STAR BANKS ADVENTURE® GAME & MONEYCONFIDENTKIDS WEBSITES
Effective Date: This policy was posted and became effective on April 6, 2021.
The MONEY CONFIDENT KIDS websites (“MCK Site”) and the Star Banks Adventure® game (the "Game") 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").
- 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.
- 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 TO MANAGE COOKIES
- HOW LONG WE KEEP YOUR PERSONAL INFORMATION
- DATA SECURITY
- CHANGES TO OUR POLICY
- CONTACT US
INFORMATION THE SERVICES COLLECT
"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.
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. Cookies and similar technologies—such as web beacons, local storage, tags, and pixels—are small text or graphics files that are placed on your computer or other device when you visit or use the Services. Cookies are widely used for various reasons, such as allowing a website to work efficiently and to collect information about you and your online preferences. For ease, we refer to all these technologies as “cookies.”
The types of cookies we use fall into the following general categories:
- Essential cookies. These cookies are necessary for our Services to operate, such as making the MCK Site available, and they cannot be switched off in our systems. For example, they are needed for us to offer region-specific MCK Sites.
- Performance cookies. These cookies allow us to understand how our Services are used. They collect information, such as how many visitors we have, what areas of our Services are accessed, how visitors move around within our Services, whether they receive error messages, and if electronic communications we send (as applicable) are opened or links within the communications are clicked on. This information helps us measure and improve our Services, for example, by making changes to improve navigation.
- Functional cookies. These cookies allow us to provide increased functionality and personalization. For example, they help to remember choices you make, allow us to customize our digital content for you as applicable, and enable features within our Services content such as videos.
- Advertising cookies. These cookies are used by us and our advertising partners, who are authorized to place third-party cookies on our MCK Site with our permission. Advertising cookies collect information about your visit to our MCK Site and elsewhere on the internet to help understand what areas of our MCK Site are of interest to you. These cookies may also identify which other websites may have directed you to our MCK Site. Advertising cookies can help us or our partners personalize our marketing to you, including via online advertising, email, or social media.
WITH WHOM WE SHARE PERSONAL INFORMATION
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 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 Australia, the UK or European Economic Area ("EEA"), this means the Personal Information may be transferred to, stored at, and accessed from, a destination outside Australia, the UK or EEA, including to the United States. It may also be processed by staff operating outside Australia, the UK or EEA and who work for us, an affiliate or for one of our service providers. If you are located outside Australia, 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 Australia, 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 in the "Contact Us" section.
YOUR CHOICES/YOUR PRIVACY RIGHTS GENERALLY
Users in Australia, the U.K. or EEA: 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).
It is important to note, however, that the CCPA does not apply to all entities, nor does it apply to personal information maintained by financial services firms that are covered under certain exemptions described in the CCPA, and as such, the CCPA may not apply to personal information T. Rowe Price maintains about you.
Depending upon how you interact with us, you may have various rights in connection with our processing of your personal information, each of which is explained below.
- 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 consider the interests of others though, so this is not an absolute right and there are additional exceptions under the CCPA. Also, we are not obligated to respond to more than two access requests for the same individual’s personal information within a 12-month period.
- 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 or under other exceptions under the CCPA.
If your request is for data relating to you that is de-identified or aggregated so that it is no longer personal information, we are not required to re-identify the data to respond to your request.
You have a right to receive nondiscriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
Making your own privacy rights request: To exercise one or more of these rights, please contact us as explained below. Please note that we may need to verify your identity before we can fulfill your request.
- If you have an online account with us, then after logging in you may submit your request via the online form at troweprice.com/CCPA. If you submit your form without logging in first, we will deny your request. When you submit your request after logging in, we should not need further information from you to verify your identity, but we will let you know if we do. Or, you can submit your request by calling us at (844) 256-4465. Calling and having your account information available so that we can validate your identity will help us more efficiently handle your request.
- If you have an account with us but have not previously activated online access, you can submit your request by calling us at (844) 256-4465. Calling and having your account information available so that we can validate your identity will help us more efficiently handle your request. Or, you can submit your request via the form at troweprice.com/CCPA, and we will contact you as needed to verify your identity so that we can process the request.
- If you do not have an account with us, verification can involve matching up to three pieces of your personal data (as provided on your request) with our internal records. You can submit your request via the online form at troweprice.com/CCPA or by calling us at (844) 256-4465.
Authorized agent requests: An access and/or deletion request also may be made by someone else you authorize specifically to make such a request under the CCPA or by someone you have named as your agent under a power of attorney that is valid under the California Probate Code. Click here for authorized agent instructions and appropriate forms.
Handling requests we receive: If we need additional information to verify your identity, we will let you know. We will endeavor to respond to a verified request within 45 days, unless there are grounds for extending our response timeframe by up to an additional 45 days. In the event of an extension, we will explain to you why the extension is necessary. In some cases, your ability to access or delete your personal information will be limited, as required or permitted by applicable law, even when the CCPA applies to the personal information we have for you. If we cannot fulfill your request because we cannot verify your identity or due to exceptions under the CCPA (or when the CCPA does not apply to the personal information), we'll let you know in our response.
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 TO MANAGE COOKIES
Generally: The browsers of most computers and other web-enabled devices may be set up to accept all or certain types of cookies depending on your browser. If you wish to amend your cookie preferences, you can do this through your browser/device settings (check the "Help" function). Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "do not track" signals.
Internet-Based Advertising: We may use third parties, such as advertising partners, to allow us to serve you advertisements when you visit the digital content of others. The advertising partners with whom we work do not collect identifiable information such as name, address, phone number, or email address, but instead they receive information through third-party cookies about your activity on the MCK Site and elsewhere on the internet, together with information associated with your browser and device, such as device identifier, IP address, or identifier for advertising (IDFA). The information collected can be used to determine the types of advertising you see on other sites as well as on our digital content. For more information about third-party advertising cookies, internet-based advertising, and how to opt out with companies that participate in industry self-regulation, you can visit one or more of the following sites: the Digital Advertising Alliance, Network Advertising Initiative, or European Interactive Digital Advertising Alliance. You also can check and change your browser settings as discussed above under the "General" section.
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).
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
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