Six Seconds Children’s Privacy Policy
Version 2
Last Revised: August 4, 2018 

This children’s privacy policy (“Children’s Privacy Policy”) describes how Six Seconds (“Six Seconds”, “we”, “us”, and “our”) collects, uses and discloses Personal Information of users of our websites, located at http://6seconds.org/, http://eq.org/, https://tools.6seconds.org/, our mobile applications (“Applications”), and our widgets (collectively, the “Site”) and the services (“Services”) who are under 13 years of age (each a “Child” and, collectively, “Children”). As used in this Children’s Privacy Policy, “Personal Information” (which has the same meaning as “personal data” as defined in the European Union General Data Protection Regulation) means any information that can be used to contact or identify your Child (e.g., your Child’s name, email address, address, telephone number, as well as any other non-public information about your Child that is associated with or linked to any of the foregoing data).

This Children’s Privacy Policy does not apply to users age 13 or older; such users should refer to the Six Seconds Privacy Policy, available at http://6seconds.org/about/policies/privacy/.

 Children’s Online Privacy Protection Act

We are required under the Children’s Online Privacy Protection Act (“COPPA”) to obtain verifiable parental consent in order to collect, use or disclose Personal Information from Children. If you provide such consent, you agree to the collection, use and disclosure of your Child’s Personal Information in accordance with this Children’s Privacy Policy. IF YOU DO NOT PROVIDE SUCH CONSENT, YOU MAY NOT ALLOW YOUR CHILD TO USE THE SITE OR SERVICES.

Why do we need your Child’s Personal Information? We will only process your Child’s Personal Information in accordance with applicable data protection and privacy laws. We need certain Personal Information in order to provide your Child with access to the Site and Services  (including receiving preventive or counseling services directly from us). If you or your Child created a profile/registered with us, you would have been asked to check a tick box indicating your agreement to provide your Child’s data in order to access our Services, purchase our products, or view our content. This consent provides us with the legal basis we require under applicable law to process your Child’s data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your Child’s Personal Information in line with this policy, please do not use our Site or Services.

What Types of Information Do We Collect? 

Information Your Child Provides to Us.

  • During our registration process, we collect Personal Information from your Child, such as your Child’s email address, phone number, username and password.
  • If your Child contacts us via e-mail, we will collect your Child’s name and e-mail address, in addition to any other content included in the e-mail in order to send your Child a reply.
  • We collect and store any content that your Child uploads, downloads or accesses via the Site, which may include Personal Information. After registration, we will retain any information in your Child’s account and add such information to the information provided during the registration process. This will include but not be limited to information concerning eLearning, downloads, messages, and assessments.
  • We may collect your Child’s phone number and the unique device id number of the mobile device on which your Child uses the Site and Services.
  • When your Child participates in one of our surveys, we may collect additional Personal Information.
  • If your Child participates in a contest, sweepstakes or other promotion, we will collect any data your Child provides in connection with that promotion.
  • We collect information, including Personal Information, from any behavioral assessments we provide.
  • We also collect other types of Personal Information that your Child provides to us voluntarily.
  • We may also collect Personal Information at other points on the Site and Services that state that Personal Information is being collected.

 Information Collected via Technology:

  • Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from your Child, including browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your Child’s computer when using the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
  • Log Files. We collect information about the type of device your Child uses, your Child’s Open Device Identification Number (“ODIN”), date/time stamps for your Child’s visit, your Child’s unique device identifier (“UDID”), domain name, operating system, browser type, Internet service provider (ISP), referring/exit pages, operating system, clickstream data, the address of a referring site and your Child’s activity on Six Seconds. This information is not treated as Personal Information unless we combine it with or link it to any of the Personal Information listed above.
  • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your Child’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. We may use both session cookies and persistent cookies to better understand how your Child interacts with our Services, to monitor aggregate usage by our users and web traffic routing on our Services, and to improve our Services. Most Internet browsers automatically accept cookies. You can instruct your Child’s browser, by editing its options, to stop accepting cookies or to prompt your Child before accepting a cookie from the websites you visit. In addition, we use third party analytics services (e.g. Kiss Metrics) that use cookies and other technologies to analyze your Child’s use of Six Seconds. The analytics services’ ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information, and how you can opt-out of their use of such information.
  • Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Information.
  • Cookies.  “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. Our Site and Services use the following types of cookies for the purposes set out below:

Type of cookies

Purpose

Essential Cookies

These cookies are essential to provide you with services available through our Site and Services and to enable you to use some of its features.   Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Site and Services to remember choices you make when you use our Site or Services, such as remembering your login details and remembering the changes you make to other parts of our Site and Services. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site or use our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and Service and how users use our Site and Services.  The information gathered does not identify any individual visitor.  The information is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site or used our Services, whether they have visited our Site or used our Services before, and other similar information. We use this information to help operate our Site and Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. 

We use Google Analytics and other third party analytics services for this purpose. Google Analytics uses its own cookies.  It is only used to improve how our Site and Services work.  You can find out more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.  You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

You can prevent the use of Google Analytics relating to your use of our Site and Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+.  The social network will record that you have done this.

 

Information Collected from Third Party Companies. We may receive Personal Information and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Information. For example, we use Eventbrite for all of our events. Eventbrite shares the Personal Information they collect with us and we add that Personal Information to our database.

We may, and you authorize us to, rely on the instructions that we reasonably believe are given by you as a parent or guardian of your Child. For example, if a person calls our customer support number and provides the account information we request, we may assume that the person calling is the Child’s parent or guardian. We will not be held liable for any disclosure made in good faith and following reasonable procedures in responding to a request for disclosure of a Child’s Personal Information from the parent of guardian.

How Do We Use the Information We Collect?

We use the information collected from your Child (including your Child’s Personal Information) for the following purposes:

  • to provide the Services, including by providing information such as task completion rate;
  • to respond to your Child’s emails, submissions, questions, comments, requests, and complaints and provide customer service;
  • to monitor and analyze usage and trends, and to increase the functionality and user friendliness of our Services;
  • to improve our Services and to develop and improve marketing and advertising for our Services;
  • to help understand your Child’s needs and provide your Child with better assessments and tools;
  • to identify your Child as a user in our system and to facilitate the creation of and secure your Child’s account on our network;
  • to send your Child confirmations, updates, security alerts, administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services; and
  • For any other purpose that is communicated to your Child when we collect the information.

 Anonymous and/or Aggregate Data. We may also create anonymous and/or de-identified data records from your Child’s Personal Information by excluding information that makes the data personally identifiable to your Child (“Anonymous Data”). Generally, we use this Anonymous Data to gain better insight into how our Services are working and to conduct research about global trends. We reserve the right to use Anonymous Data for any purpose and disclose anonymous data to third parties in our sole discretion.

 What Information Do We Share With Third Parties?

We share the Personal Information we have collected from your Child as described below:

(a)             Users. We will share your Child’s Personal Information with other Users solely for the purpose of providing the Services. For instance, certain users — certified assessors — must have certain information, such as name, email address, and assessment information, to provide the Services to your Child.

(b)            Third Party Service Providers. We may share your Child’s Personal Information with third party service providers to: provide your Child with the Services that we offer your Child through our Site; for third party assessment tools; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Child’s Personal Information other than to provide the services requested by Company.

(c)             Affiliates. We may share some or all of your Child’s Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

(d)            Corporate Restructuring. We may share some or all of your Child’s Personal Information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Child’s Personal Information as described in this Privacy Policy.

(e)            Social Networking Sites (“SNSs”). Some of our Applications and Services may enable your Child to post content to SNSs (e.g., Facebook or Twitter). If your Child chooses to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your Child’s use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your Child’s use of any such SNSs.

(f)              Disclosure to Third Party Companies. We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Information that we collect from its customers. As a result, we may disclose your Child’s Personal Information to a Third Party Company; however, we will not disclose your Child’s Personal Information to any Third Party Company for the Third Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Child’s Personal Information that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of Third Party Companies, you should read and understand their privacy policies.

(g)             Other Disclosures. Regardless of any choices you make regarding your Child’s Personal Information (as described below), we may disclose Personal Information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Six Seconds; (c) to protect or defend the rights or property of Six Seconds or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Links to Third Party Sites or Applications

The Site or Services may contain links to other sites or applications. When you or your Child clicks on a link to any other website or location, you or your Child will leave our Site and go to another site, and another entity may collect Personal Information or Anonymous Data from your Child. Any information your Child provides on those sites or applications is provided directly to the owner of that site or application and is subject to the privacy policy of that site or application. We encourage you to read the privacy policies of every website you and your Child visits. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites. Our Children’s Privacy Policy does not apply to such sites, and we are not responsible for the content or privacy and security practices and policies of those sites.

 Security

  • For online payments, we use the payment services of Fattmerchant https://www.fattlabs.com/#/pay/sixseconds via National Processing Company (NPC) and Authorize.net . We do not process, record or maintain credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to http://www.authorize.net/company/privacy/
  • Six Seconds is committed to protecting the security of your Child’s Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Child’s Personal Information from unauthorized access, use, or disclosure. We also require your Child to enter a password to access your Account information. Please do not disclose your Child’s Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Six Seconds uses reasonable efforts to protect your Child’s Personal Information, Six Seconds cannot guarantee its absolute security.

Your Choices and Rights Regarding Information Your Child Provides.

(a)           Opt-Out. You or your Child may contact us, using the contact information below, anytime to opt out of: (i) receiving direct marketing communications, including newsletters and promotional emails or other messages from us (note that, even if you or your Child opts out of these communications, your Child may still receive messages from us regarding the administration of your Child’s account and your Child’s use of our Services); (ii) our collection of Special Personal Data; (iii) any new processing of your Personal Information that we may carry out beyond the original purpose; or (iv) the transfer of your Personal Information outside the EEA. Please note that your Child’s use of some of the Site or Services may be ineffective upon opt-out.

(b)             Changing or Deleting Your Child’s Personal Information. You or your Child may access, change, review or delete the Personal Information your Child provided us. You or your Child can also request to access, change, review, or delete the Personal Information your Child provided us by contacting us at the contact information below. IF YOU REQUEST TO DELETE SUCH PERSONAL INFORMATION, WE WILL NO LONGER ALLOW YOUR CHILD TO USE THE SITE OR SERVICES. We will delete such Personal Information using reasonable measures to protect against unauthorized access to, or use of, the information in connection with its deletion. We will take steps to delete such Personal Information as soon as practicable, but deleted information may remain in archived/backup copies for our legitimate business purposes and as otherwise required by law. Upon your request, we will delete the Child’s account and all the information and data stored for such account. We will not have any liability whatsoever for any termination of the account or related deletion of the Personal Information therein. After termination, your Child will not be able to use his or her account anymore. We will retain your Child’s Personal Information for only as long as is reasonably necessary to fulfill the purpose for which the information was collected.

(c)              Applications; De-Linking SNS. You can stop all collection of information by the Applications by uninstalling them, either through the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.  You may also de-link your Child’s SNS account (e.g., Facebook) in the “preferences” section in your account settings if you wish to de-link your Child’s Account from your Child’s SNS account. You may also manage the sharing of certain Personal Information with us when your Child connects with us through your Child’s SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how your Child may adjust our permissions and manage the interactivity between the Services and your Child’s social media account or mobile device.

If you or your Child wish to exercise any of these rights, please contact us using the contact information above. In your or your Child’s request, please make clear: (i) what Personal Information is concerned; and (ii) which of the above rights you or your Child would like to enforce.  For your Child’s protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you or Your Child used to send us your request, and we may need to verify your or your Child’s identity before implementing the request. We will try to comply with the request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you or your Child began prior to requesting such change or deletion.

How We Respond to Do Not Track Signals

We do not currently respond to “Do Not Track” signals or other mechanisms that might enable consumers to opt out of tracking on the Site or Services.

 International Users

If your Child is located outside the United States and your Child provides Personal Information to us, we may transfer such Personal Information to the United States and process it there (or any other country where we operate). By providing parental consent, you consent to the collection, transfer, use, storage and disclosure of such Personal Information as described in this Children’s Privacy Policy.

Retention. We will only retain your Personal Information until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).

 Changes

Any information that is collected is subject to the Children’s Privacy Policy in effect at the time such information is collected. From time to time, we may modify our Children’s Privacy Policy. If we make any changes, we will update the Last Revised date and post the new Children’s Privacy Policy on the Site. If we make any material changes to this Policy, we will post any modifications or changes and request verifiable parental consent in those instances in which we are legally obligated to do so. IF WE HAVE NOT RECEIVED SUCH VERIFIABLE PARENTAL CONSENT TO SUCH CHANGE WITHIN THIRTY (30) DAYS, WE WILL NO LONGER ALLOW YOUR CHILD TO USE SIX SECONDS, and we will indicate when such changes will become effective.

Contact

You may contact us regarding this Children’s Privacy Policy and our privacy practices at:

Six Seconds
PO Box 1985
Freedom, CA 95019, USA
+1 831.763.1800
[email protected]

Additional Information for European Union Users

For the purpose of applicable data protection legislation, the data controller of your Personal Information is Six Seconds of PO Box 1985, Freedom, CA 95019,. Our data protection officer and our EU representative is Tommaso Procicchiani.

Legal bases for processing

Your country only allows us to use your Personal Information on certain “legal bases”.  We generally rely on the following legal bases:

Processing purpose

Legal basis

To provide the Services
To help you share your information in the Services

You have entered a contract with us and we need to use your Personal Information to provide services you have requested or take steps that you request prior to providing services.  If you do not provide information indicated as required or mandatory within the Services, or that is otherwise necessary to provide a requested service or feature within the Services, it will not be available to you.

To personalize the Services
To send you marketing communications
To create anonymous data
For security, compliance, fraud prevention and safety
Sharing your personal information as described in this Children’s Privacy Policy

 

These processing activities constitute our legitimate interests.  We consider and balance potential impact on you and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where the impact on you overrides our interests (unless we have your consent or are otherwise required or permitted to by law).

To provide preventive or counseling services directly to a minor

 

Processing is necessary to provide minors with direct preventive or counseling services

For compliance with law; legal claims

 

Processing is necessary to comply with our legal obligations

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.

Note that different legal bases may apply to the same Personal Information when processed for different purposes.  For example, we may rely on consent where required by law, but we may rely on performance of a contract if we were to store or use photos to provide a service, or on legitimate interests if we had to review photos to investigate a complaint that a photo contained content that violated our Terms of Service.

Data Transfer

If we transfer your Personal Information out of the European Economic Area or Switzerland in a manner that requires us to apply additional safeguards to your personal information under European data protection legislation, we will do so.  Please contact us for information on any such transfers or the safeguards applied.

Complaints.  We are committed to resolve any complaints about our collection or use of your Personal Information.  If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Information, please contact us at: 6sec.org/contact  We will reply to your complaint as soon as we can and in any event, within 45 days.  We hope to resolve any complaint brought to our attention; however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.