Children's Privacy Policy

Club Penguin Legacy's Children's Privacy Policy outlines how Club Penguin Legacy handles sensitive data and private information regarding children.

An overjoyed Penguin sitting on a desk in the evergreens

Updated October 6, 2022

Club Penguin Legacy is dedicated to safeguarding the privacy of children who visit our websites and utilize our applications. This Children's Privacy Policy describes our information collection, sharing, and parental permission procedures with regard to information given by children under the age of 13 ("child" or "children"), and utilizes terminology described in our general Privacy Policy. This policy is in conformity with the Children's Online Privacy Protection Act ("COPPA") in the United States and defines our policies respecting children's personal information in the United States. OnGuard Internet has further information regarding COPPA and basic suggestions for protecting children's online privacy.

Please visit OnGuard here:

The Information we collect from Children

Club Penguin Legacy provides its users with a variety of sites and applications, some of which are especially aimed at children and others at users of all ages and their families. Our websites and applications include a wide range of activities, including some that may gather information from children. We highlight probable instances of collecting below, as well as how and when we will offer parental notification and/or request parental approval.

If we collect personal information from a child, we will keep it for as long as is reasonably necessary to fulfill the activity request or allow the child to continue participating in the activity, and to safeguard the security of our users and our services, or as required by law.

If we find that we have collected information from a child in a manner that violates the provisions of COPPA, we will either delete the information or promptly seek the parent's approval for that collection.

How Children Register for our Services

Children can register with our sites and applications in many circumstances to see content, play games, enter contests, and use special features, among other things. We may require the child to give some information during the registration process for notification and security purposes, such as a parent or guardian's email address, and the child's member or account username, and password. We may also request birth dates from minors in order to verify their ages. We highly urge children not to include any personally identifiable information in their usernames. Please keep in mind that while children may choose whether or not to share their information with us, certain services can not operate without it. As a result, if necessary information is not given, children may be unable to use some functions. We will not ask a child to supply any more information than is reasonably required in order for them to engage in an online activity.

Concerning the collecting of parent email addresses: In accordance with the rules of COPPA, we shall request a parent or guardian’s email address before collecting any personal information from a child on any child-targeted site or application, or in any situation where we inquire for age and conclude the user is age 12 or younger. If you suspect your child is participating in a personal information-gathering activity and you or another parent/guardian have not received an email offering notice or requesting your approval, please contact us at 

Club Penguin Legacy never sells the data and personal information of children and parents to third parties.

Content generated by Children

Certain activities on our websites and apps enable children to create or alter information and store it with Club Penguin Legacy. Some of these activities do not require children to give any personal information and hence may not result in parental notification or permission. If an activity permits a child to include personal information in their generated material, we will either pre-screen the submission to remove any personal information, or we will request verified parental approval for the collection by email. Stories or other open-text sections, as well as paintings that allow text or free-hand insertion of information, are examples of generated material that may include personal information. In addition to gathering content containing personal information, Club Penguin Legacy also intends to publicly upload the content or share it with a third party for the third party's own purpose, for which we will require a higher degree of parental agreement.

If Club Penguin Legacy desires to gather personal information from a child, COPPA requires us to first get parental or guardian approval by email. We will clarify what information we are gathering, how we intend to use it, how the parent may offer consent, and how the parent can revoke consent in the email. We shall erase the parent contact information and any other information acquired from the child in connection with that activity if we do not get parental consent within a reasonable period.

High-Level Consent
If Club Penguin Legacy acquires personal information from a child that will be publicly disseminated, we will seek consent at a higher level than email consent. Such "high-level" consent methods include, but are not limited to, requesting a credit card or other payment method for verification (for a nominal fee), speaking with a trained customer service representative by phone or video chat, or requiring a signed consent form by mail, email attachment, or fax. Following high-level agreement, a parent may be able to use a pin or password in future contacts to prove the parent's identification.

Teachers, with permission of Parents/Guardians
In terms of school-based activities, COPPA permits teachers and school administrators to offer consent for the collecting of personal information from children in place of parents. These events should always be communicated to parents by schools. Please visit the FERPA website for further information on parental rights regarding a child's educational record under the Family Educational Rights and Privacy Act (FERPA).

Chat-based Services for Children

Club Penguin Legacy’s games and activities allow players to connect directly with other users via a chat system. All chat systems include filters to restrict the transmission of personal information as well as age-inappropriate terms and phrases. We may utilize live moderation in addition to filters and/or urge other users to identify objectionable remarks. We strongly advise children who use these interactive elements on our sites and applications to never submit personal information about themselves or any third party, and to never attempt to bypass our filters or moderation. We also advise parents to keep a close eye on their children while they engage in internet activities.

In the absolute rarest of circumstances, when Club Penguin Legacy uses a chat system that does not filter all or almost all personal information, we will first get high-level parental authorization.

Contests and Sweepstakes

We normally request only the information essential for a child to participate in competitions and sweepstakes, such as first name (to distinguish amongst family members) and parent email address (to notify the parent where required by law). When a child wins a contest or sweepstakes, we contact the parent for further tailored information for prize fulfillment reasons.

Of course, some competitions and sweepstakes require the children to contribute their own developed content in addition to their submission. In some cases, parental approval may be required prior to submission. For additional information about our collection, notice, and consent practices, please read Content Generated by a Child above.

Communication with Children

Club Penguin Legacy may need to ask for a child's online contact information, such as an email address, on occasion in order to react to a query or request from a child. Club Penguin Legacy will instantly remove this information after replying to the query or request.

We may collect a child's online contact information, such as an email address, in connection with specific activities or services in order to interact with the children more than once. In such cases, we shall save the child's online contact information just to fulfill the request and for no other reason, such as marketing. A newsletter that delivers periodic updates regarding a website, game/activity, television show, personality/character, or feature film is one example. When we collect a child's online contact information for ongoing contacts, we will also request a parent email address in order to alert the parent about the collection and use of the child's information and to provide the parent the option to stop future contact with the child.

Persistent Identifiers

When children engage with us, certain information may be gathered automatically, both to make our sites and applications more attractive and useful to children and for different commercial objectives. The kind of computer operating system, the children's IP address or mobile device identifier, the web browser, the frequency with which the child views certain portions of our sites or applications, and information about the internet or mobile service provider are all examples. Cookies, flash cookies, web beacons, and other unique identifiers (as defined in the "Online Tracking Technologies" section of our general Privacy Policy) are used to gather this information. Club Penguin Legacy or a third party may gather this information. This information is mostly used for internal purposes:

• To provide children with access to features and activities on our sites and applications
• To customize content and improve our sites and applications
• To conduct research and analysis to address the performance of our sites and applications
• To generate anonymous reporting for use by Club Penguin Legacy

If we collect (or allow others to collect) such information from children on our sites and apps for other reasons, we will alert parents and acquire their consent before doing so.

Our Commitment to Your Child’s Privacy

To ensure the protection of your child’s personal information, we communicate our privacy and security policies to Club Penguin Legacy workers and strictly enforce privacy measures within the company through rigorous security clearance and best practices.

Child Privacy Questions

If you have any questions about Club Penguin Legacy's Children Privacy Policy or privacy practices, including when a third-party service provider is acting on our behalf, want to contact our Data Protection Officer, or want to file a complaint, please contact us at You may also ask us how to file a privacy complaint, and we will do our best to assist you.