6. Children – Under 13 Years (COPPA)
6.1. Children and COPPA Generally
As our service/product is EdTech use by students and trainers in schools/coaching institutes, including elementary and middle schools, we are especially sensitive to protect Child Students and their Personal Information.
This section describes how we treat Child Students differently from what is described above for Older Students, and is intended to also explain how we address the requirements of the Children’s Online Privacy Protection Act (“COPPA”), including requirements for parental consent and our commitment to parents’ ongoing rights regarding their child’s Personal Information.
The definitions of Personal Information and Other Information above applies also to Child Students (as defined above).
This section describes how our information practices are different with respect to Child Students.
6.2. Parental Consent
COPPA requires that an operator of an online service not collect Personal Information from a child without the prior consent of their parent, which consent can be obtained directly from the parent or through the child’s school or training institute.
In our standard practices: For child – it is strongly recommended to use parent’s contact details(email and mobile) for communication. Also we recommend parents to parallel login to their child account to continuously monitor the activities.
Parental consent, as obtained through the school or institute, is limited to collection, use and disclosure of Personal Information required for delivery of the Service (i.e. for sharing with Instructor/school and classmates, and for “internal operations”), or in the event of an Acquisition, or as compelled by law, in each case subject to the restrictions described above in “How Personal Information May Be Disclosed”. Parental consent does not permit any other disclosure to third-parties.
Parental consent can be withdrawn at any time, and Personal Information can be deleted, as described in section 5 of this Policy.
6.3. Required Information
To use the Service, an account is required. During the registration for a course, parent has to fill the physical form (on paper/tablet device) by their own, and he/she can decide/ask what’s necessary to service operations.
Students do not have public account profiles and their information is not visible outside of their Course Mate Groups and authorized institution officials except as described for Older Students under section 6.5 “Social Interactions and Content Sharing”.
6.4. Limited Use of Information
As required by COPPA for Child Students, and consistent with our business model for all Students, use of Personal Information of Students is solely for the use and educational purposes of the Instructor or school contracting with us (including through an Education Instructor), and for no other purpose. Our use of Personal Information of Students is limited to that educational or approved program context. Disclosure is also permitted in an Acquisition, or if legally required, in each case subject to the requirements stated in this Privacy Policy (see “How Personal Information May Be Disclosed”).
6.5. Social Interactions and Content Sharing
Interactions within the Course Mate Groups are visible to, and can be moderated by, the Instructor/backoffice team. All interactions through the Service are logged.
Child Students cannot use the Service to share their content or interact with individuals outside their Course Mate Groups, managed by the course Instructors.
Older Students are generally subject to the same social interaction and content sharing restrictions as Child Students, except that Older Students (and Instructors) may be permitted to share their own user-created content with individuals outside of the Service. The Older Student is responsible for determining what information, and with whom, to share in this way. Sharing outside the Service is not available for Child Students.
6.6. No In-app Purchases
In-app purchases are not available to Child Students or Teen Students. In-app purchases to upgrade accounts to access additional features or capacity may be available to Adult Students. Such upgrades are available to Child or Teen Students only through an upgrade by their institute/school or purchase by their parent.
6.7. Right to Review, Delete, Terminate
Upon request from the school/institute/parent, we will promptly provide a description of the types of Personal Information collected (also included in this Privacy Policy); an opportunity to review the Student’s Personal Information and/or have the information deleted; and the opportunity to prevent further use or online collection of a Student’s Personal Information. For information on the process to review, delete or terminate use of your child or Student’s Personal Information, and for further information about retention and deletion of Personal Information, please see section 5.2 “How you can access, change, export or suppress your Personal Information”.
