Some transactions log only a PRIVO-generated identifier
In some cases PRIVO may collect or maintain no personal information and log only a PRIVO-generated service identifier as a record of a transaction processed through the Platform. This is a limited scenario rather than a promise that all Platform use avoids personal information.
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Supporting quotations
In some cases, we may not collect or maintain any personal information and only log a PRIVO generated service identifier as record of a transaction processed by an online service provider’s use of the Platform.
Qualifications & exceptions
Applies only in some cases.
Data Access & Collection · Company practice
PRIVO may collect a child’s account details for a client service
When a child below the age of consent starts an account process for a client service, PRIVO may collect the child’s first name, date of birth, username, moderated display name and password on the service’s behalf. In some instances it may also collect gender, grade, the child’s email and a parent or guardian email to seek verifiable consent for the child’s service use.
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Supporting quotations
A child below the age of consent may begin the process of engaging with a service that needs to record its' compliant handling of data to initiate an account for a client service using the Platform. On behalf of the service, PRIVO may collect the following:
Child first name
Date of birth
Username
Moderated display name
Password
In some instances, the following information may also be collected:
Gender
Grade
Child email address
Parent / Guardian email to seek verifiable consent in the manner described above, for the child’s use of the service.
Qualifications & exceptions
The additional gender, grade and email information is collected only in some instances.
PRIVO limits collection to what participation reasonably requires
PRIVO says it does not collect more information than reasonably necessary for a child or any individual to participate in an activity. A client service may collect additional child information or request that PRIVO do so, with disclosure in the client’s privacy policy and Platform notice.
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Supporting quotations
PRIVO does not collect more information than reasonably necessary for a child or any individual to participate in an activity. The online service using the Platform may collect or request the Platform collects additional information from your child and will disclose this to you in its privacy policy and the Platform notice.
Qualifications & exceptions
Client services may collect or request additional information, disclosed in their policy and Platform notice.
PRIVO may collect parent account and contact details
On a client service’s behalf, PRIVO may collect parents’ and guardians’ first name, birth date, username, password and email. When necessary it may also collect last name, display name, a child email for the child account, a physical address for uses such as catalogues, magazines and rewards, and a mobile number for authentication and communication.
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Supporting quotations
On behalf of the online service, PRIVO may collect the following from parents and guardians:
First name
Date of birth
Username
Password
Email
The following information may also be collected from a parent or guardian when necessary:
Last name
Display name
Child email address for child account
Physical address that could be used for such things as toy catalogues, magazines, and rewards
Mobile phone number for account authentication and communication
Qualifications & exceptions
The second group of details is collected when necessary.
Data Access & Collection · Procedure
Parents may verify adulthood through financial, identity or video methods
Before asserting a parent–child relationship, a parent may be asked to choose an adulthood-verification method based on available technology. Options may include a credit-card monetary transaction, banking information, partial SSN with last name and address, birth date and/or postal code, a driver’s license number with full name and address, a trained-verifier video call, or other data reasonably designed to identify the user and parental status.
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Supporting quotations
Before asserting a parent/guardian child relationship, a parent may be asked to verify they are an adult by choosing a method in light of available technology that may include one of the following:
A credit card number in conjunction with a monetary transaction
Banking information
Partial social security number in conjunction with their last name, address, date of birth and/or postal code
A driver’s license number in conjunction with their full name and address
Video conference with a trained verifier
Or other data that is reasonably designed to identify the user and their parental status
Qualifications & exceptions
Methods depend on available technology; the list is not exhaustive.
Not stated here
Linked verification-data and parent-information pages are not supplied here.
Data Access & Collection · Company practice
Smart Age Gate collects age and device details
When a service uses PRIVO’s Smart Age Gate, PRIVO collects age or date of birth plus device type and model, operating system, browser, local time zone and nonpersonal data such as screen resolution and window size. Users disputing an incorrectly entered birth date must verify their age with one of the described methods to correct it.
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Supporting quotations
If a service uses PRIVO’s Smart Age Gate™ to provide the users with an appropriate privacy protected experience, age or date of birth is collected along with device type and model, operating system, browser and local time zone along with some other non-personal data such as screen resolution and browser window size.
If a user enters the wrong date of birth and wishes to dispute and correct their already-provided age, they will be required to verify their age using one of the methods outlined above.
Qualifications & exceptions
Applies when the client service uses Smart Age Gate; correcting a disputed age requires verification.
Data Access & Collection · Company commitment
PRIVO lists categories it does not collect
PRIVO says it does not collect precise geolocation, and says it does not collect health or biometric, sensitive or behavioral data or student records from pre-K–12 students. It also says it does not collect free or reduced lunch status. These statements concern PRIVO’s Platform rather than the separate practices of client services.
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Supporting quotations
PRIVO does not collect precise geo location data, nor does it collect health or biometric, sensitive or behavioral data or student records from pre-K - 12 students. PRIVO does not collect free or reduced lunch status.
Qualifications & exceptions
The pre-K–12 student wording is retained for the health, biometric, sensitive, behavioral and student-record list.