COPPA PRIVACY POLICY
Draw It With Me (“DIWM”) takes the privacy of children seriously. The following Children’s Online Privacy Policy sets forth our information collection, disclosure, and parental consent processes with respect to the collection of information of children 12 years old or younger (“child” or “children”), and may use terms defined in our general [Privacy Policy]. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”).
What Information Do We Collect From Children?
Login and Account Registration.
If a login is required, during the login registration process, we may collect the following information, including (i) a parent or legal guardian’s name and email address, (ii) the child’s name, age, email address, mailing address, phone number, (iii) title and description of the child’s Submitted Content (defined below) and (iv) the child’s Submitted Content. We will not require a child to provide more information than is reasonably necessary in order to participate in an activity on the Sites. If a child registers an account on the Sites, DIWM will seek verifiable parental consent prior to authorizing the account and allowing the child to use the account when using the Sites.How We Use This Information:
This information is used only internally to:
• Maintain or analyze the functioning of the Sites or Services;
• Ensure legal or regulatory compliance;
• Respond to inquiries;
• Provide the Services requested; and
• Setup and administer an account
• DIWM Marketing/Promotional purposes
Child-Provided Content.
Certain parts of the DIWM Sites allow children to provide content, including, but not limited to, videos, drawings, stories, open-text fields, amount other related content (the “Submitted Content”). 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 provide personal information in his/her created content, we either pre-screen to delete any personal information, or we seek verifiable parental consent for the collection. Once that consent is obtained, we will require that the child create a login. If Submitted Content includes personal information and DIWM wishes to post the content publicly, we will obtain parental consent before doing so.
Contests
For contests, DIWM typically only requires the information necessary for a child to participate in a particular contest. Prior to allowing (i) a child to enter a contest and (ii) submit the Submitted Content, DIWM requires verifiable parental consent. Once that consent is obtained, we will require that the child create a login.Continuous Communications with a Child.
In connections with certain activities or services, DIWM may collect a child’s online contact information, such as email address, to communicate with the child more than once. In such instances, DIWM retains the child’s online contact information to honor the request and for marketing purposes. Whenever DIWM collects a child’s online contact information for continuous communication, DIWM simultaneously requires 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.One-Time Communications with a Child.
If DIWM responds to a question or request from a child, DIWM may need to inquire and ask for the child’s online contact information, such as an email address. DIWM will then delete this information immediately after responding to the question or request.Information We Collect Automatically.
If a child visits the Sites to browse, read, or download information, the child’s web browser may automatically send us information including one or more of the following:
• The Internet domain through which the child accessed the internet;
• Internet protocol (IP) address of the computer the child is using;
• Type of browser software operating system the child is using and browser language;
• The date and time the child accessed the Website and/or the Sites;
• The internet address of the site from which the child linked the Website or Sites;
• Information about the child’s location and mobile device, including a unique identifier for the mobile device.
How We Use This Information:
This information is used only internally to:
• Maintain or analyze the functioning of the Sites or Services;
• Perform network communications;
• Protect the security or integrity of the user, Sites or Services;
• Ensure legal or regulatory compliance;
• Respond to inquiries;
• Provide the Services requested; and
• Setup and administer an account
• In the event we collect (or allow others to collect) such information from children on the DIWM Sites for other purposes, we will notify parents and obtain verifiable parental consent.
Please see below for a list of third-party processors who collect the above listed unique identifiers:
Google Analytics
Square, Inc.
Bluehost
When Is Information Collected From Children Publicly Available?
On those occasions where a child’s personal information is posted publicly, DIWM will only do so after receiving verifiable parental consent. Additionally, DIWM may share or disclose personal information collected from children in a limited number of instances, including the following:
• DIWM may share information with service providers in necessary to perform a professional, business, or technology support function for DIWM.
• DIWM may disclose personal information if permitted or required by law, such as, in response to a court order or a subpoena.
To the extent permitted by applicable law, DIWM also may disclose personal information collected from children under the following circumstances:
• If DIWM believes disclosure may prevent crime, facilitate an investigation or related to public safety or protect the safety of a child using our sites or applications;
• In response to a law enforcement or public agency’s (including schools or children services) request;
• To protect the security or integrity of the Sites, applications, and other technology, as well as the technology of DIWM’s service providers; or Enables DIWM to take precautions against liability.
How Do We Obtain Verifiable Parental Consent?
Digital Consent.
Consistent with the requirements of COPPA, we will ask for digital signature of a parent or legal guardian before we collect any personal information from a child. In the digital form 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 delete the parent contact information and any other information collected from the child in connection with that activity.
If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT provided your consent, please contact us at diwminfo@gmail.com. We will not use parent emails provided for parental consent for marketing purposes, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
In the event DIWM collects personal information from a child that is posted publicly, DIWM will seek verifiable parental consent prior to doing so. This includes but is 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 digital consent form via our website.
Teacher Consent in Lieu of a Parent.
With regard to school-based activities, COPPA allows teachers and school administrators to act instead of parents to provide consent for the collection of personal information from children. Schools should 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.Parental Choices and Controls
At any time, parents can refuse DIWM from collecting further personal information from their children in association with a particular account, and can request that DIWM delete from our records the personal information DIWM collected in connection with that account.A request to delete records may lead to a termination of an account or Services provided by DIWM.
In any correspondence such as email or mail, please always include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, DIWM takes reasonable steps to help verify a parent’s identity before granting access to any personal information.
How to Contact Us:
Please contact us at the mailing address or email below with any inquiries related to this Children’s Online Privacy Policy, the [Privacy Policy] or DIWM’s [Terms and Conditions]:
Draw It With Me, LLC
1934 Fielding Hill Lane
Draper, UT 84020
diwminfo@gmail.com