Children’s Online Privacy Protection Act (COPPA) Policy

Wearsafe Children’s Online Privacy Protection Act (COPPA) Policy
Effective Date: June 1, 2016

Wearsafe Labs LLC (“Wearsafe”, “we” or “us”), recognizes the importance of the privacy of children and of all of its users. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information about how we collect, use, and disclose the personal information we collect from children under thirteen years old as part of our Service.  Parents may register for our Services on behalf of themselves and their children, and configure the Services for the safety of their children, via their children’s mobile devices.

This Policy applies to the personal information we collect from children via the Wearsafe mobile applications (Apps) and services (collective, the “Services”). Wearsafe will handle children’s personal information as described in this COPPA Policy. Any personal information we collect about other users (e.g., parents and website visitors) will be treated in accordance with the Wearsafe Privacy Policy (“Privacy Policy”). The use of our Services and any dispute over privacy, is subject to this COPPA Policy, the Privacy Policy, and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this COPPA Policy.

Who is the Operator of Wearsafe?
What Information Do We Collect About Children and Why?
As described in further detail below, we collect personal information from children to help parents manage their family’s safety.
 
How Information is Collected. We may collect information about children directly from children or parents, as well as automatically through a child’s use of our Services. We will not require a child to disclose more information than is reasonably necessary to use our services.
 
Information We Collect Directly. We collect the following child’s information during the registration process and during use of the Services: first and last name, birth date, email address (which must be a functioning email address), password, mobile phone number, a photograph that may appear as the child’s profile picture, the child’s physical information, including gender, height, weight, hair color, eye color and personal relationships, medical conditions, and audio, image and video recordings.
 
Information We Collect Automatically. We collect geolocation information from the child’s mobile device while the Services are active.   We may also automatically collect the following information through cookies and other technologies including: domain name; browser type, and operating system type, name and model; page or screen views; links clicked; IP address; the length of time our Services are used; device name and model; and version.
 
Other Information We Collect About Children. We collect information about children’s activities on our Site and in our Apps, such as which mobile applications they use and when they use them. We do not share this information with third parties, other than our service providers. Before we analyze or use any activity data for commercial purposes, we will de-identify and/or aggregate such information.
 

How We Use Children’s Information

We use personal information collected from children for the following purposes:

  • To register and service their account;
  • To administer and improve the Service;
  • To resolve disputes and troubleshoot problems;
  • To prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our terms;
  • To compare information for accuracy, and verify it with third parties;
  • For our internal business purposes;
  • To contact you to respond to your questions or requests or to provide you with technical support;
  • To provide parents and their children with information regarding changes to the Service which may affect their account, their use of the Service, and/or the products and services available through the Service;
  • To customize the user experience of the Service;
  • To analyze trends, track user movement and gather statistical information for aggregate use; and
  • To promote the Service or customize advertising that may be visible in connection with the Service.

Aggregate or De-Identified Information. We may use aggregate or de-identified information about children for research, analysis, marketing and other commercial purposes. If we do so, we will remove names, contact information, and other personal identifiers.

How We Disclose Children’s Information to Others
We will not rent or sell any personal information about children to third parties outside of Wearsafe and its subsidiaries and affiliates without the parent’s consent, except as noted below.

In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect Wearsafe and other users of our Services.  Please view our Privacy Policy for a more complete list.  For example, we may share children’s personal information as follows:

  • Parents. We may disclose a child’s information to his/her parents or legal guardians.
  • Affiliates. We may disclose information we collect about a child to our affiliates or subsidiaries for research, marketing or other commercial purposes consistent with this COPPA Policy.
  • Service Providers. We may disclose information we collect about a child to service providers, contractors, agents or other entities who perform business functions on our behalf.
  • Business Transfers. We may transfer information we collect about a child to another entity if we are acquired by or merged with another company, if substantially all of our assets are transferred to another company or as part of a bankruptcy proceeding.
  • In Response to Legal Process. We may disclose information we collect about a child in order to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We also may disclose information we collect about a child where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this COPPA Policy or as evidence in litigation in which we are involved.
Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information
Parents and legal guardians have a right to review the information we have collected about their children, respectively, and to delete it, and to tell us to stop using it.  To exercise these rights, you may contact us at [email protected]. You will be required to authenticate yourself as the child’s parent or guardian to receive information about that child. Please note that copies of information may remain temporarily in cached or archived form on our systems after you request us to delete it.
Changes to this COPPA Policy
This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our web site and in our Apps. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our web site and in our Apps.