Effective Date: 1/12/2018
As we strive to adhere to the laws that protect children online, we would like to direct you to the Federal Trade Commission to further educate parents, guardians, and educators on how to teach children safe online practices, please watch the following videos:
For continued knowledge on protecting children online, please view the resources and other information by visiting: https://www.consumer.ftc.gov/topics/protecting-kids-online.
Section I. Collection and Usage of Information from Children and Communication with Parents
Tivoyage may make available to its users an assortment of services, some of which are primarily targeted at children and others intended for a mixed audience of users over and under the age of 13. Our Services may offer a range of activities, including activities that may collect information from children. This policy details the instances when we may collect information and how and when we will provide parental notice and/or seek parental consent. Please note if there is a need for us to collect personal information from a child, we will keep that information only so long as it is warranted and necessary to fulfill an activity request or allow the child to continue to participate in an activity, as required by law, or to ensure the security of our users and our Services. If we discover we have collected information from a child in a manner not permitted by COPPA, we will either discard the information or promptly seek the parent’s consent for that collected information.
Children may have the option to sign up for an account in our Services, take part in games, partake in contests, and participate in special features, in addition to other things. Amid the sign-up process, we may request the child to give certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. Additionally, we may request birth dates from children to prove their ages. We unequivocally encourage children never to give any personal information in their usernames. Please note that children can decide whether to impart their information to us; however, certain features can’t work without it. Subsequently, children will most likely be unable to get certain features if required information has not been given. We will not require a child to give more information than is sensibly vital in order to take part in an online activity.
Parents’ Email Addresses
In compliance with COPPA, on any child-targeted Services or in any occasion where we request age and decide the child is age 12 or under, we will request a parent or guardian's email address before we collect any personal information from the child. If you believe your child is taking part in an activity on our Site that gathers personal information and you or another parent/guardian have NOT been sent an email giving notice or requesting your consent, please do not hesitate to reach us at email@example.com. We will not utilize parents’ email addresses given for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has independently taken part in an activity that allows for such email contact.
Content Generated by a Child
Certain activities on our Services may enable children to make or manipulate content and save it with Tivoyage. Some of these activities do not expect children to give any personal information and along these lines may not bring about a notice to the parent or require parental consent. If an activity potentially enables a child to embed personal information in their created content, we will either pre-screen the submission to discard any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may incorporate personal information are stories or other open-text fields and drawings that allow text or free-hand entry of information. In the potential likelihood, Tivoyage may plan to post the content publicly or share it with a third party for the third party’s own particular use, we will obtain a detailed level of parental consent as explained below.
Verifiable Parental Consent
Email Consent: If the occasion arises and Tivoyage wishes to gather personal information from a child, COPPA requires that we first ask for a parent or guardian’s consent by email. In the email we will clarify what information we are gathering, how we intend to utilize it, how the parent can give consent, and how the parent can rescind consent. If we do not gain parental consent within a practical time, we will discard the parent contact information and any other information gathered from the child in connection with that particular activity.
Detailed Level Consent: If the occasion arises for Tivoyage to collect personal information from a child that will be posted publicly, we will ask for a more detailed level of consent. Such “detailed” level of consent will be a signed consent form by way of an email attachment. After providing a more detailed level of consent, a parent may choose to utilize a password in future exchanges on the Services as a means to confirm the parent’s identity.
Educators consent in lieu of a parent: With respect to school-based activities, COPPA permits instructors and school administrators to give consent for the obtainment of personal information from children instead of parents. However, schools must tell parents and allow parents a reasonable time to request the school not to disclose such information. To learn more about parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
Giveaways, Contests and Sweepstakes
We may have giveaways, contests and sweepstakes, and for such we ordinarily request only the information essential for a child to take part, for example, first name and parent's email address (to notify the parent where required by law). We only contact the parent for more customized information for prize-fulfillment purposes when the child wins the giveaways, contest or sweepstakes.
As you might expect, some giveaways, contests and sweepstakes ask the child to submit their self made content along with the child’s entry. Those occurrences may necessitate parental consent to precede the submission. The above, Content Generated by a Child, gives more information on our collection, notice, and consent policies.
Email Contact with a Child
It may become necessary for us to respond to a question or request from a child, at which time Tivoyage may need to be given the child’s online contact information, for example, an email address. Once Tivoyage has responded to the child’s question or request, we will discard this information promptly.
In some cases with certain activities or services, we may need to collect a child’s online contact information, for example, an email address, in order to communicate with the child more than once. In such occurrences we will keep the child’s online contact information to uphold the request and for no other reason, for example, marketing. One example of what may be sent by Tivoyage is a newsletter which may provide occasional updates about Services, games/activities, web series or other projects/information. At whatever point we collect a child’s online contact information for continuous exchanges, we will at the same time request a parents’ email address in order to tell the parent about the collection and use of the child’s information, and in addition to give the parent a chance to cease our further contact with the child. On a few instances, a child might have more than one communication from us requiring the parent to opt-out of each communication separately.
Push notifications are notifications on mobile and other devices that are regularly associated with downloaded applications, and which can communicate to the device holder even when the application isn’t being used. We will require a child to give a parent email address before the child can get push notifications from our applications that are geared for children and collect a device identifier. We will then give the parent notice of our contact with the child and will give the parent the chance to stop further notifications. We will not connect the device identifier with other personal information without obtaining consent from parent.
In the event that an application geared for children on a Tivoyage Site happens to collect geolocation data that is specific enough to reveal a street address, we will first contact the parent for consent through an email.
If we gather (or enable others to gather) such information from children on our Services for different purposes, we will tell parents and get acquire consent before such collection.
Section II. Information Collected from Children and its Availability to Others
Notwithstanding those uncommon occurrences when a child’s personal information is posted publicly (requiring advanced level parental consent), we additionally may share or disclose personal information gathered from children in limited instances, including the following: (1) We may convey information to service providers if essential to perform a business, expert, or technical support function for us; (2) We may reveal personal information if allowed or required by law, for instance, conforming to a court order or subpoena. (3)To the degree allowed by applicable law, we likewise may unveil personal information gathered from children (a) if a law enforcement or public agency (schools or children services) requests it; (b) if in good faith, we believe disclosure may prevent the instigation of a crime, help an investigation related to the safety of a child or others or ensure the safety of a child utilizing our Services; (c) to protect the security or trustworthiness of our Services and our service providers; or (d) to make it possible for us to take safety measures against liability.
Section III. Parental Choices and Controls
A parent can choose not to allow us to collect personal information from their child or deny us permission to collect additional information from their child in relation to their specific account and at any time can ask that we delete from our records the personal information we have gathered regarding that account.
Please contact us by email at firstname.lastname@example.org if you have questions concerning our policies and practices.