NET NANNY® 10 PRIVACY POLICY

This Privacy Policy describes the policies and procedures of Content Watch Holdings, Inc. (“we”, “our” or “us”) on the collection, use and disclosure of your information on www.netnanny.com (the “Site”), the Net Nanny® applications, and the services, features, content or other applications we offer (collectively with the Site, the “Services”). We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.


What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services you may choose to use or interact with while using the Net Nanny products. We encourage you to carefully review the privacy policies of any Third Party Services you access.


Children’s Privacy

As noted in the Terms of Service, the Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from a child under 13 without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”). If you are a child under 13, please do not attempt to send any personal information about yourself to us before we obtain Parental Consent. Review this Privacy Policy with your parent or guardian and make sure you understand it, and do the same with the privacy policies of all websites you visit or mobile applications you use. If you are a parent or guardian, in order to monitor and manage the digital activity of your family members on the Services, you must install one of our applications on their devices. This will collect and transmit to our servers information on their digital activity including (but not limited to) their Web browsing activity, device location, Location-Based Services (defined below), other application installations and use, screen time on certain pages or applications, general device-specific information (e.g. unique device identifier, network information, hardware model), and general monitoring of policy enforcement.


If you are a user under 13 and your parent or guardian has signed up for the Services, you understand that your parent or guardian can view all information within or associated with your Services account, including, without limitation, Web browsing activity (including URL history and search history), , device location and Location-Based Services, other application installations and use, screen time on certain pages or applications, general device-specific information (e.g. unique device identifier, network information, hardware model), and general monitoring of policy enforcement.


What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.


Account Information:

When you create an Account, you will provide information that could be Personal Information, such as your username, password and email address. If you register for or access the Services using a Third Party Service (such as your social media account login credentials), we may receive Personal Information that you have made available to share through such Third Party Service, which may include, without limitation, your user ID, email, name, and image. You may also choose to provide additional Personal Information about yourself and your family members, including photographs, , ages, sex, and name. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow us, to potentially identify you and therefore may not be anonymous. We may use your Account contact information to send you information about our Services when we feel such information is important and beneficial to you as a subscriber, as well as for promotional and newsletter purposes. You may unsubscribe from these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account password recovery purposes.


Data Collection and Net Nanny Features:

As part of the Net Nanny service the product will gather specific data and present this data to the Parent, Guardian or otherwise authorized administrator of the Net Nanny Account. This data is collected and made available to the Net Nanny Parent/Admin but only used for the purpose of product functionality and features. The data collected is directly dependent on the platform and the Net Nanny features implemented and supported for said platform. This data includes:

  • Websites that are blocked or alerted based on Net Nanny settings

  • Web searches

  • Screen Time accumulated

  • Device locations

  • Mobile Apps

  • Times devices were last seen running the Net Nanny software

  • Summarized information of Mobile Apps and their use

  • Device Type and operating system


Net Nanny does not share any data with third parties or external organizations.


Financial Information:

We do not currently collect financial information from you, such as your payment method (valid credit card number, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the “Payment Processor”) or the third parties that sell our mobile applications, including Apple and Google (each, an “App Store”). Use and storage of that information is governed by the Payment Processor’s or App Store applicable terms of service and privacy policies of those third parties.


IP Address Information and Other Information Collected Automatically on the Net Nanny Website:

  • We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate the collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

  • Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

  • We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to phone number, unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.

  • As mentioned above, in order to monitor and manage the digital activity of your family members on the Services, you must install one of our applications on their devices. We do not target or sell Services to children under 13 years of age. If a parent or guardian has consented to the collection of Personal Information from a device that may be used by a child under 13 years of age, or has otherwise installed the Services onto a family member’s device, certain other types of Personal Information in addition to the above information may be automatically collected from the Services installed on such child’s device, including (but not limited to) their Web browsing activity (including URL history and search history), phone number, device location and Location-Based Services, other application installations and use, screen time on certain pages or photographs or applications, general device-specific information (e.g. unique device identifier, network information, hardware model), and general monitoring of policy enforcement.


Email Communications:

We may receive a confirmation when you open an email from us, and when you click on any links in that email. We use this confirmation to improve our customer service.


Information Collected Using Cookies on the Net Nanny Website:

  • Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet.

  • Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.

  • Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Services.

  • This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.


Information Related to Advertising and the Use of Web Beacons on the Net Nanny Website:

To support and enhance the Services, we may serve advertisements, and also allow third parties to serve advertisements through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies including “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. We may also use analytics service providers to analyze how you interact and engage with the Services and our advertisements, so we can learn and make enhancements to offer you a better experience. Some of these entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, which may include tracking activity across time and unaffiliated properties, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google's use of cookies by visiting the Google advertising opt-out page atwww.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on athttps://tools.google.com/dlpage/gaoptout/. This information from analytics service providers may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.


Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on the Services and/or Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.


To increase the effectiveness of ad delivery, we or our service providers may deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.


Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/ orwww.aboutads.info/choices.


Aggregate Information:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). This information might include, but is not limited to, for example, session information, common account settings, and frequent parental controls activities. This statistical information is not Personal Information and cannot be tied back to you, your Account, your use of Net Nanny or your web browser.


IP Address Information on the Net Nanny Website:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.


Information You Elect to Share via Third Party Services:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.


Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.


Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account and marketing offers for products and services we think you might be interested in. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery. We may also use your email address to send you promotional and newsletter communications. You may opt out of receiving promotional and newsletter emails from us by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by using the instructions at the bottom of the corresponding email messages.


Financial Information:

As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor or the App Store. However, we may from time to time request and receive some of your financial information from our Payment Processor or App Store for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.


Information Shared with Our Service Providers:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Service Providers”). We may need to share Personal Information with our Service Providers in order to provide products or services to you. Some of our major Service Providers include, but are not limited to, Amazon Web Services, Inc., and Salesforce.com, Inc.. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers.


Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.


Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.


Information We Share with Your Consent:

Except as set forth above or in modifications to this policy, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.


Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.


We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.


We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.


What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.


If you are a parent or guardian of a user who is under 13, you may ask that (a) we stop collecting Personal Information from such user, (b) we delete any Personal Information already collected from such user, and (c) we stop disclosing Personal Information collected from such user to third parties, but continue to allow certain collection and use of Personal Information. Please note that the terms regarding deleted data outlined below in “What Choices Do I Have Regarding My Information?” also apply to deleted Personal Information from children under 13.


California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Content Watch Holdings Inc, 1055 Westlakes Drive, Suite 301, Berwyn, PA 19312.


How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing support@netnanny.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.


Where is My Data Stored?

Our servers and offices are located in the United States and our data is housed in Amazon AWS services within several US and international regions. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Services, You understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy.


What Choices Do I Have Regarding My Information?

  • You can use many of the features of the Services without registering, thereby limiting the type of information that we collect.

  • You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

  • You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.


What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.


What If I Have Questions or Concerns?Non-U.S. Users: Please be advised that your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal data may be less stringent than the laws in your country. If you have concerns about our processing of your personal data, please do not use the Services.

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@netnanny.com. We will make every effort to resolve your concerns.


Effective Date: October 31, 2017


NET NANNY® PRIVACY POLICY PRIOR TO 2019


Your privacy is important to ContentWatch Inc. To better protect your privacy, we have provided this statement which explains our online information practices, and the choices regarding the way your personal information is collected and used. We hope this statement will increase your confidence in our Web site and enhance your experience on the Internet with ContentWatch Inc.

Important note: In order to receive important product updates, notification of product error fixes, or other relevant ContentWatch information, you must choose to receive email messages from us. Please keep in mind that if you choose not to receive email messages, we will be unable to communicate with you via email.


1. INFORMATION YOU PROVIDE. There are several activities on our Web site where the collection of personally identifiable information is necessary, such as when you enter a contest or sweepstakes, make a purchase, subscribe to a service or contact us. You will know when personally identifiable information is collected because you will be asked to complete a form. Generally, we collect only your name, email address, gender, physical address and telephone and facsimile number(s). When you make a purchase, we will also collect your credit card information.


2. INFORMATION WE COLLECT. In addition to the information you provide, when you visit our Web site, we may collect information regarding the type of browser you are using (e.g., Netscape, Internet Explorer, etc.), the type of operating system you are using (e.g., Windows, Mac OS, etc.) and the domain name of your Internet service provider (e.g., America Online, Earthlink, etc.). This non-personally identifiable information is used to make our Web site as highly usable as possible for the widest variety of users. We also maintain a count of the files detected with ContentAudit, along with a count of the files cleaned with ContentCleanup. Actual file names and personally identifiable information is not tracked or recorded by ContentWatch.


We may also receive and store certain types of information automatically through the use of "cookies." Cookies are pieces of information that a Web site sends to your computer while you are viewing the Web site. We use cookies to track important information (e.g., to track items you order) and to tell us whether you have visited our Web site before. We do not use cookies to obtain personal information about you from your computer. You may set your computer to warn you each time a cookie is sent, or you may set your computer to turn off all cookies, but this will limit some functionality of our Web site.


We may also use email links located on our Web site to allow you to contact us directly with any questions or comments you may have. The information you provide in such emails is used to respond directly to your questions or comments, but may also be used to improve our Web site and its content. We may also review and discard the information provided in such emails.


The information we collect is stored on our own servers, as well as cloud servers we make use of. Some pieces of information may also be stored on servers run by the service providers with whom we contract.


3. HOW WE USE THE INFORMATION. We may use the personally identifiable information that you provide, as well as the non-personally identifiable information that we otherwise collect about you, to fulfill your requests for our products, programs and services (e.g., billing, shipping, etc.), to respond to your inquiries about our offerings, to offer you other products, programs or services that we believe may be of interest to you, and to otherwise contact you. These products, programs and services may be ours or those of our trusted subsidiaries, affiliates, business partners or sponsors. Our desire is to only market to our opted in users, those products, programs and services that may be of interest. You will have an opportunity to opt out or block such marketing at any time.


We will never disclose your credit card information or your personal identity information for marketing purposes. However, we may disclose personally identifiable information in response to legal process, for example, in response to a court order or a subpoena or a law enforcement agency's request. We may disclose personally identifiable information in connection with the sale of some or all of our assets or our business.

We may use or allow reputable third parties to present or serve the advertisements that you may see on our Web pages. In addition, some business advertisements are managed and placed on our Web pages by third party companies. This Privacy Statement does not cover any use of information that a third party ad server or network advertiser may collect from you.


4. OPT OUT POLICY. You may request at any time that ContentWatch Inc. not send any future email to you by unsubscribing from the communication within My Account.


5. SECURITY WE PROVIDE. We have attempted to place appropriate physical, electronic and managerial procedures to safeguard and help protect against unauthorized access, maintain data security and correctly use the information we collect. Agents and contractors of ContentWatch Inc. who have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Statement. Although we take appropriate measures to safeguard against unauthorized disclosures of personally identifiable information, we cannot assure you that your personally identifiable information will never be disclosed in a manner that is inconsistent with this Privacy Statement. We protect the security of your credit card information using secure socket layer (SSL) encryption.


Our Web site may contain links to other Web sites. We are not responsible for the privacy practices or the content of any such Web sites.


This Privacy Statement is subject to change at any time, at the discretion of ContentWatch Inc. However, if we determine to change this Privacy Statement in any material aspect, we will notify you of such changes by email.


6. HOW WE HANDLE CHILDREN'S PRIVACY. We do not target or sell products, programs or services to children. Children under 13 years of age may not submit personally identifiable information without the consent of a parent. We do not provide any personally identifiable information about children under 13 years of age to any third party for any purpose whatsoever.


7. HOW YOU CONTACT US. If you need further assistance, if you have any questions or concerns, or if you would like to modify your personally identifiable information in any way, you may call 1-484-856-2789 or send an email to info@contentwatch.com. You may also send mail to the following address:


Content Watch Holdings Inc,

1055 Westlakes Drive, Suite 301,

Berwyn, PA 19312.