Coppa Direct Notice for School Services
This COPPA Direct Notice for School Services (this “notice”) is provided pursuant to the Children’s Online Privacy Protection Act (“COPPA”) and provides information about Playbl’s collection, use, and disclosure of personal information collected from students under age 13 (“Students”) who use Playbl’s products and services provided to teachers, schools, and school districts (“Schools”) as part of an educational curriculum under the oversight of the School (“School Services”).
This notice does not apply to users of our products and services who (i) are age 13 or older; or (ii) use our products and services outside of the context of School Services.
By executing an order form, services agreement, or similar document with Playbl for School Services, the School provides consent, on behalf of its Students’ parents or legal guardians, to Playbl’s collection, use, and disclosure of personal information from and about Students through the Services in accordance with applicable law, including COPPA.
It is the School’s responsibility to ensure that Students’ parents/legal guardians receive copies of this Direct Notice and our Children’s Privacy Policy.
Student Information We Collect
In this notice, "Student Information” means any information that is considered “personal information” under COPPA that is collected from Students in connection with their use of the School Services. The School Services use the power of games to improve health outcomes. To provide the School Services, we collect the following information to allow Students to register for and play our games: the child's first name, and last name, email address, class/roster information. We also require the child to create a username and password. We may also collect IP address, mobile advertising ID, media access control (MAC) address, identifiers associated with cookies, pixels, tags, beacons, scripts or other similar technology, and other information that is collected automatically through a Student’s use of the School Services.
We may request additional information from Students, but this information is optional. We specify whether information is required or optional when we request it.
How We Use Student Information
Student Information. We may use Student Information collected through the School Services to:
- Register with the School Services;
- Perform our contractual obligations and provide the School Services;
- Provide support and respond to requests;
- Communicate about activities or features of the School Services that may be of interest;
- Track performance in games or other activities;
- Administer pre and post-game surveys (however, this information is de-identified and is not stored with personal information);
- Debug the School Services to identify and repair errors; and
- Maintain and improve the School Services.
Except as noted above, We do not use Student Information collected through the School Services for our own commercial purposes.
De-Identified Data. We may use de-identified data, including aggregated data, for any lawful purpose, including, but not limited to, the development, research, and improvement of our sites, services, or applications, and to demonstrate the effectiveness of the School Services.
Retention and Deletion. Schools may delete or remove Student Information from the School Services, and we will delete Student Information when such Student Information is no longer needed for the purpose for which it was collected.
How We Share Student Information
We share or disclose Student Information in the following ways:
- Parents and Teachers: We will disclose Student Information: (a) to each Student’s individual teacher(s) and parent(s)/guardian(s); and (b) as directed by the School.
- Third-Party Service Providers: We disclose Student Information to third-party services providers that assist us with internal operation of the School Services.
- Law or Legal Process: 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, we will disclose Student Information as required. We may also disclose Student Information to law enforcement agencies or for an investigation related to public safety.
- Business Needs: Additionally, if Playbl, Inc. is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of its assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer Student Information to the buyer or other successor.
Consent
We rely on consent obtained from the School, acting as an agent of the parent(s) or legal guardian(s) of the School’s Students, as permitted by COPPA, for using School Services in connection with Students under 13 years of age. By executing a services agreement with Playbl for School Services, the School represents and warrants that it has obtained all consents from Students as required under applicable law. The School must maintain records of all such consents and provide them to us if we request them.
Rights and Privacy Choices
Access, Correct, Delete, and Control Use of Student Information. We support Schools’ ability to access, correct, and delete personal information of Students. In some cases, the School can fulfil the request itself using the School Services. Alternatively, if you have any questions or concerns regarding this notice, or if the School would like to access, correct, or delete Student Information on behalf of the School or pursuant to parent/guardian requests in accordance with COPPA (or in accordance with FERPA, or other applicable laws), please contact us at support@playbl.com.
Children’s Privacy Policy
For more information about our privacy practices with respect to children, please read our Children’s Privacy Policy.
Contact
If you have questions about this notice or our privacy practices, please contact us at support@playbl.com.