The Information We Collect From Children and How We Use It
We offer our users a range of online services, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our online services offer a variety of activities, including activities that may collect information from children. In any instance where we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Children can, in many cases, register with our online services to view content, play games and engage in special features. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. We may also collect information about the health, activity and habits of children as part of the service. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features of our online services if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity selected by the child.
Certain activities that are directed to children allow users to communicate directly with other users by means of a chat system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and online services never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
On occasion, in order to respond to a question or request from a child, we may need to ask for the child’s online contact information, such as an email address. We will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about an activity. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
Push notifications are notifications on mobile and other devices that are typically associated with downloaded online services, and which can communicate to the device holder even when the online service is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed online services that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
We will first seek parental consent via email before collecting any geolocation information that is specific enough to equate to the collection of a street address.
When children interact with us, certain information may automatically be collected, both to make our online services more interesting and useful to children and for various purposes related to our business. Examples of these “persistent indentifiers” include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our online services, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by us or by a third party. This data is principally used for internal purposes only, in order to:
- provide children with access to features and activities on our online services
- customize content and improve our online services
- conduct research and analysis to address the performance of our online services
- generate anonymous reporting for our use
In the event we collect (or allow others to collect) such information from children through our online services for other purposes, we will notify parents and obtain consent prior to such collection.
The following third-party operators collect persistent identifiers through our online services: Google Analytics.
When Information Collected From Children Is Available To Others
We may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena.
- To the extent permitted by applicable law, we also may disclose personal information collected from children:
- in response to a law enforcement or public agency’s (including schools or children services) request
- if we believe disclosure may prevent a crime, facilitate an investigation related to public safety or protect the safety of a child using our online services
- to protect the security or integrity of our online services and other technology, as well as the technology of our service providers
- to enable us to take precautions against liability
We may share personal information collected from children through our online services with educational and research third-parties.
Parental Rights and Controls
Before we collect any personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email, we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
Consistent with the requirements of COPPA, on any child-targeted online service, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please contact us at email@example.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
At any time, the parent or guardian of a child with an account for our online services can:
- review the personal information we have collected in connection with that account
- refuse to permit us to collect further personal information from their child in association with a particular account
- agree to the collection and use of their child’s information, but still not allow disclosure to third parties unless that is part of the service (for example, social networking)
- direct us to delete from our records the personal information we have collected in connection with that account
Please keep in mind that a request to delete records may lead to a termination of an account, membership or other service.
In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
A parent or guardian of a child who uses our online services can contact us about their child’s use of the services as follows:
11325 Random Hills Road, Suite 450
Fairfax VA 22030