Privacy Policy (Child)

Last Revised: July 12, 2018

Eturi Corp. (“Company”, “we”, or “us”) is committed to protecting your privacy as a child, and if your parent is reading this: the Company is committed to protecting your child’s privacy. This Children’s Privacy Policy explains to children, parents, and guardians (“Parent” or “you”) (a) how we collect, use and share personal information from users of our electronic portfolio, comprising our website, located at https://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 are identified as under the age of digital majority by law (individually, a “Child”, and collectively, “Children”), and (b) how you as a parent may limit the collection, use and sharing of your Child’s personal information.

This Children’s Privacy Policy does not apply to users of digital majority or older; such users should refer to the Company Privacy Policy available at https://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 https://ourpact.com/privacy or the Company Terms of Service available at https://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.

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. The Company is dedicated to integrating the ideals of protecting children under the European Union’s General Data Protection Regulation. Although we are not a service that sells to children, and not a service that sells your child’s data, we strive to be clear and transparent about our practices regarding children’s data. We understand that the law is still developing, and will subsequently adjust this Privacy Policy (Child).

2. Information Your Child Provides

In regards to the United States, we generally 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 dataprotection@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.

As regards the European Union, our collection of personal data from a child is limited and controlled by the parent.

3. Information Automatically Collected Via Technology

When you, the Child, or if you’re a parent reading this, 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.

Geolocation: If you are the child, your location can be tracked in real-time if your parent elects to track your location and the so-called Global Positioning System (GPS) functionality and related location services features on your device are enabled. If you are the parent, please note that you can monitor your child.

4. Use Of You Data

For you, the child, the Company gives your parents information about your device, its usage and its applications as well your location, as talked about in Section 3. For all, 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 information to: (i) operate and improve our Services, Apps and Sites; (ii) understand you and your preferences to enhance your experience and enjoyment using our Site, Apps, and Services; (iii) respond to your comments and questions and provide customer service; (iv) to send your Parent(s) related information, including in 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 personal data, we may also create anonymous and de-identified data records so that we 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 Children’s personally identifiable data.

5. Sharing Of Personal Information

If you are the child, your parents receive personal data about you, but third parties only get it in some situations we describe herein. For all: 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.

If you as a parent are a California resident, California law permits such users to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those third parties. See the “Contact Information” section for where to send such requests. We do not share personal data with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal data to third parties for their direct marketing purposes by withholding consent.

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 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 dataprotection@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 dataprotection@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 deleting the child’s profile from within their account, removing the app, unpairing/removing management and un-supervising any supervised devices. At any time, Parents may contact support for assistance in completing this process. Upon successful completion of the process described above, the Child’s data will have been deleted. Optionally, Parents may request deletion of their entire account and associated data by contacting support. 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. Your Right To Withdraw Consent To Processing

Where you as a parent have provided your consent to the processing of your personal data, for yourself and/or for your child, you may withdraw your consent at any time by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal data, in particular where (i) you contest the accuracy of your personal data; (ii) the processing is unlawful and you oppose the erasure of your personal data; (iii) we no longer need your personal data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of the Company override your own.

8. Your Choices Regarding Your Personal Data

We allow a choice of forms of communication you as the parent receive from us, how you manage your public information, and how you set your sharing preferences. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receiving promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

We also provide European Union data rights as outlined in the Company Privacy Policy available at https://ourpact.com/privacy.

9. Your Personal Data Rights

You have the following rights with respect to your personal data where and to the extent they apply to your particular processing:

  • The right to request a copy of your personal data which the Company holds about you;
  • The right to request that the Company corrects any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary for the Company to retain such data;
  • The right to withdraw your consent to the processing of your personal data at any time;
  • The right to request that the Company provide you with your personal data and where possible, to transmit that data directly to another data controller (where applicable);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; and
  • The right to lodge a complaint with a European Union Data Protection or Supervisory Authority.

10. Exercise Of Your Rights With Regard To Eturi

You may let us know of your desire to enforce any of the rights described in this Privacy Policy by sending an email to dataprotection@ourpact.com, and we will respond within 30 days. Please note that we may ask you to verify your identity before taking further action on your request. Please also note that laws and contractual frameworks limit your exercise of these data rights; we welcome you to ask us questions any time, and will answer them as described above.

11. Storage And Transfer Of Your Personal Data

The data that we collect from you will be processed and stored at a destination located in the United States.

We transfer data to destinations outside the European Union as a necessary part of the performance of the Services, or with your consent, as applicable.

12. 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.

13. Contact Information

Please contact us at the following email address for inquiries relating to our Children’s Privacy Policy: dataprotection@ourpact.com or, by mail, to: Eturi Corp., Attn: Data Protection Officer - Legal, 12255 El Camino Real STE 125, San Diego CA 92130. 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.

14. 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.

15. Complaints To Supervisory Authorities

We invite you to let us know about any and all issues regarding our data processing activities or this Privacy Policy, and we will respond to you within 30 days of receipt of such notification.

If you consider that our processing of your personal data infringes European Union data protection laws, in particular if you are an EU resident, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Ireland this is the Data Protection Commissioner.