Collection of Personal Data from Kids.We recognize the need to provide additional privacy protections when dealing with the Personal Data of Kids. Our collection practices are in compliance with the Children’s Online Privacy Protection Act (“COPPA”).
Who Collects Personal Data. FAE is the operator of the FAE Websites under COPPA, which means that it is FAE who collects, owns and controls Personal Data on the FAE Websites. Here is FAE’s contact information:
Consent From a Parent Required under COPPA. COPPA requires FAE to obtain a Parent’s prior consent before collecting, using or disclosing any Personal Data from a Kid, unless any of the following exceptions under COPPA apply.
Exceptions. Prior consent from a Parent is not required for FAE to:
In addition, COPPA requires FAE to: (1) request new consent from a Parent in the event that there are material changes in the collection, use or disclosure of a Kid’s Personal Data collected on the FAE Websites; (2) offer a Parent the option to agree to the collection and use of a Kid’s Personal Data by FAE without consenting to the disclosure of the information to third parties; (3) collect and use only the information that is reasonably necessary to participate in an activity; and (4) allow a Parent to review a Kid’s Personal Data, ask to have it deleted and/or refuse to allow further use of it at anytime.
Personal Data Collected. The only Personal Data FAE currently collects through the FAE Websites are email addresses submitted to us when a Kid, Parent or other User submits a question to us. Because this activity falls into one of the COPPA exceptions listed above, FAE does not need to first obtain consent from a Parent to collect a Kid’s email address for this purpose as long as FAE deletes the email addresses after responding to the question. Because FAE does not differentiate between email addresses of Kids and other Users, FAE deletes all email addresses collected for this purpose after responding to the question.
When a Kid or other User uses the FAE Websites to search for information, the Kid or other User is not providing us with any Personal Data. We offer the search features as a service to Kids, Parents and other Users. FAE does not collect or retain any Personal Data about anyone who uses the search features. Non-Personal Data, however, may be collected as a Kid or other User searches the FAE Websites. The collection of Non-Personal Data is described below.
Non-Personal Data Collected. Other data that does not qualify as Personal Data because it cannot be used to contact or identify Users (“Non-Personal Data”) may also be collected when a Kid or other User participates in certain features of the FAE Websites, or may be automatically collected about the Kid or other User. For example, Kids and other Users have voluntarily submitted first name, city, state, age and favorite doll information in connection with fashion design contests on the FAE Websites. FAE is not currently running any such contests on the FAE Websites
In addition to the information voluntarily provided by a Kid, Parent or other User, FAE uses technology to collect Non-Personal Data about the use of the FAE Websites. For example, we use technology to track how many Users access the FAE Websites, the date and time of their visits, the length of their stays, and which pages they view. We also use technology to determine which web browsers our Users use and the address from which they accessed the FAE Websites (for example, if they connected to one of the FAE Websites by clicking on one of our banner ads).
This technology does not identify any User personally. It simply enables us to compile statistics about our Users and their use of the FAE Websites. FAE uses this Non-Personal Data and may share it with third parties to improve the content and functionality of the FAE Websites, to better understand our customers and markets, and to improve our products and services.
Use of Personal Data Collected. If a Kid or other User emails FAE with a question, FAE may use the entered email address to contact the Kid or other User with an answer to the question, but will then delete the email address. FAE does not use Personal Data for any other purpose and does not disclose Personal Data to third parties.
In addition, FAE may publish certain Non-Personal Data about Kids on the FAE Websites. For example, when Kids and other Users submitted design ideas, FAE published the first name, age, city, state and favorite Fashion Angels doll of the Kid or other User on the FAE Websites in connection with the design idea.
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