COPPA Privacy Policy NOTICE

Last modified: [May 2, 2022

 

CHILDREN UNDER THE AGE OF 13

The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (as used in this policy, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children", “child”). It 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 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.
  • Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through SpeakfullyNow.

This COPPA Privacy Policy (the “COPPA Policy”) only applies to children under the age of 13 and supplements our general Privacy Policy (the “General Policy”) at https://speakfully.com/privacypolicy. Only the General Policy applies to teens and adults.

Terms that are defined in the General Policy have the same meanings as used in this COPPA Policy for Children Under the Age of 13.

 

Information We Collect from Children

Children can access distinct parts of Speakfully and its content by being provided access to SpeakfullyNow through their school or school district (“Educational Institution”). Children may use many of SpeakfullyNow features, without providing us with personal information. However, some content and features may require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use SpeakfullyNow.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. 

Information We Collect Directly. The information we collect directly is information the Educational Institution has requested us to collect, which may include email address, content of form fields, and other information that will personally identify the child or can otherwise be linked to the child. We also require the child to create a password to be provided a key code to access information they have provided through posting or transmitting content (including any text, graphic, audio, video, or other content) through SpeakfullyNow. We may request additional information from your child, but this information is optional and at the discretion of the associated Educational Institution. We specify whether information is required or optional when requested.

Automatic Information Collection and Tracking. We may use technology to automatically collect information from our users, including children, when they access and navigate through SpeakfullyNow and use certain features. The information we collect through these technologies may include:

  • IP address.
  • One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
  • Information that identifies a device's location (geolocation information).

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the "What Information Do We Collect" [add URL to specific Privacy Policy section and delete brackets and this text] and " How Do We Use the Information" [add URL to specific Privacy Policy section and delete brackets and this text] sections of our General Policy.

How We Use Your Child's Information

We use the personal information we may collect from your child to:

  • Allow him or her to use SpeakfullyNow to report any issues or concerns to the associated Educational Institution.
  • Communicate with him or her about reports they have submitted through SpeakfullyNow.
  • Make certain metrics and other information regarding the child’s use of and access to SpeakfullyNow available to the associated Educational Institution.

We use the information we collect automatically through technology (see the "What Information Do We Collect" section of our General Policy) and other non-personal information we collect to improve SpeakfullyNow and to deliver a better and more personalized experience by enabling us 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.
  • Speed up searches.

 

Our Practices for Disclosing Children's Information

We do not share, sell, rent, or transfer children's personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children's personal information:

  • To third parties we use to support our internal operations, who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
  • If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or that of our customers, or others, including:
  • protecting the safety of a child,
  • protecting our safety and security,
  • enabling us to take precautions against liability, and
  • disclosing to law enforcement agencies or for an investigation related to public safety.

In addition, if we are involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our 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.

 

Accessing and Correcting Your Child's Personal Information

At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information.

You can review, change, or delete your child's personal information by:

  • Sending us an email at support@speakfully.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

A list of all operators that may collect or maintain personal information from children through SpeakfullyNow is available upon request.

Please direct your inquiries about any operator's privacy practices and use of children's information to the operator at its contact information provided.