Effective Date: April 21, 2025

1. Introduction & Scope

This privacy policy (“Privacy Policy”) explains how White Picket Media, Inc. (“WPM,” “we,” “us,” or “our”) collects, uses, discloses, and protects information through:

• Your use of our typing game services, including the features available at LucyJupiter.com, JackJupiter.com, and any related applications, software, accounts, or services (collectively, the “Services”).
• Your participation in our affiliate program (“Affiliate Program”).

The Services are designed for children (“Child Player” or “Child Players”) to use for practicing typing skills. However, registration and account creation for the Services must be completed by a parent or legal guardian (“Parent”). This Privacy Policy details the information collected from Parents during registration and account management, the limited information related to the Child Player's use of the Services under the Parent's authorized account, and the information collected from individuals who sign up for our Affiliate Program (“Affiliate Partner” or “Affiliate Partners”).

We are committed to protecting children's privacy online. This policy is designed to comply with the U.S. Children's Online Privacy Protection Act (COPPA) and other applicable privacy laws. WPM is the data controller responsible for the information collected through the Services and the Affiliate Program.

You understand and agree that WPM may store and process Personal Information (as defined below) on computers located outside of the European Union, including, but not limited to, in the United States. By using the Services or participating in the Affiliate Program, you consent to the collection and processing of your Personal Information (and, if applicable as a Parent, the authorized Child Player's information) outside of the European Union.

Parental Responsibility and Eligibility: By creating an account for the Services and providing WPM with your personal data, you warrant that you are a Parent over the age of eighteen (18) (or otherwise above the age of majority within your jurisdiction) and that you consent to this Privacy Policy on behalf of yourself and any Child Player you authorize to use the Services under your account. If you are a child under 13, please do not attempt to register an account yourself; ask your Parent to register for you.

Affiliate Partner Eligibility: By signing up for the Affiliate Program, you warrant that you are over the age of eighteen (18) (or otherwise above the age of majority within your jurisdiction) and consent to this Privacy Policy regarding the information collected for the Affiliate Program.

2. Information We Collect

We collect different types of information from different user groups. "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

A. Information Collected From Parents:

• Account Registration Data: When a Parent creates an account, we collect the Parent’s first and last name, email address, and a password. If the Service involves paid subscriptions or purchases, we may also collect billing information (such as address and credit card details) through our secure payment processor. Purpose: To create and manage the Parent account, provide the Services, process payments (if applicable), obtain verifiable parental consent, communicate important account or service information, and provide customer support.
• Communication Data: This includes any communications Parents send to us via email, contact forms, or support channels. Purpose: To respond to inquiries, provide support, maintain communication logs, and address legal claims.
• Marketing Data: This includes Parent preferences regarding receiving optional marketing communications like newsletters about our Services. Purpose: To send relevant information about our Services based on Parent preferences.
• Verification Data: Information necessary to obtain Verifiable Parental Consent (VPC) under COPPA before allowing a Child Player to access features that collect Personal Information. This may involve confirming via email or using another COPPA-compliant method. Purpose: To comply with legal requirements for protecting children's privacy.

B. Information Related to Child Players:

• Player Name: Under the Parent's account, a Child Player can choose a player name or username (e.g., "Emily", "Logan"). We strongly advise Parents to guide their children to choose a name that does not reveal their real full name or other identifiable details. Purpose: To personalize the game experience, track game progress associated with that player profile, and potentially display on leaderboards within the Service if this feature exists.
• Gameplay Data: We collect information about the Child Player's interaction with the typing games, such as scores, levels completed, typing speed, accuracy, and progress over time. This data is linked to the Player Name. Purpose: To provide the core functionality of the typing game, allow players to track their improvement, operate and enhance the Service, and provide feedback to the Player and Parent.
• (Conditional) Social Sharing Information: If a Parent enables the optional social sharing feature for a Child Player, the Child Player may choose to share specific gameplay achievements (like a high score) on third-party social media platforms. We process the action of sharing but typically do not collect personal information from the social media platform itself. The shared content and the act of sharing are then subject to the privacy policy of that third-party platform. Purpose: To allow users to optionally share their progress with friends or family, if enabled by the Parent.

C. Technical Data (Collected Automatically from Parents, Child Players, and Affiliate Partners visiting our sites):

• Technical Data: This includes IP address, device type (e.g., computer, tablet), operating system, browser type, and general usage information like session duration and interaction with Service features or website pages. Purpose: To operate and maintain the Services and Affiliate Program infrastructure, ensure compatibility across devices, secure the systems against misuse, perform necessary troubleshooting, and conduct basic, anonymized internal analytics to understand service usage patterns and improve the Services (e.g., identifying popular game levels or technical issues). This technical data is NOT used for behavioral advertising directed at Child Players or to build detailed profiles of Child Players for third-party use.

D. Information Collected From Affiliate Partners:

• Affiliate Registration Data: When an Affiliate Partner signs up for our Affiliate Program, we collect their first and last name, email address, and their preferred payment email address (e.g., PayPal email or Wise email). Purpose: To establish and manage the Affiliate Partner relationship, process affiliate sign-ups, verify identity, communicate essential program information (including if sign-up is incomplete), and facilitate commission payouts. We do not use this information for unrelated marketing purposes unless the Affiliate Partner separately opts-in.

E. Information We Do NOT Collect from Child Players:

• We do not ask Child Players to provide more Personal Information than is reasonably necessary to participate in the typing game activity.
• We do not collect sensitive personal information (such as health data, biometric data, specific geolocation) from Child Players.
• We do not collect contact information (like email address or phone number) directly from Child Players. All communication occurs through the Parent account.

3. When and Why Information is Collected (Including Parental Consent)

• Directly from Parents: We collect Parent information during account registration for the Services, when purchasing services (if applicable), when contacting support, or when opting into marketing communications.
• From Child Player Activity: Player Names are provided under the Parent account. Gameplay Data is generated automatically as the Child Player uses the Services.
• Directly from Affiliate Partners: We collect Affiliate Partner information during the Affiliate Program sign-up process.
• Automatically: Technical Data is collected automatically when Parents, Child Players, or Affiliate Partners interact with our websites or Services.
• Verifiable Parental Consent (VPC): In compliance with COPPA, before we collect, use, or disclose any Personal Information from a Child Player under 13 (beyond the limited data needed for internal operations like basic gameplay and security), we will obtain verifiable consent from the Child Player's Parent. We typically do this via an email sent to the Parent during registration, requiring a confirmation step. The Child Player's access to certain features may be limited until VPC is obtained.
• Social Sharing: Information related to social sharing is collected only if a Parent explicitly enables this optional feature within the account settings and the Child Player initiates a share.
• No Sale of Personal Information: WPM does not sell Personal Information collected from Parents, Child Players, or Affiliate Partners to third parties.

4. Cookies and Similar Technologies

WPM uses necessary cookies (small text files stored on your device) and similar technologies to operate the Services and our website effectively.

• Session Cookies: Temporary cookies deleted when you close your browser, used for functions like keeping you logged in.
• Persistent Cookies: Remain on your device for a set period, helping remember preferences.
• Purpose of Cookies: We use cookies primarily for essential functions: maintaining login sessions (Parents, Child Players), remembering user preferences (like volume settings), ensuring security, supporting basic operation, and potentially managing affiliate tracking (e.g., attributing sign-ups referred by an Affiliate Partner).
• Analytics: We may use first-party analytics or privacy-focused third-party analytics tools (e.g., Google Analytics configured with IP anonymization and data sharing restrictions) to collect aggregated, non-identifying information about how the Services and website are used.
• No Tracking/Advertising Cookies within Child Services: We do NOT use third-party cookies, web beacons, or similar technologies within the logged-in game environment for the purposes of behavioral advertising, tracking Child Players across different websites or services, or building user profiles for commercial purposes.
• Managing Cookies: Most web browsers allow you to control cookies through settings. Disabling essential cookies may impair the functionality of the Services or Affiliate Program features.

5. Marketing Communications

This section applies primarily to Parents and potentially Affiliate Partners. We may send marketing communications or newsletters about our Services to Parents. Parents can opt-out at any time via the "unsubscribe" link or account settings. Opting out of marketing does not affect essential service-related emails (e.g., account notifications, password resets, policy updates). We do not send marketing communications to Child Players. Affiliate Partners will not receive general marketing communications unless they specifically opt-in; however, they will receive necessary communications related to the administration and operation of the Affiliate Program (e.g., payment notifications, program updates).

6. Disclosure of Personal Information

We do not disclose Personal Information except in the limited circumstances described below:

A. Parent Personal Information: We may share Parent Personal Information with:

• Third-party service providers for essential functions (payment processing, hosting, data storage, customer support, email delivery), under confidentiality obligations.
• Professional advisors (accountants, auditors, insurers, attorneys).
• Government bodies or law enforcement if required by law or to protect rights/safety.
• A third party in the event of a business transfer (merger, acquisition, etc.), with notice as required by law.

B. Child Player Information: We do not sell Child Player Personal Information. We share Child Player Information (Player Name, Gameplay Data) only with:

• Third-party service providers strictly necessary to operate the Services (e.g., hosting), under confidentiality agreements, solely for the purposes outlined.
• As required by law, to protect a child's safety, respond to judicial process, or for public safety investigations.
• In connection with a business transfer, subject to confidentiality and notice.
• We do NOT share Child Player Personal Information with third parties for their marketing or advertising purposes.

C. Affiliate Partner Information: We may share Affiliate Partner Personal Information with:

• Payment processors (like PayPal or Wise) to facilitate commission payouts.
• Third-party service providers essential for operating the Affiliate Program (e.g., hosting, email delivery for program communications, potentially affiliate tracking platforms), under confidentiality obligations.
• Professional advisors.
• Government bodies or law enforcement if required by law (e.g., for tax reporting related to payouts) or to protect rights/safety.
• A third party in the event of a business transfer, with notice as required by law.
• We do NOT share Affiliate Partner Personal Information with third parties for their unrelated marketing purposes.

We require all third parties who receive Personal Information from us to respect the security of the data and to treat it in accordance with the law and our instructions.

7. Data Security

WPM has implemented reasonable administrative, technical, and physical security measures designed to protect the Personal Information we collect. Access is limited to those with a legitimate business need and bound by confidentiality. However, no internet transmission is 100% secure. We will notify affected individuals and regulatory bodies of a data breach where legally required.

8. Retention of Data

• A. Parent Personal Information: Retained as long as the Parent's account is active and as necessary thereafter for legal obligations (e.g., accounting), dispute resolution, and agreement enforcement.
• B. Child Player Information: Retained only as long as reasonably necessary to provide the Services under the Parent's active account. Parents can request deletion (see Section 9). May be retained in backups for a limited period.
• C. Affiliate Partner Information: Retained for the duration of the Affiliate Partner's participation in the program and as necessary thereafter to fulfill the purposes for which it was collected, including processing final payments, complying with legal and financial obligations (e.g., tax reporting), resolving disputes, and enforcing agreements.

9. Your Rights (Including Parental Rights under COPPA and Affiliate Partner Rights)

A. Parent Rights Regarding Their Own Information: Subject to local law, Parents may have the right to access, correct, request erasure of, restrict processing of, object to processing of, withdraw consent for, and request portability of their own Personal Information.

B. Parental Rights Regarding Child Player Information (COPPA): As a Parent, you have specific rights regarding the Personal Information we collect online from your Child Player(s) under 13:

• Right to Review: Review the Personal Information collected from your Child Player.
• Right to Delete: Request deletion of the Personal Information collected from your Child Player.
• Right to Refuse Further Collection or Use: Refuse further collection or use of your Child Player’s Personal Information. This may involve deleting a specific Child profile or the entire Parent account, potentially preventing further use of the Services.

C. Rights of Affiliate Partners: Subject to local law and contractual obligations, Affiliate Partners may have the right to access, correct, request erasure of (subject to legal/financial retention needs), restrict processing of, object to processing of, and request portability of their Personal Information collected for the Affiliate Program.

Exercising Your Rights: To exercise any of these rights (for yourself, your Child Player, or as an Affiliate Partner), please contact us using the details in Section 13. We will take reasonable steps to verify your identity before processing your request. We aim to respond within thirty days or as required by law.

10. Third Party Links

The Services or our website may contain links to Third-Party Sites not operated by WPM. Their information practices are not covered by this Privacy Policy. We encourage you to review their privacy policies.

11. Responding to Do Not Track Signals

Our Services and website are not currently configured to respond to browser DNT signals. However, we limit tracking as described in this policy, especially for Child Players, and do not use third-party tracking cookies for advertising within the logged-in child service environment.

12. Notification of Changes

We may update this Privacy Policy. Changes will be posted here with an updated "Effective Date." We encourage review periodically. For material changes, especially affecting Child Player information practices requiring new consent, we will provide more prominent notice (e.g., email to Parents/Partners) and may require renewed consent. Continued use after the Effective Date constitutes acceptance.

13. Contact Us

If you have questions about this Privacy Policy, our data practices, or wish to exercise your rights, please contact us using our online form at https://www.lucyjupiter.com/customer-service

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