JSG and COPPA
Information Collected From Kids, How It’s Used, and How That Is Communicated With Parents
Some of JumpStart Games’s Sites are primarily targeted at children and their parents and others are for users of all ages and their families. Sites and certain applications include activities or options that may collect or allow certain information from children to be entered online. Any personal information entered by a child or collected by the Site or application will be retained only as long as reasonably necessary to complete the activity or to allow the child to participate in the activity, to ensure the security of the users and our services or as may be legally required. In the event that we discover information from a child has been collected inconsistent with COPPA, that information will either be deleted or an email immediately be sent to the parent seeking their consent.
Those potential instances of collecting a child’s information is summarized below along with how and when parental notice will be sent or parental consent requested.
We ask all users for their birth dates to validate their ages. Children under the age of 13 have the option to play as a Guest (in which case no personal information is collected) for single session play or, if they wish to register as a user in order to obtain full access to the Site and games, provide limited information to begin the registration process. The parent email address is hashed and the hash is used only for the internal purpose of contacting that parent to let them know that their child has requested to register for the Site and providing the parent with a link to register the child and/or print out a Verifiable Parental Consent form to email or fax back to us. In order to fully participate and benefit from our Sites registration is required. This includes the ability to view content, play games, participate in contests, and engage in special features, among other things.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. During the registration process, we may ask the child to provide 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. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. We never require a child to enter more information than is reasonably necessary in order to fully participate in online activity or full use of our applications. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at email@example.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Content Generated by a Child
Certain activities on our sites and applications allow children to create or manipulate content and submit it to JumpStart Games. If the particular activity does not require children to provide any personal information it may not result in notice to the parent or require parental consent. However, if an activity potentially allows a child to insert personal information in their created content, participation on a forum or other activity we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are videos, photos, audio files, stories or other open-text fields, and drawings that allow text or free-hand entry of information. If JumpStart Games plans to post the content publicly or share it for any reason verifiable parental consent will immediately be sought prior to any such use.
About Verifiable Parental Consent:
Email Consent. In the event the Sites or Application seeks to collect personal information from a child, COPPA requires that consent of a parent or guardian be requested by email. Each email will explain what information is being collected, how it will be used, how the parent can provide consent, and how the parent can revoke consent. In the event parental consent is not received within a reasonable time, the parent contact information and any other information collected from the child in connection with that activity will be deleted.
Verifiable Parental Consent. No personal information collected from a child will be posted publicly without the receipt of a higher level of consent from the parent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax.
Certain games and activities allow users to communicate directly with other users by means of a chat system. In almost all cases where children are involved, the Sites employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. Children who use chat on our sites and applications are directed to never provide personal information about themselves or any third party, and not attempt to circumvent our filters or moderation. Parents are urged to carefully supervise their children when the children participate in online activities.
For any forum that does not filter all or nearly all personal information, Verifiable Parental Consent must be on file before any child under the age of 13 can participate.
Contests and Sweepstakes
On that information necessary for a child to participate, (usually only the child’s first name) and the parent’s email address (for notification purposes only), is collected for contests and sweepstakes. We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
If a Site or application collects a child’s geolocation information that is specific enough to equate to the collection of a street address, parental consent will be requested via email.
The list of third-party operators who collect persistent identifiers on our sites and applications and links to their privacy policies may be found here.
When Information Collected From Children Is Available To Others
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
Parental Choices and Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Parents/guardians of children under the age of 13 can print out and mail or fax us a signed form that allows them to review any personally identifiable information collected with their permission, about their child, have this information deleted, and/or request that there be no further collection or use of their child's personally identifiable information. You can download the form here. We will take steps to verify the identity of anyone requesting personally identifiable information about a child and to ensure that the person is in fact the child's parent or legal guardian. In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. 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.