COPPA: DIRECT NOTICE TO EDUCATIONAL INSTITUTIONS ACTING AS AGENTS FOR PARENTS WITH CHILDREN UNDER THE AGE OF 13 WITH RESPECT TO CHILDREN’S USE OF THE CLASSCRAFT PRODUCT
Under the United States’ Children’s Online Privacy Protection Act (COPPA), online service providers such as Classcraft must provide parental notification and obtain verifiable parental consent before collecting personal information from children under the age of 13, except in limited situations (for exceptions to this consent requirement, please see 16 CFR § 312.5(c)).
In order for Classcraft to rely on consent obtained from a child’s educational institution instead of the parent under COPPA, Classcraft must provide the educational institution with the same type of direct notice regarding its practices as to the collection, use, or disclosure of personal information from children as it would otherwise be required to provide to the parent, as follows:
Classcraft relies on educational institutions to consent under COPPA to the collection of a child’s information on the parent’s behalf; to collect the contact information needed to obtain parental consent; and to provide the means by which parental consent can be obtained regarding the collection, use, and disclosure of such information.
Classcraft intends to collect personal information from students, including children under the age of 13, but only to the extent that is reasonably necessary to enable students to participate in the Classcraft product. Classcraft requires parental consent for the collection, use, and/or disclosure of any child’s personal information. Classcraft will not collect, use, or disclose any personal information from a child if parental consent is not provided.
Should such consent be provided, Classcraft may collect the following personal information from the child:
For a more complete explanation of what data is collected, how it is collected, how it is used, and who may have access to it, please see our Personal Information Collected Data table located at https://files.classcraft.com/classcraft-assets/legal/pdf/en/CC_InformationCollected_2021-EN.pdf.
Because Classcraft is intended to be played in groups within the classroom and/or school setting, as well as to provide, when applicable, data to school and/or district leaders regarding student behavior, information collected about students, including children covered by COPPA, is intended to be shared within the School Environment (i.e. the classroom, teachers, and school and district administration and employees/agents). Specifically, Classcraft stores the following information that educational institutions and students may choose to share within the School Environment:
Please see our Personal Information Collected Data table, located at https://files.classcraft.com/classcraft-assets/legal/pdf/en/CC_InformationCollected_2021-EN.pdf, for details on personal information that may be shared and which users may have access to that information.
Upon request from the educational institution, Classcraft will provide a description of the types of personal information collected; an opportunity to review the child’s personal information and the right to have the information deleted; and the opportunity to prevent further use or online collection of a child’s personal information.
If a child’s personal information is collected without parental consent or collected beyond the scope needed for participation in the Classcraft product, Classcraft will delete such information as soon as possible. If you believe that information from a student under the age of 13 has been provided in violation of these terms, please contact us at [email protected].
As a best practice, Classcraft recommends that educational institutions make this notice available to parents so that they may review the personal information collected.
Please feel free to contact Classcraft with any questions or concerns:
Classcraft Studios Inc
125 High Street, Boston, Massachusetts 02110