The Elizabeth Dole Foundation (“EDF” or “we”) is committed to protecting the privacy of children who use our site. The Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to the 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”) and outlines our practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit the Federal Trade Commission’s website.
THE INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
EDF offers to its user a site, in which some content may be targeted at children. Our site offers a variety of information, including program applications 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. These instances include but are not limited to: applying to participate in EDF programs, submitting content to EDF, and participating in EDF’s online communities. 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, in many cases, register with our sites and applications to view content and participate in EDF programs, among other things. During the registration process, we may ask the children provide certain information for notification and security purposes, including a parent or guardian’s email address, phone numbers, addresses, and the child’s first name and gender. We may also ask for birth dates from children to validate their ages. We strongly advise children to never provide any personal information. Please note that children can choose whether to share their information, but participation in certain programs require such information. As a result, children may not be able to participate in certain programs 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.
- 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 child 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 privacycontact@elizabethdolefoundation.org. 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 content.
Content Generated by a Child
Certain activities allow children to create content. 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 any activity potentially allows a child to insert personal information in their created content, we will either prescreen the submission to delete any personal information, or we will seek verifiable parental consent by email for collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, EDF 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 Consent. In the event EDF wishes 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 event EDF collects 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 is not limited to requiring a signed consent form by mail, email attachment, or fax.
- 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 education record under the Family Education Rights and Privacy Act (FERPA), please visit the U.S. Department of Education’s website.
Geolocation Data
If a child-directed EDF site collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
Persistent Identifiers
When children interact with us, certain information may automatically be collected for various purposes related to our business. Examples include the child’s IP address, the web browser, 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 EDF or by a third party. This data is principally used for internal purposes only, in order to:
- Provide access to our site
- Improve our site
In the event we collect (or allow others to collect) such information from children on our site 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 the operator’s privacy policies and collection and use practices:
Elizabeth Dole Foundation
600 New Hampshire Ave, NW
Suite 1020
Washington, DC 20037
Phone: 202-249-7170
Email: privacycontact@elizabethdolefoundation.org
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 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 CHOICE AND CONTROLS
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular activity and can request that we delete from our records the personal information that we have collected in connection with that activity. Please keep in mind that a request to delete records may lead to termination of a service or participation in a program.
Where a child had registered for an EDF program, we allow parents to access, change, or delete the personally identifiable information that we have collected from their children by sending an email to privacycontact@elizabethdolefoundation.org. A valid request to delete personal information will be accommodated within a reasonable time. In any correspondence, please include the child’s name and the parent’s email address and telephone number. To protect the children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.