I. Introduction
The Wally’s Kids’ Club site, owned by The Old Spaghetti Factory, is committed to providing a safe, fun environment for kids and their families on the Internet sites of our clients. The Wally’s Kids’ Club site collects the minimal information needed to communicate with our registrants. All information is kept confidential and is not released to anyone for any purpose. Wally’s Kids’ Club owns the information collected on its client website and does not share the information with its restaurant partners. Wally’s Kids’ Club encourages families to explore together online but realizes that the opportunity for kids to use the Internet unsupervised is a reality. Parents and guardians of kids who visit this site can be assured that any personal information provided to this site will be collected and maintained in accordance with the Children's Online Privacy Protection Act ("COPPA"). This privacy policy explains how the information provided by our Guests is collected and used.

II. Information Collection and Use
Wally’s Kids’ Club sites collect the child's email address, birth date (including year), nickname, zip code and a password via the signup at the Welcome Page. Wally’s Kids’ Club uses the nickname and password created by the child to create and maintain the child user accounts. The child's email address is only used to send a newsletter that may contain special promotional offers on behalf of the restaurant sponsor. The child's birthday information is used to personalize the child's experience on the site. The Zip code information is used in aggregate to determine how many birthday coupons a restaurant location can expect to receive in any given month. A child's participation in an activity on site will not be conditioned on requiring more personal information than is necessary to participate in that activity.

Parent or Guardian Access and Consent
Each Wally’s Kids’ Club site also requires and collects a parent or guardian's email address. Upon Guest registration, the parent or guardian receives an email alerting them to their child's registration. At that time or any time thereafter, the parent or guardian may revoke the consent, refuse allowance to further pursue and collect the child's personal information and direct Wally’s Kids’ Club site to delete the information through the instructions posted at the Unenroll function of the site. The parent or guardian first must log on using the child's sign-in information and then click the Unenroll button in order to display the prompt to close the child's account and unsubscribe from receiving emails. The parent or guardian reserves the right to review the personal information collected from their child(ren) by request through the Feedback function of the site. Note: if the child's parent or guardian does not revoke consent, Wally’s Kids’ Club site com will use the child's information for the purpose described above.

Information collected upon registration by Guests under 13 years of age will be deleted when the parent or guardian advises www.wallyskidsclub.com to unenroll their child(ren). We do not transfer any personal information to any 3rd party.

Any Guest registration received with a parent or guardian's non-deliverable email address will be instantly eliminated from the site's database. For more questions on this feel free to contact:

Wally’s Kids’ Club c/o The Dussin Group
0715 S.W. Bancroft Street
Portland, Oregon 97239
Telephone: 503-225-0433
Email: info@www.wallyskidsclub.com

Email a Friend
The Email a Friend feature is a one time email that does not record or store the email entered. The Friend must enroll before any further contact from Wally’s Kids’ Club site can be initiated.

Front time to time, a contest may run on the site, in the form of a prize or vacation giveaway. Children will not be required to submit more information than necessary to participate in the sweepstakes/giveaway. Any demographic information requested is optional and does not need to be provided to participate in the contest.

Guests under 13 years of age who register in the contests will need to provide their first name and a parent or guardian's email address. If such a Guest wins, notification is sent to the parent or guardian via the parental email address gathered the time of contest registration. Publication of names, ages or images for contest winners under 13 require verifiable parental or guardian consent. All prizes and contest winnings will be sent to the parent or guardian.

III. Security
We use layered password protection to protect against loss that results in unauthorized distribution, use, or misuse, or unauthorized access, disclosure, or alteration of personal information in the possession or control of Wally’s Kids’ Club site.

IV. Cookies and IP Addresses
What are cookies? Cookies are small pieces of information that a Web site transfers to an individual's hard drive for record-keeping purposes. Wally’s Kids’ Club sites do use cookies that assist in navigation when a Guest returns to our Site. We do allow cookies from sponsors but it is not promoted nor tied to personal registration information of the user. Wally’s Kids’ Club sites do not control these cookies. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. Please review your browser's Help feature for additional information. If a user's browser is set to not accept cookies a user may experience limited site functionality.

Wally’s Kids’ Club sites use a dedicated web server that automatically tracks and collects IP addresses. This information is not used by the sites and is not stored with the personal guest information.

V. Disclosure of Information
Wally’s Kids’ Club sites collect Guest information for internal purposes only. All information collected is kept confidential and no personal information is shared with any outside party. Wally’s Kids’ Club sites only share aggregate demographic information with its restaurant client partner and all information collected on this Web site is owned by Creative Consumer Concepts (C3).

However, personal information provided to a Wally’s Kids’ Club site is subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.

Our site contains links to other sites whose information practices may be different from ours. Guests should consult the other sites' privacy notices, as the sites are not covered by our privacy policy.

VI. Changes to Privacy Policy
If any changes are made to this privacy policy regarding the use of children's personal information, parents or guardians will be notified via email. At that time, we will obtain parental consent for any new uses of children's personal information. The changes will also be posted on this Web site.

Creative Consumer Concepts is a supporter of the Children's Advertising Review Unit (CARU) Kid's Privacy Safe Harbor Program. CARU is an independent, non-profit organization whose mission is to build users' trust and confidence in the Internet by promoting the use of fair information practices. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by CARU.

If you have questions or concerns regarding this statement, you should first contact Creative Consumer Concepts by email at info@www.wallyskidsclub.com. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact CARU at http://www.caru.org/caru.aspx?id=634228897.

VIII. Contact Us
IIf you have any questions, comments or concerns regarding the Wally’s Kids’ Club site, this privacy policy, or practices please contact us at:

Wally’s Kids’ Club c/o The Dussin Group
0715 S.W. Bancroft Street
Portland, Oregon 97239
Telephone: 503-225-0433
Email: info@www.wallyskidsclub.com

This privacy statement is effective as of 4/2010.