UpToTen.com > Privacy policy
     Personal information and the respect of privacy in cyberspace

> Who do we collect personally identifiable information from ? - Information collected on this site,     Minors, AdultsSecurity, E-commerce, General Conditions

Children and parents, take careful note of the following information:

Parental consent and the UpToTen User Account

In compliance with COPPA (Children's Online Privacy Protection Act) and all European legislation currently in force, only the parents and legal guardians are permitted to give personally identifiable information concerning of child 12 and under: To comply with these laws, we have created the UpToTen User Account.

Through the UpToTen User Account, the child's parent or legal guardian can send all the information concerning their child(ren) that is necessary for the subscription process. The information we ask for allows us to deliver a personalized and fulfilling experience for club members.
Through the UpToTen User Account, the child's parent or legal guardian has immediate access to and complete control over the personally identifiable information UpToTen holds concerning them. The parent / guardian can modify or delete that information at any time through the UpToTen User Account.

What sort of information is collected by this site ?

This site is home to a multitude of activities, games and services for both parents and children.
Only children accompanied by an adult can access UpToTen Kids. We ask the parent or guardian to identify themselves and to open a free UpToTen User Account before we allow access to the child. Some of the data collected is personally identifiable information (first and last names, professional or home address, email address...), and some is not ( gender, age, browser used on the PC...)

We collect personally identifiable information concerning the parent or guardian during the sign-up process. For the Boowa and Kwala club, we require personally identifiable information about the child. The inscription for the Club can only be completed via a valid UpToTen User Account. The data we collect concerning children under the age of 13 is therefore provided by their parent or guardian (in compliance with COPPA (Children's Online Privacy Protection Act) and all European legislation currently in force).

The following text aims to clearly state UpToTen's policy concerning personal data collected on the site. We will explain how the information is collected and for what reasons.

UpToTen does not sell, exchange or broadcast publicly information provided by users without their consent and this in strict accordance with the relevant applicable laws (the COPPA, for example). UpToTen respects the concerns and private lives of its visitors and their families. All information given remains the sole property of UpToTen.

UpToTen will partner with commercial institutions in order to offer club members and UpToTen User Account holders quality products and services. Unless otherwise stated, adhesion to UpToTen via a Boowa & Kwala Club membership or an UpToTen User Account gives the adherent access to direct promotion for UpToTen products and those of carefully chosen partners.

Our partners' products will be recommended by Boowa and Kwala and will therefore be quality, well-known brands that are suitable for Boowa and Kwala fans.

UpToTen makes every effort to ensure that it complies with all relevant laws and regulations and will make prior inquiries with conversant authorities.

1- In order to gain access to UpToTen Kids, some information is required from the responsible person (parent / guardian for any child under the age of 13) ;

  • E-mail address,
  • First name and surname,
  • The ages of the children in their charge
  • Their age
  • This information is required in order to benefit from free and unlimited access to the UpToTen services : UpToTen Kids and UpToTen Parents.

The holder of an UpToTen User Account is responsible for the children s/he subscribes to the Boowa & Kwala Club and for those s/he allows to enter the site using his/her account.

Each e-mail submission implicitly implies a subscription to the UpToTen newsletter. However, each newsletter offers the possibility to unsubscribe

2- The subscription process for the Boowa and Kwala club requires that we collect certain information concerning the prospective member. We collect this information only from the parent or legal guardian. We only collect such information as is absolutely necessary to offer the future member a full, personalized service. We make our best efforts to ensure that the information collected is always the strict minimum.

Should we require more information than is provided in the Boowa and Kwala club subscription process, we will request such information only through the parent / guardian and in full respect of the COPPA.

Parents / legal guardians have the right of access to all personally identifiable data we hold concerning their child(ren). They also have the right to have this information modified or deleted. Parents can exercise this right through their UpToTen User Account.

UpToTen can use this information for awarding prizes, checking the participants' compliance with regulations, publication or replying (all usage of this type will be clearly indicated and explained to visitors as and when they are asked to provide information), for internal use such as assessing the level of interest of the various site modules for visitors to enable UpToTen to provide the best possible personalized service. In the event of UpToTen wishing to display information provided by visitors publicly on the site, the visitors in question will be warned beforehand and will have the possibility of refusal.

You will find your « UpToTen User Account » in the « UpToTen Parents » section

The « UpToTen Parents » section will also be your hub of contact with the UpToTen team and the UpToTen community at large.

You will :

  • Find expert advice about multimedia and the positive role it can play in your children's education ;
  • Discover how UpToTen Kids can contribute to your children's education ;
  • Learn how to get the most out of UpToTen Kids and the Boowa & Kwala Club ;
  • Meet the UpToTen team and the people behind Boowa & Kwala ;
  • Be given the opportunity to dialogue with us and communicate with the UpToTen community.
  • The Parent forums provide a platform for you to ask questions, make suggestions and share your experiences ;
  • Have your say in the ongoing development of UpToTen.com for you and your children ;
  • Regularly find updated information and articles ;
  • Have 100% control over your personal data ;
  • Be able to sign your children up for the Boowa & Kwala Club ;
  • Learn more about the items available in Boowa & Kwala's Toyshop.

Concerning children (who therefore have the legal status of minor)

UpToTen encourages parents and legal guardians to take an active participation in the time that their children spend on the on-line games, competitions and other interactive activities present on its site.

UpToTen will not divulge any information of a personal nature without prior indication and/or explicit authorization, independently of its originator, to a third party for any reason whatsoever.

Minors should neither send nor display information on our Web site without the consent of their parents of legal guardians. UpToTen realizes that this can be difficult to control and makes every effort to ensure that young visitors are aware that they must have the permission of their parents or legal guardians. . For the on-line security of your children, minors are allowed to participate in contests ONLY through your UpToTen User Account. Should they win a prize, we will use the information that you provided in your UpToTen User Account to deliver it.

Concerning people who have reached the age of majority

Information provided during registration or at any other time can be used by UpToTen for commercial activities, with prior consent and on the condition that the user is warned on-line. If the user has any objection, he can prevent the use of this personal information either by making a request via e-mail or by modifying the membership form.


> Sending e-cards
> The UpToTen newsletter
> Recommending a site or s specific page
> Requesting a game
> Showing art in the Boowa and Kwala gallery
> Writing to us
> Links
> Cookies
> E-commerce applications
> Your UpToTen User Account

Access to your information is only authorized for UpToTen employees, third parties who require certain data to carry out their functions or for the collecting or treatment of information. Under the terms of our employment and service contracts, all information collected through activities directed by UpToTen or in the name of UpToTen will be considered confidential.


We do not manually check the messages and are in no way responsible for their contents. An e-mail message is sent from our site (UpToTen.com) to the recipient, with a link back to the UpToTen Kids site, where the electronic postcard is displayed. Only people who have the appropriate, coded link can view the electronic postcard.

The sender must give his/her first name and e-mail address, and the e-mail address of the recipient. Club members only need give the e-mail address of the recipient.

We then send an e-mail to both parties.


For all users under the age of 13, we ask that they join the Boowa and Kwala club in order to participate in the life of the site and to enhance their on-line experience. A club newsletter is sent once a month.

For all users age 13 or over we offer a newsletter. We only ask for the first name and the e-mail address. Every newsletter contains clear instructions as to how to unsubscribe.


The user chooses a specific page within UpToTen Kids and an e-mail message is sent from our site (http://www.uptoten.com) to the recipient, with a link back to the page chosen.

The sender must give his/her first name and e-mail address, and the e-mail address of the recipient. Club members only need give the e-mail address of the recipient.

We then send an e-mail to both parties.


By authorizing your child to join the Boowa and Kwala club, you also authorize UpToTen to display the first name or nickname of your child in the games index next to a game that he/she requested. We will send a prize to all children who have a game dedicated to them in such a way. In order to send this prize we will use the address that you provide in your UpToTen User Account. If no address is given, no prizes will be sent.


By authorizing your child to join the Boowa and Kwala club, you also authorize UpToTen to display any artwork he/she may submit and you further authorize UpToTen to display the first name or nickname of your child next to the artwork concerned. If you do not wish to see your child's first name associated with the artwork, you must let us know that you wish to use his/her nickname when the artwork is sent. We will send a prize to all children who's artwork is shown. In order to send this prize we will use the address that you provide in your UpToTen User Account. If no address is given, no prizes will be sent.


We use the addresses of those who write to us solely to reply to the e-mail. This contact is a once-off and the addresses are not kept for future communication.


We have a very strict policy concerning the security of the UpToTen window and we do not to link to other sites from within the UpToTen window other than carefully screened partner sites those sites necessary for application updates (Macromedia for the Flash plug-in, for example). We have created http://www.kidsites.org - a directory for kids that contains the sites that we feel are of a sufficiently high standard to be positive for the child and/or the parent. We link to other sites that are commercial, educational, or just plain fun. We are not responsible for these other sites, and we advise you to check their privacy policies as well.

For our internal purposes, we gather date, time, browser type, Flash version, pageviews and the IP address of all visitors to our site. We keep this information for system administration, to analyze and improve compatibility, to report aggregate information to our advertisers and for our internal audit log. We do not link IP addresses to anything personally identifiable.


Cookies are data elements that are stored on your hard drive. Cookies allow you to navigate more easily and allow you to keep your preferences during your visit(s) to a given site.


Cookies are very widely used and are hugely beneficial to you. Most Internet sites use them extensively. By indicating how a user navigates through the site, cookies can help us to identify those parts of the site work best and those that work least well. Most updates and improvements are based on information from Cookies. Most importantly, Cookies allow you to access UpToTen without identifying yourself every time.

Please note the following :

We do not use Cookies to track individual users (except for on-line purchases where tracking a customer is necessary). We do not use Cookies to extract information from your computer.

When you open an UpToTen User Account, UpToTen.com places one cookie on your computer. This cookie contains NO personal data. It is designed only to make your access to the site seamless.

Please note that you control the Cookies that sites you visit can place on your computer. Most browsers are set up to accept Cookies by default. You can disable Cookies in your browser, limit the type of Cookies you will accept or ask to be warned when a site places a Cookie on your computer. However, should you do this, you will need to identify yourself every time you wish to visit UpToTen. It is also probable that parts of UpToTen Kids and UpToTen Parents will not function correctly (specifically, but not limited to, the toy store, your UpToTen User Account, and certain games for your children.

You may occasionally get cookies from our advertisers, however. We do not control these cookies. The use of advertising cookies sent by third-party servers is standard in the Internet industry. We also work with a third party that serves some of the ads to our sites.


Use of UpToTen e-commerce applications are subject to the policies and terms and conditions covering the sites, including those with respect to collection of personal information necessary to process any orders. The policies and terms of use covering these can be accessed from the pages of our sites and from within these applications themselves. These applications are intended for adults and a credit card is required in order to complete the ordering process. We have developed our own applications and house them on our secure server.

All credit card information is collected directly by our bank on their own secure servers. This ensures maximum security and peace of mind for our users.

All the information sent and received at the time of payment are encrypted using 128 bit encryption technology (the strongest commercially available today). The encryption keys are provided by Verisign(http://www.verisign.com), the world leader in this field.

In the future we may call upon outside contractors to process and fulfill orders made from the UpToTen Store. In this case, UpToTen will choose only trusted, reliable partners with a household name. They will then be responsible for adhering to our own privacy and security policies.


Communication security

You are the only person who has access to your e-mail account. This is the reason that we use your e-mail address to identify you (your UpToTen User Account Username).

We can ensure your privacy by communicating with you solely via this e-mail address as you are the only possible recipient. Sending your password to this address, for example, is therefore safe.

General Conditions that apply to our privacy policy

Although UpToTen follows and complies with the Children's Online Privacy Protection Act, the regulations promulgated thereunder and the currently applicable European laws concerning children on the Internet, this does not guarantee safety or that the relevant person is a child or a parent or legal guardian, and UpToTen does not guarantee the actual identities claimed by its users. Also, we do not guarantee that your children will not voluntarily release personal information about themselves or about you or their friends or other acquaintances on our site or on sites that they visit or link to from our site. It is very important that parents understand the features, uses and potential risks of using UpToTen.com. That's why we advise all users to practice safe computing and urge parents to advise their children not to give out any personally identifiable information without their consent.

UpToTen is not immune from the possibility of acts of piracy. UpToTen can therefore not be held responsible for any pirated content within its pages. We guarantee, however, that we employ the strictest controls and security measure to ensure that acts of piracy do not occur.

UpToTen makes no guarantees, warranties or representations that you or your child will be absolutely safe or insulated from inappropriate content or behavior and we do not guarantee, warrant or represent that a child will not try to circumvent, or be successful in circumventing, the features on our site. Furthermore, UpToTen does not assume any obligations, liability, or responsibilities associated with such behavior or associated with the obligations of parental supervision.

UpToTen reserves the right to change the information, features, products, policies, promotions, disclosures and disclaimers at any time. Changes to this Privacy Policy will be posted on the UpToTen site. Please check these terms periodically for changes. At the top of the policy we indicate the date of the last update. The continued use of the UpToTen web site following the posting of changes to these terms will mean you accept such changes, and any off-line consent provided under COPPA will be deemed to apply to the revised policies and new or modified features. However, in the event there is a material change in our data collection, use or disclosure practices, we will obtain a new consent.

These contractual conditions shall be analyzed and governed by the laws of MAURITIUS without regard to its conflict of law provisions. If any of the terms of these conditions are found to be illegal, invalid or void for any reason it shall be considered severable and shall not affect the validity or application of the other provisions.

Thank you for being concerned with kids' privacy and safety issues and for taking the time to read this Privacy Policy. We hope that you and your children enjoy UpToTen.com. If you have any questions or comments, please feel free to contact us.

We hope that we have made the functioning of this site sufficiently clear and that we have responded positively to your expectations. If you have any questions and/or suggestions about security, don't hesitate to contact us at steve@uptoten.com

UpToTen, Astor Court, Port Louis, Mauritius
Tel: (230) 213 68 37
© UpToTen. All rights reserved

UpToTen reserves the right, at all times, to modify or to renew its privacy policy.

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