The Foundation develops and makes available certain online educational resources through its Website that are directed to students, which may include children (the “Services”). We may partner with foundations, non-profits, or for-profit entities to make these resources available. In the course of providing these Services, we may come into contact with information, including Personal Information, from children.
COPPA requires us to inform parents and legal guardians (collectively, “parents”) about our practices for collecting, using, and disclosing Personal Information from children. COPPA also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s Personal Information. This COPPA Policy notifies parents of the types of information we may collect from children, how we use the information we collect, our practices for disclosing that information, and our practices for notifying and obtaining parents’ consent when we collect Personal Information from children, including how a parent may revoke consent.
- Information We Collect
During the registration process on the Website and any related platforms, we may ask children to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s name, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any Personal Information in their usernames. Children must create their own usernames, but are not required to provide an email. We will use usernames and email addresses (if provided) to track children’s attendance and progress in our courses. We also collect information pertaining to the type of operating system that a child uses.
We enable [registered] users to communicate with others on or through the Website through chat, email, mobile application, and posting to public areas of the Website (“Social Features“). The nature of these Social Features, which allow users to post their own content, means that children could post Personal Information about themselves. Since we do not monitor or review this content before it is posted, we cannot prevent this from happening. We also cannot control the actions of third parties who use our Website and might see this Personal Information. We therefore strongly encourage parents to educate their children about safe internet use and to monitor their children’s use of Social Features.]
3. How We Use and Share Your Child’s Information
We use Personal Information collected from children to:
- provide our Services; and
- track progress and participation in our programs and related initiatives.
We may use the information we collect automatically through technology to:
- Estimate our audience size and usage patterns;
- Store information about the child’s preferences, allowing us to customize the content according to individual interests; and
- Speed up a user’s searches.
We do not sell, rent, or transfer children’s Personal Information other than as described in this COPPA Policy. We may disclose the Personal Information that we collect about children to provide our Services, to third parties we use to support the internal operations of our Website (provided that such third parties are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential), to comply with the law, and to protect the Foundation and other users of our Services.
If the Foundation is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Foundation’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the Personal Information we have collected or maintain to the buyer or other successor.
- Verifiable Parental Consent
In the event the Foundation asks a child for their Personal Information, COPPA requires that we first seek a parent’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.
- 5. Parents’ Rights to Access, Correct, Delete, and Control Our Use of Children’s Personal Information
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 correct or 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. To exercise these rights, you may contact us in accordance with the information provided in Section 8 of this COPPA Policy. You will be required, and we may take reasonable steps, to authenticate yourself as the child’s parent to receive information about that child. In any correspondence, please include the child’s username and the parent’s email address and telephone number. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.
6. Operators That Collect or Maintain Information from Children
The following are all the operators that may collect or maintain Personal Information from children through the Website:
Please direct inquiries about such third-party operators’ privacy practices and use of children’s information to such individual operators.
- 7. Changes to This COPPA Policy
This COPPA Policy is current and effective as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Website. If we make any changes to this COPPA Policy that materially affect our practices with regard to the Personal Information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website.
- Contact Information
To make an inquiry regarding this COPPA Policy or our privacy practices related to children, please contact us at: firstname.lastname@example.org or via our toll-free number: 212-767-1200.