List of child-directed websites:
THE INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
Future offers to its users a range of products and services, some of which are primarily targeted at children, and others that are intended for a general audience. Our products and services offer a variety of activities, including activities that may collect information from children. Below we summarise 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 fulfil the activity request or allow the child to continue to participate in the activity, 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.
About the collection of parent email address – Consistent with the requirements of COPPA, on any child-targeted site or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity 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 email@example.com. We will not use parent emails provided for parental consent purposes 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 Created by a Child
Certain activities on our child-directed sites give children the opportunity to create content and share it with Future via email. 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 include personal information in their created content, we will either screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Furthermore, personal information (e.g. contact details) relating to the child will be deleted within 30 days of receipt. Examples of created content that may include personal information are stories, opinions and ideas (i.e. open-text), and drawings that involve text or free-hand entry of information. If, in addition to collecting content that includes personal information, Future 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.
About Verifiable Parental Consent:
- Email-Plus Consent – In the event Future wishes to collect personal information from a child for internal purposes only, 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. Once we receive parental consent we will send a second email confirming this. 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 event Future collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email plus 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 allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
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 personalised information for prize-fulfilment purposes when the child wins the contest or sweepstake. The parent email address (obtained from the child) will be deleted upon completion of the contest or sweepstake.
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. Please see “Content Created by a Child” above for more information on our collection, notice, and consent policies.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, Future may need to ask for the child’s online contact information, such as an email address. Future 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 honour the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a site or activity. 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 our sites, certain information may be collected, both to make our sites 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, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies (a small text file that is created by a website and stored on your computer through your browser). This information may be collected by Future or by a third party (see list below). This data is used for internal purposes only, in order to:
- Ensure that the site functions properly;
- Enable us to conduct research and analysis to understand, address and improve the use and performance of the site; and,
- Diagnose and respond to problems.
List of third parties:
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; (iii) to protect the security or integrity of our sites and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
PARENTAL CHOICE AND CONTROLS
At any time, parents can refuse to permit us to collect further personal information from their children, and can request that we delete from our records the personal information we have collected. Please keep in mind that a request to delete records may lead to a termination of a membership or other service.
Where we have collected personal information from a child, we use the following method to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
- Parents can contact our privacy team to request access to, change, or delete their child’s personal information by sending an email to us at firstname.lastname@example.org. A valid request to delete personal information will be accommodated within a reasonable time.
Any other inquiries may be directed to:
- By email: email@example.com
- By telephone: +44 (0)1225 442244
- By post: Privacy Officer, Future US LLC, Full 7th Floor, 130 West 42nd Street, New York, NY, 10036.
In any correspondence such as email or mail, please include the child’s name 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.