of the removed information and/or content to only these purposes.

 

INFORMATION WE COLLECT

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Personal identifiers and contact information such as name, mailing address(es), email address(es), phone number(s), user ID, and device ID;
• Sensitive personal identifiers such as gender and age;
• Commercial Information, such as purchase history;
• Other demographic information such as marital status, what language(s) you speak, whether you own or rent a property, information related to co-owners or other persons living at the property, household income;
• Banking/financial information such as payment card information, checking account numbers, payment preferences;
• Commercial information such the type(s) of Services subscribed to, service dates, customer type, account balance and status;
• Internet and network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system;
• Geolocation data such as geographic location indicators from mobile devices, websites, and service addresses;
• Documents containing personal information such as order forms, copies of checks, and drivers’ licenses, or other documents you provide to validate your identity in connection with exercising any privacy rights you may have;
• Audio/visual information such as call recordings, chat transcripts, text messages, and pictures or images you provide;
• Professional/employment information such as employer, occupation;
• Education information such as education level; and
• Inferences drawn from other Personal Information or data that relate to your familial relationships, preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

While we generally do not obtain other Personal Information that is often considered “sensitive,” such as genetic or biometric information (e.g., fingerprints, facial recognition images), government issued identification numbers (e.g., social security numbers, passport numbers), insurance policy numbers, or medical, health, or insurance-related information, we may do so when such Personal Information is necessary to offer you certain Services or where otherwise permitted by law. 

The types of Personal Information we collect about you may vary based on how you use our Services and your relationship with us.

Nothing in this Privacy Notice addresses, or should be read to limit or restrict, how we collect, use, or process, anonymous, de-identified, or aggregate information. 

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, and bank account information (collectively, “Business Information”). We do not treat this information as Personal Information, unless required by law, because it relates to a business or a business contact.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Website(s) and/or Mobile Applications and in connection with using the Services (“Usage Data”). For example, each time you use the Website(s), we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Website(s). If we can reasonably associate this data with you, directly or indirectly, we treat it as Personal Information. If we cannot reasonably associate this information is with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written or electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

HOW WE COLLECT INFORMATION

Personal Information You Provide

We may ask you to provide us with Personal Information when you communicate with us online or offline, including events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Services or we may not be able to fulfill your requested interaction. In addition, we may acquire your Personal Information when you contact us by telephone, postal mail, social media interaction, or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire Personal Information that you provide about other people, for example, when you refer a friend to our Services or purchase one of our Products as a gift.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokers, marketing and sales agencies or partners, analytics firms, and other customers or consumers.

Cookies and Interest-Based Advertising

Cookies and Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the Services, such as saving your preferences from visit to visit to present you with a customized version of the Websites, without requiring you to log into the Website(s) each time you visit. We also do this so that we may determine the usefulness of our navigational structures and to support our marketing efforts. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of the Website(s) or Services may not work if you delete or disable cookies.

We use the following types of cookies:

• Session Cookies: Session cookies keep track of you or your information as you move from page to page within our Websites and are typically deleted once you close your browser. For example, session cookies allow our online order forms to function properly.
• Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to our Websites. For example, persistent cookies may allow us to remember your preferences.
• Advertising Cookies: Advertising cookies are used to learn more about you and advertise products/services that might interest you.
• Analytics Cookies: Analytics cookies help us understand how our Websites are working and who visits them. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Notice. Google also provides a free browser add-on, called the Google Analytics Opt-out Browser Add-on, which provides website users the ability to prevent their data from being used by Google Analytics. You may download the browser add-on here.

We employ software technology that enables us to track certain aspects of a user's visit to the Websites. This technology helps us better manage content on the Websites by informing us what content is effective, how consumer engage with our Websites, and how consumers arrive at and/or depart from our Websites. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs". Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session, such as IP address and the type of browser used, and Personal Information, if provided by the user.

If you arrive at the Website(s) by "clicking through" from another website, certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Website(s), may be transmitted to us and we may use it. You should review the Privacy Notice of any website from which you reached the Website(s) in order to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Notice. Such information may be associated with other User activity data or Personal Information.

Third Parties that Collect Information on Our Sites

Automatic Data Collection

Certain third parties collect Personal Information and/or Usage Data from users of our Sites using automatic collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their respective privacy policies. You may opt-out of certain cookies, as detailed above at “Cookies and Automated Tools.”

Residents of California, and other certain other consumers, may be able to opt-out of the sale and sharing of Personal Information as outlined below under “Additional California Consumer Rights.”

Social Media Widgets

The Website(s) and/or Mobile Applications may include social media features, such as the Facebook Like button, Google Plus, Pinterest, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.

HOW WE USE AND SHARE INFORMATION

Generally

We may use Personal Information for internal purposes, such as for: 

• Account creation, fulfillment, servicing, and customer support: to create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their products and services, engage in general customer service operations, provide newsletters, announcements, service bulletins and other information, or to otherwise fulfill the purpose for which you provide your information;
• Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;
• Collection and credit reporting: to collect on outstanding balances and update credit reporting agencies;
• Customer communications and interactions: to administer surveys, polls, sweepstakes, contests, promotional events, or to otherwise communication and interact with customers and consumers;
• Website use and analytics: to provide you with access to and use of our Websites and Services, analyze consumers’ use of our Websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data;
• Eligibility and pricing: to determine if consumers are eligible for certain products, services, or offers and the pricing related to such offers;
• Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;
• Business operations: to evaluate, develop, and improve business operations, products and services offered, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, perform business administration, and other normal business activities. Your geolocation data may specifically be used to show you content (including advertising and sponsored messaging) based on geographic location;
• Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others;
• Information security and fraud prevention: to operate information security and anti-fraud programs; and
• Other purposes: for any other purpose with your consent.

Communication Opt-Outs

To opt-out of certain communications, please follow the instructions at https://www.highlights.com/communication-preferences or, in the case of commercial emails, by clicking on the opt-out link in the footer of all non-transactional email messages.

Reviews and Testimonials

If you provide a review or testimonial, we may post it publicly on our Websites, Mobile Applications, or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Gifts

We may collect information about gift recipients to fulfill the purchase of a gift. Personal Information about gift recipients is not shared with third parties for their direct marketing purposes.

Service Providers

We allow access to your Personal Information by Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services. Categories of service providers we use include:

• Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and collect past due balances;
• Payment processors, which help us to accept and process the payments for our products/services to you;
• Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys, and other outreach campaigns;
• Research and development vendors, which help us develop and improve our products and services;
• Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);
• IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
• Professional service firms, which provide accounting, legal, auditing, and other professional services; and
• General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information we provide to them other than as specified by us. 

In the past twelve months we may have shared each category of Personal Information that we collect (listed above) with Service Providers.

Sharing and Selling Information with Third Parties

There are times when you provide Personal Information to us in areas of the Service that may be managed or participated in by one or more Third Party Business(es). Moreover, we rent, sell, share, and transfer Personal Information to: 
     (i)    list buyers who market their goods and services (commonly known as “list rental”); 
     (ii)    our advertising, marketing, and sponsorship clients to market their goods and services; 
     (iii)    “data coops,” which are pooled databases containing the customer information of multiple publishers to enable the marketing use of such customer information by participating publishers; 
     (iv)    consumer data suppliers/resellers, data enrichment providers and aggregators, and other entities in the online behavioral advertising ecosystem for purposes of online behavior advertising (“OBA”), data optimization, lead generation, and other data-driven projects; 
     (v)    social media and social networking services; and 
     (vi)    companies that help us with our Products and Product recommendations. 

In all such cases, the Personal Information may be used by us and by such Third Party Businesses for their own purposes, each pursuant to its own privacy policies. While we may seek to require Third Party Businesses to follow appropriate privacy policies, we do not bear any responsibility for any actions or policies of third parties.

We also share your Personal Information with our parent, subsidiaries, affiliates, and other related entities, such as those listed at: https://shop.highlights.com/.

In the past twelve months, we sold or shared the following categories of Personal Information to some of the Third Party Businesses with which we work:

• Personal identifiers and contact information such as name, mailing address(es), email address(es), phone number(s), user ID, and device ID;
• Commercial Information, such as purchase history;
• Other demographic information such as marital status, what language(s) you speak, whether you own or rent a property, information related to co-owners or other persons living at the property, household income;
• Commercial information such the type(s) of Services subscribed to, service dates, customer type, account balance and status;
• Internet and network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system;
• Geolocation data such as geographic location indicators from mobile devices, websites, and service addresses;
• Audio/visual information such as call recordings, chat transcripts, text messages, and pictures or images you provide;
• Professional/employment information such as employer, occupation;
• Inferences drawn from other Personal Information or data that relate to your familial relationships, preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

HOW LONG WE RETAIN YOUR DATA 

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. We do so in accordance with our data retention policies and applicable laws.

Access and Correction

If you would like to receive access to your information and/or request the correction of inaccurate information, you may do so by sending an email to privacyteam@highlights.com or sending a written request to the following postal address: 
Highlights for Children
Attn: Privacy Team
1800 Watermark Drive
Columbus, Ohio 43215

OTHER PRIVACY PROVISIONS

Security

We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ reasonable administrative, technical, and physical safeguards to protect such personal information from unauthorized access, disclosure, and use. However, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Website(s) and/or Mobile Applications we cannot and do not guarantee the absolute security of any information you transmit on our Website(s) and/or Mobile Applications, and you do so at your own risk.

Links and Other Websites

Please be aware that our affiliated institutions, promotional partners, advertisers, sponsors, and other third-party websites accessible through the Website(s) may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information through linked websites.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of ourself, users, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable law.

Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our reasonable judgement, the new entity plans to handle your information in a way that materially differs from this Notice.