Kids Web Services Privacy Policy
Privacy PolicyKids Web Services
If you are under 18 and using KWS to verify your age, you can also view our Teen Privacy Policy.
- Under-18 age verification users have a Teen Privacy Policy Legal Rights & Agreement Rules
If you are an employee, contractor, or authorised user of one of our Partner companies, click here.
- Under-18 age verification users have a Teen Privacy Policy Legal Rights & Agreement Rules
Last updated: 10 September 2026
- This policy covers KWS and information reasonably linked to you Use & Processing
Introduction
Welcome to Kids Web Services (KWS). We are committed to protecting your privacy and the privacy of children online. Our mission is to make the internet safer by building technology that enables companies to responsibly interact with their audiences.
This Privacy Policy explains how we collect, use, share, and store (process) your personal information when you interact with our age verification and parent consent management platform known as Kids Web Services (KWS), including our websites. When we say ‘personal information’, we not only mean information that can identify you, such as your name, email or address, but also any information that could reasonably be linked back to you.
- This policy covers KWS and information reasonably linked to you Use & Processing
This Privacy Policy also explains how we process and safeguard any personal information we collect directly from children in the COPPA Children’s Privacy Statement.
- This policy covers KWS and information reasonably linked to you Use & Processing
We also explain how you can exercise your rights relating to your personal information, including the right to object to certain types of processing we carry out.
- This policy covers KWS and information reasonably linked to you Use & Processing
We’ve provided summaries to help you identify key information at a glance. Click on the ‘Learn more’ links for more information.
The legal entity responsible for the information that we collect through KWS is Kids Web Services Ltd (we / us). Kids Web Services Ltd belongs to the Epic Games family of companies. If you have any questions about this Privacy Policy, please see the Contact Us section at the bottom.
- Kids Web Services Ltd is responsible for information collected through KWS Legal Rights & Agreement Rules
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What is KWS?
KWS is an age verification and parent consent management platform.
It’s used by:
- You, to verify your age and/or manage what personal information your child can share online.
- Operators of apps, games and other digital services (Apps), whom we call our Partners as follows: (i) if you are an end-user of their Apps, to verify your age; or (ii) if you are a parent or guardian of a child end-user of their Apps, to verify that you are an adult and to obtain your consent before they process certain personal information of your child (required by privacy laws in certain countries).
We provide different types of services to you and our Partners. We’ve explained this below.
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Parent Verification
The Parent Verification service enables our Partners to verify that the parents or guardians of their child end-users are adults (Parent Verification).
- KWS controls direct Parent Verification and Age Verification interactions under GDPR Legal Rights & Agreement Rules
Where the General Data Protection Regulation (GDPR) applies, we act as a controller of any personal information processed when you interact with us directly. For example, when you use our services to verify your age or participate in our AgeGraph. This means we are responsible under data protection laws for how your personal information is used when you interact with us directly during Parent Verification.
- KWS controls direct Parent Verification and Age Verification interactions under GDPR Legal Rights & Agreement Rules
The Partner is the controller of any personal information processed before you are directed to the KWS website and when you interact with the Partner directly. This means our Partner is responsible under data protection laws for how your personal information is used before you interact with us directly, and you should read the Partner’s privacy policy to understand how the Partner uses your personal information. We are not responsible for the privacy practices of the Partner.
- Partners control information handled before referral and in their own interactions Legal Rights & Agreement Rules
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Age Verification
The Age Verification service enables our Partners to verify the age of their end-users (Age Verification).
- KWS controls direct Parent Verification and Age Verification interactions under GDPR Legal Rights & Agreement Rules
Where the GDPR applies, we act as a controller of any personal information processed when you interact with us directly. For example, when you use our services to verify your age or participate in our AgeGraph. This means we are responsible under data protection laws for how your personal information is used when you interact with us directly during Age Verification.
- KWS controls direct Parent Verification and Age Verification interactions under GDPR Legal Rights & Agreement Rules
The Partner is the controller of any personal information processed before you are directed to the KWS website and when you interact with the Partner directly. This means our Partner is responsible under data protection laws for how your personal information is used before you interact with us directly, and you should read the Partner’s privacy policy to understand how the Partner uses your personal information. We are not responsible for the privacy practices of the Partner.
- Partners control information handled before referral and in their own interactions Legal Rights & Agreement Rules
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AgeGraph
Once you have successfully verified your age through our Parent Verification or Age Verification service, we will store your verified status alongside your hashed email address. Then, you can use your email address to: (i) manage your child's permissions for the same and other Partner Apps that use our Parent Verification service, or (ii) access other Partner Apps that use our Age Verification service. This is so that you won’t need to provide your Verification information again.
- AgeGraph reuses a successful verification across participating Partner Apps Linking & Identification
If you have successfully verified that you are an adult through our Parent Verification service, you won’t need to provide your Verification information again when accessing Partner Apps using our Age Verification service, and vice versa.
- AgeGraph reuses a successful verification across participating Partner Apps Linking & Identification
We call this network of verified individuals AgeGraph. We are solely responsible for how personal information is used for AgeGraph.
- AgeGraph reuses a successful verification across participating Partner Apps Linking & Identification
How to opt-out of AgeGraph
AgeGraph eliminates the need to collect Verification information more than once, minimising personal information collection and providing a safer service to you and our Partners.
- AgeGraph reuses a successful verification across participating Partner Apps Linking & Identification
You can, however, always choose to be removed from AgeGraph by emailing privacy@kidswebservices.com or using the opt-out link in the email we send you confirming that you have successfully verified.
- You can opt out of AgeGraph Account & Service Control
How AgeGraph works
AgeGraph is designed with privacy at the forefront, storing as little personal information as possible. Here’s how it works:
- Once you have been successfully verified, we remember this by storing:
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- your verified age threshold (e.g. 16+ , 18+);
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- the method of verification used, e.g. ‘individual verified by payment card using StripeStripe
’, but we never store the verification details (e.g. your card details) themselves;
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- the date and time you verified your age for the first time and subsequent times using AgeGraph, as well as the Partner and Partner App for which those verifications were made;
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- the country in which your device is located at the time of initially interacting with us; and
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- a KWS generated transaction ID for each verification and any transaction IDs provided to us by our verification partners such as Stripe.
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
We call this the verified status.
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- We then store this verified status against your hashed email address in AgeGraph. In non-technical terms, this means we scramble your email address using an algorithm so that it’s no longer directly identifiable as an email address.
- AgeGraph keeps verification metadata, but not the verification details themselves Retention & Deletion
- We can’t attribute the information in AgeGraph to you until you choose to provide your email address to verify your age again for a game or service powered by KWS’ technology, which is then hashed using the same algorithm and matched against the hashed email address we have stored.
- Providing your email again reconnects an AgeGraph record to you Linking & Identification
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The Parent Consent Management service enables our Partners to obtain your permission for the Partner’s processing of your child’s personal information in their Apps. It also enables you to manage the personal information your child can share online for each Partner App via your designated Parent Portal.
- Parent Consent Management provides app-specific permissions through a Parent Portal Account & Service Control
We are responsible for how your personal information is used for Parent Consent Management services.
- Parent Consent Management provides app-specific permissions through a Parent Portal Account & Service Control
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Age Gate
The Age Gate service enables our Partners to identify the country in which an end-user’s device is located and whether they are over/under the applicable age of digital consent in their country (i.e. the age below which permission from a child user’s parent/guardian is required for certain processing of the child user's personal information) or other age specified by the Partner. Where the GDPR applies, our Partners act as a controller for personal information processed as part of the Age Gate services. This means our Partner is responsible under data protection laws for how your personal information is used and you should read the Partner’s privacy policy to understand how the Partner uses your personal information for these services. We are not responsible for the privacy practices of the Partner.
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Kid Account Management
On occasion, we also provide account management services for our Partner’s end-users who are children, which we call Kid Account Management services. Where the GDPR applies, our Partners act as a controller for personal information processed as part of the Kid Account Management services. This means our Partner is responsible under data protection laws for how your personal information is used and you should read the Partner’s privacy policy to understand how the Partner uses your personal information for these services. We are not responsible for the privacy practices of the Partner.
- Partners are controllers for Kid Account Management where GDPR applies Legal Rights & Agreement Rules
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Personal information we collect
We collect information from you directly and through your interactions with KWS. We also receive information about you from our Partners when you or your child interact with their Apps. The information we collect and receive can include:
- KWS receives information from you, your interactions and Partners Data Access & Collection
- Account information. Your email address, which you give to us directly or which you or your child gives to a Partner who then shares it with us. When you interact with Parent Consent Management services, we also assign you a unique ID number that we use to recognise you when communicating with that Partner.
- KWS receives information from you, your interactions and Partners Data Access & Collection
- Verification information. Information you provide when you respond to a request from, or by us on behalf of, a Partner to verify your age, as well as your email address. You will be asked to select one verification method from the options available to you. The information you will be asked to provide depends on the verification method you choose and the country in which you are located, and will include some, but never all, of the following information: your name, date of birth, mailing address, credit or debit card information, a personal identity number (such as a CPF number in Brazil, a CURP number in Mexico, certain digits of a RRN number or i-PIN in the Republic of Korea, and certain digits of a US social security number in the US), a cell phone number, face scan, a government-issued identity document, or a photo of your face. Please note, if you select ID Scan & Selfie as the method to verify your age, we will uniquely identify your image against your selected ID, which may be considered biometric data.
- Verification data depends on your chosen method and country Data Access & Collection
- Device and usage information. When you interact with KWS, we automatically collect information about your devices (computers, phones, tablets etc.) and your use of and interactions with KWS, including in order to identify your country and language. We do this using server logs, web beacons, or similar technologies. Device information includes data about the operating systems and hardware and software versions, device identifiers, internet protocol (IP) address, login data, browser type and version, time zone setting, country and language. Usage information includes site navigation, the KWS features you use, the actions you take, the time, frequency and duration of your activities, data about the performance of KWS and any problems you experience, including error reports, each of which are used for the purpose of evaluating the performance of KWS and detecting errors. We do not use device or usage information to track your online activity, for browser fingerprinting or to build a profile on you for advertising or any other purposes.
- KWS automatically collects device and usage data with stated use limits Data Access & Collection
- KWS says it does not track online activity regardless of Do Not Track settings Data Access & Collection
- Customer support information. Information you give us when you contact us for help, such as your name, the content of your chats and other communications with us. When you contact us for customer support, chat sessions with our representatives may be monitored and recorded.
- Support information includes communications and potentially recorded chats Data Access & Collection
The information we collect relating to your child includes the following:
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Age information. The child’s age or date of birth. The Partner may collect this information directly from the child and/or we may collect it from you.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Unique ID. A unique user ID for the child, which we link to you.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Permissions. The permissions you granted for the child’s access to features of our Partners’ Apps.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Preferences. Your child’s preferred level of access to features of our Partners’ Apps, subject to your Permissions.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Country and Language. The child’s country (and in, in some cases, the child’s region or US state) and language.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
- Customer support information. Information your child gives us when they contact us for help, such as their name, the content of their chats and other communications with us. When your child contacts us for customer support, chat sessions with our representatives may be monitored and recorded.
- Support information includes communications and potentially recorded chats Data Access & Collection
We do not collect information directly from children except as described below in our COPPA Children’s Privacy Statement.
- Child-related data includes age, linked IDs, permissions and preferences Data Access & Collection
Our COPPA Safe Harbor certifications
We are a valid licensee and participating member of the Entertainment Software Rating Board’s Privacy Certified Program (ESRB Privacy Certified), a Federal Trade Commission (FTC)-approved COPPA Safe Harbor Program. We have voluntarily undertaken this privacy initiative to help protect your privacy. As a licensee in this privacy certification program, we are subject to audits of our services and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified. The technology behind our consolidated Parent Consent Management and Parent Verification solution has been reviewed and certified by ESRB Privacy Certified. This includes AgeGraph, when the parent has verified their adult status using a COPPA-compliant verification method. You can view our certification here. When implemented correctly by our Partners, these technologies facilitate compliance with the US Children’s Online Privacy Protection Act (COPPA).
- ESRB certification has method and implementation conditions Legal Rights & Agreement Rules
Kids Web Services (KWS) is certified by the kidSAFE Seal Program when implemented with KWS’ default templates. To learn more, click here or go to www.kidsafeseal.com.
- kidSAFE certification applies when KWS uses its default templates Legal Rights & Agreement Rules
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COPPA Children’s Privacy Statement
This statement explains how we process information collected directly from children. In most cases, our services are intended to be used either by adults or teens. For example, a parent may grant permissions for their child to access certain features of a Partner’s Apps or give us information about their child’s age. We process information relating to their child to provide services to our Partners, as further described in personal information we collect above.
- Direct child collection includes support requests with limited retention Retention & Deletion
However, in certain circumstances we collect information directly from a child, including:
- Direct child collection includes support requests with limited retention Retention & Deletion
- Customer support information: Information a child gives us when they contact us for help, such as their name, the content of their chats and other communications for us. When a child contacts us for customer support, chat sessions with our representatives may be monitored and recorded. This information is retained for 10 days after the customer support ticket has been closed, unless it needs to be retained to comply with legal obligations, resolve disputes, enforce our agreements or protect our rights.
- Direct child collection includes support requests with limited retention Retention & Deletion
This data is shared with our service providers who help us facilitate customer support. We share data only to provide, maintain and secure KWS, or if we’re required to do so by law, as further described here. We do not sell this data (or any other data) to anyone.
- Direct-child data is shared for KWS operations or legal requirements, not sold Sharing & Disclosure
- KWS limits sharing to the policy and says it does not sell information Sharing & Disclosure
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
As a parent, you have certain rights over how we handle the personal information collected directly from your child. This may include a right for you to review, access, or delete the personal information that has been collected by us from that child, and to refuse at any time to permit the collection from that child of such personal information. For information on how to exercise your rights, click here.
- Parents may have review, access, deletion and collection-refusal rights Account & Service Control
We maintain a comprehensive information security program designed to protect personal information collected directly from children. See "Keeping your information secure" for more information.
- KWS maintains an information security program for directly collected child data Security & Safeguards
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Why we collect your personal information and our legal basis for processing
We use the information we collect only when we have a valid reason and legal basis to do so. We determine the legal bases based on the purposes for which we collect your information. The legal bases we rely on may include the following:
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- to provide a service you’ve asked for under a contract we have entered into, or which we are about to enter;
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- Service delivery uses specified adult and child information Use & Processing
- AgeGraph relies on interests in reducing repeat collection and easing parental consent Legal Rights & Agreement Rules
- KWS uses listed data to maintain services, troubleshoot and provide support Use & Processing
- Device, usage and support data may help improve or develop services Use & Processing
- Safety processing uses specified data to protect services and people Security & Safeguards
- where we need to comply with a legal or regulatory obligation or to protect your vital interests;
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- where we ask for your consent to process your information for specific purposes and you have the right to withdraw your consent at any time.
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
Learn more
Most commonly, we use your personal information for the following purposes
Description
Categories of data
Legal bases
Purpose: To provide our services to you
- Service delivery uses specified adult and child information Use & Processing
We use your information to provide our services to you and our Partners.
- Service delivery uses specified adult and child information Use & Processing
Here are some examples:
We use your Verification information to verify your age so that you can: (i) consent to your child accessing features of our Partners' Apps, or (ii) access a Partner App or age-restricted feature of a Partner App. We also use your verified status for the purposes of AgeGraph .
- Age data supports access checks and tells Partners when consent is no longer needed Use & Processing
We store your child's Age information to notify our Partner when they have reached an age where they no longer require your consent to the processing of their personal information.
- Age data supports access checks and tells Partners when consent is no longer needed Use & Processing
Your data
- Account information
- Service delivery uses specified adult and child information Use & Processing
- Verification information
- Service delivery uses specified adult and child information Use & Processing
- Device and usage information
- Service delivery uses specified adult and child information Use & Processing
- Customer support information
- Service delivery uses specified adult and child information Use & Processing
Data about your child
- Age information
- Service delivery uses specified adult and child information Use & Processing
- Unique ID
- Service delivery uses specified adult and child information Use & Processing
- Permissions
- Service delivery uses specified adult and child information Use & Processing
- Preferences
- Service delivery uses specified adult and child information Use & Processing
- Country and Language
- Service delivery uses specified adult and child information Use & Processing
Performance of the contract you are party to which requires our services or for pre-contractual steps to enable you to access the relevant Partner Apps, or if you are under the age of contractual capacity, our legitimate interest to operate and provide you with services you access or request.
- Service delivery uses specified adult and child information Use & Processing
Explicit consent for biometric processing where you select ID Scan & Selfie as your verification method to verify your age. Use of your biometric data for these purposes is also in the substantial public interest to safeguard children.
- Verification methods have different consent bases Legal Rights & Agreement Rules
Consent in certain jurisdictions if you select face scan as your verification method to verify your age.
- Verification methods have different consent bases Legal Rights & Agreement Rules
Consent if you select ConnectID as your verification method to verify your age.
- Verification methods have different consent bases Legal Rights & Agreement Rules
For AgeGraph our legitimate interest in: (i) eliminating the need to collect and process Verification information more than once, minimising personal information collection and providing a safer service to you and our Partners; and (ii) pursuing our mission to make the internet safer by making it easier for you to provide, and children and our Partners to obtain, verifiable parental/guardian consent. The easier it is for you to provide—and children and our Partners to obtain—verifiable parental consent, the more likely that children will be honest about their age.
- AgeGraph relies on interests in reducing repeat collection and easing parental consent Legal Rights & Agreement Rules
Purpose: To maintain our services
We use your information to ensure our services are operating properly, to troubleshoot and provide customer support.
Your data
- Account information
- Verification information
- Device and usage information
- Customer support information
Data about your child
- Age information
- Unique ID
- Permissions
- Preferences
- Country and Language
Performance of the contract you are party to which requires our services or for pre-contractual steps to enable you to access the relevant Partner Apps, or if you are under the age of contractual capacity, our legitimate interest to operate, maintain and provide you with services you access or request.
Purpose: To improve and develop new products and services
- Device, usage and support data may help improve or develop services Use & Processing
We may sometimes use your information to help us improve and develop products and services, including to develop updates and add new functionality, products and features based on your comments and feedback and an understanding of how you and others use them.
- Device, usage and support data may help improve or develop services Use & Processing
Your data
- Device and usage information
- Device, usage and support data may help improve or develop services Use & Processing
- Customer support information
- Device, usage and support data may help improve or develop services Use & Processing
Our legitimate interest in improving and developing new products and services, while applying appropriate safeguards that protect your privacy.
- Device, usage and support data may help improve or develop services Use & Processing
Purpose: To promote safety and security
- Safety processing uses specified data to protect services and people Security & Safeguards
We use your information to help protect and improve the safety and security of our services, our end-users, our Partners and their end-users.
- Safety processing uses specified data to protect services and people Security & Safeguards
For example, we use information to detect and protect against error, fraud, breach of our terms or policies, or criminal or malicious activity.
- Safety processing uses specified data to protect services and people Security & Safeguards
Your data
- Account information
- Safety processing uses specified data to protect services and people Security & Safeguards
- Verification information
- Safety processing uses specified data to protect services and people Security & Safeguards
- Device and usage information
- Safety processing uses specified data to protect services and people Security & Safeguards
- Customer support information
- Safety processing uses specified data to protect services and people Security & Safeguards
Data about your child
- Unique ID
- Safety processing uses specified data to protect services and people Security & Safeguards
- Country and Language
- Safety processing uses specified data to protect services and people Security & Safeguards
Depending on the circumstances, we rely on the following legal bases: (i) to comply with legal obligations; (ii) to protect vital interests; or (iii) our legitimate interest in providing a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others' rights, property and interests, while applying appropriate safeguards that protect your privacy.
- Safety processing uses specified data to protect services and people Security & Safeguards
- Safety processing may rest on legal duties, vital interests or legitimate interests Legal Rights & Agreement Rules
Purpose: To communicate with you
We use information we collect, like your email address, to interact with you directly.
Here are some examples:
We may email you to let you know that you have been successfully verified.
We may notify you of a new permission request from your child. We may email you to confirm that the email address belongs to you.
We may email you to let you know that your email address has been submitted to access a Partner App or age-restricted feature of a Partner App.
We may also respond to inquiries or other communications from you or your child, or inform you of changes to our terms, policies, or products or services.
We do not send marketing communications to you or children using our Partners' Apps.
Your data
- Account information
- Device and usage information
- Customer support information
Data about your child
- Customer support information
When using, processing or sharing information for this purpose, we do so on the legal basis of performance of a contract or, if we have not entered into a contract with you or you are under the age of contractual capacity, our legitimate interest to operate and provide you with services and/or our legitimate interest in fulfilling and responding to your requests.
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Reasons we share your personal information
We do not share your personal information with others except as described in this Privacy Policy (like to provide, maintain and secure KWS, or if we’re required to do so by law). We do not sell any of your information to anyone.
- KWS limits sharing to the policy and says it does not sell information Sharing & Disclosure
We share your information as follows:
- Service providers. As with most companies, we use third parties to help us provide KWS, such as IT and hosting providers or payment card processors. For example, we share Verification information with payment card processors we use to verify your age. Some of these providers may process your personal information on our behalf, for the purposes set out in this Privacy Policy. These providers are subject to contractual obligations governing privacy, data security and confidentiality. We maintain a current list of the service providers that we use here. We also share personal information in some cases with our professional advisers and other service providers who are sometimes independent ‘data controllers’, such as lawyers, accountants and insurers (e.g. when enforcing our contract with you or in the event of claims against us).
- Providers and professional advisers may receive information Sharing & Disclosure
- Partners. If you or your child uses a Partner App, we share your personal information with our Partners to deliver the services which you have requested from either us or our Partners. For example, if you verify your age through KWS, we communicate your verified status to the Partner to enable the Partner to proceed with obtaining your permissions (whether using Parent Consent Management or otherwise) for their collection of your child’s personal information, or giving you access to their App or age-restricted features of their App. If your child is an end-user of a Partner, we may communicate their Age information to the Partner in order to notify the Partner that your child has reached an age where they no longer require your consent to the collection of their personal information. We also provide Partners with updates to your child’s Preferences and the Permissions you give your child through the Parent Portal.
- Partners receive verification status and child-permission updates Sharing & Disclosure
- Other companies within our group. We may share your information with our Epic Games family of companies, including companies that we may acquire in the future, but only to the extent necessary to fulfil purposes set out in this Privacy Policy, or otherwise as authorised by you. For example, our group companies assist us in the provision of customer support to our Partners.
- Epic group sharing is limited by policy purposes or your authorisation Sharing & Disclosure
- Other legal or regulatory process.
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- We may share your personal information if we believe it is reasonably necessary:
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- where required by law;
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- to comply with legal processes;
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- to permit us to pursue available remedies, including commencing or responding to any claims;
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- to enforce or apply our terms;
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- to protect the security or integrity of our services;
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- to protect the rights, property, interests or safety of KWS, our employees, customers, our end-users or our Partners’ end-users; or
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- for risk management purposes.
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- The categories of information we disclose and our legal basis for doing so depends on the circumstances, but generally it is to comply with legal obligations, to protect vital interests or act in our legitimate interest to provide a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others’ rights, property and interests, and responding to legal requests from governmental and law enforcement agencies.
- KWS may disclose information when it believes legal or protective needs justify it Sharing & Disclosure
- If we are acquired. If we are involved in a merger, acquisition, or sale of assets, we may share your personal information with the acquiring or receiving entity. The categories of information we disclose and our legal basis for doing so depends on the circumstances, but would include our legitimate interest in operating, selling and expanding our business, including through such transactions. If a change happens to our business, the new owners may only process your personal information in the same way as set out in this Privacy Policy.
- An acquiring entity may receive information but remains limited by this policy Sharing & Disclosure
- A note about aggregated data. We may derive aggregated data from your personal information and we may share this information in aggregated form with our Partners as part of our services. For example, we may aggregate Usage information to calculate the percentage of parents/guardians who provide verifiable parental consent to their child accessing a certain feature of one of our Partner’s games. However, because this data has been through a process to de-identify personal information so that it can no longer be associated in the Partner’s hands with a person, the aggregated data cannot directly or indirectly reveal your identity to the Partner.
- KWS may share de-identified aggregate information with Partners Sharing & Disclosure
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Keeping your information secure
We value your trust and maintain a comprehensive information security program designed to protect personal information using administrative, physical, and technical safeguards. The specific security measures used are based on the sensitivity of the personal information collected. While we cannot guarantee that loss, misuse or alteration of data will not occur, we have measures in place designed to protect against inappropriate access, loss, misuse, or alteration of personal information under our control. For example:
- Security safeguards do not guarantee against loss, misuse or alteration Security & Safeguards
- Our security team regularly reviews our security and privacy practices and enhances them as necessary to help protect the integrity of our systems and your personal information.
- Security safeguards do not guarantee against loss, misuse or alteration Security & Safeguards
- We work to limit access to your personal information to those employees, agents, contractors and other third parties strictly on a “need to know” basis.
- Security safeguards do not guarantee against loss, misuse or alteration Security & Safeguards
- We use secure server software to encrypt personal information, and we only partner with security companies that meet and commit to our security standards.
- Security safeguards do not guarantee against loss, misuse or alteration Security & Safeguards
Third-party websites, services and apps
Some of the correspondence you receive from us may contain links to third-party websites, online services or mobile applications that are not affiliated to or operated by us, including those of our Partners. We are not responsible and accept no liability for the content, security or privacy practices of those other operators.
- KWS disclaims responsibility for linked third-party services Legal Rights & Agreement Rules
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Your rights and access to your personal information
We provide you with rights and choices about the personal information we collect and hold about you. The specific choices available to you may vary depending on your location and applicable law.
- Access, deletion and correction rights have location and legal limits Account & Service Control
- Transfer and temporary restriction rights are conditional Account & Service Control
- Right of access: You have a right to request access to your personal information and to be provided with a copy of your personal information, including the categories of your personal information we collect and disclose.
- Access, deletion and correction rights have location and legal limits Account & Service Control
- Right of deletion: You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law. See How to exercise your rights for information on how to delete your personal information.
- Access, deletion and correction rights have location and legal limits Account & Service Control
- Right of correction: You have the right to request that we correct inaccurate information about you, though we may need to verify the accuracy of the new data you provide to us.
- Access, deletion and correction rights have location and legal limits Account & Service Control
- Right to object (legitimate interest): Where we process your personal information based on legitimate interests, you can object to this processing where you feel it impacts on your fundamental rights and freedoms. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- You can object to legitimate-interest processing, subject to exceptions Use & Processing
- Right to object (marketing): We do not send marketing communications from KWS to our end-users or end-users of our Partners.
- Right to transfer: You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to a third party.
- Transfer and temporary restriction rights are conditional Account & Service Control
- Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
- Transfer and temporary restriction rights are conditional Account & Service Control
- Right to withdraw consent: Where you have previously provided your consent, you have the right to withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal information. However, this will not affect the lawfulness of the processing based on consent before its withdrawal.
- KWS ties processing to purpose-specific legal bases Legal Rights & Agreement Rules
- Consent withdrawal does not undo prior processing’s lawfulness Use & Processing
- Right to complain: If you have a complaint about the handling of your personal data, or feel that we have not complied with your legal rights, please contact us by emailing privacy@kidswebservices.com. You also have the right to lodge a complaint with our supervisory authority, the UK Information Commissioner (www.ico.org.uk), which is the regulator responsible for data protection in the United Kingdom. You can also lodge a complaint with your local supervisory authority for data protection. See here.
- You may complain to KWS or a data-protection regulator Legal Rights & Agreement Rules
- Rights relating to your child’s personal information: As a parent/guardian, you have certain rights over how we handle the personal information of your child. This may include a right for you to review, access, or delete the personal information that has been collected by us (in our capacity as a controller) from that child, and to refuse at any time to permit the collection from that child of such personal information. If you withdraw your consent, your child may lose access to certain apps, games or other digital services. We will advise you if this is the case at the time you withdraw your consent.
- Withdrawing a child’s consent may remove access to apps or services Account & Service Control
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How to exercise your rights
If you want to exercise any of your rights and are not able to do so by following the instructions in our Account Management FAQs, you can email us at privacy@kidswebservices.com at any time.
- Rights requests can be emailed and may require identity verification Account & Service Control
Before we process such requests, we may ask you to verify your identity (like by logging-in to your account or providing us with certain information) if warranted for a particular disclosure. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. No payment is usually required to exercise your rights. However, we may request payment where allowed by law (for example, if your request is manifestly unfounded or excessive).
- Rights requests can be emailed and may require identity verification Account & Service Control
Please note that we provide age verification services for our Partners (i.e. operators of apps, games and other digital services). To dispute an age verification outcome (including an estimated age if you used face scan as your verification method), please contact the Partner directly. They make all final decisions relating to your app, game or service account.
- Age-verification disputes go to the Partner Account & Service Control
If you are a United States or Australian resident, refer to the Location-specific rules section below for more information on your legal rights.
- Rights requests can be emailed and may require identity verification Account & Service Control
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Our retention of personal information
You can delete some personal information whenever you like by contacting us at privacy@kidswebservices.com.
- Retention depends on purpose, data type and legal needs Retention & Deletion
Otherwise, we retain personal information for as long as necessary to fulfil the purposes we collected it for, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements or protecting our rights.
- Retention depends on purpose, data type and legal needs Retention & Deletion
Retention periods vary significantly depending on the different data types, the purposes for which they were collected and the context of our interactions with you. To determine the appropriate retention period, we consider:
- Retention depends on purpose, data type and legal needs Retention & Deletion
- the amount, nature and sensitivity of the data;
- Retention depends on purpose, data type and legal needs Retention & Deletion
- the potential risk of harm from unauthorised use or disclosure of the data;
- Retention depends on purpose, data type and legal needs Retention & Deletion
- the purposes for which we process the data and whether we can achieve those purposes through other means;
- Retention depends on purpose, data type and legal needs Retention & Deletion
- applicable legal, regulatory, tax or accounting requirements.
- Retention depends on purpose, data type and legal needs Retention & Deletion
For example, customer support information is retained for 10 days after the customer support ticket has been closed, unless it needs to be retained to comply with legal obligations, resolve disputes, enforce our agreements or protect our rights.
- Support information is normally kept for ten days after ticket closure Retention & Deletion
We require any third-party service providers we use to delete personal information once it is no longer necessary for them to provide the services or to satisfy any legal, regulatory, tax, accounting or reporting requirements.
- Providers must delete unneeded data; Partner-controller retention is separate Retention & Deletion
Where our Partners act as controllers when processing you or your child’s personal information (i.e. Age Gate services and Kid Account Management services), please refer to their privacy policies or contact the Partner directly for information on how long they retain your personal information.
- Providers must delete unneeded data; Partner-controller retention is separate Retention & Deletion
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International transfer of personal information
We transfer your personal information in the following ways:
- Information may transfer outside the UK, Switzerland and EEA Sharing & Disclosure
- As we explain above, we share your personal information within our group of companies. Our group companies are located in the United States and other countries outside the UK, Switzerland and EEA.
- Information may transfer outside the UK, Switzerland and EEA Sharing & Disclosure
- As we explain above, we use third-party service providers to help us provide KWS, such as hosting providers or payment card processors. Some of these providers, including their servers, are based outside the UK, Switzerland and EEA.
- Providers and professional advisers may receive information Sharing & Disclosure
- Information may transfer outside the UK, Switzerland and EEA Sharing & Disclosure
- As we explain above, we also provide your information to Partners. Some of these Partners are based outside the UK, Switzerland and EEA.
- Information may transfer outside the UK, Switzerland and EEA Sharing & Disclosure
Countries where we and our service providers and Partners operate may not offer the same level of data protection as your home country. We use specific contracting frameworks approved by the UK Government, Swiss Government and European Commission that are designed to give personal information protection essentially equivalent to that in the UK, Switzerland and EEA (as applicable). We may also need to transfer your information to provide KWS to you in accordance with our existing agreements with you, such as the KWS Terms of Use.
- Information may transfer outside the UK, Switzerland and EEA Sharing & Disclosure
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A cookie is a small piece of text sent to your browser by a website you visit. We and other organisations use necessary cookies to make KWS work. We may also set analytics cookies that help us make improvements by measuring how you use KWS. You can set your browser to block or alert you about these cookies, but some parts of KWS may not then work. This table explains the cookies we use and why.
- Necessary and analytics cookies can be blocked, with possible service effects Data Access & Collection
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Do Not Track and Global Privacy Control signals
KWS does not track our end-users’ online activities, regardless of whether or not they have “Do-Not-Track” enabled in their browser. This means we go further than Do-Not-Track technology, which is not supported by all browsers, and where it is supported, is not enabled by default. By not tracking our end-users’ online activities (regardless of any Do-Not-Track signal), we achieve the intent of that technology for everyone. We are not aware of any third party that may collect personal information about our end-users’ online activities over time and across third party websites when our end-users use our website or services. For more information on “Do Not Track,” click here.
- KWS says it does not track online activity regardless of Do Not Track settings Data Access & Collection
For the same reasons, we do not respond to Global Privacy Control (GPC) signals, which are designed to allow users to opt out of the sale of their personal information or use of their personal information for targeted advertising purposes. We do not sell your personal information, or use or share it for targeted advertising purposes. See Reasons we share your personal information for more information on when we share your personal information.
- KWS does not respond to GPC because it says it does not sell or target ads Sharing & Disclosure
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Location-specific rules
Depending on where you are resident, specific rules apply.
- Australian residents can escalate unresolved inquiries to the OAIC Legal Rights & Agreement Rules
Australian residents
If you are a resident of Australia and you are not happy with how we responded to your inquiry or it has not been satisfactorily addressed, you may lodge a complaint with the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or +61 1300 363 992.
- Australian residents can escalate unresolved inquiries to the OAIC Legal Rights & Agreement Rules
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United States residents
If you are a resident of the United States and believe that we have not responded to your inquiry or it has not been satisfactorily addressed, please contact ESRB Privacy Certified at privacy@esrb.org or by using their online contact form here.
- US residents can contact ESRB Privacy Certified about unresolved inquiries Legal Rights & Agreement Rules
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California residents
This additional section applies to California residents because of the specific privacy laws in that state. It explains the additional rights and details required by the California Consumer Privacy Act of 2018, as amended, and its implementing regulations (CCPA). For the purposes of this section, Personal Information, Sensitive Personal Information, Third Parties, Business Purposes, Commercial Purposes, Sell, Share and Business have the meanings given to them under the CCPA.
- The California supplement uses CCPA definitions and covers KWS as a Business Legal Rights & Agreement Rules
- California sensitive-information use is limited; KWS says it does not Sell or Share Sharing & Disclosure
Learn more
Categories of Personal Information we collect
We act as a Business when we interact with you directly, including when you verify your age and participate in AgeGraph.
- The California supplement uses CCPA definitions and covers KWS as a Business Legal Rights & Agreement Rules
When acting as a Business, we have collected the following categories of Personal Information in the past 12 months (using the categories described in the CCPA). This list includes all categories that we collect, but the categories that apply to you will vary depending on how you interact with KWS:
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Identifiers – including Account information and Device and usage information.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Personal information described in Section 1798.80(e) of the California Civil Code – including Verification information you provide.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Commercial information – including Usage information.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Internet activity – including Usage information.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Geolocation – we only collect the country, and if in the US, the state in which you are located.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Characteristics of protected classifications under California or federal law - including age (40 or older).
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
- Sensitive Personal Information - including Verification information you provide like your government ID.
- California’s twelve-month collection list varies with your KWS interactions Data Access & Collection
We do not use or disclose Sensitive Personal Information for purposes other than those that are necessary to perform KWS or permissible under the CCPA.
- California sensitive-information use is limited; KWS says it does not Sell or Share Sharing & Disclosure
We do not Sell or Share Personal Information, including for our end-users that we know are under the age of 16.
- California sensitive-information use is limited; KWS says it does not Sell or Share Sharing & Disclosure
For more information on:
- the categories of sources from which your Personal Information is collected, see Personal information we collect;
- California source, purpose and recipient disclosures refer to the main policy Legal Rights & Agreement Rules
- the Business Purposes or Commercial Purposes for collecting your Personal Information, including Sensitive Personal Information, see Why we collect your personal information and our legal basis for processing; and
- California source, purpose and recipient disclosures refer to the main policy Legal Rights & Agreement Rules
- the categories of Third Parties to whom we disclose your Personal Information, see Reasons we share your personal information.
- California source, purpose and recipient disclosures refer to the main policy Legal Rights & Agreement Rules
Your rights
If you are a California resident, you have the right to:
- California residents have access and correction rights, with response limits Account & Service Control
- know and access what personal information we collect about you, including the categories of personal information collected and sources, the business or commercial purposes for collection, the categories of third parties with whom we disclose personal information, and the specific pieces of personal information collected;
- California residents have access and correction rights, with response limits Account & Service Control
- correct your personal information; and
- California residents have access and correction rights, with response limits Account & Service Control
- deletion of your personal information.
- California deletion has operational and legal retention exceptions Retention & Deletion
We will delete your personal information, unless retention is necessary for operational or legal reasons, including to:
- California deletion has operational and legal retention exceptions Retention & Deletion
- provide KWS, complete transactions, or perform our contract with you;
- California deletion has operational and legal retention exceptions Retention & Deletion
- ensure the security or integrity of KWS, or debug KWS;
- California deletion has operational and legal retention exceptions Retention & Deletion
- exercise legal rights on behalf of ourselves or others;
- California deletion has operational and legal retention exceptions Retention & Deletion
- enable internal uses aligned with user expectations; or
- California deletion has operational and legal retention exceptions Retention & Deletion
- comply with a legal obligation.
- California deletion has operational and legal retention exceptions Retention & Deletion
- We may also limit how we respond to your requests, including when necessary to handle legal claims, comply with applicable laws or legal obligations, or cooperate with law enforcement.
- California residents have access and correction rights, with response limits Account & Service Control
- California deletion has operational and legal retention exceptions Retention & Deletion
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Other US state residents
- Other state-law rights apply according to the law in force where you live Account & Service Control
Certain US states, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia have each enacted a comprehensive privacy law, which are in effect as of the date of this Privacy Policy. Other states may enact comprehensive privacy laws in the future. These laws provide residents of those states with certain rights to their personal data. Terms used in this subsection are defined by the applicable privacy law in force in your state of residence. Generally, however, they provide residents with the rights set forth below.
- Other state-law rights apply according to the law in force where you live Account & Service Control
Learn more
Your rights
If you are a resident of a state with a comprehensive privacy law in effect, you have the right to:
- Other state-law rights apply according to the law in force where you live Account & Service Control
- know whether we are processing your personal data;
- Other state-law rights apply according to the law in force where you live Account & Service Control
- access and obtain a copy of your personal data;
- Other state-law rights apply according to the law in force where you live Account & Service Control
- Other state-law correction and deletion rights have exceptions Account & Service Control
- correct your personal data (except for residents of Utah and Iowa); and
- Other state-law correction and deletion rights have exceptions Account & Service Control
- deletion of your personal data.
- Other state-law correction and deletion rights have exceptions Account & Service Control
- Certain legal obligations and operational needs may limit how we respond to your requests. These exceptions may include:
- Other state-law correction and deletion rights have exceptions Account & Service Control
- providing KWS or performing our contracts;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- conducting research to develop or improve KWS;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- identifying and fixing technical issues;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- performing other internal operations consistent with user expectations;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- preventing or responding to security incidents, fraud, identity theft, or other illegal or harmful activities;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- handling legal claims;
- Other state-law correction and deletion rights have exceptions Account & Service Control
- complying with applicable laws or legal obligations; or
- Other state-law correction and deletion rights have exceptions Account & Service Control
- cooperating with law enforcement.
- Other state-law correction and deletion rights have exceptions Account & Service Control
We do not sell personal data that we collect, process personal data for targeted advertising or profile our end-users through automated means to make decisions that have legal or similarly significant effects, including for our end-users that we know are under the age of 18.
- KWS says it does not sell, target ads or use significant-effect automated profiling Inference & Profiling
For more information on:
- the categories of personal data processed by us, see Personal information we collect;
- Other-state disclosures refer to the main collection, purpose and sharing sections Legal Rights & Agreement Rules
- our purposes for processing personal data, see Why we collect your personal information and our legal basis for processing;
- Other-state disclosures refer to the main collection, purpose and sharing sections Legal Rights & Agreement Rules
- the categories of third parties with whom we share personal data and the categories of personal data we shared, see Reasons we share your personal information; and
- Other-state disclosures refer to the main collection, purpose and sharing sections Legal Rights & Agreement Rules
- our processing of sensitive data from a known child under 13, see information relating to your child as set out here.
- Other-state disclosures refer to the main collection, purpose and sharing sections Legal Rights & Agreement Rules
Exercising your privacy rights
To exercise your privacy rights, use one of the methods listed in the Contact us section below. Only you (or an authorized representative on behalf of a California resident) may submit a verifiable request, which must include enough information for us to confirm your identity and understand the request. Authorized agents of California residents must include written permission signed by the resident, who may also need to verify their identity directly. Requests may be denied if we cannot verify your identity or authority. Appeals can be submitted using the same contact methods listed in the Contact us section below.
- Verifiable rights requests and appeals use the Contact Us channels Account & Service Control
We will not discriminate against you for exercising any of your privacy rights under applicable law.
- Verifiable rights requests and appeals use the Contact Us channels Account & Service Control
Nevada residents
Nevada residents have the right to direct a business not to sell certain kinds of personal information that the business has collected about them. We do not sell personal information. If you are a Nevada resident and wish to submit a request relating to this right, please email us at privacy@kidswebservices.com.
- Nevada residents can email a no-sale request Sharing & Disclosure
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Contact us
We work hard to ensure that the processing of your personal information is carried out fairly and lawfully. If you have any questions regarding our privacy practices, need information or require assistance, please contact us at:
- KWS’s Data Protection Officer accepts privacy questions and assistance requests Account & Service Control
Attn: Data Protection Officer
- KWS’s Data Protection Officer accepts privacy questions and assistance requests Account & Service Control
Kids Web Services Ltd, C/O Shepherd And Wedderburn LLP, 1-6 Lombard Street, London, England, EC3V 9AA, United Kingdom
- KWS’s Data Protection Officer accepts privacy questions and assistance requests Account & Service Control
Email: privacy@kidswebservices.com
- KWS’s Data Protection Officer accepts privacy questions and assistance requests Account & Service Control
If you are located inside the European Economic Area (EEA), you can alternatively contact our representative in the EEA at:
- EEA and Brazil users have named regional privacy contacts Account & Service Control
Attn: KWS GDPR Representative
- EEA and Brazil users have named regional privacy contacts Account & Service Control
Mishcon de Reya Representative Services (Europe) Limited, 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland
- EEA and Brazil users have named regional privacy contacts Account & Service Control
Email: representative@mishcon.com
- EEA and Brazil users have named regional privacy contacts Account & Service Control
If you are located in Brazil, you can contact our Data Protection Officer in Brazil: Henrique Fabretti of Opice Blum, Bruno Advogados Associados
- EEA and Brazil users have named regional privacy contacts Account & Service Control
Email: privacy@kidswebservices.com
- EEA and Brazil users have named regional privacy contacts Account & Service Control
If you are located in the US, you can also call us on: (919) 447-4560.
- KWS’s Data Protection Officer accepts privacy questions and assistance requests Account & Service Control
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Changes to this Privacy Policy
We may modify this Privacy Policy at any time. When we do, we will update the ‘Last updated’ date on this Privacy Policy. In some cases, such as when we make material or substantive changes to our policies and practices, we will also notify you of the relevant changes by email or within KWS as appropriate.
- KWS may change the policy and gives additional notice in some cases Legal Rights & Agreement Rules
If you object to any changes, you may delete your personal information as described in How to exercise your rights.
- KWS may change the policy and gives additional notice in some cases Legal Rights & Agreement Rules
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