Before the

FEDERAL TRADE COMMISSION
Washington, DC 20580


In the Matter of

Request for Investigation of Nickelodeon’s
and PlayFirst’s Mobile Application
SpongeBob Diner Dash Mobile Application
)
)
)
)
)













COMPLAINT AND REQUEST FOR INVESTIGATION

Submitted by

Center for Digital Democracy










Of Counsel:

Jordan Blumenthal
Jessica Wang
Georgetown Law Students



December 17, 2012

Angela J. Campbell
Laura M. Moy
Institute for Public Representation
Georgetown University Law Center
600 New Jersey Avenue, NW
Suite 312
Washington, DC 20001
(202) 662-9535
Counsel for Center for Digital Democracy


Table of Contents
I. Background....................................................................................................................1
A. Nickelodeon.............................................................................................................2
B. PlayFirst ...................................................................................................................3
C. SpongeBob Diner Dash............................................................................................5
D. Downloading SpongeBob Diner Dash.....................................................................7
II. Nickelodeon and PlayFirst Make False Representations in their Privacy
Statements for SpongeBob Diner Dash .........................................................................9
III. Nickelodeon and PlayFirst Fail to Comply with the Children’s Online Privacy
Protection Act ..............................................................................................................11
A. SpongeBob Diner Dash Is Directed to Children Under the Age of 13..................11
B. Nickelodeon and PlayFirst Collect Several Types of Personal Information
from Children.........................................................................................................14
1. First and Last Name....................................................................................... 15
2. Email Address................................................................................................ 16
3. Other Online Contact Information................................................................. 16
C. Nickelodeon and PlayFirst Fail to Comply with COPPA’s Notice
Requirement ...........................................................................................................20
D. Nickelodeon and PlayFirst Fail to Comply with COPPA’s Requirement that
it Obtain Verifiable Parental Consent Before Collecting Personal
Information from a Child.......................................................................................23
IV. Conclusion ...................................................................................................................23

Appendix A: Nickelodeon and PlayFirst Press Release ................................................. A-1
Appendix B: SpongeBob Diner Dash Page in Apple App Store.................................... A-3
Appendix C: Nickelodeon Group Privacy Policy........................................................... A-5
Appendix D: PlayFirst, Inc. Privacy Policy.................................................................. A-11

1
Before the
FEDERAL TRADE COMMISSION
Washington, DC 20580

In the Matter of

Request for Investigation of Nickelodeon’s
and PlayFirst’s SpongeBob Diner Dash
Mobile Application
)
)
)
)
)





The Center for Digital Democracy (“CDD”), by its attorneys, the Institute for
Public Representation (“IPR”), asks the Federal Trade Commission (“FTC”) to
investigate and bring an action against Nickelodeon and PlayFirst for deceptive
marketing of the SpongeBob Diner Dash game and for violating the Children’s Online
Privacy Protection Act (“COPPA”). Nickelodeon and PlayFirst represent that SpongeBob
Diner Dash collects personal data from users “in accordance with applicable law, such as
COPPA,” when in fact the app neither provides the type of notice required by COPPA,
nor makes any attempt to obtain prior, verifiable parental consent required by COPPA.
I. Background
When Nickelodeon launched SpongeBob Diner Dash in May 2012, the press
release announced that “Nickelodeon, the number-one entertainment brand for kids, has
joined forces with PlayFirst, the leading full-service publisher of casual games, to launch
a new, downloadable SpongeBob SquarePants(TM) Diner Dash(TM) game.” Paul
Jelinek, vice president, Digital Media Products, Nickelodeon Networks, stated that
“Joining one of the top properties for kids—SpongeBob SquarePants—with one of the
top casual games in the market—Diner Dash—is a significant step in the expansion of
Nickelodeon's casual gaming business.” He added that “PlayFirst has demonstrated that
they understand how to tap the exploding mass market interest in interactive

2
entertainment. This launch will continue to grow the kids’ demographic for casual
downloadable games.”
1
As of October 20, 2012, SpongeBob Diner Dash had been
downloaded 10 million times.
2

A. Nickelodeon
Nickelodeon is the leading cable network for children. It reaches around 100
million households in the United States.
3
Nickelodeon is part of MTV Networks, which is
a subsidiary of Viacom Inc.
4
Viacom is a media conglomerate with interests in cable and
satellite television, as well as movie production and distribution, and online and mobile
platforms.
5
In 2012, Viacom reported revenues of $13.89 billion for the most recent fiscal
year.
6

Nickelodeon is Viacom’s most lucrative cable channel.
7
It is home to popular
children’s programs, including SpongeBob SquarePants, Dora the Explorer, and iCarly.
8


1
A copy of this press release is included at Appendix A.
2
SpongeBob Diner Dash Reaches 10 Million Downloads, PlayFirst,
http://blog.playfirst.com/2012/10/spongebob-diner-dash-reaches-10-million-downloads/.
3
Nickelodeon Inc. Company Information, Hoovers, http://www.hoovers.com/company-
information/cs/company-profile.Nickelodeon_Inc.717f2165fbbd50b4.html.
4
Nickelodeon is a part of MTV Networks as well other cable networks such as BET,
Comedy Central, CMT, and VH1. MTV Networks, Viacom,
http://www.viacom.com/ourbrands/medianetworks/mtvnetworks/pages/default.aspx;
Nickelodeon Inc. Company Profile, Yahoo Finance,
http://biz.yahoo.com/ic/117/117074.html.
5
Business Summary, Yahoo Finance, http://finance.yahoo.com/q/pr?s=VIA+Profile.
6
Amy Chozick, Viacom Profit Increases, But Movie Division Hurts Revenue, N.Y.
Times Media Decoder Blog (Nov. 15, 2012),
http://mediadecoder.blogs.nytimes.com/2012/11/15/viacom-profit-increases-but-movie-
division-hurts-revenues/.
7
Amy Chozick, The Man Who Would Be Redstone, N.Y. Times (Sept. 22, 2012),
http://www.nytimes.com/2012/09/23/business/media/philippe-dauman-the-man-who-
would-be-redstone.html?ref=viacominc.
8
Nickelodeon, nick.com.

3
In addition to its children’s cable channels, Nickelodeon utilizes its popular characters to
reach children through “consumer products, online, recreation, books, and feature
films.”
9
Nickelodeon has greatly expanded placement of its characters and franchises in
applications in an effort to reach children through mobile platforms.
10

B. PlayFirst
PlayFirst was incorporated in 2004 and is headquartered in San Francisco.
11

PlayFirst specializes in “casual games,” mobile application games that appeal to broad
audiences and can be played for short periods of time.
12
PlayFirst advertises its games as
those that can be played “whether you’re in line at the store, on your lunch break or
lounging at home.”
13


9
Nickelodeon, Viacom,
http://www.viacom.com/ourbrands/medianetworks/mtvnetworks/Pages/nickelodeon.aspx.
SpongeBob is used to “promote unhealthy foods like imitation fruit snacks, Popsicles,
PEZ candy, Cheese Nips crackers, and Kraft Macaroni & Cheese. Nickelodeon,
NickToons, and Nick Jr. recently have advertised unhealthy foods like Cocoa Puffs, Air
Heads candies, Chuck E. Cheese's, and Fruit Roll-Ups.” Nickelodeon Knocked for
Pitching Junk Food to Kids, Center for Science in the Public Interest, (Dec. 3, 2012),
http://cspinet.org/new/201212031.html.
10
Tricia Duryee, Nickelodeon’s Mobile Plans Include 20 New Apps In 2010, paidContent
(Jan 21, 2010), http://paidcontent.org/2010/01/21/419-nickelodeons-mobile-plans-
include-20-new-apps-in-2010/; Andrii Degeler, Nickelodeon Brings SpongeBob to
Windows 8 With Its New App, The Next Web (Nov. 19 2012),
http://thenextweb.com/insider/2012/11/19/nickelodeon-releases-app-for-windows-8/.
11
Company Overview of PlayFirst, Inc., Bloomberg Businessweek,
http://investing.businessweek.com/research/stocks/private/snapshot.asp?privcapId=11852
266.
12
Frequently Asked Questions, Casual Games Association,
http://www.casualgamesassociation.org/press.php#casualgames.
13
“At PlayFirst, we believe you can have fun anywhere, any time and at any age. That’s
why we’re committed to creating mobile games for everyone to enjoy, including the fan-
favorite DASH® and Stars series of games like Diner Dash®, SpongeBob Diner Dash®
and Mall Stars™. Whether you’re in line at the store, on your lunch break or lounging at
home, you only need a minute to dive into a PlayFirst game—but you’ll find a lifetime of


4
PlayFirst is a leader in mobile application games that can be played on Apple, and
also serves Android devices.
14
PlayFirst games are played by “tens of millions of fans
worldwide,” and PlayFirst has about eight million monthly active users.
15
PlayFirst
distributes the original Diner Dash game, which has been described as “a character-
driven strategy/time management game, and one of the top-selling downloadable titles of
all time.”
16
It also distributes many different variations including “DinerTown Zoo,”
“DinerTown Pets,” and “Hotel Transylvania Dash.”
17

Most of PlayFirst games are “freemium” games. Freemium is a “business model
that provides a game to players free of charge, but charges a premium fee for special
features, powers, or content.”
18
According to the game industry trade magazine
Gamesauce, “[w]ith PlayFirst, the monetization framework is conceived from the very

entertainment. PlayFirst games are played by tens of millions of fans worldwide, and
we’re just getting started.” About Us, PlayFirst, http://www.playfirst.com/about.
14
Available on the Android platform exclusively on Kindle Fire. Jason Ankeny,
PlayFirst serves up ‘Diner Dash’ for Android as Kindle Fire exclusive, Fierce Developer
(Nov. 19, 2012), http://www.fiercedeveloper.com/story/playfirst-serves-diner-dash-
android-kindle-fire-exclusive/2012-11-18; PlayFirst is listed as one of the largest
publishers of online casual games by the Casual Games Association. Frequently Asked
Questions, Casual Games Association,
http://www.casualgamesassociation.org/press.php#casualgames.
15
Id.; Kathleen De Vere, After PC Downloads and Social Fail, PlayFirst Sees Its
Fortunes Rise Again On Mobile, Inside Mobile Apps (Jun. 7, 2012),
http://www.insidemobileapps.com/2012/06/07/with-a-pivot-to-mobile-playfirst-sees-its-
fortunes-rise-again/.
16
Brian Anthony Thorton, Stellar Stories - With Marco Demiroz of PlayFirst,
Gamesauce (Nov. 2, 2012), http://gamesauce.org/news/2012/11/02/stellar-stories-with-
marco-demiroz-of-playfirst/.
17
All Games, PlayFirst, http://www.playfirst.com/all_games.
18
Justin Davis, The Dark Future of Freemium Games, and How We Can Avoid It, IGN
(July 20, 2012), http://www.ign.com/articles/2012/07/20/the-dark-future-of-freemium-
games-and-how-we-can-avoid-it.

5
beginning as an integral part of the design process. That said, their primary focus is to
ensure that the game is a fun and addicting experience.”
19

In a presentation entitled “Mobile Game Monetization: Separating Myth From
Realilty,” at the 2012 Casual Connect conference in Seattle, PlayFirst President and CEO
Marco DeMiroz explained how the PlayFirst economic model works.
20
PlayFirst
conceives of game players as falling into three categories: 1) “minnows” are new players
who have made 1-2 in-app purchases; 2) “dolphins” have been playing an average of 4-6
months and made 8 or more purchases; and 3) “whales” have been playing a long time
and made 16 plus purchases. Whales are the most valuable because the dollar value of
their in-app purchases is 43 times higher than the purchases of minnows. DeMiroz also
explained that PlayFirst conducts research to determine how game players behave. It uses
this research to target different messages and content to different users with the goal of
“migrating” players from the minnow category to whales.
C. SpongeBob Diner Dash
SpongeBob Diner Dash combines the popular “Diner Dash” game format with
characters and themes from the highly successful Nickelodeon children’s program
SpongeBob SquarePants. The objective of the game is for children to help SpongeBob
quickly take orders, serve food, provide the bill to customers, and clear dirty dishes so

19
Brian Anthony Thorton, Stellar Stories - With Marco Demiroz of PlayFirst,
Gamesauce (Nov. 2, 2012), http://gamesauce.org/news/2012/11/02/stellar-stories-with-
marco-demiroz-of-playfirst/.
20
A video of his presentation is available at
http://gamesauce.org/news/2012/11/02/stellar-stories-with-marco-demiroz-of-playfirst/
and at http://casualconnect.org/lectures/mobile/mobile-game-monetization. The
discussion of the economic model starts approximately 14 minutes into the video.

6
that additional customers can be seated as fast as possible. Children control SpongeBob
by tapping and swiping on the screen. The customers leave tips depending on their
satisfaction with the service.
21
Children use tips to purchase coins. Coins can be used to
purchase tools that increase “productivity,” such as shoes that make SpongeBob walk
faster or a frying pan that makes the food cook faster.
After completing each level, users are prompted to upgrade to a full version
(which costs $1.99) and to purchase additional coins, as shown in Figure 1.

Figure 1
When a child taps on the “buy” button to purchase coins, the app asks for an iTunes
password, and the purchase is charged to the credit card associated with the iTunes
account.

21
Chris Morris, SpongeBob Diner Dash, Common Sense Media,
http://www.commonsensemedia.org/mobile-app-reviews/spongebob-diner-dash;
SpongeBob Diner Dash, PlayFirst, http://www.playfirst.com/game/spongebob-diner-
dash?gclid=COXSs6SC7bMCFUOK4AodFksAPA.

7
D. Downloading SpongeBob Diner Dash
SpongeBob Diner Dash may be downloaded from the Apple App store.
22
The
game is also featured on the PlayFirst website.
23
In the Apple App store, SpongeBob
Diner Dash is featured in the kids’ games section, as shown in Figure 2. It is rated for
ages 4+.

Figure 2


22
SpongeBob Diner Dash, iTunes, https://itunes.apple.com/us/app/spongebob-diner-
dash/id333578095
23
SpongeBob Diner Dash, PlayFirst, http://www.playfirst.com/game/spongebob-diner-
dash.

8
The Apple App store describes the game as follows: “PlayFirst and Nickelodeon team up
to bring you the dish-flipping fun of Diner Dash with a super awesome SpongeBob
twist!” Clicking to read more brings up additional information including that
SpongeBob Diner Dash collects personal user data as well as non-personal
user data (including aggregated data), connects with 3rd party social
media applications, allows communication with other app users, and/or
offers in-app purchases. User data collection is in accordance with
applicable law, such as COPPA. User data may be used, for example, to
respond to user requests; enable users to take advantage of certain features
and services; personalize content and advertising; and manage and
improve Nickelodeon’s services.
24


It refers to the Nickelodeon Group Privacy Policy for more information.
25

The description of SpongeBob Diner Dash on the PlayFirst website, as shown in
Figure 3, does not disclose its information collection practices. It does have a small
“privacy” link at the bottom of the screen that takes one to the general PlayFirst, Inc.
Online Privacy Policy. This policy states that “We do not knowingly collect personal
information from children under 13.”
26


24
See Appendix B.
25
See Appendix C.
26
See Appendix D.

9

Figure 3
II. Nickelodeon and PlayFirst Make False Representations in their Privacy
Statements for SpongeBob Diner Dash
Section 5(a) of the FTC Act prohibits unfair and deceptive acts or practices in or
affecting commerce.
27
As the FTC explains on its website, “[w]hen companies tell
consumers that will safeguard their personal information, the FTC can and does take law
enforcement action to make sure that companies live up to these promises” by bringing
actions under Section 5.
28
For example, in United States v. RockYou, Inc., the FTC
brought an action against RockYou, a social gaming website. RockYou’s privacy policy

27
15 U.S.C. §45(a).
28
Making Sure Companies Keep Their Privacy Promises to Consumers,
http://www.ftc.gov/opa/reporter/privacy/privacypromises.shtml.

10
represented that it did not knowingly collect or maintain personal information from
children under 13 and that it would delete any such information once it learned it had
collected it. In fact, the company did knowingly collect email addresses and other
personal information from children and did not delete the information. Thus, the FTC’s
complaint alleged that this statement was false and misleading under Section 5.
29

Likewise, Nickelodeon and PlayFirst engage in deceptive acts by making
misrepresentations in their privacy notices. Specifically, the privacy statement in the
Apple App store assures parents that “[u]ser data collection is in accordance with
applicable law, such as COPPA.”
30
In reality, as will be shown below, the SpongeBob
Diner Dash app does collect personal information from children without complying with
COPPA.
In addition, PlayFirst’s privacy policy discloses that it collects and uses personal
information, but represents that it does not knowingly collect personal information from
children under 13. This claim is contradicted by the content of its own website’s
promotion of the game, which—as can be seen from Figure 4—is clearly directed at

29
Complaint, United States v. RockYou, Inc., No. 3:12-CV– 01487-SI (N.D. Cal., filed
Mar. 26, 2012), available at
https://docs.google.com/viewer?url=http%3A%2F%2Fftc.gov%2Fos%2Fcaselist%2F102
3120%2F120327rockyoucmpt.pdf. The complaint also alleged that RockYou collected
personal information from children in violation of COPPA. The case was settled when
RockYou entered into a consent decree barring deceptive claims, imposing civil penalties
and other forms of relief. United States v. RockYou, Inc., No. 12-CV-1487-SI (N.D. Cal.,
filed Mar. 28, 2012).
30
SpongeBob Diner Dash iTunes Page.

11
children.
31
Thus, the FTC should investigate Nickelodeon and PlayFirst for engaging in
deceptive practices in violation of Section 5.
III. Nickelodeon and PlayFirst Fail to Comply with the Children’s Online
Privacy Protection Act
Under COPPA, an operator of a mobile application directed to children may not
collect personal information from a child unless it provides notice of the information
collected and obtains “verifiable parental consent before any collection, use and/or
disclosure of personal information from children.”
32

A. SpongeBob Diner Dash Is Directed to Children Under the Age of 13
In determining whether an online service is directed to children, the Commission
considers “its subject matter, visual or audio content, age of models, language or other
characteristics of the website or online service, as well as whether advertising promoting
or appearing on the website or online service is directed to children. The Commission
will also consider . . . whether a site uses animated characters and/or child-oriented
activities and incentives.”
33
Using this test, SpongeBob Diner Dash is clearly directed to
children under age 13.

31
PlayFirst’s website promotes other games directed children, such as DinerTown Zoo, a
game that lets children build a virtual zoo; DinerTown Pets, which lets children build a
virtual pet store; and Mall Stars, which lets children build a virtual mall.
32
16 C.F.R. § 312.5(a)(1). The FTC has found COPPA violations against mobile
applications. See United States v. W3 Innovations LLC, No. CV–11–03958 (N.D. Cal.,
filed Aug. 12, 2011); “[T]he term Internet is intended to apply to broadband networks, as
well as to intranets maintained by online services that either are accessible via the
Internet, or that have gateways to the Internet.” Frequently Asked Questions about the
Children's Online Privacy Protection Rule, Question 6, Federal Trade Commission (Oct.
7, 2008), http://www.ftc.gov/privacy/coppafaqs.shtm#privacy.
33
16 C.F.R. § 312.2.

12
SpongeBob Diner Dash features the characters from one of Nickelodeon’s leading
children’s television shows, SpongeBob SquarePants. SpongeBob SquarePants has been
the most watched television program for kids ages 2-11 for the past twelve years.
34

According to Nielson data, over two million children ages 2-11 watch SpongeBob
SquarePants every Saturday. In addition, over an eight-month span 39% of those
watching SpongeBob were between the ages of 2-5.
35

The SpongeBob Diner Dash game characters include SpongeBob, a bright yellow
sea sponge; Patrick, a pink starfish; and Mr. Krabs, a red crab and the owner of the
Krusty Krab.
36
These animated characters are designed to appeal to children. According
to Jane Gould, the Senior Vice President of Consumer Insights for Nickelodeon/MTVN
Kids and Family Group, SpongeBob is “expressly designed to entertain 6-to-11-year-
olds.”
37

The visual and audio content of the SpongeBob Diner Dash application also
demonstrates that the application is directed to children under the age of 13. SpongeBob
Diner Dash’s visual design employs bright colors and a variety of underwater restaurants
that serve as levels. Each restaurant is designed to appeal to children, including

34
John Consoli, Holiday Kid Specials Offer Marketers Early Christmas Presence,
Broadcasting and Cable (Nov. 8, 2012),
http://www.broadcastingcable.com/article/490309-
Holiday_Kid_Specials_Offer_Marketers_Early_Christmas_Presence.php.
35
Roni Caryn Rabin, Is SpongeBob SquarePants Bad for Children?, N.Y. Times Well
Blog (Sept. 12, 2011), http://well.blogs.nytimes.com/2011/09/12/is-spongebob-
squarepants-bad-for-children/.
36
SpongeBob Diner Dash, PlayFirst; SpongeBob Characters, Nickelodeon,
http://spongebob.nick.com/characters/sandy_character.html.
37
Lauren Effron, Nickelodeon Responds to Study Claiming ‘SpongeBob’ Hinders
Preschoolers Attention Spans, ABC News (Sept. 12, 2011),
http://abcnews.go.com/blogs/health/2011/09/12/nickelodeon-responds-to-study-claiming-
spongebob-hinders-preschoolers-attention-spans/.

13
“Dutchman’s Inn,” a pirate ship, and “Glove World,” an amusement park.
38
The audio
content comes from SomaTone Interactive, a company that promotes its ability to create
“Gamey-Kids music.”
39

Finally, SpongeBob Diner Dash utilizes child-oriented activities and incentives.
The game is simple, repetitive, and fast-paced. Children control SpongeBob and the
patrons by sliding their finger and tapping on different locations on the screen. The game
also incorporates child-oriented incentives. On each level, children receive additional
game currency for attaining certain scores and for completing “SpongeBob’s Challenge.”
In addition, children can unlock incentives through earning or purchasing in-game
currency. These include additional characters from the SpongeBob SquarePants
television show, new levels, and items that assist SpongeBob in serving patrons faster,
such as the frying pan shown in Figure 4.

38
See Appendix B.
39
Audio Services, SomaTone Interactive,
http://www.somatone.com/videogamecomposers.

14

Figure 4
Because SpongeBob Diner Dash is clearly directed at children under age 13, it
may only collect personal information if it complies with COPPA’s notice and consent
requirements.
B. Nickelodeon and PlayFirst Collect Several Types of Personal
Information from Children
Under the COPPA Rule “personal information” is defined as “individually
identifiable information about an individual collected online.” Personal information
includes a first and last name as well as an “e-mail address or other online contact
information, including but not limited to an instant messaging user identifier, or a screen
name that reveals an individual’s e-mail address.”

SpongeBob Diner Dash collects
several types of personal information from children. It collects children’s names, email
addresses, and at least one other form of online contact information.

15
1. First and Last Name
The definition of personal information includes “a first and last name.”
40

SpongeBob Diner Dash allows collection of children’s first and last names. When a child
enters the application for the first time, she is prompted to a screen with a text box
stating, “Enter your name.”

Figure 5
The application allows a child to enter seven characters without a space. As demonstrated
in Figure 6, this will allow some children to include both a first and last name.

Figure 6
The application does not tell the child not to use his or her real name, or to use only a first
name.

40
16 C.F.R. § 312.2.

16
2. Email Address
The definition of personal information includes “an e-mail address.”
41
SpongeBob
Diner Dash collects children’s email addresses. As children enter their names on the first
screen, they are offered the option to select a checkbox stating, “I want the Playfirst
newsletter for game tips and news!” As shown in Figure 7, children who check the box
are instructed on the next screen to “Enter your email address to stay connected!”

Figure 7
This prompt creates the expectation that the child must submit an email address to play
the game. The screen collecting the email address does not attempt to obtain verifiable
parental consent. It does not even warn children to check with their parents.
3. Other Online Contact Information
The definition of personal information also includes “other online contact
information, including but not limited to an instant messaging user identifier, or a screen
name that reveals an individual’s e-mail address.”
42
It appears that SpongeBob Diner
Dash collects at least one form of “other online contact information” to contact children

41
16 C.F.R. § 312.2.
42
16 C.F.R. § 312.2.

17
through push notifications.
43
Push notifications are similar to other types of online
contact such as text messaging. In the words of mobile technology company Urban
Airship, “[p]ush notifications allow you [the operator] to send messages directly to the
people who have installed your app, even when the app is closed on a device. . . . Send
messages to your full audience, segment your audience into specific groups, or send
custom messages to individuals.”
44

When a child first opens SpongeBob Diner Dash, he is told that “SpongeBob
Diner Dash would like to send you notifications,” as shown in Figure 8.

Figure 8
This dialog box does not disclose what type of contact information the application
collects and uses to send notifications; nor does it warn children to check with their
parents before tapping “OK.” If the child taps on “don’t allow,” the dialog box will
reappear every time the child opens the application after that. If a child selects “OK,”
SpongeBob Diner Dash will send the child notifications such as the one in Figure 9.

43
Notifications such as these may originate locally from the application itself (“local
notifications”), or remotely from an operator’s server (“push notifications”). About Local
Notifications and Push Notifications, Apple,
http://developer.apple.com/library/mac/#documentation/NetworkingInternet/Conceptual/
RemoteNotificationsPG/Introduction/Introduction.html. It was not possible for CDD or
IPR to determine whether the notifications SpongeBob Diner Dash sends to children are
local notifications are push notifications.
44
Push Notifications, Urban Airship, http://urbanairship.com/products/push-
notifications/.

18

Figure 9
According to Clueful, an online privacy monitoring service, SpongeBob Diner
Dash collects each child’s Unique Device Identifier (“UDID”), a string of numbers that
can be used to uniquely identify a child’s mobile device.
45
The FTC recently found that
UDID is the most common piece of information collected and shared by child-directed
apps.
46
In addition to being central to mobile advertising and analytics,
47
UDIDs can be
used to send push notifications to a specific device.
48
A UDID is therefore a form of
online contact information similar to an instant messaging user identifier.

45
Clueful, http://www.cluefulapp.com/; Federal Trade Commission.
46
Federal Trade Commission, Mobile Apps For Kids: Disclosures Still Not Making the
Grade 9 (2012), available at
http://www.ftc.gov/os/2012/12/121210mobilekidsappreport.pdf.
47
The End of UDIDs—What it Means for Mobile Advertising, mobyaffiliates,
http://www.mobyaffiliates.com/blog/the-end-of-udids-what-it-means-for-mobile-
advertising/ (“The majority of mobile analytics revolves around the UDID in order to
capture conversion data that tells advertisers how users are engaging with ads. It is a
permanent, universal, identifier of a device and is therefore very useful for advertisers
when it comes to tracking what users are doing, especially when that tracking takes place
between multiple ad company partners.”).
48
If Apple Is Really Rejecting Apps over Use of UDID, the Lack of Alternatives Is a
Problem, The Next Web, http://thenextweb.com/apple/2012/03/26/if-apple-is-really-
rejecting-apps-over-use-of-udid-the-lack-of-alternatives-is-a-problem/.

19
On Apple devices, app operators now also use “device tokens” to send push
notifications.
49
Device tokens are identifiers of 64 hexadecimal characters unique to each
device.
50
Apple’s programming guide for push notifications describes the device token as
an identifier “analogous to a phone number” that allows the Apple Push Notification
Service to identify and locate the device that is the intended recipient of a notification.
51

App developers can view a device token list of all users of an application, tagged with
other information, and select specific devices to contact.
52

Regardless of whether SpongeBob Diner Dash collects children’s UDIDs, device
tokens, or both, it is collecting and using “online contact information” that can be used to
send custom messages to individual children in the form of push notifications. These
identifiers constitute personal information under the existing COPPA Rule.
Thus, SpongeBob Diner Dash collects and uses at least three types of personal
information from children. To comply with COPPA, it must give parents notice regarding
that collection and use.

49
Are “UDID” and “Device Token” Synonymous?, Urban Airship Support Center,
https://support.urbanairship.com/customer/portal/articles/125827-are-%22udid%22-and-
%22device-token%22-synonymous-.
50
Id.
51
Apple Local and Push Notification Programming and Guide, Mac Developer Library,
http://developer.apple.com/library/mac/#documentation/NetworkingInternet/Conceptual/
RemoteNotificationsPG/ApplePushService/ApplePushService.html.
52
See the sample device token list in Urban Airship’s developer guide. Server: iOS Push
API, Device Token List, Urban Airship Documentation,
https://docs.urbanairship.com/display/DOCS/Server%3A+iOS+Push+API#ServeriOSPus
hAPI-DeviceTokenList.

20
C. Nickelodeon and PlayFirst Fail to Comply with COPPA’s Notice
Requirement
COPPA requires that notices to parents be placed in specific locations and include
specific information. SpongeBob Diner Dash does not comply with either requirement.
COPPA Rule 312.4(b) requires that the operator of an online service directed at
children “post a link to the notice of its information practices with regard to children on
the home page of its website or online service and at each area on the website or online
service where personal information is collected from children.” Nickelodeon and
PlayFirst do not satisfy this requirement. There is no link to the privacy policy from
within SpongeBob Diner Dash when information is collected from children or at any
other time. This is important because once an app has been downloaded, a parent is
unlikely to return to the App Store for more information.
Even using the more “expansive view of what constituted a privacy disclosure”
used by the FTC in its recent report, Mobile Apps for Kids, SpongeBob Diner Dash falls
short.
53
We found what might be considered privacy notices on the SpongeBob Diner
Dash promotion page in the Apple App Store, on the Nick Games website, and on the
PlayFirst website. However, none of these disclosure statements contained the content
required by the COPPA Rule.
Not only is the Apple App Store description of SpongeBob Diner Dash
affirmatively misleading in that it represents that the app complies with COPPA, but it
fails to provide an adequate description of the personal information collected from

53
For purposes of the report, the FTC examined disclosures or links on the app
promotion page, on the developer’s website, or in the app itself. Federal Trade
Commission, Mobile Apps For Kids: Disclosures Still Not Making the Grade (2012).

21
children. COPPA Rule 312.4(b)(2) requires among other things that notice to parents
include the name, address, telephone number, and email address of all operators
collecting or maintaining personal information from children; the types of personal
information collected from children and whether it is collected actively or passively; how
such personal information is or may be used by the operators; whether personal
information is disclosed to third parties, and if so, the types of business in which third
parties are engaged and the general purposes for which such information is used; whether
the third parties have agreed to maintain the confidentiality, security and integrity of the
data; and that the parent can review and have deleted the child's personal information and
deny permission for further collection.
54

The Apple App store discloses that SpongeBob Diner Dash “collects personal
user data as well as non-personal user data (including aggregated data), connects with 3rd
party social media applications, allows communication with other app users, and/or offers
in-app purchases.” It further states that “User data may be used, for example, to respond
to user requests; enable users to take advantage of certain features and services;
personalize content and advertising; and manage and improve Nickelodeon's services.
55

This description fails to include contact information for the operators, the types of
personal information collected by children, how third parties are using the data, whether
third parties have agreed to maintain the confidentiality and security of the data, and that
parents have a right to review, delete and refuse further collection of data. The
information that is provided is vague, e.g., used to “enable users to take advantage of

54
16 C.F.R. § 312.4(b)(2)(ii), (iv), (vi).
55
See Appendix B.

22
certain features and services,” and does not provide sufficient details for parents to make
an informed choice.
Nor is this deficiency remedied by the link to the nick.com privacy policy.
56
That
privacy policy applies to virtually all of the websites and online services within the
Nickelodeon Group. Indeed, the link on the Nick Arcade website takes the user to the
same privacy statement. The general privacy statement does not identify the information
collected by SpongeBob Diner Dash or how it is used. It is also long, complex and uses
language that many parents are unlikely to understand, such as “third party advertising
networks, data exchanges, traffic measurement service providers, marketing analytics
service providers.” It also does not specifically identify what information is collected
from children or how that information is used.
Finally, the privacy policy on the PlayFirst website does not satisfy the COPPA
notice requirements. Like the Nickelodeon Group privacy policy, PlayFirst has one
policy governing its many games and does not specifically discuss SpongeBob Diner
Dash. The privacy policy is long, complex, vague, and difficult to read. It does not
specifically address information collected from or used to contact children. Instead, as
discussed earlier, it misrepresents that it does not knowingly collect personal information
from children under 13.

56
Privacy Policy/Your California Privacy Rights, Nickelodeon (May 23, 2012),
http://www.nick.com/info/privacy-policy.html.

23
D. Nickelodeon and PlayFirst Fail to Comply with COPPA’s
Requirement that it Obtain Verifiable Parental Consent Before
Collecting Personal Information from a Child
Apart from a few limited exceptions, COPPA requires operators that direct
applications towards children to obtain verifiable parental consent.
57
Not only do
Nickelodeon and PlayFirst fail to provide parents notice as required by COPPA, they
make no effort to “obtain verifiable parental consent” before collecting personal
information from a child.
Moreover, Nickelodeon and PlayFirst’s collection of personal information
through SpongeBob Diner Dash does not fall within any of COPPA’s exceptions. The
only exception that could possibly apply here is one that allows operators to provide
newsletters, but only if they “make reasonable efforts … to ensure that the parent
receives notice and has the opportunity to request that the operator make no further use of
the information.” This effort must be made “immediately after the initial response and
before making any additional response to the child.”
58
Nickelodeon and PlayFirst make
no attempt to notify parents or provide any information about the ability to opt-out of
communications, thus violating COPPA.
IV. Conclusion
In sum, SpongeBob Diner Dash is a child-directed mobile app that collects
children’s personal information including full name, email address, and other online
contact information without providing notice to parents or obtaining prior parental
consent as required by COPPA. In addition, Nickelodeon and PlayFirst are engaging in a

57
16 C.F.R. § 312.5(a).
58
16 C.F.R. § 312.5(c)(3).

24
deceptive practice by falsely representing in the privacy disclosure for SpongeBob Diner
Dash on the Apple App Store that its data collection is in accord with COPPA. Thus, the
Center for Digital Democracy respectfully requests that the FTC promptly initiate an
investigation of Nickelodeon and PlayFirst, enforce the relevant provisions of COPPA
and the FTC Act, stop the collection of children’s personal information without parental
notice and consent, and seek all other appropriate remedies.

Of Counsel:

Jordan Blumenthal
Jessica Wang
Georgetown Law Students





December 17, 2012
Respectfully submitted,


Angela J. Campbell
Laura M. Moy
Institute for Public Representation
Georgetown University Law Center
600 New Jersey Avenue, NW
Washington, DC 20001
(202) 662-9535
Counsel for Center for Digital Democracy

NEW YORK, May 9 /PRNewswire/ -- Nickelodeon, the number-one
entertainment brand for kids, has joined forces with PlayFirst, the leading
full-service publisher of casual games, to launch a new, downloadable
SpongeBob SquarePants(TM) Diner Dash(TM) game. SpongeBob SquarePants Diner
Dash launches on game portals all over the U.S. this month, and will also
roll out in international markets in the months to come. It is the latest
title to join Nick Arcade, Nickelodeon's paid downloadable game service on
http://www.nickarcade.com, and PlayFirst's portfolio of innovative original
and licensed casual games.
"Joining one of the top properties for kids -- SpongeBob SquarePants --
with one of the top casual games in the market -- Diner Dash -- is a
significant step in the expansion of Nickelodeon's casual gaming business,"
said Paul Jelinek, vice president, Digital Media Products, Nickelodeon
Networks. "PlayFirst has demonstrated that they understand how to tap the
exploding mass market interest in interactive entertainment. This launch
will continue to grow the kids' demographic for casual downloadable games."
"SpongeBob SquarePants is one of the most popular properties in the
world, and we are thrilled to bring it into our family of engaging,
accessible downloadable games," said Rich Roberts, vice president, sales
and business development, PlayFirst. "We joined forces with Nickelodeon to
combine the excitement of Diner Dash with the fantastical world of Bikini
Bottom to deliver a new experience that all ages will enjoy."
PlayFirst's Diner Dash has become one of the most popular games on the
Web with more than 100 million plays worldwide. The original hit game
follows Flo as she grows her fledgling diner into a five-star restaurant,
satisfying customers of all types along the way. SpongeBob SquarePants
Diner Dash will feature the same classic game mechanic and fast-paced fun
of the original game with the characters from Bikini Bottom and sponge
worthy storylines.
Nick Arcade, available on http://www.nickarcade.com, has served over 20
million downloads in the past year. Nick Arcade features more than 80
family- friendly games, including popular Nick-content like "Danny Phantom
Ghost Frenzy" and "Dora's Carnival Adventure" and non-branded favorites
like "Feeding Frenzy" and "Magic Ball 2." All Nick Arcade games are
available for download on a try-before-you-buy model, and are priced at an
average of twenty dollars to own. A first-ever kids' downloadable games
subscription for $7.95 per month -- the "Nick Arcade Pass" -- is also
available for Nick Arcade visitors. This pass offers members a new
downloadable game of their choice each month that is theirs to keep, a
variety of discounts on other games, and discounts on clothing and other
items available in the Nick Shop.
Launched in July 1999, the Emmy-nominated series, SpongeBob SquarePants
has been the most watched animated series for kids on television for the
past six years. SpongeBob SquarePants is consistently one of the top rated
kids' shows on television, with the Saturday play of the series ranking as
the number one rated program among Kids 2-11. Nearly 69 million viewers
tune into the show each month, making it the most watched show on
Nickelodeon among Total Viewers (ages two and up) including 24.7 million
Kids 2-11, 14.7 million Tweens 9-14 and 33.4 million Adults 18+. (Source:
Nielsen Media Research - April 2006). SpongeBob's adult viewers also
continue to tune-in and have increased by +66% since the premiere of the
show in 1999.
About PlayFirst, Inc.
PlayFirst is the leading publisher of highly-original games made for
casual gamers wherever they play. Committed to fostering creativity,
PlayFirst works with talented internal and external developers to bring
innovative games to multiple platforms, including PC, Mac and mobile.
PlayFirst's portfolio of games includes the record-breaking hit Diner
Dash(TM) which has more than 100 million plays worldwide. Founded in 2004,
PlayFirst is funded by Mayfield Fund, Trinity Ventures and Rustic Canyon
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Appendix A: Nickelodeon amd PlayFirst Press Release
A-1

Partners. For more information visit http://www.playfirst.com.
About Nickelodeon
Nickelodeon, in its 27th year, is the number-one entertainment brand
for kids. It has built a diverse, global business by putting kids first in
everything it does. The company includes television programming and
production in the United States and around the world, plus consumer
products, online, recreation, books, magazines and feature films.
Nickelodeon's U.S. television network is seen in more than 89 million
households and has been the number- one-rated basic cable network for more
than ten consecutive years. Nickelodeon and all related titles, characters
and logos are trademarks of Viacom Inc. (NYSE: VIA and VIA.B).
DINER DASH and PLAYFIRST are trademarks of PlayFirst, Inc.


SOURCE Nickelodeon
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Appendix A: Nickelodeon amd PlayFirst Press Release
A-2
What's New What Is ITunes What's on ITunes ITunes Charts How To
Screenshots
IPhone IPad
DescrIptIon
PIayFIrst and NIckeIodeon team up to brIng you the dIsh-IIIppIng Iun oI DIner Dash wIth a super awesome Sponge8ob
twIst! Soak up 5-star IeedIng Iun wIth Sponge8ob!
Mr. Krabs Is expandIng hIs Krabby Patty empIre, one restaurant at a tIme. HeIp Sponge8ob seat, serve and satIsIy aII
kInds oI IIshy customers In IIve coIorIuI 8IkInI 8ottom restaurants. SIIde and tap to send Sponge8ob to customers'
tabIes. Take orders, seat customers, and coIIect bIg tIps to upgrade your restaurants!
DIve Into cuIInary chaos under the sea wIth Sponge8ob DIner Dash!
Sponge-tastIc game Ieatures IncIude:
- ExpIore 5 restaurants, IncIudIng the Krusty Krab, Dutchman's Ìnn, and more
- SpecIaI guest appearances Irom PatrIck Star and other characters Irom the show
- PIay on IPhone and IPad
- Cet tons oI Iast-paced IeveIs Ior hours oI Iun
- Shop Ior awesome power-ups at the store
- Connect wIth CameCenter to show oII your scores
- UnIock addItIonaI restaurants, IncIudIng the Coo Lagoon and Crab CasIno, through In-App purchase
Sponge8ob DIner Dash coIIects personaI user data as weII as non-personaI user data (IncIudIng aggregated data),
connects wIth 3rd party socIaI medIa appIIcatIons, aIIows communIcatIon wIth other app users, and]or oIIers In-app
purchases. User data coIIectIon Is In accordance wIth appIIcabIe Iaw, such as COPPA. User data may be used, Ior
exampIe, to respond to user requests; enabIe users to take advantage oI certaIn Ieatures and servIces; personaIIze
content and advertIsIng; and manage and Improve NIckeIodeon's servIces. For more InIormatIon regardIng
NIckeIodeon's use oI personaI user data, pIease vIsIt the NIckeIodeon Croup PrIvacy PoIIcy:
http:]]www.nIck.com]InIo]prIvacy-poIIcy.htmI. Our PrIvacy PoIIcy Is In addItIon to any terms, condItIons or poIIcIes
agreed to between you and AppIe, Ìnc., and NIckeIodeon and Its aIIIIIated entItIes are not responsIbIe Ior AppIe's
coIIectIon or use oI your personaI user data and InIormatIon. Use oI thIs app Is subject to the NIckeIodeon End User
LIcense Agreement: http:]]www.nIck.com]InIo]euIa.htmI.
NIckeIodeon Web SIte Sponge8ob DIner Dash Support
What's New In VersIon 2.1
New Ianguages added: SImpIIIIed ChInese, Korean, ÌtaIIan, French, SpanIsh, 8razIIIan Portuguese, Cerman, Dutch,
SwedIsh


ThIs app Is desIgned Ior both
IPhone and IPad
Free
Category: Cames
Updated: ]un 07, 2012
VersIon: 2.1
SIze: 43.0 M8
Languages: EngIIsh, ChInese,
Dutch, French, Cerman, ÌtaIIan,
Korean, Portuguese, SpanIsh,
SwedIsh
SeIIer: MTV Networks
© 2012 VIacom ÌnternatIonaI
Ìnc. AII RIghts Reserved.
NIckeIodeon, Sponge8ob
SquarePants and aII reIated
tItIes, Iogos and characters
are trademarks oI VIacom
ÌnternatIonaI Ìnc. Created by
Stephen HIIIenburg. DIner
Dash © 2005 PIayFIrst, Ìnc.
AII rIghts reserved.
Rated 4+
RequIrements: CompatIbIe
wIth IPhone, IPod touch, and
IPad. RequIres IOS 3.2 or Iater
Customer RatIngs
Current VersIon:
1934 RatIngs
AII VersIons:
2113 RatIngs
Top Ì n-App
Purchases
1. FuII VersIon Upgrade $1.99
2. Sponge8ob's Resta. $5.99
3. SpoonIuI oI TIps $0.99
4. Cup oI TIps $2.99
5. Coo Lagoon $0.99
Sponge8ob DIner Dash
8y NIckeIodeon
Open ITunes to buy and downIoad apps.


VIew More 8y ThIs DeveIoper
Appendix B: SpongeBob Diner Dash Page in Apple App Store
A-3
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*+)' 0.-/2.-2,
ITunes ITunes
ITunes
DownIoad ITunes 10
What Is ITunesZ
What's on ITunes
ITunes Charts
A-Z Features
How Tos
Mor e ITunes
DIgItaI MusIc 8asIcs
AIrPIay
ITunes CIIts
ITunes U
IPod + ITunes Support
AccessIbIIIty
Par tner Pr ogr ams
SeII Your Content
Partner as a Company
Partner as a Content ProvIder
]oIn the AIIIIIate Program
LInkIng TooIs
ITunes LP and ITunes Extras
App Store VoIume Purchase
ITunes Stor e
8rowse ITunes Store
8rowse App Store
8uy MusIc Now
8uy ITunes CIIt Cards
Redeem ITunes CIIt Cards
ITunes Corporate SaIes
Free SIngIe oI the Week
ÌnsIde ITunes
Terms oI Use PrIvacy PoIIcy CopyrIght © 2012 AppIe Ìnc. AII rIghts reserved.
Shop the AppIe OnIIne Store (1-800-MY-APPLE), vIsIt an AppIe RetaII Store, or IInd a reseIIer. AppIe ÌnIo SIte Map Hot News RSS Feeds Contact Us
8ecome a Ian oI the ITunes and App Store pages on Facebook Ior excIusIve oIIers, the
InsIde scoop on new apps and more.
Customer RevIews
Worth It!
by Marqu27
Love the game! Ìt was worth payIng Ior!
(Cet the app) ;)
Fun
by KrIs krIs :)
ThIs app Is Iun but the peopIe who come need more patIence. AIso It Is hard to get tIps
Spongebob Dash
by TabItha41
Awesome game!
6. CIove WorId $0.99
7. MedIevaI Moments $0.99
8. AtIantIs $0.99
9. CIam CasIno $0.99
10. ]ar oI TIps $4.99
More by NIckeIodeon
Dora A8Cs VoI 1: Letters & Let.
VIew Ìn ITunes
ScrIbbIe Hero
VIew Ìn ITunes
Sponge8ob DIner Dash DeIuxe
VIew Ìn ITunes
KIds' ChoIce Awards 2012
VIew Ìn ITunes
Monkey Quest: Thunderbow Fr.
VIew Ìn ITunes

Appendix B: SpongeBob Diner Dash Page in Apple App Store
A-4
THE NICKELODEON GROUP PRIVACY POLICY AND YOUR CALIFORNIA PRIVACY RIGHTS
LAST UPDATED: 05/23/2012
Welcome! This Privacy Policy governs the websites and online services within the Nickelodeon Group, which includes the websites and online services
listed here, including those operated by NeoPets, Inc. and Atom Entertainment, Inc. (collectively, the "Nickelodeon Sites¨ and, individually, "Site¨). By
accessing any of the Nickelodeon Sites, you are consenting to this Privacy Policy. This Privacy Policy describes what information the Nickelodeon Sites
collect from users, including children, when they visit the Nickelodeon Sites; how such information is used and stored; when such information may be
disclosed to third parties; how users, parents, and guardians can control the use and disclosure of collected information; and how information is
protected.
Our visitors´ privacy is important to us, and we recognize the need to provide additional privacy protection for children on the Nickelodeon Sites
permitting such visitors. Our privacy practices are guided by the United States' Children's Online Privacy Protection Act of 1998, as well as data
privacy laws in the United States and other applicable countries. Younger visitors should always check with their parents or guardians before entering
information on any website and we encourage families to discuss their household guidelines regarding the online sharing of personal information.
SUMMARY.
For your convenience, the following is a quick summary of our Privacy Policy. Please read the entire Privacy Policy for more detailed information.
WHAT INFORMATION WE
COLLECT.
The Nickelodeon Sites collect only the information that is reasonably necessary for the activities available on the
particular website. In general, we collect three types of information:
1. Information that you actively give to us (for example, during registration, sweepstakes, purchases or content
submissions);
2. Information we automatically collect about your computer or wireless devices (such as your IP address, cookie
ID, and other unique device identifiers); and
3. Information we collect from third parties, including through your registered third-party social media providers.
For more detailed information regarding the information we collect, please go here
HOW WE STORE SUCH
INFORMATION.
We store your information using reasonable security precautions and for only as long as we think reasonably
necessary. Despite such precautions, there is always a chance that someone may impermissibly access your
information. If you think a third party has accessed your information, please contact us immediately as instructed
below.
For more detailed information regarding how we store information, please go here
HOW WE USE SUCH
INFORMATION.
In general, the information we collect may be used to respond to your requests; enable you to take advantage of
Nickelodeon Sites features and services; personalize your experience and the advertising you see; send you special
offers and promotions from Nickelodeon, the Viacom family of companies, and on behalf of third-parties whose
products or services might be of interest to you; measure analytics; and manage and improve the services available
on the Nickelodeon Sites.
For more detailed information regarding how we use such information, please go here
INFORMATION WE SHARE
WITH THIRD PARTIES.
Depending upon the circumstances, we may share collected information with (a) law enforcement or others as
needed to protect or defend our rights and the rights of others; (b) third parties we hire to handle certain activities;
(c) advertisers or third parties with whom we may partner to provide you additional content, products or services;
(d) business partners who sponsor a sweepstakes or contest or who jointly offer a service or feature on the
Nickelodeon Sites; (e) within the Viacom family of companies; (f) in the event of a corporate transaction; and (g)
otherwise with your consent.
For more detailed information regarding our information sharing practices, please go here
WHAT INFORMATION
OTHERS MAY COLLECT.
We may use a number of advertising networks, analytics service providers and other such companies to, for
example, serve targeted advertisements or analyze the performance of the Nickelodeon Sites. These companies
may use their own unique identifiers, and their use of these technologies is within their control and not ours. Our
Privacy Policy does not cover any information that these companies may collect from you.
For more information about these third parties and how you might be able to control how they use your information,
please go here
YOUR CONTROL OVER
YOUR INFORMATION.
You have the right to access, update and correct factual inaccuracies in any personally identifiable information we
collect about you.
You can stop the delivery of commercial e-mail messages from the Nickelodeon Sites by following the instructions in
e-mails you receive.
You may have choices about the use of your information by third parties wishing to deliver certain targeted
advertising to you.
Parents and guardians can review any personally identifiable information collected about their children and request
that such information be deleted and/or that no further information be collected.
For more detailed information regarding your control over your information, please go here and here
QUICK LINKS.
LOG ÌN | JOÌN THE CLUB
PRÌVACY POLÌCY/YOUR CALÌFORNÌA PRÌVACY RÌGHTS
nick t eennick nickt oons nick at nit e nickjr icar ly.com addict inggames mor e
Appendix C: Nickelodeon Group Privacy Policy
A-5
QUICK LINKS.
I. INFORMATION COLLECTION AND USE.
A. Registration Information
B. Social Platform Registrations and Social Media Plugins
C. Computer Information Collected By Us
D. Computer Information Collected By Others
E. Contests and Sweepstakes
F. Electronic Postcards and Messages
G. Electronic Newsletters
H. Interactive Features and Services
I. Wireless Marketing Services
J. Geolocation Information
K. Financial Information
L. Other Data Collection and Use
II. DISCLOSURE TO THIRD PARTIES.
A. Law Enforcement and Safety
B. Agents
C. Third Parties/Advertisers
D. Co-Branded Sites And Features
E. Viacom and Other Affiliated Businesses
F. Business Transfer
G. With Your Consent
III. INTERNATIONAL TRANSFER.
IV. SECURITY, STORAGE AND RETENTION OF INFORMATION.
V. ACCESSING AND CORRECTING INFORMATION; TERMINATION OF WIRELESS SERVICES.
A. Reviewing Your Information
B. Parental Access
C. Termination Of Wireless Services
VI. ONLINE SAFETY.
VII. LINKS TO THIRD PARTIES.
VIII. YOUR CALIFORNIA PRIVACY RIGHTS.
IX. CONTACT US
I.INFORMATION COLLECTION AND USE.
We may request or collect certain information when you visit the Nickelodeon Sites. However, visitors are required to share only the information that
is reasonably necessary to participate in the particular activity.
A. Registration Information: The information required to register varies by Site, but may include: (a) birth date; (b) gender; (c) country;
(d) state; (e) zip code; (f) user name and password; (g) wireless telephone number; (h) email address; and (i) other profile information such as
avatar preferences, communications preferences, and interests. If the Site either is directed to children under 13 or has actual knowledge that a user
is under 13 years old, the child is asked to provide his or her parent's or guardian's email address. For certain countries, visitors or their parents will
receive an activation email and must follow the procedures or otherwise agree to the terms within the activation email within a certain time period to
activate the account; accounts not activated within that time period will be deleted.
Registration information is used to enable visitors to take advantage of site offerings; respond to visitor´s requests for products, services, and
information; manage games; serve appropriate material; customize the content you see when you visit the Nickelodeon Sites; and offer visitors
special offers and promotions from Nickelodeon Sites and the "Viacom family of companies¨ (which comprises Viacom International Inc. and its
subsidiaries and affiliates), as well as on behalf of selected third parties offering products, programs or services, that we believe may be of interest to
you.
B. Social Platform Registrations and Social Media Plugins: Some of the Nickelodeon Sites permit or require you to register or log into
your account via a social networking platform such as Facebook Connect or Flux, or permit you to use social media plugins such as the Facebook
"Like¨ or Google "+1¨ buttons. When you use these social networking platforms and plugins, your username and password for the services and other
information available about you or collected from you on these services may be shared with us.
When you use social networking platforms and plugins, you share your information with them and their privacy policy applies to their collection, use,
and disclosure of such information. In addition, they may be able to collect information about you, including your activity on the Nickelodeon Sites,
and they may notify your connections on the social networking platform about your use of the Nickelodeon Sites. Such services may also employ
unique identifiers which allow your activity to be monitored across multiple websites for purposes of delivering more targeted advertising to you. For
more information about Facebook Connect, please go here. For more information on Flux, please go here. Please note that their privacy policies may
be different from our own and we encourage you to read them.
C. Computer Information Collected by Us: When visitors come to a Site, we automatically collect certain information from their
computers or mobile devices, such as the type of computer operating system (e.g., Windows XP or Mac OS), the visitor's IP address, the web
browser (e.g., Internet Explorer, Safari, Chrome and Firefox), UDID (for mobile devices), information about the websites visited before and after
visiting the Site, the web pages and advertisements viewed and links clicked on within the Nickelodeon Sites, interactions with e-mail messages sent
by a Site or the Viacom family of companies (e.g., links clicked on and whether the messages were opened or forwarded), information collected
through the use of unique identifiers such as cookies (see below), information regarding the Internet service provider, and other standard server log
information ("Computer Information").
We may use cookies, web beacons, or similar technologies (collectively referred to as "Tracking Technologies¨) on the Nickelodeon Sites. "Cookies"
(which may be html files, Flash files or other technology) are text files that help store user preferences and activity. "Web beacons¨ (also known as
image tags, gif or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising
responses. The Site and/or third parties may use "cookies¨, "web beacons¨ and other similar tracking technologies (collectively, "Tracking
Technologies¨) to collect Computer Information automatically as you browse the Site and the web.
Appendix C: Nickelodeon Group Privacy Policy
A-6
Technologies¨) to collect Computer Information automatically as you browse the Site and the web.
We may use Tracking Technologies to help tailor our content, allow users to move between certain Nickelodeon Sites without logging into each Site,
enable the internal functioning of the Nickelodeon Sites, understand Site and internet usage, improve or customize the content, offerings or
advertisements on this Site, personalize your experience on the Site (for example, to recognize you by name when you return to the Site),
understand your interactions with email messages originating from the Nickelodeon Sites or the Viacom family of companies (such as the links clicked
on and whether the messages were opened or forwarded), save your password, save your online game or video player settings, enable you to use
shopping carts, help us offer you products, programs or services that may be of interest to you, deliver relevant advertising, maintain and administer
the Nickelodeon Sites. These Tracking Technologies collect "click stream¨ data and additional other information regarding your visits to the
Nickelodeon Sites (such as your visits to specific webpages, use of features, purchasing history or preferences), may collect such other information
across multiple sessions on the Nickelodeon Sites and other websites offered by the Viacom family of companies and may also collect your IP
address or some other identifier unique to the device you use to access the site ("Identifier¨). An Identifier may be automatically assigned to any
device you use to access the Nickelodeon Sites.
By visiting a Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to
track your activities and your use of a Site through these Tracking Technologies and Identifiers and that we may use Tracking Technologies in the
emails we send to you.
The Nickelodeon Sites adhere to the Self-Regulatory Principles for Online Behavioral Advertising. Click here for more information about the
Nickelodeon Sites and online behavioral advertising. On sites that are directed to children under 13 or where Nickelodeon has actual knowledge that a
user is under 13, Nickelodeon does not direct targeted advertising to such children based on the child´s visits to the Nickelodeon Sites and other
websites that the child visited.
Our Third Party Advertising Service Providers (as defined in Section D) do not have access to Tracking Technologies set by the Nickelodeon Sites
except to the extent necessary to provide services to the Site. The Third Party Advertising Service Providers, as well as advertisers, may themselves
set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash
cookies, if you have not removed them) and/or they may otherwise have access to other information about you.
You have a number of options with respect to the Tracking Technologies set by the Nickelodeon Sites:
You can prevent the use of certain Tracking Technologies (other than Flash cookies) by using the controls in your Web browser. To do so, you
must complete both of the following steps:
1. Delete existing Tracking Technologies through the "Internet Options¨ sub-option of the "Tools¨ menu option of your browser or otherwise as
directed by your browser´s support feature; and
2. Disable future Tracking Technologies by using the same browser controls. Additional information on disabling most Tracking Technologies may
be available through your browser´s support feature. (See the "help¨ section of your browser for more information.)
You may be able to have the device you use to access the Nickelodeon Sites warn you each time a cookie or most other Tracking Technologies
is being set (other than Flash cookies), or you can choose to turn off such warnings. This is done through your browser on the device you use to
access the Nickelodeon Sites. Additional information on warnings and removal of warnings may be available through your browser´s support
feature.
Please note that deleting, rejecting, disabling or turning off Tracking Technologies through the above options will not remove Flash cookies. For more
information about Flash cookies and how to remove them from your computer, please visit here
Please be aware that certain areas and features of Nickelodeon Sites can only be accessed in conjunction with Tracking Technologies, and that
disabling Tracking Technologies might prevent you from accessing such content.
D. Computer Information Collected By Others: Nickelodeon Sites use a variety of third-party advertising networks, data exchanges,
traffic measurement service providers, marketing analytics service providers, and other third-party service providers (collectively, "Third Party
Advertising Service Providers¨) to, for example, serve advertisements on the Nickelodeon Sites, facilitate targeting of advertisements, and measure
and analyze advertising effectiveness and/or traffic on the Nickelodeon Sites ("Targeting Services¨). These Targeting Services enable us to display
advertisements based on your visits to the Nickelodeon Sites and other websites you have visited and may include delivering advertisements or other
content for products and services that may interest you. Targeting Services also help prevent you from seeing repeated advertisements and enable
us to research the usefulness of certain advertisements. On sites that are directed to children under 13 or where Nickelodeon has actual knowledge
that a user is under 13, Nickelodeon does not direct targeted advertising to such children based on the child´s visits to the Nickelodeon Sites and other
websites that the child visited.
These Third Party Advertising Service Providers do not have access to Tracking Technologies set by the Nickelodeon Sites except to the extent
necessary to provide services to the Nickelodeon Sites. The Third Party Advertising Service Providers, as well as advertisers, may themselves set
and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled in your browser (or, for Flash
cookies, if you have not removed them) and/or they may otherwise have access to Other Information about you. In addition, Third Party Advertising
Service Providers may collect aggregate log data separately and independently from what the Nickelodeon Sites collect.
You should be aware that different rules might apply to the collection, use or disclosure of your information by third parties in connection with their
advertisements, promotions and other websites you encounter on the Internet. The use of such technology by these third parties is within their
control and not the Nickelodeon Sites. Even if we have a relationship with the third party, we do not control those sites or their policies and practices
regarding your information and this Privacy Policy does not cover any use of information that they may collect from you. We encourage you to
research and direct any of your questions in this regard to these third parties. Use of a third party´s Tracking Technology is subject to their own
privacy policies.
With respect to the Tracking Technologies set by Third Party Advertising Service Providers and advertisers (and outside the control of the
Nickelodeon Sites), you have a number of options:
You can opt-out of the use of information for these advertising purposes by two such Third Party Advertising Service Providers, Demdex and
DoubleClick by using those Providers´ opt-out tools. You can access Demdex´s tool at http://www.donottarget.com/ and DoubleClick´s at
http://www.google.com/intl/en/privacy/ads/. We also may from time to time permit other Third Party Advertising Service Providers and
Advertisers to collect Information on the Nickelodeon Sites. Some of these Providers and Advertisers may participate in the Network
Advertising Initiative´s Opt-Out Tool and/or the Self-Regulatory Program for Online Behavioral Advertising Please click on the links to these tools
to learn more about your choices.
Please note the following with respect to opting out of Tracking Technologies set by Third Party Advertising Service Providers and advertisers:
The opt-out tools discussed above are "cookie based." This means that the tools rely on cookies to remember your choices with respect
to the use of your information by the parties that offer you those choices. If you opt-out but then use the controls in your browser to delete all
Tracking Technologies, you may have to opt-out again, a second time, in order to re-establish your opt-out preferences.
Opt-outs are browser-specific. This means, for example, that if you opt out while using Internet Explorer 9, this choice will not affect the
collection of information collected by Tracking Technologies when you use Mozilla Firefox on the same device. It also means that opting out on
one device will not affect the collection of information by Tracking Technologies on other devices you may use to access the Nickelodeon Sites.
You also can prevent the use of certain Tracking Technologies (other than Flash cookies) on a particular device by using the controls in your
Web browser. To do so, you must complete both of the following steps:
1. Delete existing Tracking Technologies through the "Internet Options¨ sub-option of the "Tools¨ menu option of your browser or otherwise as
directed by your browser´s support feature; and
2. Disable future Tracking Technologies by using the same browser controls. Additional information on disabling most Tracking Technologies may
be available through your browser´s support feature. (See the "help¨ section of your browser for more information.)
You may be able to set the !"#$%"&'()&)*"&+(&,%%"**&+-"&.$%/"0(!"(1 Sites warn you each time a cookie or most other Tracking Technologies is being
set (other than Flash cookies), or you can choose to turn off such warnings. This is done through your browser on the device you use to access
the Nickelodeon Sites. Additional information on warnings and removal of warnings may be available through your browser´s support feature.
Opting-out of, deleting, rejecting, disabling or turning off Third Party Advertising Service Providers´ Tracking Technologies does not mean that
you will no longer receive online ads. Opting-out of, deleting, rejecting, disabling or turning off Third Party Advertising Service Providers´
Tracking Technologies only means that such ads will no longer be tailored to your specific viewing habits or interests, but you will continue to
see ads on the Nickelodeon Sites.
Appendix C: Nickelodeon Group Privacy Policy
A-7
see ads on the Nickelodeon Sites.
PLEASE NOTE THAT THE USE AND STORAGE OF FLASH COOKIES TYPICALLY CANNOT BE CONTROLLED THROUGH YOUR BROWSER. For more
information about Flash cookies and how to remove them from your computer, please visit here
E. Contests and Sweepstakes: The Nickelodeon Sites may offer online contests and sweepstakes. To enter these contests and
sweepstakes, you may be required to provide your first name and email address and/or additional information required for the management of the
contest or sweepstakes. On sites that either are directed to children under 13 or where we have actual knowledge that a user is a child under 13, we
may collect the child´s e-mail address to enter the child in the contest or sweepstakes, store such child´s email address for the duration of the
sweepstakes, and use it for notification if he or she is the winner. For certain contests or sweepstakes on such sites, we may ask for the email
address of the child's parent or guardian to inform the parent or guardian of his or her child's entry and give the parent or guardian the option to
have the child's entry deleted.
F. Electronic Postcards and Messages: Some Nickelodeon Sites provide visitors the opportunity to send electronic postcards and "wish
lists¨ of items they want to family or friends, which means we will send, on the visitor´s behalf, email messages to family and/or friends. To do so,
visitors must provide the email address of the recipient of such electronic postcards or email messages. Email addresses provided to us for this
purpose are used solely to send the requested postcard or email message and are deleted from our system once the postcard or message is sent. In
some cases, we may offer visitors an incentive (e.g., points to be used in an online game) for referring information about products to the visitor's
family or friends. In such cases, we will comply with all applicable legal requirements. Please note that this feature may not be available to visitors in
certain regions.
G. Electronic Newsletters: Visitors can provide their email addresses to receive email newsletters and promotions from the Nickelodeon
Group, the Viacom family of companies, and our business partners. Visitors may change their preferences regarding emails at any time through the
unsubscribe link in the newsletters or, for certain Nickelodeon Sites, by logging into and changing the preferences for their account.
When visitors to Nickelodeon Sites that either are directed to children under 13 or have actual knowledge that a user is a child under 13 years old ask
to receive our email newsletter(s), they will be asked to provide their first name, email address and the email address of their parent/guardian. We
will send the child's parent/guardian a notification email informing them of the child's request to receive by email the newsletter on an ongoing basis
and give the parent/guardian the option to have his or her child's information removed from our newsletter database. The link to remove the child´s
information will expire approximately 48 hours from the time it is sent, but at any time after receiving this notification email, the child's
parent/guardian may request that we stop sending the child the newsletter(s) by following the "unsubscribe" instructions found at the end of any of
the newsletter emails. Parents/guardians may at any time review any personally identifiable information collected online about their child. See
section V (B) below. When a child provides a parent's/guardian's email address when signing up for newsletter(s), that email address is used to send
the notification email message and is subsequently deleted from our system.
H. Interactive Features and Services: Some of the Nickelodeon Sites offer interactive features and services, such as message boards,
chat rooms, electronic mail services, comment boxes, messaging services, and member profile pages. For certain countries, on Nickelodeon Sites
that either are directed to children under 13 or have actual knowledge that a user is a child under 13 years old, we either will obtain the consent of
the child´s parent before allowing the child to use these interactive features and services or will use reasonable technical measures to delete all or
virtually all personal information from a child´s postings before they are made public and also delete such information from our records. We use the
information collected through interactive features and services to enable you to participate in such features and services.
I. Wireless Marketing Services: Consistent with local law, appropriately aged visitors may have the opportunity to register for special
promotions, services, news, programming and information delivered via text messaging and/or wireless devices. To do so, visitors may be asked to
provide their telephone number, wireless email address, carrier´s name, and/or their opinion regarding certain goods and/or services. Visitors must
opt in to receive wireless marketing material from businesses within the Nickelodeon Group and Viacom family of companies through one of the
following methods: (a) filling out the registration information on any Nickelodeon Sites´ wireless marketing registration page; or (b) sending a specific
word, code or symbol via a text message to a telephone number designated by us in any promotional material. The visitor may also be asked to
confirm his or her acceptance to receive such wireless marketing services.
Visitors that register for wireless marketing services acknowledge, understand and agree that they will be charged by the visitor's wireless carrier for
all messages sent to the visitor from the Nickelodeon Sites or Viacom family of companies. Standard messaging rates will apply, unless noted
otherwise. Under no circumstances will the Nickelodeon Group or the Viacom family of companies be responsible for any wireless email or text
messaging charges incurred by such visitor or by a person that has access to a visitor's wireless device, telephone number, or email address.
J. Geolocation Information: We may collect and store information about your precise geographic location if you enable your computer or
mobile device to send us location information. You may be able to change the settings on your computer or mobile device to prevent it from providing
us with such information. We use this information, for example, to enable visitors to take advantage of Site offerings; respond to visitor´s requests for
products, services, and information; manage games; customize the content visitors see when visiting the Nickelodeon Sites; and to offer visitors
special offers and promotions from Nickelodeon Sites and the Viacom family of companies, as well as on behalf of selected third parties offering
products, programs or services that we believe may be of interest to our visitors.
K. Financial Information: We collect and use financial information, such as credit card numbers and security codes, for the limited
purposes described below.
i. Arcades: Users who are of legal age to form a binding contract may purchase games available on the Nickelodeon Sites (e.g., games
from Shockwave.com). Purchasing such games may require providing information to process the order including full name, billing and/or shipping
addresses, billing address, email address, credit card number, control payment number, PIN, card security code, expiration date and/or a phone
number. After successfully entering a valid credit card number/expiration date and completing the order process, an account is created. We use this
information to process the order and to send order confirmations via email, as well as to send information about products and services of interest and
as otherwise required by law. If you make purchases using a pre-paid card, we will not require you to enter any personally identifiable information
to complete your purchase.
ii. Consumer Products: Certain of the Nickelodeon Sites provide pages and/or links to pages offering visitors who are of legal age to
form a binding contract the opportunity to purchase consumer products (the "Shops"). To do so, visitors need to provide contact, shipping, billing and
credit information. These pages may be hosted and operated by a third party that is independent and separate from the Nickelodeon Sites. This third
party collects personal information about shop visitors and may share this information with us. We use this information to process the order and to
send order confirmations via email, as well as to send information about products and services of interest and as otherwise required by law. Before
providing information on these pages, we encourage you to review the posted privacy policies which govern such third party´s use of your
information, as they may differ from ours.
iii. Virtual Items/Memberships: Some of the Nickelodeon Sites may offer memberships, online subscriptions and/or virtual items for use
in conjunction with the Nickelodeon Sites' games. When you enter into a transaction for a membership, subscription, virtual item or similar
transaction, you may be asked to provide the credit card and/or billing information and email address. We will use this information to fulfill your
specified requests, as well as to inform you about additional products or service opportunities and as otherwise required by law. Please also see the
information regarding payment processors in Section II(B) below.
L. Other Data Collection and Use.
We collect search query information when visitors search for information on the Nickelodeon Sites. We also collect information from visitors when
they contact us with questions and comments.
We may use this information, along with any of the other information described above, to (i) analyze use of the Nickelodeon Sites and understand
and improve our service offerings; (ii) prevent potentially prohibited or illegal activities; and (iii) for any other purposes disclosed to you at the time
we collect your information or pursuant to your consent.
We may combine information collected through the Nickelodeon Sites with information we collect from other sources (e.g., social media integration
services), other Viacom family of company´s sites, offline records or publicly available information). It is your responsibility to provide complete and
accurate information and to keep such information up to date. We are not responsible for any problem or liability arising from your failure to do so.
II. DISCLOSURE TO THIRD PARTIES.
We may share your information with third parties for the limited purposes described below. In the U.S., parents of children under the age of 13 have
the option of consenting to the collection and use of their child's personal information without consenting to the disclosure of that information to
certain third parties.
A. Law Enforcement and Safety.
You acknowledge, consent, and agree to the extent legally permissible in this jurisdiction to allow us to access, preserve, and/or disclose the
information we collect and/or content you provide to us (including information you may have posted on bulletin boards or internal site communication
Appendix C: Nickelodeon Group Privacy Policy
A-8
information we collect and/or content you provide to us (including information you may have posted on bulletin boards or internal site communication
systems) to a law enforcement agency or other third parties if required to do so by law or with a good faith belief that such access, preservation, or
disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce the Terms of Use of the respective Nickelodeon Sites; (c) respond
to claims that the content violates the rights of third parties; (d) respond to your requests for customer service; or (e) protect the rights, property, or
personal safety of the owners of the Nickelodeon Sites, any user of the Nickelodeon Sites, a third party or the general public. We also may disclose
user information whenever we believe disclosure is necessary to limit our legal liability; to protect or defend our rights or property; or protect the
safety, rights, or property of others.
If you have concerns about the conduct of a particular user, please send an e-mail to nickprivacy@nickonline.com. This email is not to contact us
about the status of your account.
B. Agents.
Information collected through the Nickelodeon Sites may be transferred, disclosed or shared with third parties engaged by us to handle and deliver
certain activities, such as message boards, sweepstakes and contests, e-cards, payment processing, newsletters, and advisory boards, and to
perform other technical and processing functions, such as sending postal mail and email, maintaining data integrity, programming operations, user
services or technology services. We may provide these third parties information collected as needed to perform their functions, but they are
prohibited from using it for other purposes and specifically agree to maintain the confidentiality of such information. Some of these agents, such a
payment processors, may request additional information during the course of offering their services. Before you provide additional information to
third party agents, we encourage visitors to review their privacy policies and information collection practices.
C. Third Parties/Advertisers.
Some Nickelodeon Sites partner with outside third parties to provide you with additional content, products, or services that we believe may be of
interest. For example, we may partner with a greeting card company, software manufacturer, social media plugin provider, or mobile phone provider
to offer you electronic cards, games, social networking, or text messaging services. These partners operate websites and services that are separate
and independent from the Nickelodeon Sites and, accordingly, may have their own privacy policies. If you consent or register with one of our
partners, that means you grant the Nickelodeon Sites permission to give your registration and other information, including e-mail address, to that
third party. If you have identified yourself as residing in the EU, we will not share your email address or other personally identifiable information with
third parties for advertising purposes unless you have "opted-in."
In addition, Third Party Advertising Service Providers may use their own Tracking Technologies to gather information about you. Please see Section
I(D) above for more detailed information regarding such use of Tracking Technologies.
For more information on our use of third party advertisers and the self-regulatory principles, please click here
D. Co-Branded Sites and Features
Some Nickelodeon Sites offer co-branded services and features, such as events and promotions that we put together with another company ("Co-
Branded Partner"). Such services may be hosted on a Site and/or our Co-Branded Partner's website. We may share your information with our Co-
Branded Partner and your voluntary use of or participation in a co-branded service or feature means that you opt-in and affirmatively consent to both
the Nickelodeon Sites and our Co-Branded Partner collecting and using the information you provided during registration and/or in connection with the
specific co-branded feature for fulfillment, marketing or administrative purposes. If you wish to opt-out of a Co-Branded Partner's future use of your
information for marketing purposes, you will need to contact the Co-Branded Partner directly. The Co-Branded Partner will be identified on the co-
branded feature or service.
E. Viacom and Other Affiliated Businesses
The Nickelodeon Sites are part of the Viacom family of companies. Where permitted by law, we may share information we collect about you within
the family of Viacom family of companies´ websites and other affiliated businesses so that we can, for example, provide you with information about
products and services that might interest you.
F. Business Transfer
In the event that assets relating to one or more of the Nickelodeon Sites are transferred or sold to another entity as a result of, for example, a
corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy, information collected at the Nickelodeon Sites may be
transferred to the acquiring company.
G. With Your Consent
We may otherwise disclose your information pursuant to your consent.
III. INTERNATIONAL TRANSFER.
The Nickelodeon Sites are designed for and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. We
make no representation that the Nickelodeon Sites are operated in accordance with the laws or regulations of, or governed by, other nations. By
participating in activities on the Nickelodeon Sites, you certify that you meet the age and other eligibility requirements for the Nickelodeon Sites as
set forth in the respective Terms of Use Agreement for each Site. If you do not meet the age and other eligibility requirements of the particular Site
you are visiting, please discontinue using that Site immediately as your continued use of the Nickelodeon Sites indicates that you are agreeing to the
collection, use, disclosure, management and storage of your Information as described in this Privacy Policy.
Please be aware that by providing us with personal information, you understand and agree that: (1) due to our international operations, your
personal information may be transferred to and stored on servers located outside your resident jurisdiction; (2) to the extent you are a resident of a
country other than the United States, you consent to the transfer of such data to the United States for processing by our affiliates in accordance with
this Privacy Policy and (3) the Privacy Policy and the collection of information pursuant to the Privacy Policy shall be governed by and construed in
accordance with the laws of the United States, without giving effect to any principles of conflicts of law. Our affiliates comply with the U.S.-EU Safe
Harbor. Please see the Safe Harbor Privacy Policy for detailed information on these affiliates' privacy practices.
If you do not consent to the terms of this Privacy Policy, please do not use the Nickelodeon Sites because your use of the Nickelodeon Sites
represents your consent. If you have already provided personal information, please contact us about how you would like us to handle such
information.
IV. SECURITY, STORAGE AND RETENTION OF INFORMATION.
The Nickelodeon Sites maintain reasonable technical and organizational steps to help ensure that information collected is secure, including limiting the
number of people who have physical access to our database servers and use of electronic security systems and password protections which guard
against unauthorized access. The Nickelodeon Sites conduct financial transactions via secured transmissions. We limit access to visitor´s information
to employees and contractors who are authorized for the proper handling of such information, and any employee found violating our standards of
security and confidentiality will be subject to our disciplinary processes. We also take reasonable steps to help make sure our third-party agents
protect the security of your personal information. However, as with most Internet sites or services, it is possible that third parties may unlawfully
access such personal information through a number of means despite our efforts.
Information collected at the Nickelodeon Sites will not be stored for longer than is necessary for the purposes described in this Privacy Policy, or to
otherwise meet legal requirements.
V. ACCESSING AND CORRECTING INFORMATION; TERMINATION OF WIRELESS SERVICES.
A. Reviewing Your Information
You have the right to access, update and correct factual inaccuracies in personally identifiable information that we collect online at the Nickelodeon
Sites, subject to certain exceptions. To do so, you should log into your account or you may e-mail us at nickprivacy@nickonline.com. To help protect
your privacy and the security of your personally identifiable information, we will take reasonable steps to verify your identity before granting access.
B. Parental Access
Parents/guardians of children under the age of 13 can print out and mail or fax us a signed form that allows them to review any personally
identifiable information collected about their child, have this information deleted, and/or request that there be no further collection or use of their
child's personally identifiable information. You can download the form here. We will take steps to verify the identity of anyone requesting personally
identifiable information about a child and to ensure that the person is in fact the child's parent or legal guardian.
Appendix C: Nickelodeon Group Privacy Policy
A-9
C. Termination of Wireless Services
You may cancel one or more wireless services via your wireless device at any time by using the unsubscribe mechanism provided by the Nickelodeon
Sites at the time the message is sent, or by sending a text message that says "STOP", "END", "CANCEL", "REMOVE", "UNSUBSCRIBE" or "QUIT".
Nickelodeon Sites will terminate your registration for the most recent wireless service you received. Any of these words followed by the word "ALL" in
the user's termination request will cancel all of the user's registered wireless services with the Nickelodeon Sites. If you unsubscribe from one or all
of wireless service(s) via your wireless device, the service(s) will be terminated immediately and will cancel your previous opt-in.
VI. ONLINE SAFETY.
Some of the Nickelodeon Sites offer you and your child an online safety guide which we encourage you to use as starting point for discussing safety
and privacy concerns with your child. Of course, involvement in your family´s online lives is the most important safety tool available. Some of the
various guides are available here:
http://www.neopets.com/safetytips.phtml
http://www.nick.com/club/parents-online-safety-guide.html
VII. LINKS TO THIRD PARTIES.
The websites that comprise the Nickelodeon Sites may contain links to other sites, including those of sponsors, advertisers, social networking
platforms, and survey companies. These other websites are governed by their own privacy policies or information collection practices, which may be
substantially different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those
websites.
VIII. YOUR CALIFORNIA PRIVACY RIGHTS.
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of
personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us:
nickprivacy@nickonline.com email, or you may contact us via regular mail at:
Nick.com CA Privacy Coordinator
Nickelodeon Online
1515 Broadway
New York, New York 10036
This document is the sole statement of the Nickelodeon Sites' Privacy Policy and no summary, restatement or other version thereof, or other privacy
statement or policy, in any form, including, without limitation, machine-generated, is valid. In interpreting this Agreement, the English version
governs the interpretation and meaning of the obligation set forth herein. To the extent there is an ambiguity or conflict with the Privacy Policy in
other languages, the Privacy Policy in English governs.
IX. CONTACT US
If you have any other questions about our information handling practices, including our practices with respect to children's personal information,
please contact us at:
Nick.com CA Privacy Coordinator
c/o Nickelodeon Online
1515 Broadway
New York, New York 10036
Or email us at:
nickprivacy@nickonline.com
Or call this number:
+1 212-846-2543
Other operators who may collect or maintain information through the websites include:
NeoPets, Inc., Glendale, California
Atom Entertainment, Inc. San Francisco, California
A complete lising of The Nickelodeon Sites that this Privacy Policy applies to is available here.
TEENS
Games for Girls
Fun Quizzes For Girls
PRESCHOOL
Preschool Games
Preschool Printables
Kids Crafts
Kids Recipes
PARENTÌ NG
Parents
Baby Names
Baby
Pregnancy Week by
Week
Pregnancy
Funny Stuff for Moms
GAMES
Free Online Games
iPhone Games
Kids Virtual Worlds
Racing Games
ONL Ì NE GAMES
Download Games
Hidden Object Games
© 2012 Viacom International Inc. All Rights Reserved. Nick and all related titles, logos and characters are trademarks of Viacom International Inc.
PRIVACY POLICY / YOUR CALIFORNIA PRIVACY RIGHTS - UPDATED 05/23/2012 TERMS OF USE COPYRIGHT COMPLIANCE SITEMAP
NEWSLETTER SAFETY GUIDE GROUND RULES PARENTS REPORT A CONCERN CLOSED CAPTIONING CONTACT AD CHOICES
Appendix C: Nickelodeon Group Privacy Policy
A-10
All Games
Top 10 Games
Community
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Privacy Policy
PlayFirst, Inc. Online Privacy Policy
Last updated November 9, 2012
Welcome to PlayFirst.com!
OUR PRIVACY COMMITMENT
As our guest and customer, PlayFirst, Inc. ("PlayFirst") respects your privacy rights and recognizes the importance oI protecting the inIormation you have shared with
us. To demonstrate this commitment, we adopted this Privacy Policy to guide how we collect, store, and use the inIormation you provide us online.
Your California Privacy Rights
TABLE OF CONTENTS
Q1. What inIormation does this Privacy Policy cover?
Q2. What types oI personal inIormation do we collect about our guests?
Q3. How is your personal inIormation used and shared?
Q4. What choices do you have about the collection, use, and sharing oI your personal inIormation?
Q5. What kinds oI security measures do we take to saIeguard your personal inIormation?
Q6. How can you update your personal inIormation and proIile?
Q7. How can you ask questions, or send us comments, about this Privacy Policy?
Q8. How will you know iI we amend this Privacy Policy?
Q1 What information does this Privacy Policy cover?
This Privacy Policy applies only to personal inIormation collected on PlayFirst websites and in PlayFirst games or other PlayFirst content available on our websites
where this Privacy Policy is posted, and does not apply to any other inIormation collected by PlayFirst through any other means. This Privacy Policy does not apply to
our international aIIiliates, or any websites maintained by other entities to which we link. PlayFirst is thereIore not responsible Ior the content or activities provided on
those websites.
Finally, the terms oI this Privacy Policy are subject to all applicable laws.
Q2 What types of personal information do we collect about our guests?
Personal inIormation is inIormation that identiIies you and may be used to contact you. We don't require personal inIormation to access our website, but iI you preIer
not to disclose personal inIormation, you may not be able to enjoy certain Ieatures oI our website.
Information You Provide to Us
We will collect personal inIormation Irom you when you use certain Ieatures on our website. For example, we collect personal inIormation when you:
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A-11
create an account
subscribe to our newsletter or other promotions
use "Tell a Friend" Ieatures
create a public proIile
make a purchase or send a giIt
participate in promotions
post on our Iorums or participate in our chat rooms or use our tips Ieature
submit a game
submit a game review
submit a high score
participate in our survey or provide Ieedback
sign up to participate in our beta program ("FirstPeek")
contact us (such as to report abuse or to submit customer service request)
Depending on the activity, this inIormation may include:
name
e-mail address (both your address and the recipient address Ior giIt purchases and Tell a Friend)
address
phone number
credit card inIormation
instant messenger ID
unique computer ID number (used Ior registering trial periods)
other comments that you provide to us
Additionally, we may also collect other types oI inIormation (known as demographic inIormation) such as your date oI birth, gender, hobbies, occupation, resume,
company inIo, or computer or game related inIormation. This demographic inIormation may be associated with your personal inIormation. Date oI birth may be used to
ensure compliance with applicable laws.
Information Collected Through Technology
When you visit our website, we passively collect inIormation through technology to enhance the Iunctionality oI our website and games. We collect inIormation through
technology in the Iollowing ways:
To optimize our website, when you visit our website we automatically collect and store: the UniIorm Resource Locator (URL) oI the website Irom which you linked
directly to our website; the Internet protocol (IP) address oI the computer you are using; the browser soItware you use and your operating system; the date and time
you access our sites; and the URL oI your destination aIter you leave our website.
We use "Cookies" to provide you with a more personal and interactive experience on our website. Cookies are pieces oI inIormation that a website stores on your
computer. We use cookies to maintain your website preIerences, to automate your log-ins to our website, to help analyze traIIic to our websites, and to track
downloads or reIerrals. This inIormation may be associated with the personal inIormation available in your account.
Google Analytics: We are working with a service-provider, Google Analytics, that assists us in better understanding your use oI our websites. PlayFirst will place
cookies on your computer upon a visit to our site to collect inIormation and we share that inIormation with Google Analytics through certain technical means (see
below). Blocking cookies served Irom third party domains will not block the technology used to collect this inIormation. The inIormation Google Analytics collects
educates us on such things as search engine reIerral, how you navigate around our site, traIIic driven by banner ads, responses to email, unique visitor identiIication, and
product browsing and purchasing inIormation, and allows us to better serve your interests and provide you with more personalized product oIIerings. PlayFirst does not
allow Google Analytics to collect the Iollowing personal inIormation about its users: Iull name, credit card number, username, complete birth-date, mailing address,
phone number or password inIormation. Google Analytics analyzes the inIormation it collects on our behalI and returns its analysis to us through a secure web
connection. Other than allowing use oI collected data on an aggregate basis, Google Analytics is contractually required to maintain all inIormation collected and its
analyses in conIidence. You have the option to deactivate Google Analytics trackingsee below to learn about your options.
We and our service provider Google Analytics use "Clear GIFs" to analyze traIIic on our websites, and within HTML e-mails to determine whether the e-mails have
been opened. Clear GIFs (also called Web Beacons, or Web Bugs) are small images embedded on web-pages and in email communications. We do not use clear
GIFS to collect or store any oI your personal inIormation.
We incorporate in some games an "Online Service" to enable access Irom within the game to our website and online services including proIiles, medals and badges,
chat, player matching, high scores and other online or multiplayer Iunctionality between one or more users. The Online Service is downloaded and installed with some
games and accesses our website to provide its Iunctionality; accordingly this Online Service is part oI our website. Use oI the Online Service is optional and is not
required to play the game except to use those Iunctions which must connect to our website or the Internet such as chat, online store, and multiplayer game play.
PlayFirst collects, through its logs, all your activities during your use oI the Online Service, including, but not limited to click paths, chat, advertising, purchase, and
multiplayer game play inIormation. II you make a purchase in an online store within the game, PlayFirst will collect inIormation such as the billing address, credit card
inIormation, items browsed, and your prior purchases. This inIormation will be tied to a unique computer ID that will be assigned to your computer when you use the
Online Service (and iI you are logged in through a PlayFirst Account, your PlayFirst Account). Some Ieatures oI the Online Service may require that you have a
PlayFirst Account beIore its use. This inIormation may be used by us to enable the Online Service to Iunction, identiIy abuse, ensure compliance with our Terms oI
Service, and to understand patterns oI play behavior in order to provide better services to the visitors oI our Site. You must be at least 13 years old to use the Online
Service.
Purchase Through Third-Party Sites. We may reIer you to our distribution partners such as the iTune App Store, Amazon when you wish to make a purchase or learn
more about our games. In those instances, your purchase and access oI the games will be subject to our distribution partners` privacy policies.
Appendix D: PlayFirst, Ìnc. Privacy Policy
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more about our games. In those instances, your purchase and access oI the games will be subject to our distribution partners` privacy policies.
Social Log-In. We may allow you to log into our Site or access the Services by using your log-in inIormation Irom social network sites such as Facebook and Twitter
('Social Log-In¨). II you choose to log into our Site or Services using your Social Log-In, then we may gain access to inIormation that you have stored with such social
network sites. We may also include certain Iunctionalities that are integrated with such social network sites. Your use oI such Iunctionalities is Iurther subject to the
privacy policies oI such social network sites.
Advertisements that are managed by third parties may be placed on our website. These companies are called "Network Advertisers." Network advertisers who may
place advertisements on our websites may also use cookies and web beacons to collect non-personal inIormation when you click on or move your cursor over one oI
their banner advertisements. You may not realize this inIormation is being collected. In some cases, we may have access to inIormation Irom web beacons and cookies
used by network advertisers on our sites and this inIormation may permit us to identiIy other sites that you have visited that are also associated with the network
advertiser. Finally, once you've clicked on an advertisement or third party logo and have leIt our websites, our Privacy Policy no longer applies and you must read the
privacy policy oI the advertiser to see how your personal inIormation will be handled on their website.
Our provision oI a link to any other website or location is Ior your convenience and does not signiIy our endorsement oI such other website or location or its contents.
We have no control over, do not review, and cannot be responsible Ior, these outside websites or their content. Please be aware that the terms oI our Privacy Policy do
not apply to these outside websites.
We do not knowingly collect personal information from children under 13.
Q3 How is your personal inIormation used and shared?
A3 Whatever the purpose may be, we will only collect inIormation to the extent reasonably necessary to IulIill your requests and our business objectives. For example,
we use personal inIormation submitted through a job application to evaluate your candidacy, or, we use an email address obtained Irom the newsletter registration to
deliver the newsletter emails.
PlayFirst Activities and Updates
We use your personal inIormation to:
respond to your requests Ior inIormation and newsletters,
provide you with access to games and services,
notiIy you oI changes to your tip requests,
provide product support, customer services and other communications related to your transactions on our website or with our products (e.g., reminders about
posting you have made, expirations oI postings you have made, or updates to soItware you have licensed),
determine iI you are eligible to receive certain products, services or promotions,
respond to your FirstPeek Ieedback,
provide you with additional inIormation that may be oI interest, including marketing materials, and
support other everyday business purposes, such as product development, job applications, and website administration.
Sharing of Information with Third Parties
Other than as described below with respect to PlayFirst service providers, we do not generally sell, trade, rent or share your personal inIormation with third parties
without your express consent, though we may directly pass onto you inIormation Irom third parties that we think may be oI interest. Only when you expressly opt-in to
receive communications, such as through a check-box, Irom selected third parties whose products or services PlayFirst thinks might be oI interest to you, will we share
your e-mail address with those parties.
Public Display of Information
II you participate in chat, online Iorums, tips, have a public proIile, or post your high scores, your username will be visible to the public. You may also display your
name, contact inIo through some oI these services. In addition, our chat, tips and Iorums allow you to communicate with members oI the online community. Whenever
you give out inIormation in public areas, that inIormation can be collected and used by people you do not know so you should not give out personal inIormation.
Service Providers
We occasionally employ other companies to perIorm services necessary to our internal operations. For example, we may partner with other companies to IulIill an order
Ior games, deliver promotional emails, or provide customer service. While providing services Ior us, these companies may access your personal inIormation, and are
required to use it solely as directed by us Ior the purpose oI our requested service. These companies are obligated to maintain your personal inIormation in conIidence.
We may also provide postal addresses to the U.S. Post OIIice or other couriers Ior delivery purposes.
Purchase or Sale of Businesses
Although we currently do not have a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, "AIIiliates"), this may
change in the Iuture. We may share some or all oI your Personal InIormation with these AIIiliates, in which case we will require our aIIiliates to honor this Privacy Policy.
II our company or our assets are acquired by another company, that company will possess the personal inIormation collected by us and it will assume the rights and
obligations regarding your personal inIormation as described in this Privacy Policy. The provisions oI this paragraph will also apply iI we are sold as part oI bankruptcy
proceedings.
Appendix D: PlayFirst, Ìnc. Privacy Policy
A-13
Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our
Websites and Others
Please note that we may disclose any inIormation as permitted or required by law, when we believe in good Iaith it is necessary Ior saIety purposes, required Ior legal
reporting, or to protect our legal rights or enIorce our Terms oI Use or any contest rules. We may also disclose inIormation about you to our auditors or legal advisors,
or in response to a subpoena.
Aggregate Information
We may take your personal inIormation and make it non-personally identiIiable. We do this either by combining it with inIormation about other individuals (aggregating
your inIormation with inIormation about other individuals), and by removing characteristics (e.g., your name) that make the inIormation personally identiIiable to you.
This process is known as de-personalizing your inIormation. We may use de-personalized inIormation in any way and share it with third parties.
Q4 What choices do you have about the collection, use, and sharing of your personal information?
When you create a PlayFirst Account, we give you the option to receive communications Irom us or selected third parties. You can change your preIerence at any time
by accessing your account.
II you signed up to receive newsletters or other emails Irom us, you can opt-out any time simply by clicking the unsubscribe link at the bottom oI the message, or by
sending an email to our online customer support. II you have opted-out Irom receiving communications Irom us, we may share that inIormation with the third parties who
perIorm services on our behalI so that they do not contact you on our behalI. Note that you may have more than one email option (e.g., both newsletters and
promotions) and unsubscribing Irom one will not unsubscribe you Irom the others. You may change these options by accessing your account or through our support
Iorm http://support.playIirst.com/
As a visitor to PlayFirst.com, you have the option to deactivate the ability oI Google Analytics to analyze your browsing and purchasing behavior on our site. You may
also choose to continue to beneIit Irom the improved shopping experience which the Google Analytics analysis allows us to provide to you, but maintain anonymity. II
you delete your cookies, you will need to opt-out again. To learn more about the various levels oI privacy and conIidentiality you can select with respect to Google
Analytics and to exercise your choice, click here.
Your California Privacy Rights
Since 2005, CaliIornia Civil Code Section 1798.83 permits our customers who are CaliIornia residents to request certain inIormation regarding our disclosure oI
personal inIormation to third parties Ior their direct marketing purposes. We may share our customer's personal inIormation with unaIIiliated third parties Ior their own
direct marketing purposes only as described in this Privacy Policy.
II you would like to know
the categories oI personal inIormation that we disclosed in the prior calendar year to such third parties about you Ior the purposes oI the third parties' marketing, and/or
the names and addresses oI such third parties, please contact us through our support Iorm at http://support.playIirst.com
II you have questions or wish to send us comments about this Privacy Policy, please e-mail or contact us at:
PlayFirst, Inc.
Attn.: Legal Counsel
160 Spear Street, Suite 1300
San Francisco, CA 94105
Email Address: Privacy¸playIirst.com
Phone Number: (415) 848-5800.
Q5 What kinds oI security measures do we take to saIeguard your personal inIormation?
The security and conIidentiality oI your inIormation is extremely important to us. That's why we have technical, administrative, and physical security measures in place to
protect your personal inIormation Irom unauthorized access and improper use. Web user data is stored behind a Iirewall, and is only accessible to authorized
employees. In addition, we encrypt the transIers oI sensitive personal inIormation. We also review our security procedures periodically to consider appropriate new
technology and updated methods. But, despite our reasonable eIIorts, no security measure is ever perIect or impenetrable.
Q6 How can you update your personal information and profile?
You may update or delete your personal inIormation or modiIy your account preIerences by accessing the account area oI our website. II you wish to delete your e-mail
address Irom our system, your account will also need to be deleted. You may also contact us directly to make changes or ask questions about your account through our
support Iorm.
Q7 How can you ask questions, or send us comments, about this Privacy Policy?
II you have questions or wish to send us comments about this Privacy Policy, please e-mail or contact us at:
PlayFirst, Inc.
Attn.: Legal Counsel
160 Spear Street, Suite 1300
Appendix D: PlayFirst, Ìnc. Privacy Policy
A-14
San Francisco, CA 94105
Email Address: Privacy¸playIirst.com
Phone Number: (415) 848-5800
Any personal inIormation you provide to the above e-mail and postal mail addresses will not be used to send you promotional materials, unless you request it.
Q8 How will you know iI we amend this Privacy Policy?
We may amend this Privacy Policy at any time. II we make any material changes in how we collect, use, or share your personal inIormation, we will prominently post
notice oI the changes on the websites covered by this Privacy Policy. Any material changes to this Privacy Policy will be eIIective 14 days Iollowing our posting oI
notice oI the changes on the websites covered by this Privacy Policy.
PlayFirst develops great mobile games for family and friends
At PlayFirst, we believe you can have Iun anywhere, any time and at any age.That`s why we`re committed to creating mobile games Ior everyone to enjoy,including the
Ian-Iavorite DASH® and Stars series oI games like Diner Dash®, SpongeBob Diner Dash® and Mall Stars¹.
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Appendix D: PlayFirst, Ìnc. Privacy Policy
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