LAST UPDATED: January 1, 2020
REGO Payment Architectures, Inc. ("REGO," "we," "us") provides technology platforms designed for the management of the under-18 age group in the global online market. REGO Digital Wallet is an online system, provided by REGO Payment Architectures, Inc., that enables parents to control and guide their children through their online transactions and allows children to make parent authorized purchases through the Internet (the “Service”).
By using the Site and App, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site and App and email us at firstname.lastname@example.org to let us know your concern.
Table of Contents
- Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification
- Children Under 13 Years of Age
- Types of Information Collected
- How Information Is Used
- How Personal Information Is Disclosed
- Links and Third Party Sites
- Data Security
- Changing or Deleting Information
- Third Party Services
- Third Party Advertisers
- Jurisdictional Issues
- A Note to EU Citizens
- Contacting Us
Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification
REGO Payment Architectures, Inc. is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor Certification Program (“the Program”). The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to safeguarding children's personal information collected online. The PRIVO COPPA certification Seal posted on this page indicates REGO has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at privacy@ regopayments.com, or call (215) 247-5500. If you have further concerns after you have contacted us, you can contact PRIVO directly at email@example.com.
REGO is also in the process of obtaining the GDPRkids™ Privacy Assured Shield with PRIVO.
Children Under 13 Years of Age
We are very concerned about the safety of children online. We comply with the Children’s Online Privacy Protection Act of 2000 (“COPPA”) to the extent it applies to us and to our App. We do not knowingly collect Personal Information from children under the age of 13 on our Site which is for adults. Only a parent, guardian or authorized adult (“Parent”) may create an REGO account for a child in our App. The Parent provides all information required to set up a parent profile and child profile(s), including the child’s REGO User ID and Password. A child’s use of REGO and participation and access to the App is currently not conditional upon his/her providing any Personal Information - they only need their REGO User ID and Password. In any event, a child’s use of REGO and participation and access to the App will not be conditional upon his/her providing any more Personal Information than is reasonably necessary for them to participate in an activity. Parents have a right to consent to our use of their child’s Personal Information without having to consent to the disclosure of that information to third parties, as we do not share your child’s Personal Information with any third party, other than service providers and agents necessary to provide the Service.
Types of Information Collected
REGO gathers two types of information through the Site: "Personal Information" and "Non-Personal Information". Personal Information is information collected online that can be used to identify, contact or locate an individual. Non-Personal Information is information that does not reveal an individual’s specific identity, such as aggregated information, demographic information and IP addresses.
We collect the following Personal Information from Parents when they create an REGO account in our App: Parent’s first and last name, child name (Note: Only if a child’s actual full name is provided by Parent, a Parent does NOT need to use child’s actual name for a child profile), street address, zip code, email addresses, telephone numbers, Parent user ID and profile name/password, child user ID and profile name/password.
We collect the following Non-Personal Information from Parents when they create an REGO account: nickname for child profile (if child’s actual name is not used), gender, date of birth, age and other demographic information about the child, time zone, information used as reminders of password and user IDs, transaction thresholds, allowed merchants, websites and applications. We collect credit card information from a Parent, including card number, expiration date, billing address and CVV number to use to process approved purchase transactions to load funds into the family REGO account. For security reasons, we do not store your credit card information on our servers; we use a third party hosting provider to store and transmit that information in accordance with PCI (Payment Card Industry) Data Security Standards. We also gather purchasing and transaction information based on purchases made using the REGO service for reporting to Parents and participating merchants. This purchasing and transaction information may be compiled and analyzed on an individual, account and aggregated basis and used by us for any purpose.
We collect the following Non-Personal Information from children (a) when they use the Wishlist functionality on our App or a merchant’s site: the url for the merchant site and the particular products, services, games or other items they wish to purchase from the merchant using the Service, and (b) particular merchants they would like their Parents to authorize as approved merchants.
When you visit and interact with the Site, REGO and its third party service providers may also collect other Non-Personal Information (for example, a catalog of the Site pages you visit). This Non-Personal Information is generally collected through the Site from server log files, environmental variables and cookies.
Server Log Files. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. IP addresses may be used for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
Environmental Variables. Certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version may be collected. These environmental variables are collected by most websites, and can be used to optimize your experience on the Site.
How Information Is Used
Our primary purpose for collecting information is to provide the Service. We use Personal Information in the following ways:
Purchase Transactions. We will use Personal Information and credit card information to process approved purchase transactions initiated by a child using the REGO Service and to enable the delivery of products purchased using the REGO Service. Purchase and transaction information will be used for reporting to Parents and participating merchants, and for repudiation purposes.
Notifications and Alerts. Email and telephone numbers will be used to provide Parents with transaction alerts, approval requests or other reporting, notices or alerts that Parents elect to receive in their parent profiles, child profiles or otherwise as part of the REGO Service.
Administrative Communications.From time to time, in our sole discretion, we may use Personal Information to send to you important information regarding the Service or the Site, changes to our terms, conditions, and policies and/or other administrative information.
Other Communications. From time to time, we may use Personal Information to inform you of products, programs, services and promotions that we believe may be of interest to you.
Promotions. We may operate sweepstakes, contests and similar promotions (collectively, "Promotions") through the Site and App. We may ask you or your child for certain Personal Information (such as name and email address) when you enter and, if applicable, win a Promotion. You should carefully review the rules, if any, of each Promotion in which you participate through the Site, as they may contain additional important information about our use of Personal Information about you. To the extent that the terms and conditions of such rules concerning the treatment of Personal Information about you conflict with this Policy, the terms and conditions of such rules shall control.
Internal Business Purposes. We may also use Personal Information for our internal business purposes, such as audits, research and analysis to maintain, protect and improve the Service and the Site, ensure the technical functioning of the Service and the Site and develop new services.
As Non-Personal Information does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-Personal Information, which does not personally identify you, with Affiliated Entities and other third parties, for any purpose. We may provide Non-Personal Information, including demographic information about you and/or your child, such as gender, age, transaction or purchase history and wishlist items to participating merchants in order to assist them in tailoring their offerings to your child or otherwise.
How Personal Information Is Disclosed
Purchase Transaction Merchants. We will share with participating merchants and their agents and service providers transaction information for authorized purchases and your physical address for delivery of products purchased from the participating merchant using the REGO Service. We will share credit card information and to the extent necessary Personal Information with participating merchants and their payment processors to process approved purchase transactions initiated by a child using the REGO Service.
Third Party Service Providers. We work with third parties who provide services including, but not limited to, credit card processing, operating and hosting our Site and/or our App/platform, data storage, email and/or text messaging delivery services and contractors who assist with programming and technical aspects of our Site and App. We reserve the right to share Personal Information with such third parties for the sole purpose of enabling them to provide such services.
Promotions.We reserve the right to share Personal Information in connection with promotions with third parties sponsors of such promotions (irrespective of whether such promotions are hosted by us), in accordance with the rules applicable to such promotion. You should carefully review the rules, if any, of each promotion in which you participate through the Site, as they may contain additional important information about a sponsor's or other third parties' use of your Personal Information. To the extent that the terms and conditions of such rules conflict with this Policy, the terms and conditions of such rules shall control. If you do not wish to have your Personal Information shared with third parties, you should not participate in our promotions.
Assignment.We reserve the right to transfer any and all information that we collect to an Affiliated Entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of REGO's business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
Law enforcement; emergencies; compliance. We reserve the right to disclose Personal Information and any other information we collect as we believe to be appropriate (a) under applicable law; (b) to comply with legal process served on us, as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on us; (c) to respond to governmental requests; (d) to enforce our User Agreement and terms and conditions of the Service; (e) to protect our operations or those of any Affiliated Entities; (f) to protect the rights, privacy, safety or property of REGO, the Affiliated Entities, you or others; and (g) to respond to any claims and permit us to pursue available remedies or limit the damages that we may sustain.
Links and Third Party Sites
The security of your Personal Information is important to us. We follow generally accepted industry standards to protect the information you submit to us. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Once we receive your information, we use HTTPS encryption to transmit sensitive information such as credit card numbers and user ID and passwords. All Personal Information you provide for the REGO Service is stored on secure third party infrastructure in accordance with their security procedures and the Payment Card Industry Data Security Standard. User ID and password are used so that only the Parent can access and view the Personal Information and certain other REGO account information and a child’s User ID and password are needed to make a transaction using the REGO Service. We recommend that you do not divulge and you inform your children that they not divulge REGO user IDs and passwords to anyone. Ultimately, you are responsible for maintaining the secrecy of your REGO User IDs and passwords and REGO shall not be responsible or liable in any way for damages or losses resulting from a Parent or child divulging or not protecting their user IDs and/or passwords.
Changing or Deleting Information
If Parents would like to review, correct, update or delete Personal Information or Non-Personal Information that was previously provided by Parents to us through the Site, they may do so by logging into their REGO account and correcting, updating or deleting such information in the Parent profile or child profile(s). Please note that if required information (marked with an asterisk) is deleted, the REGO Service will not function and can no longer be used. If a Parent deletes all information from the Parent profile their REGO account will be closed and all information except transaction information will be removed from our system. Parents may also elect to delete an entire child profile, in which event such child may no longer use the REGO Service. If a Parent is unable to correct, update or delete their information as described above or wishes to refuse further contact with their child by the Site, they should contact REGO at firstname.lastname@example.org with their specific request. Please note that we may need to retain certain transaction information for record keeping and reporting purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We are not responsible for removing information from the databases of third parties with whom we have already shared information. We will retain your information for as long as your REGO Account is active or as needed to provide you services. If you wish to cancel your REGO Account or request that we no longer use your Personal Information to provide you Services, Parents should log into their Parent profile in their REGO Account and select the “delete” button, and if your attempt to close your account online is unsuccessful, you should contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you no longer wish to receive electronic newsletters and/or promotional emails that we may send to you, you may opt-out of receiving them by following the opt-out instructions included in each newsletter or email, or logging into your Parent profile and changing the REGO communications switch to “off”. If your attempts to opt-out by these methods are unsuccessful, you should email us at firstname.lastname@example.org with your request. We also offer Parents the opportunity to opt-out of certain communications by logging into their Parent profile in their REGO account and updating the communication settings.
Third Party Services
We may optionally allow Parents to use their Open ID credentials to sign up for our Service. How this works is a Parent enters a userid /password from one of the open ID providers (like Google for example) and we pull in information from their profile so that they will not need to enter the same information again. This is restricted to email address, userid /password. We do not share any Personal Information with the open ID providers; rather we get information from open ID providers to make the sign up process easier for Parents.
Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit our App. Please note that these companies may use information (not including Personal Information) about your visit to this Site in order to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to this Site, these companies may place or recognize a unique cookie on your browser. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit http://www.networkadvertising.org/managing.
The Site and App are controlled and operated by REGO from the United States, and is not intended to subject REGO or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. REGO does not represent or warrant that the Site or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
A Note to EU Citizens
REGO complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:
the right to have your personal information updated to ensure it is up-to-date and accurate.
the right to withdraw your consent to any processing that is currently being done under your consent.
the right to receive a copy of the personal information we hold about you.
right to request that we delete personal information in certain circumstances.
the right to have us transfer to another controller the personal information that you have provided us with.
the right to request a restriction on the processing of your data in some limited circumstances.
right to request that we stop processing your data.
For more information on how to action these rights please contact us at: email@example.com.
If you are an EU citizen and would like to make a complaint about the way we process your personal data, you can contact the relevant Data Protection Authority (DPA). Please contact us using the details below to find out more.
If you have any questions regarding this Policy or our information practices, please contact us by e-mail at firstname.lastname@example.org, write us at the address below or call (215) 247-5500. Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your e-mail correspondence with us.
REGO Payment Architectures, Inc.
325 Sentry Parkway
Blue Bell, Pennsylvania 19422
Attention: Customer Service
© Copyright 2020 REGO Payment Architectures, Inc. All rights reserved.