We market and sell our products to adults who purchase or otherwise subscribe to our Services. Some of our products and services can then be used by children at the direction and under the supervision of these adults. Some of our Services—Empass Assess, FreXP, Empass APIC, Empass MAPPR offer online learning and assessment tools that children may access. These tools may collect Personal Information from children, as defined by COPPA. Below, we provide a list of likely situations of such collection and describe how and when we will provide parental notice and seek prior verifiable parental consent.
We do not knowingly collect, use, disclose or store any Personal Information from children unless we have obtained prior verifiable parental consent. In any instance where we collect Personal Information from a child, we will not collect more Personal information than is reasonably necessary for the child to participate in the Service, and we will retain that information only as long as reasonably necessary to fulfill the request or allow the child to participate in the Service, ensure the security of our users and Services, or as required by law. In the event that we discover that we have inadvertently collected information from a child in a manner inconsistent with COPPA’s requirements, we will delete that information and attempt to notify the child’s parent. If you believe that we might have collected Personal Information from your child without consent, please contact us
Account Creation and Child Login Credentials
An adult teacher or parent purchaser of any Service may open an account for a child by creating the child’s login credentials. We collect child’s user credentials each time a child log in to the app or platform to access the Services. We will not use this information for any purpose other than authenticating the child’s login and facilitating access to the Services. Our staff is not authorized to access or disclose child’s login information as most of it is programmatically collected and administered. Any information regarding child’s login credentials is strictly controlled by their teacher or authorized assessor who is responsible for creating the child’s account.
Communicating With Us
Nevertheless, if a child does communicate with us, we will collect the child’s Personal Information to directly respond to the child’s request for assisting them on a one-time basis, and we will delete the child’s Personal Information after responding.
We automatically receive and record certain technical information from a child’s browser, including the child’s IP address, for internal purposes only. When we collect an IP address, we combine it with other information submitted by the user’s browser, such as requests for files from the web server. This information is used to generate analytics reports, create access logs, which are used for analyzing user types and locations, determining trends (e.g. which pages are used the most, which browsers are most frequently used by visitors to access the site, and which areas of the world site users are accessing our products from most frequently). Our access logs do not contain any information which can be uniquely associated with any particular IP address or Personal Information about any individual user.
Children Account Activity
Certain activities on certain Services allow children to create or manipulate content and save it on our Services. Some of these activities do not require children to provide any Personal Information. If a Service requests or allows a child to provide Personal Information in their created content, we will seek prior verifiable parental consent in order to collect that information. Examples of created content that constitutes or may include Personal Information include the following:
We do not use children video or voice recordings or the information provided by children in free-form text fields for any internal purpose; we only transmit the voice recordings and the content provided in free-form text-fields for analysis, scoring and review by certified assessors or teachers. Children may not share their video or voice recordings or the information provided in free-form text fields with anyone else, and they cannot privately communicate with anyone using the Service.
Additional educational information is collected as the child progresses through the Service, such as amount of time logged in, reading rate, and assessment scores. This information allows the Service to adapt to the child and inform the assessors of the children to rate and review their performance.
For parent purchasers, in the event we wish to collect the Personal Information outlined above from a child, we provide parental notice and seek verifiable parental consent via the email address provided during account creation. In our initial email, we describe what Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the parent can consent to the collection of such information, and your parental rights over such information. This email contains an activation link you must click. We send another email message to confirm we have obtained consent after a reasonable time delay. In this confirmatory message, we indicate how the parent can revoke consent to our collection of Personal Information.
Consent—Schools As Agents of Parents
Where a school or school state/district contracts with us to offer the Services solely for the benefit of their children and for the school system and for no other commercial purpose, the school or school district may consent to the collection of children’s Personal Information on their parents’ behalf. We encourage schools and school districts using our Services to notify parents that our Services are being used in their schools.
We provide the schools and school districts using our Services with the notices required under COPPA, including a description of the Personal Information we collect from children, how we collect it, how we use it, how we disclose it, how the school or school district can consent to the collection of such information, and all other rights over such information.
How We Share Personal Information Collected From Children We do not provide any child’s Personal Information to third parties—we use this information for internal purposes only.
Parental and School Access and Control Over Personal Information Collected From Children
If you no longer wish to have Personal Information of a child collected by an application installed on a mobile device, you may uninstall the application by using the standard uninstall processes available on the mobile device or via the mobile application marketplace or network.