Children’s Privacy Notice
HeartFirst Education, LLC (“Company” or “We, Our, Us, HeartFirst Education”) is committed to protecting the privacy of children who use our websites, online services (such as educational courses, live video classes, social network features, etc.) and applications (together, our “Services”). This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), But in general, this information applies to all learners where local law regulates activities for children under certain ages. For COPPA, this is under 13 years.
THE INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
We offer range of sites and applications, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our sites and applications offer a variety of activities, including activities that may collect information from children. We collect almost all personal data about Children directly from Parents / Guardians, but we do collect data from Children. Once we have verified parental consent of Parents / Guardians, we collect information directly from Children on our platform. Below we summarize potential instances of collection and outline how and when we will provide parental notice and 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 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.
Registration
Children can not register on our sites and apps, accessing various content, contests, activities, and special features. During registration, we may request info for notification and security, like parent/guardian email, child’s first name, gender, chosen username, and password. Birthdates may be asked to verify ages. We advise children not to use personal info in usernames.
No last names are disclosed on the network. While we collect both the parents’ first and last names, we only share the child’s first name and username publicly. We strongly advise children never to provide any personal information in their usernames. This approach ensures safety while ensuring a meaningful online experience for all users.
Children cannot enroll themselves in activities that require payment, but they may join free challenges (like drawing) or Learner groups (like an onboarding group).
Parents / Guardians will receive notice via email for all Services, whether paid or free and can un-enroll their Children at any time. Parents / Guardians can always see the Child’s Learner accounts, but cannot themselves participate in Learner activities.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 13 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 support@heartfirsteducation.org In our specific operational framework, during sign-up, we will exclusively collect parental email addresses. All correspondence will be directed towards parents, excluding the child. Furthermore, following enrollment and purchase, promotional emails will be dispatched to parents’ email addresses. This procedural mechanism highlights our strong dedication to being open and communicating responsibly.
Content Generated by a Child
We may allow Children to mark activities they like or want to attend and we may infer a Child’s interest in topics from these records in order to make recommendations. Children also share information during classes or in activities as well as when reporting emergency safety and compliance issues.
Our activities take place over online videos in which video images and audio of the Children are recorded, along with chats and messages.
Certain information is required that we need to provide the Services. Other information is optional and if not provided, Parents / Guardians and Children will still be able to participate with HeartFirst Education without any changes in the quality of Services.
Verified accounts
Once we obtain verified parental consent, we may use and share personal data collected from Children for many purposes described in our Privacy Notice and emphasized in this Notice. We recommend activities and new features to Parents / Guardians and Children based on their engagement with us.
We may send these messages within our platform or mobile apps to Children and Parents / Guardians through push notifications if Parents enable this feature.
We may also send this information via email to Parents / Guardians, along with surveys or other information related to HeartFirst Education.
We do not, however, send marketing emails to Children. Children may receive other emails, such as a notification that class is starting.
If your Child receives marketing emails, please notify us immediately so we can make sure it is marked in our system that the Child is using the Parent / Guardian email address.
We do use technology, like cookies and other trackers, to help us gather information about activities once logged into HeartFirst Education, but we do not allow third-party analytics or advertising providers to collect personal data for their own purposes of Learner. Please see our Privacy Notice for more information on our general website.
Information is shared to:
Teachers can see information such as:
Account and profile information provided by Parents / Guardians or Children
Video verification
Child communications to the teacher (Parents / Guardians will receive a copy)
Teachers, other Learners, and Guests can see information such as
Video image and voice audio and potentially background images of their home and family members (recorded and shared, too)
Children’s communications, posts, uploads, content, responses, opinions, etc.
Sometimes, Teachers or other Learners may need assistance such as an interpreter available during sessions or may have guests or other Teachers.
If Children engage in any activity, what they do is available to the other participants, whether children, Teachers, assistants, or guests, and may be available to other Parents / Guardians, as well as HeartFirst Education employees, contractors, partners, and vendors.
Chat
We’ve intentionally disabled private messaging features within our network. This step enhances security, especially for children. We prioritize their safety by ensuring that no private messaging occurs. This approach eliminates concerns related to personal information or inappropriate language. By opting in for this safeguard, we create a safer online environment for all Learners. We also recommend that parents carefully supervise their children when the children participate in online activities.
Video recordings
We record video, audio, and written communications of Children and Teachers during live classes. The class recordings are made available to the Teacher for the class and may be shared with the entire class (and their Parents / Guardians) to view. Where the Teacher is an organization, recordings may be accessed by the entire Teacher organization, and access would not necessarily be limited to one Teacher.
We may use recordings to provide feedback to Teachers, for customer support, for operational needs (such as a glitch in the recording), and for compliance, enforcement, and safety purposes.
We will obtain additional parental consent before we use recordings for promotional or other unexpected purposes.
We request that Teachers not copy the recordings or share the recordings with anyone aside from those who are permitted to have them, and also request that recordings not be downloaded or re-shared. We expect all participants to abide by our standards of conduct, but we cannot control or monitor what such third parties (other parents, etc.) ultimately do with recordings.
Third-party sites and tools
Some Teachers may ask Child Learners and their Parents to use third-party sites and services. Parents should review the privacy notices for those third-party sites and services to understand their privacy practices. These third parties are not our service providers, and we are not responsible for and may not have reviewed those third-party sites and services.
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 site, game/activity, television show, personality/character, or feature movie. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent’s email address 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.
Persistent Identifiers
When children interact with us, certain information may automatically be collected, both to make our sites and applications 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 which we define under our general Privacy Policy. This information may be collected by HeartFirst Education 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 our sites and applications
– Customize content and improve our sites and applications
– Conduct research and analysis to address the performance of our sites and applications
– Generate anonymous reporting for use by HeartFirst Education
– 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
We send a direct notice with these privacy disclosures and obtain verifiable parental consent from Parents / Guardians before collecting, using, and sharing Personal Data from their Children as described in this COPPA Notice. We follow the required processes to obtain verified parental consent to set up full accounts. Where activities are paid by an organization, other verification methods may be used to verify a parent’s identity or the school may qualify to grant consent.
Review and update information
Parents / Guardians may review and update certain of their Child’s information by logging into their account. In a Parent / Guardian account, a Parent / Guardian can review topics of interest we have inferred based on their Child’s likes and past classes or activities. Parents can choose to opt out of recommendations based on their Child’s history of participation and instead choose the learning topics they want to see.
Deletion
Parents / Guardians can also request that we delete the personal data we have collected in connection with that account.
Please keep in mind that a request to delete records may lead to termination of an account, membership, or other services.
However, if we need to keep the data for other valid reasons, such as fraud, compliance, and safety, we will not delete the information. We will continue to protect it and delete it when appropriate.
In addition, we will exercise commercially reasonable efforts to delete personal data collected from Children when it is no longer needed for the purpose for which it was collected.
We will not generally be able to guarantee a deletion from backups, but when feasible we will. If the backups are used for restoration, we will re-delete the records, based on the record of deletion requested.
No consent / revoke consent
If Parents / Guardians do not consent or withdraw consent, then we will not collect, use, or disclose any personal data about their Child, except as needed for legal compliance and enforcement purposes, and their Child will not be allowed to use the HeartFirst Kids network powered by HeartFirst Education in any way.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: support@heartfirsteducation.org
To register a complaint or concern, please contact us at: support@heartfirsteducation.org