Thank you for using Club Penguin Atake.

Referred to in this document as 'We', the 'Site', 'Us'.

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Introduction to the Privacy Policy

Our Privacy Policy covers the various data and privacy information included in the website and applications.

This Privacy Policy outlines how to remove, manage, and export your data from Club Penguin Atake, as well as the types of data we collect. We realise the huge responsibility that comes with getting sensitive information and are dedicated to keeping it secure.

Before using any Club Penguin Atake websites or applications, please read the policies in this document.

We've provided explanations and examples to make things as clear as possible. If you have any queries concerning this Privacy Statement, please send us an email at [email protected].

If you do not agree to our policies (“Terms of Service”, “Privacy Policy“, “Community Guidelines“, "Advertised, Partnered & External Services Policy"), please stop using our services immediately.

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Ownership Statement

By using Club Penguin Atake, you agree that we are fully independent from The Walt Disney Company and/or the Disney Interactive Media Group (collectively, "Disney"). We are an independent project. We don't have any sort of relationship with Disney. You agree to release Disney, as well as any of its employees or agents, from any liability, corporate or personal loss resulting from the use of our services.

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Information you provide us

Club Penguin Atake collects information about you primarily from the data you provide to our services.

• Information about you:
  By using Club Penguin Atake's services, you provide information to create an account. You can find out more about the procedure here. The data provided by you is your email, Club Penguin Atake username and password. Your password is securely encrypted and is not accessible to anybody, including our staff members. Club Penguin Atake only uses this data for account maintenance and will not share it with anybody else without prior notification.
• Advertised, Partnered & External services:
  Please visit the Third Party Guidelines, always available at https://www.cpatake.boo/policies/third-party.
• Digitally transmitted requests or inquiries sent to us via forms on our website, including the sign in and registration areas located on our applications:
  We save correspondence data to better serve you. We make every effort to anonymize the data we collect from you when you use the Website's forms. Anti-spam measures, particularly on third-party forms or services, may collect your IP address.
  When you use the services on our sign in and registration pages, we actively collect the information required from you, which includes a valid email address, penguin username, and password. Your password is securely encrypted and is not accessible to anybody, including our staff members. Both of the functions provided by these services are used to keep the user account active.

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Data obtained from third parties

Club Penguin Atake collects first- and third-party data through our website and game analytics, specifically using Google Analytics and Microsoft Clarity. We utilize these tools to track user activities on our website, including behavioral data, heatmaps, and session replays. This data enables us to enhance and offer our products and services.

We gather information on how you use and interact with our website. This includes data collected by first- and third-party cookies, as well as other tracking technologies. The goal of collecting this information is to determine the popularity of our products and services, optimize our website, improve security, and support our advertising activities (if those are currently running).

Google Analytics (also called GA4):

1. Data Collection: Google Analytics collects first-party cookies, device/browser data, and on-site/app activities to measure and report user interactions on GA4-enabled websites and apps.
2. IP Address Handling: GA4 does not log or keep IP addresses while collecting data. Instead, it uses IP addresses for geolocation during data collection and then discards them. Google anonymizes IP addresses by default, meaning the whole IP address is not saved or displayed in the reporting interface.
3. Privacy Information: For more details on how Google collects and uses your data, visit the Google Privacy Statement: how Google uses data from sites and apps that use Google's services. For information on how Google protects your data, visit this website: support.google.com/analytics/answer/6004245.

Microsoft Clarity:

1. Data Collection: Microsoft Clarity collects user interaction data, such as mouse movements, clicks, and scrolls, to create heatmaps and session replays, helping us understand user behavior and improve user experience.
2. IP Address Handling: Clarity anonymizes IP addresses before storing data, ensuring that IP addresses are not saved or displayed in the reporting interface.
3. Privacy Information: For more details on how Microsoft collects and uses your data, visit the Microsoft Privacy Statement: how Microsoft uses data from sites and apps that use Microsoft's services.

Per your request, we will tell you via email: [email protected] of the source and type of information we have obtained about you within a reasonable time after receiving the personal data, but no later than one month.

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Cookies

We utilise first and third party cookies to collect behavioural metrics, heatmaps, and session replay data. Below is a table of key cookies used by Club Penguin Atake. Please note that GA4 stands for Google Analytics 4, MSC stands for Microsoft Clarity and CF stands for Cloudflare.

Cookie	Purpose	Expiration
_ga	GA4: Distinguishes unique users.	2 years
_ga_<container-id>	GA4: Persists session state.	2 years
CLID	MSC: Identifies the first-time Clarity saw this user on any site using Clarity.	1 year
MUID	MSC: Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising**, site analytics, and other operational purposes.	2 years
_clck	MSC: Persists the Clarity User ID and preferences, unique to that site is attributed to the same user ID.	1 year
_clsk	MSC: Connects multiple page views by a user into a single Clarity session recording.	Session*
ANONCHK	MSC: Indicates whether MUID is transferred to ANID, a cookie used for advertising**. Clarity doesn't use ANID and so this is always set to 0.	1 year
MR	MSC: Indicates whether to refresh MUID.	N/A (managed by Clarity's internal logic)
SM	MSC: Used in synchronizing the MUID across Microsoft domains.	N/A (managed dynamically)
zaraz-consent	CF: Stores your consent to Google Analytics and Microsoft Clarity.	1 year

*expires when browser is closed
**Club Penguin Atake does not have Microsoft/Bing Ads, those cookies are not applicable.

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Your Security Rights

Under these guidelines, Club Penguin Atake gives members the ability to change their account information or end their relationship with the website. Furthermore, under applicable data privacy regulations, you have specific rights in certain regions (such as the European Economic Area).
This could include the right to

• request access to and a copy of your personal information,
• request modification or erasure,
• limit the processing of your personal information,
• data portability, where applicable.

In some cases, you may also be able to object to the processing of your personal information. Please send a written notice to [email protected] to make such a request. Any request will be reviewed and processed in accordance with the applicable data protection legislation.

If we are processing your personal information with your consent, you have the right to withdraw it at any time. Please keep in mind that this has no influence on the legality of the processing before it is withdrawn.

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Your California Privacy Rights

This Club Penguin Atake Privacy Policy conditional section is only applicable to California residents.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, allows our California users to request and obtain information about the categories of personal information (if any) that we disclosed to third parties for direct marketing purposes, as well as the names and addresses of all third parties with whom we shared personal information in the previous calendar year, once a year and free of charge.

If you are a California resident and want to make such a request, please send us an email at [email protected] with the subject line "My California Privacy Rights".

If you are under the age of 18, live in California, and have a registered account with Club Penguin Atake, you have the right to have any incorrect information publicly posted on the Application or Website erased. To seek the removal of such data, please write an email to [email protected] with the subject "My California Privacy Rights" and include the email address associated with your account, as well as a statement that you reside in California. We will ensure that the data is not publicly shown on our website/app, but please be aware that it may not be completely removed from our systems.

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Revisions

Club Penguin Atake keeps the right to update this privacy policy at any moment. These conditional policies may be modified in response to abuse or security concerns, regulatory or legal obligations, or changes to our policies.