Last Revised: June 26, 2019
1. Note To Parents And Guardians
We are required under the Children’s Online Privacy Protection Act (“COPPA”), with limited exceptions, to obtain verifiable parental consent in order to collect, use, or disclose personal information from Children. Many of our Apps and Services are intended for general audiences and do not knowingly collect any personal information from Children.
2. Information Your Child Provides
In regards to the United States, we generally do not collect personal information from your Child, except in those instances under COPPA where personal information may be collected without verifiable parental consent. We do not solicit your Child to contact us or provide us with personal information. If in the event that your Child does contact customer support or another Company channel, we will only collect the data included in that communication. We may also obtain information from other sources and combine that with information we collect on our Services. Please contact us at email@example.com if you have questions about the information we collect. We are prohibited by law from conditioning a Child’s participation in a game, the offering of a prize, or another similar activity on the Child’s disclosure of more personal information from the Child than is reasonably necessary to participate in that activity.
As regards the European Union, our collection of personal data from a child is limited and controlled by the parent.
3. Information Automatically Collected Via Technology
When you, the Child, or if you’re a parent reading this, your Child uses our Services, some information is automatically collected, including but not limited to: device operating system, Internet Protocol (“IP”) address, access times, browser type and language, and device identifier numbers, and list of installed applications.
We also collect information about your Child’s usage and activity on our Sites. Additionally, if you authorize it, geolocation data may be collected, transferred, and stored as part of providing our Services. This is necessary to display your Child’s device location to you, the parent or legal guardian.
Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
Geolocation: If you are the child, your location can be tracked in real-time if your parent elects to track your location and the so-called Global Positioning System (GPS) functionality and related location services features on your device are enabled. If you are the parent, please note that you can monitor your child.
4. Use Of You Data
For you, the child, the Company gives your parents information about your device, its usage and its applications as well your location, as talked about in Section 3. For all, we use personal information collected through our Site, App and Services for purposes described in this Policy or disclosed to your Child on our Site, App, or in connection with our services. For example, we may use your information to: (i) operate and improve our Services, Apps and Sites; (ii) understand you and your preferences to enhance your experience and enjoyment using our Site, Apps, and Services; (iii) respond to your comments and questions and provide customer service; (iv) to send your Parent(s) related information, including in confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; and (vi) link or combine it with other personal information we get from third parties, to help understand your needs and provide you with better service.
From your personal data, we may also create anonymous and de-identified data records so that we may better understand usage of our Services and improve our offering. Company reserves the right to collect, create, use and disclose anonymous and de-identified data records to third parties at its discretion. To reiterate, we do not sell Children’s personally identifiable data.
5. Sharing Of Personal Information
We may also share aggregated or de-identified information in our sole discretion.
If you as a parent are a California resident, California law permits such users to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those third parties. See the “Contact Information” section for where to send such requests. We do not share personal data with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal data to third parties for their direct marketing purposes by withholding consent.
6. Parent’s Choices Regarding Personal Information
We provide Parents the following choices with respect to the collection, use, retention and disclosure of personal information. A Parent has the right to review his/her Child’s personal information, and/or ask us to update or delete the Child’s personal information by contacting us at firstname.lastname@example.org. A Parent may prohibit us from sharing a Child’s personal information with a third party by requesting such prohibition by contacting us at email@example.com. Notwithstanding any such requests, we may continue to share a Child’s personal information with third parties for the Internal Purposes and Enforcement Purposes (each as described above).
If a Parent chooses to prohibit any future collection, use or disclosure of the Child’s personal information, the Parent may do so by deleting the child’s profile from within their account, removing the app, unpairing/removing management and un-supervising any supervised devices. At any time, Parents may contact support for assistance in completing this process. Upon successful completion of the process described above, the Child’s data will have been deleted. Optionally, Parents may request deletion of their entire account and associated data by contacting support. Company will not have any liability whatsoever for any termination of the account or related deletion of the Child’s personal information. When we delete personal information, it will be deleted from our active databases but may remain in our archives.
7. Your Right To Withdraw Consent To Processing
Where you as a parent have provided your consent to the processing of your personal data, for yourself and/or for your child, you may withdraw your consent at any time by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal data, in particular where (i) you contest the accuracy of your personal data; (ii) the processing is unlawful and you oppose the erasure of your personal data; (iii) we no longer need your personal data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of the Company override your own.
8. Your Choices Regarding Your Personal Data
We allow a choice of forms of communication you as the parent receive from us, how you manage your public information, and how you set your sharing preferences. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receiving promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
9. Your Personal Data Rights
You have the following rights with respect to your personal data where and to the extent they apply to your particular processing:
- The right to request a copy of your personal data which the Company holds about you;
- The right to request that the Company corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for the Company to retain such data;
- The right to withdraw your consent to the processing of your personal data at any time;
- The right to request that the Company provide you with your personal data and where possible, to transmit that data directly to another data controller (where applicable);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; and
- The right to lodge a complaint with a European Union Data Protection or Supervisory Authority.
10. Exercise Of Your Rights With Regard To Eturi
11. Storage, Retention And Transfer Of Your Personal Data
The data that we collect from you will be processed and stored at a destination located in the United States.
We transfer data to destinations outside the European Union as a necessary part of the performance of the Services, or with your consent, as applicable.
12. Security Of Your Personal Information
We are committed to protecting the security of your Child’s personal information. We use a variety of industry-standard security technologies and procedures to help protect your Child’s personal information from unauthorized access, use, or disclosure. While Company uses reasonable efforts to protect your Child’s personal information, no security measure is completely secure, and we cannot guarantee the security of your information.
13. Contact Information
15. Complaints To Supervisory Authorities
If you consider that our processing of your personal data infringes European Union data protection laws, in particular if you are an EU resident, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Ireland this is the Data Protection Commissioner.