Last Updated: April 28, 2020
Dear Doodles, Inc. (“Dear Doodles”, “we”, “us”, “our”) is dedicated to providing educational and empowerment content and a Virtual Playdates Service while protecting the privacy of children and parents.
WHAT IS “PERSONAL INFORMATION”?
PRIVACY PRACTICES FOR STUDENTS UNDER 13 YEARS OLD
Dear Doodles takes your children’s privacy very seriously. It is Dear Doodles’ policy to prohibit the collection of information from children under 13 until we first obtain parental consent from the child’s parent or legal guardian.
How Does Dear Doodles Obtain Parental Consent?
The Children’s Online Privacy Protection Act (COPPA) requires us to obtain parental consent from a child’s parent or legal guardian before we can collect personal information from children under 13 years of age. Therefore, we only collect personal information through the Services from with parental consent for that child to use the Services and disclose personal information to us.
If we discover that we are collecting information from children under 13 years old without parental consent, we will delete this information as quickly as we can. If you believe that a child’s participant under the age of 13 has violated our policy and may be participating in the Dear Doodles Services without parental consent, please notify us immediately at firstname.lastname@example.org.
Can I View My Child’s Dear Doodles Information?
Absolutely! As a parent or guardian of a Student under 13 years old, you have the ability to request information from Dear Doodles regarding the type of data being collected, view your child’s information and online activity, and, if you choose, request that we stop making further use of your child’s information.
For more information on how to do this, please contact email@example.com.
WHAT INFORMATION DOES Dear Doodles COLLECT?
Because of the interactive nature of the Dear Doodles Services, we collect different types of information that come from a variety of sources. The following section explains the types of information the Dear Doodles Services collect (including from Students under 13).
Information that You Provide to Us
- VIRTUAL PLAYDATES ENROLLMENT INFORMATION
We collect the following personal information when a parent enrolls in the Dear Doodles Virtual Playdate program:
- First and Last Name
- Email Address
- Phone Number
- Child’s/Children’s Name
- Child’s/Chidren’s Age
- INFORMATION WE COLLECT AUTOMATICALLY
There are some types of information that are collected automatically every time a user accesses the Dear Doodles Services. This automatic collection also applies to all users, including users under 13 years old. Dear Doodles records details of user activity on the Services, including the frequency of Services usage, operating systems and browsers used and IP addresses. The information we automatically collect enables Dear Doodles to improve the design, content and internal performance of our Services. We also may use this information in aggregate form in order to analyze site usage and the popularity of our Services.
Our Services also implement “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a website server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page.
You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Dear Doodles Services.
DOES DEAR DOODLES SHARE PERSONAL INFORMATION (INCLUDING INFORMATION FROM STUDENTS UNDER 13) WITH OTHER PEOPLE?
Dear Doodles respects the privacy of all participating children will not sell, rent, or purchase any Personal Information collected during the use of Dear Doodles Services. Dear Doodles will only transfer or otherwise disclose the information it collects (including from users under 13) to employees and independent contractors of Dear Doodles, its subsidiaries, affiliates, and Service Providers if the information will enable that party to perform a business, professional, or technical support function for Dear Doodles, or if required to do so by law.
We will also transfer or otherwise disclose personal information in response to judicial process, to comply with legal requirements, and, as permitted under provisions of law, to provide information to law enforcement agencies or in connection with an investigation on a matter related to public safety. We may also use your information as permitted by law to protect our rights or property, the Dear Doodles Services, or its users.
Our Service Providers provide support for the internal operations of Dear Doodles Services and are required not to disclose this information to any other third party who is not a Service Provider for any purpose.
SECURITY OF YOUR PERSONAL INFORMATION
Dear Doodles secures your personal information (including personal information from users under 13) from unauthorized access, use or disclosure through a username and password. Dear Doodles secures the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.
OUR LOCATION & DATA TRANSFERS
Our Services and the servers that make the Dear Doodles website available are governed by U.S. law, but may not be located in the country where you live. By using the Dear Doodles services, you agree to the transfer, collection, processing and use of data by Dear Doodles.
THIRD PARTY WEBSITES
Dear Doodles is not responsible for the policies, content, and practices of third-party websites to which the Services may link. Please refer to these sites’ privacy policies to learn how they collect and use personal information.
If Dear Doodles materially changes the way that it collects, uses or discloses Personal Information, we will notify users via email. In the event that Dear Doodles materially changes the way that it collects, uses, or discloses Personal Information of Students under 13, we will notify parent(s) or guardian(s) via email.
A FINAL NOTE TO PARENTS/GUARDIANS REGARDING USER POSTS:
While Dear Doodles is an online learning environment meant for educational use, it is still a service that is provided on the Internet. As with every internet-based service, it is important to be aware of your surroundings and about the information you post online. Dear Doodles encourages parents to stress the importance of and talk about online safety with their children. A great resource about talking to your children about being online can be found here: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online (July 2013).
DEAR DOODLES CALIFORNIA PRIVACY NOTICE
Please note that certain exemptions and limitations apply to your rights and Dear Doodles’ obligations under the CCPA. These rights and requirements may not apply in certain situations depending on your relationship with Dear Doodles, our other legal obligations, or as otherwise provided in the CCPA.
Personal Information We Collect. Dear Doodles collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device (“Personal Information“). The specific pieces of Personal Information we collect from a given consumer depends on how that consumer interacts with Dear Doodles. As a general matter, Dear Doodles has collected the following categories of Personal Information from Consumers within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, online identifier, Internet Protocol address, email address, account name, state identification number, or other similar identifiers.||YES|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, address, telephone number, state identification number, insurance policy number, education, employment information, financial information, medical or health insurance information.
Note that some Personal Information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.||YES|
|D. Commercial information||Records of products or services purchased or considered, other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information||Behavioral information, biological characteristics, fingerprints, and sleep, health, or exercise data.||YES|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data||Physical location or movements.||YES|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information||Current or past job history or contact information.||YES|
|J. Nonpublic education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Pt 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other Personal Information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal Information does not include (i) deidentified or aggregated Consumer information, (ii) publicly available information from government records, or (iii) information protected by certain federal privacy laws and subject to an exclusion under the CCPA.
Sources for the Personal Information We Collect. We collect the Personal Information described above from the following sources:
- Directly from you. The Personal Information we collect directly from you depends on your interactions with Dear Doodles, such as when you communicate with us, enroll your child in our services, fill out a form, or submit an inquiry to Dear Doodles.
- Indirectly from you. We collect certain Personal Information automatically from your use of the Site mobile application.
- Third parties. As described in more detail below.
Use of Personal Information. Depending on your interactions with Dear Doodles, we may use or disclose the Personal Information we collect about you for one or more of the following business purposes:
- to provide you with our services, which includes, but is not limited to, confirming your child’s enrollment to our Virtual Playdates Service and other Site features, communicating with you, ensuring that your child is receiving safe and appropriate care, and complying with licensing regulations and other legal requirements.
- for our direct marketing efforts, including when we send you marketing communications about our services that may be of interest to you, respond to your inquiries, and send you promotional messages, advertising, surveys, and other information that may be of interest to you.
- to create and maintain a trusted and safe Virtual Playdates environment (e.g., to detect and prevent fraud, abuse, or security incidents, conduct security investigations and risk assessments, enforce our policies, or comply with our legal obligations and licensing requirements).
- to maintain and improve the security and functionality of the Site by processing the Personal Information we collect automatically from your use of the Site. We use this information to personalize your user experience; ensure that our web pages appear and function properly; improve the Site, programs, products, services, advertising, and content; and perform other functions.
- for other purposes as permitted by law, such as notifying you about changes to the Site; protecting our rights and property; complying with a law, regulation, legal process or court order; or fulfilling any other purpose with your consent.
We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without notifying you.
Disclosing Personal Information. Dear Doodles may disclose Personal Information for a bona fide business purpose to the following categories of Third Parties:
- childcare center regulators.
- medical providers.
- law enforcement, regulatory and other governmental agencies.
- service providers or third parties.
- parent entities, affiliates and subsidiaries.
- cookie information recipients, subject to their respective privacy notices.
In the preceding twelve (12) months, Dear Doodles has disclosed the following categories of Personal Information for a business purpose:
- California Customer Records Personal Information categories.
- protected classification characteristics under California or federal law.
- commercial information.
- internet or other similar network activity.
No Sale of Personal Information. Dear Doodles has not sold Personal Information in the preceding twelve (12) months. If Dear Doodles ever chooses to sell Personal Information, you would have the right to opt out of the sale of your Personal Information.
Your Rights and Choices. The CCPA provides Consumers with specific rights regarding their Personal Information. The following paragraphs describe your CCPA rights and explain how to exercise those rights. Each of these rights is subject to our receipt of your verifiable consumer request (see Submit a Consumer Privacy Request ).
Right to Disclosure. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months, such as:
- the categories of Personal Information we have collected about you.
- the categories of sources for the Personal Information we have collected about you.
- our business or commercial purpose for collecting or selling that Personal Information.
- the categories of third parties with whom we share that Personal Information.
- if we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Dear Doodles is only required to respond to two disclosure requests within a 12-month period.
Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Dear Doodles is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Dear Doodles is only required by law to respond to two access requests within a 12-month period.
Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for Dear Doodles or our Service Providers to:
- complete the transaction for which we collected the Personal Information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- debug products to identify and repair errors that impair existing intended functionality.
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- comply with a legal obligation.
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Submit a Consumer Privacy Request. To exercise any of the above rights, please submit a verifiable consumer privacy request to Dear Doodles:
- by email at privacy@DearDoodles.com
- or write to us at Dear Doodles Inc., 3130 Alpine Road, Suite 288, PMB 146, Portola Valley, CA 94028.
We cannot respond to your request or provide you with Personal Information unless we can verify your identity and your authority to make the request and confirm that the Personal Information relates to you. A verifiable consumer privacy request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we have collected Personal Information or an authorized representative.
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You do not have to register with Dear Doodles to make a verifiable consumer privacy request. We will only use Personal Information provided in a verifiable consumer privacy request to verify the requestor’s identity or authority to make the request.
Dear Doodles’ Response. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Authorized Agent. You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”) may make a verifiable consumer request related to your Personal Information. If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent, and we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not do any of the following as a result of your having exercised your right under the CCPA:
- deny you goods or services.
- charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- provide you a different level or quality of goods or services.
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California Civil Code sections 1798.83-1798.84 entitles California residents to ask us for a notice that identifies the categories of Personal Information we share with affiliates and/or third parties for marketing purposes and provides contact information for such affiliates and/or third parties. If you are a California resident and you would like to request a copy of this Privacy Notice, please contact us at privacy@DearDoodles.com with the subject line “Request for California Privacy Information.”
Changes to this California Privacy Notice. We reserve the right to amend this California Privacy Notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on our website and update the effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
Contact Information. If you have any questions or comments about this California Privacy Notice, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us:
- by email at privacy@DearDoodles.com.
- or write to us at Dear Doodles Inc., 3130 Alpine Road, Suite 288, PMB 146, Portola Valley, CA 94028.
Last Updated: April 28, 2020