How is children’s personal information treated?
If you are a minor (under the age of 18), you may not disclose Personal Information to us. Company only collects limited Personal Information about students (“Children’s Personal Information”) directly from the parent or guardian who has registered on our site and paid for the Services. If you are below the age of eighteen (18), please do not send any Children’s Personal Information about yourself to us, other than what we request from your parent or guardian who registers for the Services. In the event that we learn that we have collected Children’s Personal Information directly from a student, we will delete that information as quickly as possible. If you believe that a student may have provided us Children’s Personal Information without parental involvement, please contact us at compliance@Mindletica.com. Hereinafter, references to “Personal Information” shall apply to personal information of individual Website users who are not student registrants. References to “Children’s Personal Information” shall only apply to personal information of student users of the Website. General references to “information” shall apply to all users. Notwithstanding anything to the contrary, if you are a minor and your parent has signed up for the Website, you understand that your parent can view all information within or associated with the account, including without limitation progress reports and usage data that tracks your performance on games, assessments and other tests available through the Services.
What Personal Information Does Company Collect?
The information we gather from customers enables us to personalize and improve our services. We collect the following types of information from our customers:
Information You Provide to Us:
We receive and store any information you enter on our Website or provide to us in any other way. The types of Personal Information collected include your full name, email address, ZIP code, credit card and/or other payment information, Children’s Personal Information (child’s name, gender, birth date, age, ethnicity, grade, school, email address, cell phone number, upcoming tests, answers to questions), IP address, browser and location information, username, password and any other information necessary for us to provide our services. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features. The Personal Information you provide is used for such purposes as answering questions, sending product updates, and communicating with you about Company’s products and services, including specials and new features. The Children’s Personal Information you provide shall only be used for creating your individual account (which will allow you to receive progress reports that include tracking your child’s performance and progress). You may modify or remove your Personal Information or Children’s Personal Information identified below at any time by logging into your account and accessing features to edit your profile and/or account information.
Children can, in many cases, register with our sites and applications to sign up, view content, play games, participate in contests, and engage in special features, among other things. 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, the child’s first and last name, date of birth, ethnicity, school, gender, email, cell phone, the child’s member or account username, and password. 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.
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 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 firstname.lastname@example.org 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.
Personal Information Collected Automatically:
We receive and store certain types of information whenever you interact with our Website or use our services. Company automatically receives and records information on our server logs from your browser including your IP address, cookie information, and the page you requested. Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our Website and its components, similar to TV ratings that indicate how many people watched a particular show. Company only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Website or services so that we can make the Website appealing to as many customers as possible, and improve those services. As part of this use of information, we may provide aggregate information to our partners about how our customers, collectively, use our Website or services. We share this type of statistical data so that our partners also understand how often people use the Website or services, so that they, too, may provide you with an optimal online experience. Again, Company does not disclose aggregate information to a partner in a manner that would identify you personally.
We often receive a confirmation when you open an email from Company if your computer supports this type of program. Company uses this confirmation to help us make emails more interesting and helpful. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. When you receive e-mail from Company, you can opt out of receiving further e-mails by following the included instructions to unsubscribe.
We send questions to your child each day, reminders to them for completing tasks, reminders for appointments they book, and messages related to their performance and learning. We may also send students, parents and teachers practices reminders through our texting service. You can opt-out from these notifications or modify the frequency of these notifications at any time through the app or device settings.
Content Generated by a Child
Certain activities on our sites and applications allow children to create or manipulate content and save it with Mindletica. 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 insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, Mindletica also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
About Verifiable Parental Consent:
Email Consent. In the event 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 Mindletica 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.
Certain activities that are directed to children allow users to communicate directly with other users by means of a chat system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
Where Mindletica employs a chat system that does not filter all or nearly all personal information, we will first seek high-level consent from the parent.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission. Please see Content Generated by a Child above for more information on our collection, notice, and consent policies.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, Mindletica may need to ask for the child’s online contact information, such as an email address. Mindletica will delete this 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. One example would be a newsletter that provides occasional updates about a site, game/activity, television show, personality/character, or feature movie. 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.
What About Cookies?
Will Company Share Any of the Personal Information it Receives?
Your Personal Information and Children’s Personal Information is an integral part of our business. We neither rent nor sell your Personal Information or Children’s Personal Information to anyone. We share your Personal Information and Children’s only as described below. As explained below, we only share Children’s Personal Information associated with your account directly with you to report on your child’s performance using our Services. We never share that Children’s Personal Information with any third party. A child’s usage data (i.e. performance on tests, games, etc. available on the Services) is shared through aggregated, anonymous comparisons, but never in a way that could personally identify the child. In addition, we do not offer students chat rooms or community features that allow the sharing or posting of Children’s Personal Information in a public forum.
Again, please note that references to “Personal Information” only apply to personal information of individuals who are not students. Affiliated Businesses We Do Not Control: We anticipate that we may become affiliated with a variety of businesses and work closely with them. In certain situations, these businesses may sell items to you through the Website. In other situations, Company may provide services, or sell products jointly with affiliated businesses. These transactions or services may or may not be commercial in nature; we will not share your Children’s Personal Information in connection with any commercial third party transaction or service. You can easily recognize when an affiliated business is associated with your transaction, and we will share your Personal Information that is related to such transactions with that affiliated business.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Examples include sending email, analyzing data, and providing user services. Unless we tell you differently, Company’s agents do not have any right to use Personal Information or Children’s Personal Information we share with them beyond what is necessary to assist us. We will also require that these agents agree to protect the security of the information we share with them. You hereby consent to our sharing of Personal Information and Children’s Personal Information for the above purposes.
User profiles: User profile information including your user name, email address, and other information you enter (“User Submissions”) may be displayed to other users to facilitate user interaction within the Website. Minors are not allowed to enter or upload User Submissions. If the registration process is completed correctly, no Children’s Personal Information will ever be displayed to any third party through a User Profile. Email addresses are used to add new User Submissions to user profiles and to communicate through User Submissions. Users’ email addresses will not be directly revealed to other users by Company, except, when the user is “connected” to another user via a shared group membership, or an invitation, or if the user has chosen to include their email address in their User Profile.
Communication about the Website or in response to User Submissions: As part of the Website and services, you will receive from Company email and other communication relating to your child’s progress and use of the Services or User Submissions. You acknowledge and agree that by allowing your child to use the Website and Services, and by posting such User Submissions, Company may send you email and other communication that it determines in its sole discretion relate to such activity and your User Submissions.
Promotional Offers: We may send offers to you on behalf of other businesses. However, when we do so, we do not give the other business your name and address. If you do not wish to receive these offers, please send an email with your request to help@Mindletica.com.
Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if Company, or substantially all of its assets were acquired, or in the unlikely event that Company goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Company may continue to use your Personal Information and Children’s Personal Information as set forth in this policy.
Protection of Company and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
Is Personal Information About me Secure?
What Personal Information Can I Access?
Company allows you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list will change as the Website changes.
- Name and grade of the child
- User’s email address
- Username and password
- User preferences
- Usage Analytics (i.e. progress reports) of the child
What Choices Do I Have?
Questions or Concerns
If you have any questions or concerns regarding privacy on our Website, please send us a detailed message at compliance@Mindletica.com. We will make every effort to resolve your concerns.
Effective Date: September 9, 2016
2030 N. Sedgwick, Unit E