<h1>PRIVACY POLICY</h1>

Welcome! You are downloading or have installed, opened and/or otherwise are using our Carmen Sandiego™ Returns game ("Carmen Sandiego Game" or “Game”).

The Carmen Sandiego Game is owned and developed by Houghton Mifflin Harcourt Publishing Company ("HMH," "we," "our" or "us") and is being made available for installation and use pursuant to the Limited Software Warranty and License Agreement, which can be found here: http://www.hmhco.com/common/CarmenSandiego/software-warranty-license-agreement-ios

This "Privacy Policy" describes how HMH may collect, use and disclose certain information about or in connection with your gameplay and/or other authorized uses of the Game.
This Privacy Policy does not apply to data HMH may collect, request or receive from other sources or in connection with the marketing or your purchase of the Game. This Privacy Policy also does not apply to the download, installation or use of any other HMH applications or software, or to any visit(s) to any other websites of HMH or its partners. For HMH’s Privacy Policy governing any of your interactions with HMH’s products, properties or websites, please see our Privacy Policy here: http://www.hmhco.com/common/privacy-policy. We also refer you to the privacy policies of any third parties, such as any licensors, promoters, distributors and/or retailers you may have interacted with in connection with any investigation, promotion, distribution or purchase of the Game.

Information You Provide to Us.   This Game, in its current version, does not transmit personal information such as name, email address, or phone number to us or to third–parties.
We may, in future versions of the Game, request certain personal information, such as an email address for providing you with customer support, or for promotional purposes, or credit card, log-in or other information for making purchases of additional game modules, or registration information for license management, or other information for purposes we will disclose at the time such information is requested or collected. We will update this privacy disclosure when any such or similar features or functions are introduced.
Please note that you may have provided personal and other information at the time you purchased or downloaded this Game (including any in-app purchases or purchases of additional game modules) from Apple, Amazon, Intel or other third party retailer or other partner associated with the technology, promotion, distribution and/or sale of the Carmen Sandiego Game. HMH may or may not be affiliated with or have any direct contractual relationship with any such third parties, and so any information you provide will be governed by the privacy policies of such third parties.
Information We Collect or Store As You Access and Use the Game. We and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information ("Usage Information") whenever you install, open or use the Carmen Sandiego Game. We use this information to support our internal operations and for supporting business analysis and operations, product development, and/or improving our products and services. This Usage Information may include:

  • Network–related information such as IP address, the SSID of your local Internet access point, or the identity of your ISP or carrier;
  • Device technical attributes and characteristics, such as data about your operating system, hardware, display size, screen resolution, and network carrier information;
  • Unique identifiers, such as the physical WiFi address or “MAC address” of your device, platform-specific identifiers such as Apple’s Identifier for Advertising or the Android ID or similar identifiers, as well as device serial numbers;
  • How often you use the Game and aspects of your gameplay;
  • Certain other Device data, including directly or indirectly derived location information and/or timestamps; or
  • Identifiers and information stored in cookies and web beacons, as well as other technical information.

How and When Do We Disclose Information to Third Parties? We will not share your information with third parties for any third party marketing or advertising purposes.  We do disclose information for the following purposes:

  • To Third Parties Providing Services on Our Behalf. We may use third party vendors to perform certain services on behalf of us such as hosting, operating online services, tracking activities and analytics, delivering content, and enabling the Game’s functionality. Our vendors are not permitted to use your personal information for their own purposes without your express consent. 
  • Interactions with Third Party Platforms.  The Game or portions of the Game may permit some visitors to share content via social media accounts, to interact with a social media plugin or to log on via other third party platform accounts such as those available through Apple's Game Center or Facebook, if the visitor has a pre-existing account with those platforms.  Certain of these interactions are age-gated and will only permit users who confirm they are at least 13 years old to undertake the interaction.  When a visitor uses such social media platforms and plugins, some social media account information may be shared with us, such as a user name.  To the extent you access these third party platforms to undertake the interactions, you and your information will be subject to the privacy policy and the terms and conditions governing such third party platforms.  
  • Administrative and Legal Reasons. We may access, use, preserve, transfer and disclose your Usage and Personal Information: (i) as required or permitted by applicable law, regulation, subpoenas, governmental requests or legal process; (ii) to investigate violations of potential violations of the Terms of Use; (iii) to protect the safety, rights, property or security of the Online Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Such disclosures may be carried out without notice to you.
  • Affiliates and Business Transfer. We may share your information including Usage Information with our parent, subsidiaries and affiliates ("Affiliates"). We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Game or related game or similar offerings; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets related to the Game, or in connection with any other corporate change, including during the course of any due diligence process.
  • We may share your information (including information which by itself or combined with other information can be personally identifiable information) with third parties in connection with an investigation of fraud, intellectual property infringement, piracy, or other activity that is illegal or may expose you or us to legal liability, including as required by law enforcement or other government officials. We also may share such information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, investigate or enforce our terms and conditions, combat fraud and/or comply with a judicial proceeding, court order or legal process served on HMH.

What Information Do We Collect on Parts of Our Online Services Directed to Children?  We have taken steps to have the Game comply with the Children’s Online Privacy Protection Act (COPPA). For example, we do not use the Game to collect personal information (as broadly defined by COPPA) for purposes of any online behavioral or interest-based advertising during gameplay.
We may, however, in compliance with COPPA, collect or share certain information to support our internal operations, such as: providing analytics, enabling or delivering certain types of content or features, improving or maintaining the Game, delivering and measuring the quality of customer experience, or providing or responding to requests for customer support. If you believe that we have collected Personal Information from someone under the age of 13, please contact us at: privacy@hmhco.com.
What About Changes to the Privacy Policy? We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy.
Relationship to Terms of Use and Other Contracts. This Privacy Policy must be read in conjunction with the Game’s Limited Software Warranty and License Agreement (see link above), and the provisions of such Limited Software Warranty and License Agreement are incorporated herein by reference.  To the extent the Limited Software Warranty and License Agreement conflict with this Privacy Policy, the terms of this Privacy Policy will control in respect of the subject matter hereof. To the extent this Privacy Policy conflicts with the terms and conditions of any other specific agreement you enter with us, the terms and conditions of such specific agreement will control.

Who Can I Contact? If you have questions, comments or complaints regarding the Privacy Policy for this Carmen Sandiego Game or the manner in which we or our service providers treat your information, contact us at: privacy@hmhco.com.