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Privacy Policy

STAR BANKS ADVENTURE® GAME & MONEYCONFIDENTKIDS WEBSITES

Privacy Policy

Effective Date:  This policy was posted and became effective on December 3, 2019.

The Star Banks Adventure® game (the "Game") and the MONEYCONFIDENTKIDS websites (“MCK Site”) are provided in the (i) United States by or on behalf of T. Rowe Price Associates, Inc., a Maryland corporation with its registered office at 100 East Pratt Street, Baltimore, MD 21202, (ii) United Kingdom by or on behalf of T. Rowe Price International Ltd, incorporated in England and Wales with its registered office at 60 Queen Victoria Street, London, EC4N 4TZ, UK; (iii) in Australia by or on behalf of T. Rowe Price Australia Ltd., a limited liability company incorporated under the laws of New South Wales with its registered office at Level 50, 1 Farrer Place, Suite 50B Sydney, NSW Australia (collectively "T. Rowe Price," "we," "our" or "us").

This Privacy Policy explains our privacy practices for the MCK Site and the Game, which is available as a mobile application that can be downloaded from various mobile storefronts (e.g., Apple App Store and Google Play). The Game is intended to provide a fun financial education game for children younger than the age of 16 ("Child" or "Children"). The MCK Site is directed to the parents and legal guardians (collectively, “Parents”) of Children and offers resources to help Parents provide a sound financial education to Children. The MCK Site also may be of interest to educators of Children.

The MCK Site and Game are referred to collectively as the “Services.” We provide this Privacy Policy to inform users (and the Parent of any Child user) about our privacy practices for the Services. This Privacy Policy only covers information collected through the Services and does not cover information collected through any other T. Rowe Price website or application or information collected offline by T. Rowe Price (unless specifically stated).

Please review our full Privacy Policy below – but here are some key points to know:

  • Children or any other users are not asked to provide their name, address, or other contact information in order to play the Game or otherwise use the Services.
  • The Services may collect certain Personal Information from Parents or other adults who use some features of the Services (e.g., signing up for a newsletter through the MCK Site).
  • The Services and the third-party service and content providers we use to operate the Services, may collect IP address, mobile device ID, and similar device identifiers – but only for analytical and other internal-operations purposes — by means of cookies, beacons, and other technologies.
  • The Services do not contain social network integration (though the Services may have links to other T. Rowe Price pages or accounts on third-party social-networking services).
  • The Game does not include any in-app purchases.

Please review this Privacy Policy carefully. In addition, please review the Terms of Use, which governs your use of the Services. The Terms of Use for those accessing the Services through the U.S. is here and the Terms of Use for those accessing the Services through the U.K. or Australia are here.

This Privacy Policy explains:

  • INFORMATION THE SERVICES COLLECT
  • WITH WHOM WE SHARE PERSONAL INFORMATION
  • THIRD-PARTY ANALYTICS PROVIDERS
  • THIRD-PARTY LINKS TO OTHER SITES
  • WHERE WE STORE YOUR PERSONAL INFORMATION
  • YOUR CHOICES/YOUR PRIVACY RIGHTS GENERALLY
  • RIGHTS OF PARENTS TO REQUEST DELETION
  • HOW LONG WE KEEP YOUR PERSONAL INFORMATION
  • DATA SECURITY
  • CHANGES TO OUR POLICY
  • CONTACT US

INFORMATION THE SERVICES COLLECT

Personal Information

"Personal Information" (also sometimes called "personal data") is information that could reasonably be used to contact or identify a specific person (for example, first and last name, and email address). Personal Information also includes an IP address, mobile device ID, and other similar unique device identifier ("Device Identifier") that is associated, on a persistent or on-going basis, with the computer, mobile phone or other device (any, a "Device") of a Child or other person that is used to access the Services. It includes any information which is classified as “personal information” or "personal data" under applicable privacy legislation.

All Users (Children and Adults)

The Services do not collect name, address, or other contact information from users who download and play the Game or go to the MCK Site. However, we and our third-party service and content providers may collect the Device Identifier of any user who visits the Services. We, and our third-party service and content providers, use this information solely to support internal operations, including maintaining, securing, and analyzing the functioning of the Services and for analytics purposes.

If in the future the Services offer a feature that collects Personal Information from a Child beyond that described, T. Rowe Price will – as required by applicable law – provide the Child's Parent prior notice of the Services’ privacy practices and obtain the Parent's consent to the collection of the Child's Personal Information.

Please note that, as required by law, we will not condition a Child's participation in an activity on the Services on the Child's disclosing more than is reasonably necessary to participate in such activity. We use Personal Information only for the purpose that it was provided and for internal purposes as described in this Privacy Policy.

Adults

We may offer features through which we will collect Personal Information (e.g., an email address) from a Parent or other adult – such as the ability to sign-up for a newsletter, submit feedback through the MCK Site, or utilize other adult-directed features.  We may use Personal Information collected from adults to allow you to use certain features of the Services; to contact you regarding your use of the Services and, in our discretion, changes to policies of the Services; to improve the Services, and for our internal business purposes; and for other purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Other Information

In addition, we and our third-party service providers may automatically or passively collect certain information about use of the Services whenever someone visits or interacts with the Services ("Usage Information"). Usage Information may include the browser and operating system being used, all of the areas viewed and visited within our Services, gameplay (for users of the Game), and the time of day, among other information. We may use Usage Information for a variety of operational purposes, including enhancing or otherwise improving the Services.

Cookies and Similar Technologies

We, and our content and service providers, may use various technologies to collect Usage Information and Device Identifier, including the following:

  • Cookies and Local Storage. Cookies and local storage are data files placed within a browser on your Device when the Device is used to access the Services. These technologies are able to store a unique identifier for your Device that can be used to recognize your Device whenever it visits the Services. A Flash cookie is a data file placed on your Device via the Adobe Flash plugin, which may be built-in to or downloaded to your Device. Flash cookies may be used for various internal operations purposes, such as enabling a Flash feature and remembering preferences. If you choose to disable cookies or to adjust your Flash privacy settings on your Device, some features of the Services or our content may not function properly. For more information about Flash and the privacy choices Adobe offers, visit: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.
  • Web Beacons. We or our third-party service providers (such as analytics companies) may set web beacons (small graphic images or other web programming code, also known as "1x1 GIFs" or "clear GIFs") and similar technologies on our Services. Web beacons can recognize certain types of information on your Device such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of internal operations purposes including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, and to improve your experience on the Services.
  • Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with the Services, such as the links you click on, for analytics and other internal operations purposes. The code is temporarily downloaded onto a Device from our web server or a third-party service provider, is active only while it is connected to the Services, and is deactivated or deleted thereafter.

WITH WHOM WE SHARE PERSONAL INFORMATION

We may share information we collect for any user, including Personal Information, as otherwise described in this Privacy Policy, and in the following limited circumstances:

T. Rowe Price family of companies. We may share your Personal Information among our family of companies, including our subsidiaries and affiliates, in order to administer the Services, provide you with customer support, understand preferences of visitors to the MCK Site, send adults who use the Services information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Policy. These affiliated companies will not further disclose Personal Information collected from users of the Services except in accordance with this Privacy Policy.

Other Third-Party Service Providers. We use third-party service providers to support the internal operation of the Services, such as hosting the Services, designing and/or operating features of the Services, or performing other administrative services. We also may provide information collected from adult users of the Services to other service providers performing services on behalf of T. Rowe Price related to the Services, such as sending email or other communications.. We provide our service providers with the information that is necessary for them to perform the services. Our service providers will act under our instructions, and we instruct them not to use or further disclose your Personal Information for any other purpose.

External auditors, accountants, and legal and other professional advisors. In some cases, we may disclose information collected from users of the Services, including Personal Information, to other third parties providing auditing, accounting, legal, or other professional services to us (provided that these third-party service providers have also agreed to use the information we provide them only to perform services for us and not to use or further disclose Personal Information for any other purpose).

Administrative or Legal Reasons. We may also transfer and disclose information, including Personal Information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend policies applicable to the Services (or any site or app that comprises the Services) or to protect the safety, rights, property or security of T. Rowe Price or any other individual or entity.

Business Transfers. We may also disclose and transfer your information, including Personal Information: (i) to a subsequent owner, co-owner or operator of all or any component of the Services or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of T. Rowe Price’s ownership interests, assets, or both, or other corporate change, including, without limitation, during the course of any due diligence process.

THIRD-PARTY ANALYTICS PROVIDERS

T. Rowe Price works with third-party traffic measurement services to provide us with information regarding use of the Services, including the pages viewed and the actions users take when interacting with the Services, such as – for the Game – levels completed, goals selected, and quiz questions answered correctly or incorrectly and – for the MCK Site – activities used or downloaded. Our service providers may set and access their own tracking technologies on your Device (including cookies and web beacons) and may collect or have access to your Device Identifier and Usage Information, provided that your Device Identifier will be used only to support internal operations. We may share Usage Information about visitors with analytics providers and other vendors for similar purposes.

THIRD-PARTY LINKS TO OTHER SITES
The Services may contain links to third-party web sites that T. Rowe Price does not control, such as links to other T. Rowe Price pages or accounts on third-party social media platforms. We are not responsible for the privacy or data collection practices of any third party.

WHERE WE STORE YOUR PERSONAL INFORMATION
The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which you are located. For example, if you are located outside of the United States, please be aware that information we collect may be transferred to and processed in the United States.

If you are located in the UK or European Economic Area ("EEA"), this means the Personal Information may be transferred to, stored at, and accessed from, a destination outside the UK or EEA, including to the United States. It may also be processed by staff operating outside the UK or EEA and who work for us, an affiliate or for one of our service providers. If you are located outside the UK or EEA, then in addition to the above, this also means that Personal Information may be transferred to, and stored at, a destination in the UK or EEA.

For transfers of Personal Information collected from users of the Services residing in the UK or EEA to T. Rowe Price entities outside the UK or EEA, T. Rowe Price will be bound by the EU Standard Data Protection Clauses (pursuant to Article 46(2)(c) General Data Protection Regulation), which the European Commission has assessed as providing an adequate level of protection for Personal Information (or other appropriate safeguards), to ensure that your data is protected adequately. You can ask for a copy of such appropriate safeguards by contacting us as set out below (Contact us).

YOUR CHOICES/YOUR PRIVACY RIGHTS GENERALLY

Particularly for users in the U.K., EEA, or Australia, you may have various rights in connection with our processing of your Personal Information, each of which is explained below. If you wish to exercise one or more of the below rights for yourself (or, if a Parent would like to exercise a right in relation to their Child), please contact us with your request at Global_Privacy@troweprice.com, and include your name, email and postal address, as well as your specific request and any other information we may need in order to provide or otherwise process your request. Given the nature of the Personal Information typically collected by the Services, we may need to contact you to request additional information necessary to locate any Personal Information we may have that would be subject to your request.

·         Access. You may have the right to confirm with us whether your Personal Information is processed, and if it is, to request access to that Personal Information including the categories of Personal Information processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.

·         Rectification. You may have the right to rectify inaccurate or incomplete Personal Information concerning you.

·         Deletion. You may have the right to ask us to erase Personal Information concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

·         Restriction. In limited circumstances, you may have the right to request that we restrict processing of your Personal Information. This may apply where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored Personal Information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.

·         Portability.  You may have the right to receive Personal Information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have may have the right to transmit that data to another entity.

·         Objection. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by us and we can be required to no longer process your Personal Information. This may include requesting human intervention in relation to an automated decision (when applicable) so that you can express your view and to contest the decision.

·         Make a Complaint. You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the UK is the Information Commissioner's Office (the 'ICO'). If you are based in, or the issue you would like to complain about relates to any other location, please contact us as stated below (Contact us).

RIGHTS OF PARENTS TO REQUEST DELETION

Without limiting the rights described above, Parents of a Child user certain countries (including the U.S.) have the right to review and request that the T. Rowe Price delete any Personal Information that the Services have collected and retained about their Child, if any. T. Rowe Price will honor such requests regardless of where your Child lives. If you would like to request that T. Rowe Price delete any Personal Information T. Rowe Price may have about your Child or if you would like to request that the Services make no further collection of Personal Information about your Child, please contact T. Rowe Price as described in the "Contact Us" section below.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your Personal Information for as long as it is necessary for the purpose for which that information was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

DATA SECURITY

We have implemented technical and organizational security measures in an effort to safeguard Personal Information in our custody and control. Such measures we have implemented include, limiting access to Personal Information only to employees, contractors and authorized service providers who need to know such information for the purposes described in this Privacy Policy, training for our employees and contractors, as well as other technical, administrative and physical safeguards.

While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

CHANGES TO OUR POLICY
We reserve the right to change our Privacy Policy from time to time. If we decide to make a material change to our Privacy Policy, we will endeavor to make you aware of that fact by, for example, notifying you of these changes via email (for adults users who have provided us with an email address) and/or posting an alert on the home page of a relevant website and/or taking any further action as required by applicable law.

CONTACT US
If you have any questions about this Privacy Policy and/or about the privacy policies and practices of our service providers, please contact us via email at Global_Privacy@troweprice.com.

The postal mailing address details of our Global Privacy Office are as follows:

Global Privacy Office

T. Rowe Price

100 East Pratt Street

Baltimore, MD 21202

Global_Privacy@troweprice.com