THE INFORMATION WE COLLECT FROM CHILDREN, HOW WE — USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
UFE offers to its end-users a range of sites and applications, some of which are primarily targeted at children, and others that are intended for end-users of all ages and their families. Our sites and applications offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance in which we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or service or allow the child to continue to participate in the activity or service, and ensure the security of our end-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 parental consent for that collection.
Children can, in many cases, register with our sites and applications. 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 and mobile phone number, the child’s first name and gender, the child’s mobile phone number and passcode, and date of birth to validate age. 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 or service.
ABOUT THE COLLECTION OF PARENT EMAIL ADDRESS
Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the end-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 feel free to contact us at Privacy@Ulzi.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.
CONTENT GENERATED BY A CHILD
Certain activities on our sites and applications allow anonymous individuals to create or manipulate content and save it with UFE and therefore may not result in notice to the parent or require parental consent. If we become aware that an anonymous activity has resulted in a child providing personal information in such content, we will edit the submission to delete any personal information.
ABOUT VERIFIABLE PARENTAL CONSENT
Email Consent. In the event UFE wishes to collect 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.
High-Level Consent. In the event UFE collects personal information from a child that will be posted publicly, 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.
Where UFE employs a chat system, we will first seek high-level consent from the parent.
EMAIL CONTACT WITH A CHILD
On occasion, in order to respond to a question or request from a child, UFE may need to ask for additional online contact information for the child. UFE will delete this additional 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. 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 applications, and which can communicate to the device holder even when the application 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 applications 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.
If a child-directed UFE site or application collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
provide access to features and services 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
generate anonymous reporting for use by UFE
In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.
We do not allow third-party operators to collect persistent identifiers on our sites and applications.
Please contact us at the mailing or email address below with questions about the operators’ privacy policies and collection and use practices:
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 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 (i) in response to a law enforcement or public agency’s (including schools or child services) request; (ii) 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; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
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 in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account or other service.
Where a child has registered for an Ulzi.com 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 can view or change their child’s personal information (except the child’s mobile phone number) provided during the registration process by accessing the child’s account. Parents will need their child’s passcode; the login page explains how to recover a lost or unavailable passcode.
Parents can contact Ulzi to request access to, change, or delete (including the child’s mobile phone number) any of their child’s personal information provided during registration or subsequently collected by sending an email to us at Privacy@Ulzi.com. A valid request to delete personal information will be accommodated within a reasonable time.
In any correspondence such as e-mail or mail, please include the child’s mobile phone number and the parent’s email address. 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.