CHILDREN’S PRIVACY POLICY

Last Modified:  October 18, 2016

We are committed to protecting the privacy of children who use our site and app. This Children’s Privacy Policy (“policy”) explains our information collection, use, disclosure, and parental consent practices with respect to information provided by children, and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practice regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online, please visit OnGuard Online.

  1. Information We Collect From Children, and How We Use It

  2. How and When we Communicate With Parents and Obtain Verifiable Parental Consent

  3. When Information Collected From Children Is Available To Others

  4. Parental Controls

  5. Changes to this Policy

  6. How to Contact Us

 

1.         Information We Collect From Children, and How We Use It

Our site and app are primarily targeted at children and their families and offer a variety of activities, including our Reading Racer app that may collect information from children.  Below we summarize potential instances of our collection and use of information from children.  Section 2 describes how and when we will provide parental notice and/or seek parental consent for this collection of information. 

  • Registration Information.  Children can register with our site and app to view content, play our games in practice or racer mode, and participate in contests, among other things. 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 gender, age, avatar, username.  We strongly advise children never to provide any personal information in their usernames.  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 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.

  • Collection of Parent Email Address.  Consistent with the requirements of COPPA, on our child-targeted site or app, or in any instance where we ask for age and determine the user is under age 13, we will ask for a parent or guardian email address before we collect any personal information from the child.

  • Content Generated by a Child.  Certain activities on our site and app allow children to create content, and we collect it. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to submit personal information, we will seek verifiable parental consent by email prior to the first collection and send you email verification that we received consent.  Examples of created content that may include voice recordings if a child reads text on the app, first name, last name, gender, and email address or any content a child creates in connection with a contest, sweepstakes or game of skill. 

  • Session Information.  We automatically collect session information when you play a game on the app such as the number of words you read per minute and the number of games you play.

  • Persistent Identifiers.  When children interact with us, certain information may automatically be collected, both to make our site and app more interesting and useful to children and for various purposes related to our business.  Examples include the type of computer operating system, the child’s IP address or mobile device identifier, web browser type, the frequency with which the child visits various parts of our site and app, the web pages the child reviews before or after reviewing our app or site, when the child visits our app or site, uses our app on third party platforms, or opens emails we send and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, web beacons, and other unique identifiers (which we define in the Definitions section of our general Privacy Policy ).

  • Contests and Sweepstakes.  For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.  Some contests and sweepstakes ask the child to submit their own created content along with the child’s entry.  Please see Content Generated by a Child  above for more information on our collection of this content.  In those instances, we may require parental consent prior to submission. Please see Section 2 How and When we Communicate with Parents and Obtain Verifiable Parental Consent  below for more information on our notice and consent policies.

  • 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 sites and applications;

  • customize content and improve our sites and applications;

  • conduct research and analysis to address the performance of our sites and applications; and

  • generate anonymous reporting of our use.

In any instance that we collect personal information from a child, we will retain that information only as 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.  If 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.

2.         How and When we Communicate With Parents and Obtain Verifiable Parental Consent

COPPA requires us to first seek a parent or guardian’s consent before collecting personal information from a child.  We may obtain verifiable parental consent to collect children’s personal information in several ways:

  • Email Consent.  We will send you an email in which 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, your child’s profile information and prevent further use of the game by the child or remove your child’s application to participate in a contest, sweepstakes or game of skill. 

  • High-Level Consent.  If we collect personal information from a child that will be posted publicly (including content generated by a child for games, contests of skill and sweepstakes), we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.

  • Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (“FERPA”), please visit the FERPA site.

If we collect (or allow others to collect) personal information from children on our site or app for purposes other than what is described in Section 1 (“Information We Collect From Children, and How We Use It”) , we will notify parents and obtain consent prior to such collection.

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 feel free to contact us at info@readingracer.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.

 

3.         When Information Collected From Children Is Available To Others

 

In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following: 

  • We may share information with our employees, contractors, affiliates, distributors, dealers, vendors, suppliers and service providers if necessary for them to perform a business, professional, or technology support function for us (including without limitation, sweepstakes, contests and games of skill).

  • We may transfer all information (including personal information) to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets.  Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this policy, or to a new privacy policy if you are given notice of that new privacy policy and you affirmatively opt-in to accept it.  Personal information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity. 

  • 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 the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications;

    • to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or

    • to enable us to take precautions against liability.

The following is a list of third-party operators who collect persistent identifiers on our site and app: 

  • Amazon Web Services

       410 Terry Ave. North

       Seattle, WA

       98109-5210

       Phone: (206) 266-1000

       Email: cis@amazon.com

       (You can find out more information about AWS’s privacy practices here:  https://aws.amazon.com/compliance/data-privacy-faq/.)

  • Unity [Note to Developeer:  Please insert Unity’s address, phone number and email address from your contract with them.  COPPA requires we include that here.]  You can find out more information about Unity’s privacy practices here:  https://unity3d.com/legal/privacy-policy.)

4.         Parental Choices and Controls

At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected from their children 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.

Where a child has registered for an account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:

  • Parents may delete or modify personal information from their child’s profile at any time by clicking on the settings icon. A set of options will pop up.  Next to the privacy option, there is a toggle switch which permits you to indicate whether you do or do not want your data to be collected and stored by us in the future.  If you move this switch to no, we will no longer collect your child’s personal information going forward.

  • To remove any previously stored profile information about your child, please contact us by e-mail at info@readingracer.com, or by US postal mail at Seashells Education Software, Inc., 66 Bovet Road, Suite 380, San Mateo CA 94402, and request removal of such past data. A valid request to delete personal information will be accommodated within a reasonable time. 

5.         Changes to This Policy

Because of changes in technology, industry practices, regulatory requirements and the growth and development of our business, or for other business reasons, we may need to modify this policy from time to time.  We will alert you by email if this policy is revised (if you have given us your email address), and we will post a copy of the new policy with its effective date on our site and app.  Where required by applicable law, we will obtain your consent to material changes to the policy.  It is therefore important that you register with the site or app and notify us if you change your email address.  If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes.  

6.         How to Contact Us

Please contact us at the mailing or email address below with questions about our privacy policies and collection and use practices relating to children’s information:


Seashells Education Software, Inc.

66 Bovet Road, Suite 380

San Mateo, CA 94402

info@readingracer.com

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.

 
 
 
 
 
 


U.K. Patent GB1517459.2, 2016.
U.S. Patent Pending

 

© 2016 Seashells Education 

 Privacy Policy | Children's Privacy Policy | Terms of Use

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