PRIVACY POLICY of children's educational and entertaining information portal and social network, and children's Internet-game, located at www.rolypolyland.com

1. GENERAL PROVISIONS

1.1. The following terms shall be used and interpreted unambiguously in this Privacy Policy:
Administrator, Right Holder of the Site and the Internet-game – NEWKIDS MEDIA LIMITED, a legal entity, registered under the law of the Republic of Cyprus, located at the address: Poseidonos, 1, LEDRA BUISINESS CENTRE, Egkomi, 2406, Nicosia, Cyprus.
User – a natural person visiting the Site www.rolypolyland.com.
Site – children's educational and entertaining information portal and social network, located at: www.rolypolyland.com.
Internet-game – children's entertaining site, located atwww.rolypolyland.com.
User's personal information – any information that directly or indirectly identifies the User to whom it is attributed and is recognized as personal data under the applicable legislation (law).
User’s country of residence – the country in which User predominantly resides, and citizenship in which User has.
If User has more than one foreign citizenship, the country of residence is the country in which User has his/her domicile.
If the User is a stateless person, the country of residence is the country in which User has his/her domicile.
Applicable legislation (law) – the relationships between User and Administrator are governed by the law (legislation) of the Republic of Cyprus, if the application of the law of the Republic of Cyprus does not directly contradict the conflict rules of legislation of the User’s country of residence (norms determining the applicable law).

1.2. This Privacy Policy is an integral part of the Agreement on the use of the Site and the Internet-game, available at: www.rolypolyland.com/TermsAndConditions.
By acceding to the Agreement on the use of the Site and the Internet-game, User undertakes to comply with the requirements of the Privacy Policy.
All issues not regulated by the Privacy Policy are governed directly by the Agreement on the use of the Site and the Internet-game, as well as by the applicable legislation (law).

1.3. Administrator does not recommend User to post on the site and in the Internet-game any personal data and User's private information in excess of that required to participate in the Internet -game and to use other services of the Site.

1.4. By uploading personal data and private information to the Site and in the Internet-game, User provides Administrator with a permission for the collection, processing and use of personal data and private information.
Thus User agrees that personal data and User's private information may be transmitted and stored on servers located outside the jurisdiction of the User’s country of residence.

1.5. If User is under 13 years of age, consent of the User, his/her parents, other legal representatives for the collection, storage, processing and use of private data and User's personal information shall be considered by Administrator as received when Administrator receives a corresponding confirmation/authorization of User by his/her parents, other legal representatives.

2. COLLECTION, STORAGE, USE AND DISCLOSURE OF INFORMATION

2.1. Administrator may collect, process and use any information about the User, directly or indirectly related to the provision of services to the User and (or) User's participation in the Internet-game, as well as information related to execution of the terms of the Agreement on the use the Site and the Internet game, including, but not limited to:

2.1.1. Information obtained when upon User’s registration on the Site and in the Internet-game, namely: e-mail address of the User (his parents / legal representatives), age and (or) the User's birthday, gender.

2.1.2. Technical information, which is not a part of User’s personal data, such as the type of User's computer operating system (for example, Windows XP or Mac OS), "IP-address", type of Web browser (for example, Netscape , Internet Explorer, Safari, Chrome and Firefox), information gathered with the help of technical identifiers, for example, «Cookies», and other technical information which needs to be collected in order to provide full User access to participate in the Internet-game and use other Site features.

2.1.3. Other information that User has provided to Administrator by any means, the collection of which is not explicitly prohibited by legislation and international law acts.

2.2. Administrator shall notify User the use of paid features of the Site and the Internet-game requires collecting, processing and use of the specified financial information not by Administrator, but by a third party providing special services for storage, processing and use of User's payment information. Administrator has no access to that financial information.
By acceding to the Agreement on the use of the Site and the Internet-game and by using paid features of the Site and the Internet-game, User provides his/her consent to the specified third party for collection, storage, use and processing of the specified financial information.
User shall have no right to file any complaints and (or) lawsuits against Administrator in connection with improper storage, use, processing of the specified financial information.

2.3. User provides his/her consent to Administrator for the disclosure of User's private information to third parties in following cases:

2.3.1. when it is necessary to provide for full User access to participate in the Internet-game and use other Site features;

2.3.2. when it is necessary for User's transition to other sites without additional registration at these sites through links available on the Site and (or) in the Internet-game;

2.3.3. when it is necessary for the fulfillment of the terms of this Agreement and the applicable law as well as international legal instruments;

2.3.4. when it is necessary to provide User with further information and additional services, including the case if User agrees to receive newsletters and promotional materials;

2.3.5. when it is necessary to respond to claims/lawsuits of third parties;

2.3.6. when it is necessary to protect the rights of Administrator;

2.3.7. when it is necessary to transfer information to third parties that, based on concluded contracts or on the grounds provided by law, international legal acts, provide Administrator with special services of information processing.

2.4. User's consent to disclose information to third parties is not required if this information is not part of personal User data under the applicable law, as well as in cases when such information is requested by public authorities and provision of such information is mandatory for the Administrator under the requirements of applicable law, international legal acts.

2.5. Administrator ensures that the Users' personal data and other private information is collected, stored, processed and used solely for the purposes provided for in the clause 1.4. of the Agreement on use of the Site and the Internet-game, as well as for the Administrator to properly execute the conditions of the Agreement, to ensure full User access to the features of the Site and the Internet-game, and is not used in other way inconsistent with the specified objectives.
Period of storage processing and use of User's personal information and other private data is equal to the term of User's use of the Site and the Internet-game, this period may be exceeded, if it is necessary for statistical purposes, to maintain proper technical condition of the Site and the Internet-game, to protect the rights and legal interests of natural persons and legal entities, including when claims/lawsuits are filed.

2.6. Administrator ensures that User’s personal data and other private information is adequate, relevant to fulfillment of the conditions of this Agreement and is not excessive for the purpose of its storage, is saved in a form which allows identifying data subjects for no longer than it is required for storage of the data.
Administrator ensures that for the protection of personal data that is stored in automated data files, appropriate measures are taken to prevent their accidental or unauthorized destruction or accidental loss, as well as to prevent unauthorized access to it, alteration or disclosure of such data.

2.7. By entering into this Agreement User, his/her parents, other legal representatives confirm that they know of the existence of automated file with personal data (User's private data and other personal information), know the main purposes of using personal data (User's private data and other personal information) specified in this Agreement, as well as the name and address of the controller of User's personal data.
Control over User's personal data is exercised by Administrator; the location of Administrator is specified in this Agreement.

2.8. User, his/her parents, other legal representatives are entitled to:

2.8.1. Within a reasonable time taking into account technical capabilities to get confirmation on whether the User’s personal data is stored in the automated data file, as well as to obtain such data in an intelligible form;

2.8.2. Pursue, if necessary, amendment or erasure of such data if they have been processed against the applicable law, this Agreement.
With regard to the above issues on the use and storage of User's personal information and other private data, User, his/her parents, other legal representatives may contact Administrator at its address of location and (or) ask Administrator by e-mail at support@rolypolyland.com.

3. OTHER PROVISIONS

3.1. Administrator notifies User that the transfer to third parties, including other users of User's personal information and private data such as e-mail address, residence address, address of the educational institution in which the User studies, last name, user name, User's telephone number, information about the level of the User's family income, other information about the User as well as of other persons may result in adverse consequences for the User, in violation of his/her rights and privacy.
Administrator notifies User that the transfer to third parties, including other Users of financial information used to participate in the Internet-game and use other Site features, can harm the welfare of the User, including his material wellbeing.

3.2. Administrator strongly recommends User not to transmit information specified in section 3.1. to any third parties, including other Users, and not to request such information from these persons. Otherwise, Administrator shall not be responsible for any adverse effects, which result from the transfer of the specified information.

3.3. Administrator strongly recommends User not to transfer to any third party his/her password, not to publish or in any way make available any personal information of the User's personal account.
User shall undertake measures to prevent third parties’ access to his/her personal account on his/her behalf, and to secure his/her password.
User shall be responsible for security of his/her login and password, as well as for all possible actions on the Site and in the Internet-game that may be taken by a person logged on the Site and in the Internet-game under the User's login and password.

3.4. User shall immediately notify Administrator of any violation of this Privacy Policy, including unauthorized (without User's permission) access under User's login and password.

3.5. Administrator shall not be responsible for any consequences of loss of or damage to the information, which resulted from the User's violation of this Privacy Policy.

3.6. Invalidity of any provision of this Privacy Policy does not affect the validity of this Privacy Policy as a whole.

3.7. This Privacy Policy may be changed unilaterally by Administrator, and the new version of the Privacy Policy shall come into effect upon its posting on the Site, unless otherwise stipulated in the revised Privacy Policy.

3.8. The provisions of this Privacy Policy are obligatory for all previously registered Users of the Site and the Internet-game.

3.9. The Privacy Policy in its present version is valid from 19.03.2012 and becomes binding upon User upon registration on the Site.