Barter Island Privacy Policy

Last Updated: February 5, 2018

The Federal Reserve Bank of Cleveland (“Bank”, “we”, “us”) respects the privacy rights of our mobile customers and recognizes the importance of protecting the information collected about you. This privacy policy governs your use of the software application ESCAPE FROM THE BARTER ISLANDS (“Application”) for mobile devices that was created by us. The Application is an educational game that teaches about the value of money as a tool for trade. No internet access is required after installation. By using the Application, you signify your consent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Application.

About this Privacy Policy

This Privacy Policy applies to the collection, use, and disclosure of personal and non-personal information by the Bank through the Application.

User Provided Information

The Application obtains the information you provide when you download the Application. Registration with us is not required, and you are not required to provide us with any personal information in order to use the Application.

Automatically Collected Information

The Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile operating system, your mobile device manufacturer, your city, your country and information about the way you use the Application (i.e. your total play time, how long it takes to complete each segment of the Application.) This information is collected to understand your interaction with the Application and to provide support for the internal operations of the Application. We may use this data in aggregate form, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to determine how often individuals use parts of the Application so that we can analyze and improve them.

This Application does not collect precise information about the location of your mobile device.

Some aggregate Application analysis is performed for us by Google Analytics and may involve the use of cookies set by Google. View Google’s Privacy Policy.

Do third parties see and/or have access to information obtained by the Application?

Only aggregated, anonymized data is periodically transmitted to external services to help us improve the Application and our service. We will share your information with third parties only in the ways that are described in this privacy statement.

We may disclose Automatically Collected Information:

• As required by law, such as to comply with a subpoena or similar legal process;
• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• With our trusted service providers who work on our behalf, and do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

Data Retention Policy, Managing Your Information

We will retain Automatically Collected Information for up to 24 months and thereafter may store it in the aggregate.

Children

We do not use the Application to knowingly solicit data from children under the age of 13. If we were to collect and store personal information from children, we would obtain the consent of a parent or legal guardian before such collection, unless the collection of information falls within an exemption that is permitted under the Children’s Online Privacy Protection Act (“COPPA”). If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at DataPrivacyOffice@clev.frb.org to contact the Bank's Privacy Office. Include your name and details about your inquiry. We will delete information from our files within a reasonable time.

The Bank may collect information which includes persistent identifiers such as an Internet Protocol address. This information is collected solely for the purpose of providing functionality and support for our internal operations and optimizing our users’ experience.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on this page. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

Your Consent

By using the Application, you are consenting to our processing of information as set forth in this Privacy Policy now and as amended by us. “Processing,” means using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at DataPrivacyOffice@clev.frb.org. Include your name and details about your inquiries.