We offer our users a website that is intended for users of all ages. The Website offers a variety of services, including services that may collect information from children. Below we summarize potential instances of collection, and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the service, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Children can, in many cases, register with the Website to view content, sign up for our newsletter, play games, and participate in contests. 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 name, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. 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. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
About the collection of parent email address: Consistent with the requirements of COPPA, in any instance where we ask for age and determine the user is under the age of thirteen (13), we will ask for a parent or guardian’s email address before we collect any personal information from the child. If you believe that your child is participating in a service 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 firstname.lastname@example.org. We will not use parent emails provided for parental consent 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 the Website allow children to create or manipulate content and save it with the Website. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental 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 verifiable parental consent by email for the collection. If, in addition to collecting content that includes personal information, we also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
Verifiable Parental Consent
Email Consent. In the event we wish to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
High-Level Consent. In the rare event that we collect personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. 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. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Teacher consent in lieu of a parent. With regard to school-based activities, COPPA permits teachers and school administrators to provide consent for the collection of personal information from children. Schools should always notify parents about these activities.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, we may need to ask for the child’s online contact information, such as an email address. We will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a website, an activity or an event. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions, a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
When children interact with us, certain information may automatically be collected, both to make the Website more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers . This information may be collected by us or by a third party. This data is principally used for internal purposes only, in order to:
• provide children with access to features and activities on the Website
• customize content and improve the Website
• conduct research and analysis to address the performance of our Website
• generate anonymous reporting for use by us
In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.
Please contact us at the mailing address, email or phone number below with questions about our privacy policies and collection and use practices:
American Eagle Foundation
Post Office Box 333
Pigeon Forge, TN 37868
Toll Free Phone: 1-800-2EAGLES
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 the personal information we have collected in connection with that account from our records. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has registered for an account on the Website, we use two methods to allow parents to access, change or delete the personally identifiable information that we have collected from their children:
a. Parents can request access to and delete their child’s personal information by logging on to the child’s account. Parents will need their child’s username and password. The “My AEF Account” website explains how to recover a password if the child cannot recall it.
b. Parents can contact us to request access to, change or delete their child’s personal information by sending an email to us at email@example.com.
In any correspondence such as email 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.
This Policy is effective May 2016.
Copyright © 2016 by American Eagle Foundation and all rights are reserved.