Children’s Privacy Policy

PLEASE READ THIS CHILDREN’S PRIVACY POLICY STATEMENT CAREFULLY. This children’s privacy policy statement (Children’s Privacy Policy) of Kefi Holdings, LLC, a Delaware limited liability company, and/or its subsidiary and affiliated entities (collectively, “Kefi”, “we”, “us”, or “our) explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This Children’s Privacy Policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s Personal Information. For more information about COPPA and general tips about protecting children’s online privacy, please visit COPPA Rule.

COPPA requires us to inform parents or legal guardians about how we collect, use, and disclose Personal Information from children under the age of 13. COPPA also requires that we get consent from parents or legal guardians before we allow children under the age of 13 to use and interact with some sections, applications, and activities on the Services. We offer users a number of activities, some of which are directed at children under the age of 13, and other activities that are targeted for users of all ages.

Verifiable Parental or Legal Guardian Consent

Should we want to collect Personal Information from a child, COPPA requires that we first obtain a parent or legal guardian’s consent. In an email (or other approved method) sent to the parent or legal guardian we will describe what information we would like to collect, how we propose to use it, and how the parent or legal guardian can offer and cancel consent. If we do not obtain consent from the parent or legal guardian within a reasonable timeframe, we will remove the child and parent/legal guardian information collected with the request.

Teacher Consent in Replace of a Parent or Legal Guardian

For school-based activities, school administrators and teachers are allowed under COPPA to act on behalf of the parents or legal guardians to give consent when collecting Personal Information from children. Teachers and school administrators should always inform parents and legal guardians when collecting Personal Information from children on their behalf.

Information We Collect From Children, How We Use It, and Parental and Legal Guardian Rights

Registration

Children may be able to register with the Services to use our software, online applications, view content, participate in contests, receive emails, and engage in other activities. By doing so we may collect information from children. When we collect Personal Information from a child, we will hold that information only as long as reasonably necessary to allow the child to continue to use and interact with the Services.

During the registration process we may ask a child to give us information for security purposes, announcements, and notifications. This information includes a child’s name, birthdate (to validate the child’s age), gender, username, account name, password, and parent or legal guardian’s email address and other contact information. Children can choose whether to provide their information to us; provided, however, that some of our Services may not function without the required information. We strongly advise children and any user never to provide any Personal Information in their usernames.

To comply with COPPA requirements, on the Services where we ask for the age of a user who is under the age of 13 we will ask for their parent or legal guardian’s email address before we collect any Personal Information from a child. If you think that your child is involved in an activity that collects Personal Information and you or another parent or legal guardian has not received a request for consent to collect such information, please contact us using the contact information at the bottom of this page.

Automatic Information Collected and Persistent Identifiers

When children access or otherwise interact with the Services, specific information may automatically be collected. We collect this information to make the Services useful to children and other users. We also use this information for internal business purposes, including improving the Services (including the functionality of the Services) and our products, services and/or content. Some examples of this type of information include the child’s IP address, mobile device identifier, type of web browser, type of operating system, online service provider used, and the regularity with which the child visits different parts of the Services.

This data and information are collected using online technologies such as “cookies”, a “web beacon”, a “clear gif”, a “web bug”, a “pixel tag”, and other unique identifiers that are explained in the What Non-Personal Information We May Collect section of our general Privacy Policy. This information and data may be collected by the Services or by a third-party (including without limitation, Service Providers).

Children’s Content

Certain activities on or through the Service allow children to create or manipulate content and save it with Kefi. Some of these activities do not require children to provide any Personal Information and therefore may not result in notice to the parent or legal guardian or require parental or legal guardian consent. If an activity potentially allows a child to insert Personal Information in their created content, we will either pre-screen the submission to delete any Personal Information, or we will seek parental or legal guardian consent by email for the collection. If, in addition to collecting content that includes Personal Information, Kefi also plans to post the content publicly or share it with a third-party for the third-party’s own use, we will obtain parental or legal guardian consent.

Contests and Sweepstakes

From time to time, we may host promotions (such as contests or sweepstakes) that allow entry by children. In order to enter these contests, users may be asked to submit information such as their first name, email address, gender, date of birth, and content submissions. We may use an age screening mechanism to determine whether users are under the age of 13 at the time of entry. Where a user indicates that the user is under the age of 13 at the time of entry, or in all cases for a predominately child-directed portion of the Services, we may use the child’s online contact information to notify the child as to what to give the child’s parents or legal guardians to complete the promotion process. Or, we may set up a system for multiple contacts with the child regarding the promotion, in which case we will also obtain the parent’s or legal guardian’s email and give the parent or legal guardian notice and an opportunity to unsubscribe the child, as required by COPPA. In either case, we will not use such emails for other purposes not permitted by COPPA, such as marketing.

Push Notifications

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent or legal guardian email address before the child can receive push notifications from our child-directed Services that collect a device identifier. We will then provide the parent or legal guardian with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other Personal Information without contacting the parent or legal guardian to get consent.

Geolocation Data

If a child-directed Service collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.

How We Use Collected Information

This information and data are primarily used for our own purposes in order to:

  • Let users and children access and use features of the Services;
  • Improve the features and usability of the Services;
  • Let us analyze data to see how the Services are performing; and
  • Email notifications to users and children.

Sharing Information

We will not share a child’s Personal Information with other individuals or companies except in limited situations, including the following:

  • When other companies (including without limitation, Service Providers) perform services for us, like customer support, email services, delivery services, call centers, data management services, help desk providers, law firms, payment processors, accountants and shopping cart providers; provided, however, that these companies are prohibited from using a child’s Personal Information for purposes other than those requested by us or required by law.
  • Disclosing a child’s Personal Information if required or permitted by law, for example, in response to a subpoena, law enforcement, court order, or public agency’s request.
  • To protect the safety of a child.
  • To safeguard the security of the Services and Service Providers.

Parental and Legal Guardian Rights

As a parent or legal guardian you have the following rights regarding your child’s use of the Services:

  • To review the Personal Information we collected from your child;
  • To revoke the consent to use or further collect your child’s Personal Information;
  • To request that your child’s Personal Information be changed or deleted;
  • To allow the collection and use of your child’s information, but not allow disclosure to third parties unless it is part of our service;
  • To send you a new notice and get your consent if we make changes to the collection, use, or disclosure practices to which you previously agreed; and
  • Parents can exercise their rights shown directly above by contacting us.

We take steps to verify the identity of anyone requesting information about a child, to ensure that the person is in fact the child’s parent or legal guardian, and appreciate your cooperation with those steps.

If you are a parent or legal guardian and you are aware that your child has created an account that you have not consented to, please contact us so that we can take steps to terminate your child’s account with us. If you are a parent or legal guardian and you are aware that that we have collected Personal Information from your child without your consent, please contact us so that we can take steps to remove that information from our servers.

This Children’s Privacy Policy is effective as of, and was last updated and posted on, February 1, 2019.

Contact Us

If you have any other questions about our information handling practices, including our practices with respect to children’s Personal Information and/or our Children’s Privacy Policy, or would like further information regarding the Services that are directed to children under 13 years of age, please contact us at:

privacy@playkefi.com

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