Updated October 24, 2019
The General-Audience Pages of our Website, and the account login information in our app, are intended for adults. We do not knowingly solicit or collect Personal Information from Children on our General-Audience Pages and account login screen. If we learn that a Child User has provided us with their Personal Information without prior verifiable parental consent, we will take all reasonable measures to delete such information from our databases and not use such information for any purpose. If you are under the age of 18 and would like to order our Splats, please have your parent, guardian, or school administrator order our Splats for you.
Our Splats and App are generally intended to be used and enjoyed by children, teenagers, and adults of all ages. Our account creation and login features, however, are solely intended for creation and use by adults and education professionals. For this reason, we employ special measures when collecting or processing information or generally avoid or limit the collection of Personal Information from Child-Users through their use of our Splats and App. For more details on our practices related to children, please see the section on Children’s Privacy below.
You do not have to share any Personal Information to access and view our Website.
If your child is a Classroom User, additional privacy protections apply because your Educational Institution may provide us with Student Data that is subject to the Family Educational Rights and Privacy Act. For more details on our practices related to Classroom Users, please see the section on Classroom Privacy below.
HOW WE PROTECT YOUR INFORMATION, SECURITY, AND PASSWORDS
Unruly Studios takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information.
We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Please note that our Splats are designed to be usable by children, teenagers, and adults of all ages. However, only parents, legal guardians, or other adults are allowed to make purchases on our General-Audience Pages.
To set up your Splats, a parent, guardian, or educator should download the App and assist with account creation (if applicable).
In some instances, we may collect a limited amount of Personal Information from a parent, educator, or Child User (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a Child User (e.g., email alerts, push notifications). For these types of activities, we may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of Personal Information prior to collection or immediately after use, parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.).
Our Services, including our Splats and App, do not currently offer any features that would allow a Child User to publicly post or share their, or others, Personal Information with other users via the web or on our Website.
Some features on our App or Splats may allow the local storage of information (including Personal Information such as voice recordings), without the uploading of such information to the web or our servers.
We may collect and process Product Use Information and Browsing Information from a Child User through the use of our Splats, but only for purposes of reporting data back to the educational institution that owns the account (and users such as educators and admins), and supporting our internal operations, such as to help us:
We will not use Product Use Information or Browsing Information, collected through the use of our Splats and App, for behavioral or re-targeted advertising purposes or allow third-parties to track the activity of a Child User for such purposes.
With proper authentication, a parent, legal guardian, or educator always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by Unruly Studios. Please keep in mind that a request to delete such information may limit the child’s and account holder’s access to all or a portion of our Services. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us at email@example.com. We urge parents to monitor their children’s use of all digital media.
We are committed to maintaining the security and confidentiality of any Student Data, which we receive from Educational Institutions for Classroom Users. Some of the precautions we take include (a) limiting employee access to Student Data to only those employees with a need to such access to fulfill their job responsibilities; (b) requiring employees to sign confidentiality agreements upon hiring; and (c) protecting Student Data with technical, contractual, administrative, and physical security safeguards.
If you child is a Classroom User, please contact your Educational Institution if you need to request to access, make changes to, or delete Student Data on your Classroom User from our servers. Any request to access, make changes to or delete Student Data must be made by the Educational Institution’s designated administrator for the Classroom User. The administrator will be provided access to the Classroom User’s account in order to update, correct, or delete the information contained therein.
Parents and guardians of Classroom Users should contact their respective Educational Institution for any questions regarding account cancellation and data deletion.
LINKS TO OTHER WEBSITES
CALIFORNIA PRIVACY RIGHTS
Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third-parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third-parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to firstname.lastname@example.org.
VISITORS RESIDING OUTSIDE THE UNITED STATES
If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian, as applicable and legally required.
If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by writing to us at email@example.com or Privacy Manager, Unruly Studios, Inc., 2 Avenue de Lafayette, GSV Labs, Boston, MA 02111.