Last Updated: August 11th, 2008
The Children’s Online Privacy Protection Act (“COPPA”) requires that we (a) inform parents and legal guardians about how we collect, use and disclose personal information from children under 13 years of age, (b) obtain the prior verifiable consent of parents and guardians in order for children under 13 years of age to use certain features of the site, (c) do not collect more information than is reasonably necessary for a child to participate in a given activity on this site and (d) provide parents with the ability to review and delete the information collected about their kids. When we discuss “kids” in this Kids Policy, we mean children under 13 years of age. When we use the term “parent” in this Kids Policy, we mean to include legal guardians.
What types of personal information do we collect from and about kids?
This Kids Policy uses the terms “personally identifiable information” and “personal information” synonymously. When we use either, we mean information that specifically identifies a particular individual, such as the individual’s first and last name, e-mail address, postal address or phone number and any demographic or other information about a user, such as gender or a user’s number of children, when such information is directly associated with personally identifiable information. Personal information does not include “aggregate” information, which is data we collect about a group or category of products, services or customers, from which individual customer identities have been removed. For example, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data.
Direct Collection: We believe that the user experience is safest for kids when they are not able to enter personal information into the Site. Kids can surf the site and view sample content, but kids are eligible to maintain only a limited access account, which does not allow any personal information to be entered into the Site. With limited access accounts, kids cannot access certain interactive features located on the Site in connection with which kids would be able provide personal information, such as chat rooms, instant messaging, e-mail, message boards or forums and other similar interactive activities (the “Interactive Activities”).
Parents should be aware that in using the Interactive Activities, kids would be able to provide written statements and descriptions that could disclose personal information or images that could reasonably be used to identify them. Parents and kids should also note that any information or other media posted to message boards or other Interactive Activities will be accessible by other users of the Interactive Activities that are allowed by the poster to access their profile and could be used to send unsolicited messages to anyone identified in such information or media. Kids should not post any personally identifiable information, including, without limitation, names, phone numbers, or email addresses, in connection with any Interactive Activities. Parents should talk to their kids about not posting personal information in connection with any Interactive Activities on the Site.
Once we know that a user attempting to register for the Service is a kid, we do not allow that kid to enter personal information, except as permitted in accordance with applicable law (for example, we may collect a kid’s name and email address to the extent reasonably necessary to protect the safety of a child participant on the Site, to protect the security or integrity of the Site, to take precautions against liability, to respond to judicial process or to provide information to law enforcement agencies or for an investigation on matters related to public safety). However, we may collect a kid’s email address to respond to certain specific requests or inquiries (such as answering a child’s question, requesting a subscription to an online newsletter or signing up for a contest), provided that in certain circumstances we may be required to notify parents that we have collected such information and give parents the opportunity to request that we make no further use of such information. Additionally, weplay may provide the “limited access account” kid with the ability to participate in any of the weplay marketing and/or promotional programs in which the data collected is used only for internal purposes (where no information is shared or publicly disclosed). This may require an email sent to parents requesting their affirmative consent.
How do we use and share the personally identifiable information that we have collected about kids?
Parents and kids should note that any information that kids post to message boards or other Interactive Activities will be accessible by other users of the Interactive Activities with whom the kids allows to access their profile and could be used to send the kid, or anyone else identified in the information posted by the kid, unsolicited messages. Kids should not post any personally identifiable information, including, without limitation, names, phone numbers, or email addresses, in connection with any Interactive Activities. Parents should talk to their children about not posting personal information in connection with their participation in Interactive Activities on the Site.
Parents have the right to consent to our collection and use of personal information from their kids without also consenting to our disclosure of such information to third parties (except for disclosures to third parties who provide support for the internal operations of the Site and who do not use or disclose that information for any other purpose). Parents will be given the opportunity to exercise this right if their kids' actions on the site trigger an email to the parents requesting any parental consent (as discussed above). Note that all sites that are directed to children under 13 are prohibited by law from conditioning a kid’s participation in an online activity on the kid’s providing more personal information than is reasonably necessary.
How do we notify and obtain consent from parents for the collection of information from their kids?
If a kid attempts to register and indicates that his or her age is under 13, the account will automatically be flagged as a limited access account that restricts access to certain weplay features, and we will ask the kid to provide us with his or her first name and a parent’s email address so that we may contact a parent to request consent in the event the kid takes any action on the Site that would require entry of personal information (as discussed above). In the event the kid takes any such action on the Site, we will then send an email to the parent’s email address containing our notice to parents of our practices regarding use, collection and disclosure of personal information about kids (the “Notice to Parents”) and requesting verifiable consent to collection of the kid’s personal information as outlined in the Notice to Parents.
We will retain the parent’s email address for a reasonable time to allow the parent to consent to collection of the kid’s personal information and to provide a means for parents to authenticate themselves if they desire access to the child’s account. If the parent does not provide consent within a reasonable time, we will delete the email address and we will not collect any personal information from the kid.
How can parents review, change or delete personal information collected from their kids?
Parents have the right to review and have deleted from our records personal information collected from their kids. Further, at any time parents may refuse to permit us to collect further personal information from their kids. To change or delete account information that we have collected from their kids, parents must contact us by sending an e-mail to firstname.lastname@example.org. Parents should please include the child’s username and their own e-mail address in the e-mail so that we can better assist with any such inquiry or request.
What kinds of security measures do we take to safeguard your personally identifiable information?
Who do guests contact with questions or concerns about our Kids Policy?
The operator of this site is weplay, Inc. If you need further assistance, please send an e-mail with your questions, comments or concerns to email@example.com or contact as at:
Weplay, Inc. 156A Reade St. New York, NY 10013
We would be happy to assist you.