- Privacy Policy

Privacy Policy from The live version of this document is available at This document is a part of Docracy's Terms of Service Tracker project, which tracks changes to terms of service and privacy policy documents of many of the world's top websites.

Updated: November 1, 2013

Disney Club Penguin ("Club Penguin") is operated and presented to users in all locations by Disney Canada Inc. (formerly known as Disney Online Studios Canada Inc.) located at 500-1628 Dickson Avenue, Kelowna, British Columbia, Canada VIY 9X1. This Privacy Policy covers use of information collected by Club Penguin and its related mobile app(s).

We are committed to providing a fun, entertaining, and safe website for people of all ages. We are dedicated to safeguarding any personal information collected on the Club Penguin website. We ensure that our Privacy Policy and our information practices adhere to the United States Children's Online Privacy Protection Act, applicable European Union Data Protection legislation, Canadian federal and provincial privacy legislation, other applicable data privacy laws and all other applicable legislation.

To help ensure a rewarding online experience for our visitors, we provide you with this Privacy Policy that describes the information practices of the Club Penguin website (, including how we collect, use and disclose personal information.

TRUSTe Children privacy certification

  1. The Information We Collect

    We require consent from a parent when a child wants to register.  As described in this Privacy Policy, we directly collect from child users during our initial registration process a parent's email address, the child's account name, and the child's password. When a Club Penguin child registrant acquires a paid membership, we may collect additional personally identifiable information ("PII") from the registrant's parent. The types of PII that may be collected at that time include the parent's full name, email address, and credit card (or other payment method) billing information including mailing address. The Club Penguin website does not condition a child's participation in an online activity on the child providing more personal information than is reasonably necessary for that activity.

    The Club Penguin website requires child users to provide a parent's valid email address in order to register on the website to participate in the Club Penguin virtual world, play games and view content. We use the parent’s email address to send the parent a message that can be used to activate the Club Penguin account, to notify the parent about our privacy practices, and to send the parent communications either about the parent’s and child’s Club Penguin accounts or about features of our website, including periodic parent newsletters about Club Penguin, and for such other purposes as described in this Privacy Policy. This email address is correlated with the account user name. With the parent’s prior permission, we also may use this email address to send the parent promotional messages regarding Club Penguin and/or The Walt Disney Family of Companies products and services.  The parent may revoke their permission to receive promotional messages regarding Club Penguin and/or The Walt Disney Family of Companies at any time  by contacting customer support at [email protected] and may unsubscribe from promotional email communications from Club Penguin and/or The Walt Disney Family of Companies by clicking on unsubscribe links in those emails.

    We may also request a user name and email address when a user submits a form through the "Contact Us" portion of the Club Penguin website so that we may respond to the inquiry. We collect the e-mail address for the sole purpose of responding directly on a one-time basis to a specific inquiry.

    For some of our online activities - such as polls, surveys, games or contests - we may ask users to provide information that is not personally identifiable, such as country of residence or a user’s favorite color. We also enable users to chat online through our website, but we take measures so that users cannot communicate personal information through this chat function. These measures include filters and live moderation. Nonetheless, if you use the chat function within this website and disclose personally identifiable information, you should be aware that such information could be read, collected or used by other users. We strongly encourage you not to disclose personal information (such as real name, email address, telephone number, etc.) about the user or about any third party in such chats and are not responsible for the personally identifiable information you choose to submit through the chat function. Finally, we may offer blogs or other Public Forums (as defined in the Terms of Use governing the website (the "Terms of Use")), as well as other features in which you may provide us with Submissions (as defined in the Terms of Use), but we take measures, including live moderation, so that users cannot communicate personal information through these Public Forums. If you use a Public Forum on this website, and disclose personally identifiable information, you should be aware that such information could be read, collected or used by other users. We are not responsible for the personally identifiable information you choose to submit in these Public Forums.

    Additionally, when visitors come to our site, we may passively collect certain non-personally identifiable computer information, such as the type of computer operating system (e.g., Windows XP or Mac OS), the user's IP Address, the web browser (e.g., Firefox, Internet Explorer) being used, the frequency with which guests visit various parts of our sites, and information regarding the Internet service provider, in order to make our sites more interesting and useful to you and for various purposes related to our business. We or one of our contractors on our behalf may collect this non-personally identifiable information through the use of software technologies such as unique identifiers or "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn on/off all cookies. You do this through your browser (like Firefox or Internet Explorer) settings.  Please note that most browsers are automatically set to accept cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many features that make your Web experience smoother, and some of our services may not function properly.

    Finally, we collect financial information as set out in Section 5 of this Privacy Policy. We use this financial information to process payments to Club Penguin and for fraud prevention purposes. The financial information that you enter to purchase a membership is not stored by Club Penguin, but, instead, is retained by our payments processing vendor who acts on our behalf for the purpose of processing payments made to Club Penguin and for fraud prevention purposes.

    If personal information is not provided to us, then Club Penguin may not agree to Club Penguin membership and may not be able to provide access to certain content and functionality on the Club Penguin website, or to provide other information, products or services which may be requested.

  2. How We Use, Disclose, and Store the Information We Collect

    In addition to the purposes described in Section 1, we may actively collect and use email addresses and user names to track usage and to ensure users are following the site's Terms of Use. In addition, we may use an email address and user name to ban a user temporarily or permanently from the Club Penguin website if that user engages in inappropriate conduct on the site. We may also use email addresses and user names to enable parents to review PII that the children have submitted to the Club Penguin website and to provide notification regarding the site, such as any future amendments to this Privacy Policy. We also may use information in the aggregate to analyze site usage, as well as to offer products, programs, or services.

    We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena, or where we disclose information to data processors who act on our behalf (service providers or other group companies who provide support for the operations of our website and who do not use or disclose the information for any other purpose). To the extent permitted by applicable law, we also may disclose PII in response to a law enforcement agency's or other public agency's (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our website, protect the security or integrity of our website, or enable us to take precautions against liability.

    If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or business transfer, we may transfer PII to a third party as part of that transaction, to the extent permitted by applicable law.

  3. Collection of Information for Third-Party Sites and Sponsors

    Operators collect and maintain information from children through Club Penguin and we comply with the U.S. Children’s Online Privacy Protection Act.  The list of operators may be found here. about the operators’ privacy policies and use of children’s information may be directed to:

    Club Penguin
    c/o Disney Canada Inc.
    Attention Privacy
    Suite 500 - 1628 Dickson Ave.
    Kelowna, British Columbia, V1Y 9X1

  4. Security

    The security of your personal information is important to us. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. When you enter sensitive information, such as your credit card number, or our membership subscription form, we encrypt that information using secure socket layer technology (SSL).

    We operate globally and may transfer your personal information to individual companies of The Walt Disney Family of Companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union or Switzerland to the United States, we abide by the Safe Harbor Principles as set forth by the U.S. Department of Commerce, use standard contract clauses approved by the European Commission, adopt other means under relevant law for ensuring adequate safeguards, or obtain your consent. We also apply the substantive requirements of the Safe Harbor Principles when transferring personal information from Australia.

  5. Financial Information

    As noted in Section 1, if a child registrant wants to acquire a paid membership, the parent's full name, email address, credit card billing information including mailing address will be required at the time of purchase. That information is not stored by Club Penguin, and, instead, is stored by our payments processing vendor for the purpose of processing payments made to Club Penguin and for fraud prevention purposes. That information is safeguarded with appropriate security, and it will not be used for other purposes. Furthermore, our payments processing vendor has agreed to maintain the confidentiality, security, and integrity of the personal and financial information it obtains from the Club Penguin website, and only to use this information on our behalf. Our financial institution is bound by all applicable privacy laws relating to the provision of financial services.

  6. Access to Information, and Objection to Information Collection and Retention

    Please contact us as provided in Section 7 if you would like to access the PII that we have collected online from you or your child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect or maintain such information.  The deletion of data may lead to a termination of the Club Penguin account and/or membership.

    Please be sure to include your email address and a telephone number where we can reach you.  We will respond to access requests within 30 days. To protect you and your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.

  7. Changes to this Privacy Policy

    From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent.

  8. Contact Us

    If you have questions or wish to send us comments about this Privacy Policy, please send an e-mail with your questions or comments to [email protected] or write us:

    Club Penguin
    c/o Disney Online Studios Canada Inc.

    Attention Privacy
    Suite 500 - 1628 Dickson Ave.
    Kelowna, British Columbia, V1Y 9X1

    You may also telephone us at +1-877-261-9482 (US and Canada) or +1-250-469-6380. (If you are not 18 years of age or older, you must have your parent or guardian's permission to call this number.)

    Please be assured that any personal information that you provide in communications to the above e-mail and postal mail addresses and telephone numbers will not be used to send you promotional materials, unless you so request.

  9. A Final Note to Parents

    The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit the site and look through the "Kids Safety" section together. Your efforts to instill responsible information practices will help steer your children to age-appropriate sites and will go a long way toward ensuring that your children have enriching experiences online.

  10. Effective Date

    The privacy policy set out above is effective as of October 8, 2013, and applies to all information previously obtained by Club Penguin. We reserve the right to change the privacy policy at our sole discretion. Club Penguin users will be informed of any such change  by us posting a new privacy policy on the Club Penguin website and the effective date of any change of privacy policy will be clearly marked. As required by law, we will not use PII in ways that are materially different from the ones described in this Privacy Policy without also providing notification of such practices and obtaining consent to any such different uses. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

    Club Penguin has received the TRUSTe Privacy Seal in the United States, signifying that this privacy policy and our privacy practices have been reviewed for compliance with the TRUSTe program listed on the validation page available when you click on the TRUSTe Privacy Seal. The TRUSTe program covers only those properties identified on the validation page.

    If you believe that Club Penguin has not responded to your inquiry or your inquiry has not been satisfactorily addressed, you may contact TRUSTehere or the United States Federal Trade Commission through its online consumer complaint form available here.

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