Privacy Policy

Club Penguin Legacy Privacy Policy describes how Club Penguin Legacy collects, uses, and shares your personal data.

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Updated October 6, 2022

Club Penguin Legacy's privacy policy describes how Club Penguin Legacy collects, uses, and shares your personal data.

Our privacy policy is designed to provide transparency in our privacy practices and principles. Privacy is a fundamental human right, we are dedicated to treating your personal information with care and respect. 

This privacy policy defines how information submitted or collected on the sites where this policy is placed is treated. It also describes how we treat information submitted or collected on apps we make available on third-party sites or platforms, if disclosed to you in conjunction with the application's use. We adhere to this privacy policy in compliance with local legislation in the jurisdictions in which we operate.

Please take a moment to familiarize yourself with our privacy practices, accessible via headings below and contact us if you have any questions.

What is Personal Data?

Club Penguin Legacy strongly believes in fundamental privacy rights – and that those fundamental rights should not change based on where you live in the globe. That is why, regardless of where the individual lives, we classify any data that refers to an identified or identifiable individual or is linked or linkable to them as "personal data." This implies that data that directly identifies you, such as your name, is personal data, as is data that does not directly identify you but may reasonably be used to identify you, such as your device's serial number. For the purposes of this Privacy Policy, aggregated data is considered non personal data.

Your Privacy Rights

Club Penguin Legacy respects your right to know, access, update, transfer, limit processing, and delete your personal data. We have granted these rights to our worldwide customer base, and if you choose to exercise these privacy rights, you have the right not to be treated unfairly or to get less service from Club Penguin Legacy. Club Penguin Legacy does not and will never sell your data to third parties in the sense that the term "selling" is defined in California, where Club Penguin Legacy operates.

We may be unable to fulfill your request in some circumstances, for as if you ask us to remove your profile data and Club Penguin Legacy is required by law to maintain a record of that transaction. We may also refuse to accept a request if doing so would jeopardize our legitimate use of data for anti-fraud and security purposes, such as when you seek the deletion of an account that is under investigation for security concerns. Other reasons your request for privacy may be refused include: jeopardizing the privacy of others, being frivolous or vexatious, or being exceedingly impracticable. Club Penguin Legacy works with local and global law enforcement organizations agencies to keep internet users secure. All data saved is in accordance with local legislation and guidelines.

To exercise your privacy rights, please contact us at

Types of Information Collected

At Club Penguin Legacy, we believe that great products can coexist with excellent privacy. This implies that we make every effort to acquire just the personal information that we require. We only collect personal data that we need to serve you our services.

When you create an account using Club Penguin Legacy services, connect to our services, contact us (including social media), participate in an online survey, or otherwise interact with Club Penguin Legacy, we may collect a variety of information including:

Account Information. Your Club Penguin Legacy ID and related account details, including email address, devices registered, account status, and age 

Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type

Contact Information. Data such as name, email address, phone number, or other contact information

Fraud Prevention Information. Data used to help identify and prevent fraud

Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data

Other Information You Provide to Us. Details such as the content of your communications with Club Penguin Legacy, including interactions with customer support and contacts through social media channels

You are not needed to supply the personal information we have requested. However, if you do not do so, we will be unable to supply you with our products or services or answer to any requests you may have.

Information Received from Other Sources

Club Penguin Legacy may receive personal information about you from other individuals, businesses or third parties operating on your behalf, our partners who help us offer our products and services and assist us in security and fraud prevention, and other legitimate sources.

Individuals. Club Penguin Legacy may get information about you from third parties, such as if that person provided you with a product or gift card, encouraged you to join in on a Club Penguin Legacy service or forum, or shared content with you.

Partners with Club Penguin Legacy. We may also authenticate the information you give with a third party for security and fraud protection purposes.

Use of Personal Data

Club Penguin Legacy utilizes personal data to run our services, process requests, connect with you, protect you against security and fraud, and comply with the law. With your consent, we may also use personal data for other purposes.

Club Penguin Legacy only utilizes your personal information when we have a legal basis to do so.
Club Penguin Legacy may rely on your permission or the fact that the processing is required to complete a contract with you, safeguard your vital interests or those of others, or comply with the law, depending on the circumstances. We may also treat your personal data if we believe it is in our or others' legitimate interests, while keeping your interests, rights, and expectations in mind. You can contact the Data Protection Officer at if you have any queries concerning the legal basis.

Power Our Services. Club Penguin Legacy gathers personal data that is required to enable our services, including personal data acquired to better our products, for internal reasons such as auditing or data analysis, or for troubleshooting. For example, if you are experiencing an issue with one of our games and file a Bug Report, we collect data regarding your platform history with your consent to reproduce your issue.

Process Transactions. Club Penguin Legacy needs to gather data such as your name, IP address, email address information in order to conduct transactions

Communicate With You. To respond to communications or reach out to you about your account, marketing our products and services, providing other relevant information, or requesting information or feedback. We may use your personal information to send critical messages, such as communications regarding purchases and updates to our terms, conditions, and policies, from time to time. You cannot opt out of getting these vital messages since this information is critical to your contact with Club Penguin Legacy.

Security and Fraud Prevention. To safeguard individuals, workers, and Club Penguin Legacy, as well as for loss prevention and fraud prevention.

Comply with Law. To comply with relevant legislation, such as to meet tax or reporting duties or to comply with a legal governmental request.

Club Penguin Legacy does not utilize algorithms or profiling to make decisions that have a major impact on you without the option of human review.

Club Penguin Legacy retains personal data for as long as it is required to accomplish the reasons for which it was obtained, including as specified in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will keep your personal information for as long as it is required to accomplish the purposes mentioned in this Privacy Policy and our service-specific privacy summaries. When evaluating retention periods, we first carefully consider whether it is essential to retain the personal data gathered and, if retention is required, we endeavor to retain the personal data for the shortest term permitted by law.

Policies on Sharing of Personal Data

Club Penguin Legacy may share your personal information with Club Penguin Legacy-affiliated companies, service providers acting on our behalf, our partners, developers, and publishers, or others at your request. Furthermore, Club Penguin Legacy does not share personal information with other parties for marketing purposes.

Service Providers.
Club Penguin Legacy may interact with third-party service providers to operate as our service providers and carry out certain functions on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering items to consumers. Club Penguin Legacy service providers are required to treat personal data in accordance with our Privacy Policy and our guidelines. They are not permitted to use the personal data we disclose for their own purposes and are required to erase or return the personal data once we have satisfied our request.

Club Penguin Legacy may collaborate with other parties to deliver services or other items. Club Penguin Legacy and its partners, for example, provide such services such as transactions for subscriptions. Club Penguin Legacy expects its partners to secure your personal information.

Club Penguin Legacy may share personal information with other parties at your request or with your permission. We may also release information about you if we believe it is necessary or appropriate for national security, law enforcement, or other matters of public interest. We may also share information about you if there is a legal basis to do so, such as if we judge that disclosure is reasonably necessary to enforce our terms and conditions or to safeguard our operations or users, or if we are involved in a reorganization, merger, or sale.

Protection of Personal Data

Club Penguin Legacy places a high value on the security, integrity, and confidentiality of your information. We have put in place technological, administrative, and physical security measures to keep information safe against unauthorized access, disclosure, use, and alteration. We examine our security protocols on a regular basis to consider relevant new technology and methodologies. Please keep in mind, however, that no security measures are flawless or impregnable, despite our best efforts. We will keep your personal information for as long as is necessary to achieve the objectives mentioned in this privacy statement, unless a longer retention period is required or allowed by law.

Children, Personal Data, and Children’s Privacy

Club Penguin Legacy recognizes the significance of protecting children's personal data, which we define as anybody under the age of 13 or the equivalent age determined by legislation in your country. As a result, Club Penguin Legacy has introduced extra processes and safeguards to help keep children's sensitive information safe.

To access certain Club Penguin Legacy services, a child must have their account created by the parent or authorized guardian. We do not knowingly collect information from minors under the age of 13 to comply with Children's Online Privacy Protection Act, 15 U.S.C. §§ 6501–6506.

Club Penguin Legacy acknowledges the need to provide additional privacy safeguards for personal information collected from minors on our websites and services. Some of our sites and applications have age-gated features that prevent minors from using them, and we do not intentionally collect personal information from children in connection with those features. When we want to gather personal information from minors, we take extra precautions to protect their privacy, such as:

Notifying parents of our information practices with regard to children, including the sorts of personal information we may collect from children, the uses to which that information may be put, and if and with whom such information may be shared.

Obtaining parental consent for the collecting of personal information from their children, or for providing information about our products and services directly to their children, in line with current legislation.

• Limiting personal information about children is reasonably necessary for them to engage in an online activity.

• Giving parents access to, or the capacity to seek access to, personal information acquired from their children, as well as the right to request that the personal information be amended or deleted.

If we discover that a child's personal information was gathered without proper authority, we will delete it as soon as possible.

For additional information about our practices in the United States regarding children’s personal information, please read our Children’s Privacy Policy.

Cookies and Other Technologies

"Cookies" and other technologies such as web beacons may be used on Club Penguin Legacy’s websites, online services, interactive apps, and adverts. These technologies assist us in better understanding user behavior, particularly for security and fraud prevention purposes, as well as in determining which portions of our websites people have visited, as well as in facilitating and measuring the efficacy of adverts and online searches.

Communication Cookies.
These cookies facilitate network communication to and from Club Penguin Legacy's systems, including assisting us in detecting mistakes.

Strictly Necessary Cookies. These cookies are set when a specific function or service that you have visited or requested is required. For example, they allow us to display our website in the proper format and language, to authenticate and verify your web-processed transactions and preserve the contents on your local storage.

Other Cookies. These cookies are used to better understand how visitors engage with our websites and online services, such as assisting us in determining the efficiency of adverts and web searches.

If you prefer that Club Penguin Legacy does not use cookies, we provide a way for you to disable their use. Certain Club Penguin Legacy website features may be unavailable if all cookies are deactivated.

Please check or contact your provider to find out how to disable cookies.

Club Penguin Legacy usually classifies the information we gather through cookies and other similar technologies as non personal data. However, to the extent that local legislation considers Internet Protocol (IP) addresses or similar identifiers to be personal data, we regard these identifiers as personal data in such locations. Furthermore, Club Penguin Legacy may merge non personal data obtained through these technologies with other personal data held by Club Penguin Legacy. When we combine data in this manner, we regard the resulting information as personal data for the purposes of this Privacy Policy.

Transfer of Personal Data Between Countries

Club Penguin Legacy services link you to the rest of the world. To that end, your personal data may be transmitted to or accessed by organizations all over the globe, including Club Penguin Legacy-affiliated companies, in order for them to execute processing activities such as those outlined in this Privacy Policy in connection with your use of our goods and services. Club Penguin Legacy abides by regulations governing the movement of personal data across countries in order to secure your data wherever it may be.

When using or disclosing personal information transferred from the European Union, we follow the US Department of Commerce's Safe Harbor Principles, use standard contract clauses approved by the European Commission, use other means under European Union law to ensure adequate safeguards, or obtain your consent. When transmitting personal information from Australia, we also follow the substantive requirements of the Safe Harbor Principles.

Our Commitment to Your Privacy

To ensure the protection of your 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.

Privacy Questions

If you have any questions about Club Penguin Legacy’s 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.

Club Penguin Legacy takes your privacy concerns seriously and with utmost respect. Inquiries submitted in response to an access or download request are reviewed by specific staff to decide how best to react to your query or concern. All substantial contacts are usually responded to within fourteen days. In other circumstances, we may need further information or notify you that we require additional time to react.

Where your complaint shows that we could enhance our handling of privacy problems, we will take efforts to make such an update as soon as possible. If a privacy problem has had a detrimental impact on you or another person, we will take measures to rectify the situation with you or that other person.

If you are dissatisfied with Club Penguin Legacy’s response, you may file a complaint with the appropriate authority. If you ask, we will make every effort to give you information regarding appropriate complaint routes that may be pertinent to your situation.

For additional information about our practices when there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so and contact you directly about the change if we have your data on file. When there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so and contact you directly about the change. If we have your data on file United States and Latin America regarding children’s personal information, please read our Children’s Privacy Policy.

When there is a material change to this Privacy Policy, we’ll post a notice on this website, and contact you directly about the change if we have your data on file.