Prodotype websites, products and services (“applications”) are primarily general interest applications designed for adults. We do not knowingly collect personal data from children in connection with those applications.
There are certain Prodotype applications that are appropriate for and are intended for use by children. This Children's Privacy Statement applies to these applications. Where there is a conflict between this Children’s Privacy Statement and other sections of our Privacy Statement, this Children’s Privacy Statement sets the standard for how we treat children’s personal information, consistent with the requirements of the U.S. Children’s Online Privacy Protection Act and Rule (“COPPA”) and the European Union General Data Protection Regulation (“GDPR”), where applicable.
In the event we discover we have collected data from a child in a manner inconsistent with COPPA’s requirements, we will promptly either delete the data or seek parental or guardian consent for that collection. For more information about COPPA and general tips about protecting children’s online privacy, please visit appropriate online sites that suggest the same.
Where we know that a user is under 13 years old, we will:
Where a website or application is appropriate for use by children under 13 years old, children can register to (among other things):
During the registration process, we will ask the child to provide certain personal data for security purposes and so we can send notices to parents, including:
We also ask for birth dates from children to validate their ages. Some activities, such as completing tutorials, do not require children to provide any personal data and therefore may not result in notice to the parent or guardian or require parental or guardian consent. If a child chooses not to share their personal data (i.e., a parent or guardian’s email for purposes of consent) with us, this limits their access to account creation and certain features, such as publishing content publically. We will not require a child to provide more data than is reasonably necessary in order to participate in sections or features of the website or application. Also, we will keep the data consistent with our retention practices.
Depending on the website or application, we may seek different types of parental or guardian consent. In each case, when we ask for consent we will provide notice about the specific activities available to a child through the website or application.
Parental or guardian consent
Because our websites and applications include activities that allow children to create, share and publically post content, to utilize certain features and functionality, we seek further parental or guardian consent:
We also require parents or guardians to open their own account so that they can view and moderate their child’s account. For further details, please see Parental Choices and Controls below.
After providing further parental consent, we may offer parents the opportunity to use a password in future communications as a way to confirm the parent’s identity.
Teacher consent in lieu of a parent
For school-based activities, COPPA allows teachers and school administrators to act in the place of parents to provide consent for the collection of personal data from children. Schools should always notify parents about these activities. In some cases, in order that an account is not closed and so that a child can continue to use a website or application outside of the school context, we may ask schools to obtain consent directly from a parent instead of and/or in addition to providing consent in the place of a parent, so the parent can be added as a moderator.
For more information on parental rights with respect to a child’s educational record under the Indian Family Educational Rights and Privacy Act (FERPA), please see the FERPA section below.
Content Generated by a Child
Our applications include activities that allow children to create or manipulate content and save it. We honor requests to delete any content that they post on our websites and applications, unless we are required by law to retain it.
Forums and comments
Certain activities allow users to communicate directly with other users by means of user forums or comments sections. We strongly encourage children who use these interactive features on our websites and in our applications never to provide personal data about themselves or any third-party, and not to attempt to circumvent any moderation features.
In all of our contests for children, we will require only the data necessary to enter the contest, such as user name and parent email address (to notify the parent where required by law). We only contact the parent for more personalized data for prize-fulfillment purposes if the child wins the contest.
Email Contact with a Child
In some of our applications, we may collect online contact information, such as an email address, in order to communicate with a child who makes a specific request through customer service. For example, a child may email us to ask for help in understanding how to use a design tool if she or he is having trouble with. Or the child may want to sign up for a monthly newsletter.
If we have actual knowledge that we are communicating with a child under the age of 13 without parental consent, we will respond once to the communication, delete their personal information, and will not participate in any ongoing communication.
Here is how we would handle communication requests:
When children interact with us, certain data may be collected automatically, both to make our websites and applications more interesting and useful to children and for various purposes related to our business.
When Data Collected From Children Is Available To Third Parties
In addition to those cases where a child’s personal data is posted publicly (after receiving parental or guardian consent), we also may share or disclose personal data collected from children in a limited and clearly defined number of instances. Please see the “How does Prodotype disclose your personal data?” section of our Privacy Statement.
Prodotype will not use children’s personal data for advertising purposes, to create a profile about a child and tie it to an Application; or sell children’s personal information.
Parent And/Or Teacher Moderator Choices And Controls
At any time, parents, and/or teacher moderators can:
Please note that teachers only have these rights if they are moderators.
Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service and that any content saved in that account may no longer be accessible.
Where a child under 13 has registered for an account, we use two methods to allow parents/teachers to access, change, or delete the personal data that we have collected from their children:
In any correspondence such as email or mail, please include:
To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information. Please visit the “How does Prodotype protect your data“ section in the Prodotype Privacy Statement.
Users located in the European Union will be provided the right to exercise their rights to access, correct, delete, object, restrict, or obtain a copy of their personal data as described in the Prodotype Privacy Statement.
Education And FERPA
If you are using our applications through a school program, your personal data may be subject to the Family Educational Rights and Privacy Act (FERPA). India commits to protect and secure student data in the manner that FERPA requires and, also, agrees to act as a “school official” to the extent our services are used to store regulated student records in accordance with rules of the country. For more data regarding FERPA, please visit the FERPA site and the Indian Department of Education website for more information.