Privacy Policy (Child)

Last Revised: 02/24/2017

Eturi (“Company”, “we”, or “us”) is committed to protecting your child’s privacy. This Children’s Privacy Policy explains to parents and guardians (“Parent” or “you”) (a) how we collect, use and share personal information from users of our website, located at ourpact.com (the “Site”), our mobile applications, including the applications entitled “OurPact” and “OurPact Jr." (each, an “App”), and online services (collectively, the “Services”) who identify themselves as under 13 years old (individually, a “Child”, and collectively, “Children”), and (b) how you may limit the collection, use and sharing of your Child’s personal information.

This Children’s Privacy Policy does not apply to users 13 years old or older; such users should refer to the Company Privacy Policy available at ourpact.com/privacy. This Policy does not apply to websites, applications or services that do not display or link to this statement or that display or link to different privacy statements. Unless otherwise defined in this Children’s Privacy Policy, capitalized terms will have the meanings set forth in the Company Privacy Policy available at ourpact.com/privacy or the Company Terms of Service available at ourpact.com/terms.

1. NOTE TO PARENTS AND GUARDIANS

We are required under the Children’s Online Privacy Protection Act (“COPPA”), with limited exceptions, to obtain verifiable parental consent in order to collect, use, or disclose personal information from Children. Many of our Apps and Services are intended for general audiences and do not knowingly collect any personal information from Children. When our Services request age information from your Child and your Child indicates that he/she is under 13 years old, the Services will block your child from providing personal information, except as expressly set forth herein. Please note, that if you indicate that your child is under the age of 13, your child WILL NOT be blocked from using our Services.

As required under COPPA, we allow Parents to make certain choices regarding the personal information submitted by their Children as described in Section 6 below.

2. INFORMATION YOUR CHILD PROVIDES

In general, we do not collect personal information from your Child, except in those instances under COPPA where personal information may be collected without verifiable parental consent. We do not solicit your Child to contact us or provide us with personal information. If in the event that your Child does contact customer support or another Company channel, we will only collect the data included in that communication. We may also obtain information from other sources and combine that with information we collect on our Services. Please contact us at legal@ourpact.com if you have questions about the information we collect.

We are prohibited by law from conditioning a Child’s participation in a game, the offering of a prize, or another similar activity on the Child’s disclosure of more personal information from the Child than is reasonably necessary to participate in that activity.

3. INFORMATION AUTOMATICALLY COLLECTED VIA TECHNOLOGY

When your Child uses our Services, some information is automatically collected, including but not limited to: device operating system, Internet Protocol (“IP”) address, access times, browser type and language, and device identifier numbers, and list of installed applications.

We also collect information about your Child’s usage and activity on our Sites. Additionally, if you authorize it, geolocation data may be collected, transferred, and stored as part of providing our Services. This is necessary to display your Child’s device location to you, the parent or legal guardian.

Cookies: Like many websites, our Site may automatically collect information using "cookies." Cookies are small data files stored on your Child’s computer’s hard drive by a website. Among other things, cookies help us improve our Services and your Child’s experience. We use cookies to store user session data, remember your Child’s account settings and determine if your Child’s computer system is compatible with certain technologies, such as Flash and JavaScript.

Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

4. USE OF YOUR DATA

We use personal information collected through our Site, App and Services for purposes described in this Policy or disclosed to your Child on our Site, App, or in connection with our services. For example, we may use your Child’s information to: (i) operate and improve our Services, Apps and Sites; (ii) understand you and your preferences to enhance your Child’s experience and enjoyment using our Site, Apps, and Services; (iii) respond to your Child’s comments and questions and provide customer service; (iv) to send your Child related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; and (vi) link or combine it with other personal information we get from third parties, to help understand your needs and provide you with better service.

From your Child’s personal data, we may also create anonymous and de-identified data records so that may better understand usage of our Services and improve our offering. Company reserves the right to collect, create, use and disclose anonymous and de-identified data records to third parties at its discretion.

To reiterate, we do not sell your Child’s personally identifiable data.

5. SHARING OF PERSONAL INFORMATION

We do not share your Child’s personal information with third parties other than as follows: (a) with the Child’s Parent’s consent; (b) with third party vendors, consultants and other service providers who work for us and need access to your Child’s information to do that work (“Internal Purposes”); (c) to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of Company our agents, customers, members, and others including to enforce our agreements, policies and terms of use or (iii) in an emergency to protect the personal safety of Company, its customers, or any person (collectively “i”, “ii” and “iii”, “Enforcement Purposes”); (d) in connection with or during negotiation of any merger, financing, acquisition, or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company; or (d) in the event of insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset. Any acquirer of Children’s personal information held by Company will continue to abide by this Children’s Privacy Policy.

We may also share aggregated or de-identified information in our sole discretion.

6. PARENT'S CHOICES REGARDING PERSONAL INFORMATION

We provide Parents the following choices with respect to the collection, use, retention and disclosure of personal information. A Child’s registration information is always accessible to him/her. A Parent has the right to review his/her Child’s personal information, and/or ask us to update or delete the Child’s personal information by contacting us at legal@ourpact.com. A Parent may prohibit us from sharing a Child’s personal information with a third party by requesting such prohibition by contacting us at legal@ourpact.com. Notwithstanding any such requests, we may continue to share a Child’s personal information with third parties for the Internal Purposes and Enforcement Purposes (each as described above).

If a Parent chooses to prohibit any future collection, use or disclosure of the Child’s personal information, the Parent may do so by terminating the Child’s Services account on the Website and uninstalling the App. Upon receiving such request, we will delete the Child’s account information from our live databases and all the information and data stored for such account. Company will not have any liability whatsoever for any termination of the account or related deletion of the Child’s personal information. When we delete personal information, it will be deleted from our active databases but may remain in our archives.

7. SECURITY OF YOUR PERSONAL INFORMATION

We are committed to protecting the security of your Child’s personal information. We use a variety of industry-standard security technologies and procedures to help protect your Child’s personal information from unauthorized access, use, or disclosure. While Company uses reasonable efforts to protect your Child’s personal information, no security measure is completely secure, and we cannot guarantee the security of your information.

8. CONTACT INFORMATION

Please contact us at the following email address for inquiries relating to our Children’s Privacy Policy: legal@ourpact.com. We welcome questions, concerns, or complaints about the legal document, our data collection practices, our processing practices, or security issues, including loss of the parent device.

9. CHANGES TO THIS PRIVACY POLICY

This Children’s Privacy Policy is subject to occasional revision, and if we make material changes to our collection, use, or disclosure of Children’s personal information, we will revise this Children’s Privacy Policy to reflect those changes, and request verifiable parental consent in those instances in which we are legally obligated under COPPA to do so. Thirty (30) days after such notice has been sent, we will implement the planned changes and suspend the use of any accounts for which verifiable parental consent is necessary and but not received. These changes will be effective immediately for new Child users of our Services. We may also from time to time use the e-mail address of Parents to contact Parents regarding this Children’s Privacy Policy.