Children’s Online Privacy Protection Act Notice

Last modified: 4/14/25

The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (as used in this policy, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information.

This policy notifies parents of:

· the types of information we may collect from children;

· how we use the information we collect;

· our practices for disclosing that information;

· our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent; and

· all operators that collect or maintain information from children through our Services.

This policy applies only to children under the age of 13 and supplements the Shiny Gems Privacy Policy located at www.shinygems.com/privacy-policy (the “Privacy Policy”). Only our general Privacy Policy applies to teens and adults.

Any capitalized term used, but not defined, in this Shiny Gems Children’s Online Privacy Protection Act Notice (this “COPPA Policy”) has the definition given to such term in the general Privacy Policy or, if not defined in the general Privacy Policy, in the End User Terms of Use, located at https://shinygems.com/end-user-terms-of-use (“EULA”).

Information We Collect from Children

All Users, including children, are required to register for a User account before they are permitted to access and use our Services. The registration process, along with the process of associating a child’s User account with the applicable Institutional Customer, requires us to collect certain information, including personal information, from the child. The use of some content and features of the Services permit or require children to provide information that could include personal information. In addition, we use certain technologies, such as cookies, to automatically collect information from our Users (including children) when they use the Services.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. 

Information We Collect Directly 

We must receive an email address for a child (or a parent) to register the child’s User account with the Services. We also require the child to create a username and password. We may request additional information from or about your child, including the child's first and last name, a parent's first and last name, the child’s role with an Institutional Customer, and the child’s external ID from the Institutional Customer, but this information is optional. We specify whether information is required or optional when we request it.

We also collect, either directly from children or from the Institutional Customer with which a child is associated, certain information to associate accounts between the Institutional Customer and its associated Users and to facilitate account administration and institutional reporting. Such information may include state, name of the organization, district, teacher, authorized administrator, organizational units, course information and topics, grade levels taught, student or participant rosters.

The Services enable Users to enter responses to questions, sometimes using free text fields. While none of the questions or prompts in the Services call for the User to provide Personal Data, the nature of these features allows children to provide Personal Data about themselves. Such information is collected and stored only for the purpose of checking the child’s answer to the question or prompt and measuring the child’s progress. The information is maintained, in accordance with the Privacy Policy, by our Services (in the system provided by the LMS Provider) until the child’s account is deleted or you request deletion on the information as provided in this COPPA Policy and the Privacy Policy.

Automatic Information Collection and Tracking

We use technology to automatically collect information from our Users, including children, when they access and navigate through the Services and use certain of its features. The information we collect through these technologies may include: 

· one or more persistent identifiers (such as User identifiers stored in cookies) that can be used to recognize a user over time and across our different websites and online services; and

· information (such as IP Address) that identifies a device's general location (geolocation information).

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online. 

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the Information Company Collects Through Automatic Data Collection Technologies section of our general Privacy Policy. 

How We Use Your Child's Information

We use the personal information we collect from your child to: 

· register him or her with the Services and validate that he or she is the proper user of Access Credentials;

· facilitate account administration by or for your child’s associated Institutional Customer;

· track and report to your child’s associated Institutional Customer your child’s progress through the Content and responses to in-Service prompts;

· enhance and personalize your child’s experience on the Services; and

· communicate with him or her about activities or features of the Services that may be of interest.

We use the information we collect automatically through technology (see the "Information Collection and Use in Education" and "Opting-out, Correcting and Updating Your Information" sections of our general Privacy Policy) and other non-personal information we collect to: 

· improve our products and services;

· enhance and personalize your child’s experience on the Services;

· facilitate the provision of updates;

· estimate our audience size and usage patterns;

· recognize your child when your child returns to our Services or uses the Services on different devices;

· store information about the child's preferences;

· secure the Services and your child’s Access Credentials;

· troubleshoot bugs and provide support; and

· communicate with you and your child for such purposes.

Student Data about your child is subject to additional restrictions on use, which are summaries in the section of the general Privacy Policy titled Student Data.

Our Practices for Disclosing Children's Information

We do not share, sell, rent, or transfer children's personal information other than as described in this section, unless you have provided written consent for us to otherwise share, sell, rent, or transfer children’s personal information. You may revoke your authorization, in writing, at any time unless we have taken action in reliance upon it. Written revocation of authorization must be sent to the address in the Contact Informationsection of the general Privacy Policy.

We may disclose De-Identified Data that is generated from information that includes Personal Data and Student Data. In addition, we may disclose children's personal information:

· to the Institutional Customer associated with your child, including all administrators designated by such Institutional Customer and other Institution Users, so that the Institutional Customer can administer your child’s account and track progress through the assigned Content;

· to third parties we use to support the internal operations of our Services, including the LMS Provider, and to other companies or persons to provide certain services, including data management, customer relationship management and promotional services, and other services related to Shiny Gems’ business and its products and services, in each case, who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential;

· if we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request, including in connection with public health activities;

· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shiny Gems, our customers or others, including to:

· protect the safety of a child;

· protect the safety and security of the Services; or

· enable us to take precautions against liability; and/or

· to law enforcement agencies or for an investigation related to public safety.

In addition, Shiny Gems may share your child’s information (including Personal Data and Student Data) with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data and Student Data held by us about our Users is among the assets transferred.

Accessing and Correcting Your Child's Personal Information

At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information. Limiting our collection or use of your child’s information, or requesting to delete your child’s information, may result in a partial or total loss of your child’s ability to use the Services or access the Content.

You can review, change, or delete your child's personal information by:

· logging into your child's account and visiting the account profile page; or

· sending us an email at info@shinygems.org. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

A list of all operators that may collect or maintain personal information from children through the Services is available below. 

· EdApp Inc., a division of SafetyCulture Pty Ltd.

· Wikipedia

· YouTube

· Vimeo

· Google

Please direct inquiries about any third-party operator's privacy practices and use of children's information through the contact information provided below:

Shiny Gems – Privacy

privacy@shinygems.com

+1 (240) 718-8144

23415 Three Notch Rd. Ste 2008

PMB 149

California, MD, 20619

United States