Updated March 2021
This Children’s Privacy Policy outlines our practices with respect to the personal data of children. We understand the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction (“Children” or “Child”). That is why Luminary ROLI Ltd (“we”/”us”/”ROLI”) has implemented additional processes and protections to help keep Children's personal data safe.
We support the Children's Online Privacy Protection Act (“COPPA”) and the General Data Protection Regulation and the UK GDPR (together, the "GDPR"). Our goal is to minimize the information gathered from and disseminated about Children while permitting them active participation in the Platform.
ROLI does not knowingly collect, use or share personal data from Children unless we obtain verifiable parental consent or a COPPA exception applies.
Account set up:
Consistent with the requirements of COPPA and the GDPR, in any instance where we ask for age and determine the user is age 13 or under in the US, or Children aged 16 or under anywhere else in the world, for certain ROLI services and products, we will obtain verifiable parental consent before the Child may use such ROLI products and services. In those cases, if a Child wants to register to create an account to use the Platform, we require the Child to submit the following information so we can obtain verifiable parental consent:
Their parent’s email, which we use to ask for that parent’s consent
Child’s Email;
Child’s First name
Child’s Surname
Child’s Username
Child’s Password
Direct Notice:
After we obtain such information, we will send the parent a direct notice. In the direct notice, we will explain what information we are collecting and how it may be disclosed, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent’s contact information and any other information collected from the child in connection with that activity. If you believe your child is participating in an activity that collects personal data and you or another parent/guardian have NOT received an email providing notice seeking your consent, please feel free to contact us via our support page. We will not use parent emails provided for parental consent purposes to market to the parent unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact
Collection and use of Children’s information for internal purposes:
ROLI only uses your Child's information for providing and improving our Platform, including;
To create and maintain the Child's account
To communicate important notices
Send product and service information and notifications
Provide services and content
Troubleshooting
Improve our products and services
Auditing
Data analysis and research
ROLI does not share Childrens’ personal data with any third parties except to the extent it is required to share with our data processors under the duty of confidentiality in order to provide the Platform and for no other purposes, as permitted by law in order to comply with legal obligations or to protect the rights and safety of ROLI and its customers. ROLI takes all steps reasonably necessary to ensure that children's data is treated securely, with adequate protections when engaging processors on our behalf.
Limited Users:
ROLI offers only a limited version of the Platform for certain ROLI products and services for children under the age of 13 who are located in the US, or children under the age of 16 who are located anywhere else in the world (collectively called “Limited Users”). This limited version of the Platform restricts certain features and options to ensure that ROLI does not collect any personal data from the Limited User other than as provided for in this paragraph. Except in the case of responding to a specific request to register or support ROLI products from a Limited User, as more fully described below, ROLI does not collect or store any personal data from such Limited Users, apart from a persistent identifier that is used only for support of the internal operations of the ROLI Platform. The persistent identifier is not used or disclosed to contact the Limited User, including through behavioral advertising; to amass a profile on the Limited User; or for any other purpose other than internal operations. Internal support operations include the following:
Providing the Limited User with limited access to the Platform
Communicating important notices
Collecting anonymous information about how the Limited User uses our services and products
Administering our Platform and for internal operations, including troubleshooting, data analysis, testing, and research
Improving our Platform to ensure that content is presented in the most effective manner for the Limited User
Keeping our Platform safe and secure
In the event a Limited User wants to register their ROLI products to use ROLI software or has a support query, then, upon request from the Limited User, ROLI may collect the Limited User’s email address, and that Limited User’s parent’s or guardian’s email address. ROLI will then send the parent or guardian notice and an opportunity to opt-out of the collection of the Limited User’s email address. ROLI will only use the Limited User’s email address in order to respond to their specific request to register ROLI products. The Limited User’s email address will not be used for any other purpose and will not be disclosed or combined with other information. ROLI does not collect any other personal data from a Limited User except as described in this Privacy Policy. As a parent or guardian of a Limited User, you may opt-out of allowing ROLI to collect the Limited User’s email address, which will opt them out of the service, by following the link in the notice you receive from ROLI, or otherwise by contacting ROLI through our support page.
ROLI does not share Limited Users’ personal data with any third parties, except to the extent it is required to share with our data processors under the duty of confidentiality in order to provide the Platform, in order to comply with legal obligations or to protect the rights and safety of ROLI and its customers. ROLI takes all steps reasonably necessary to ensure that your data is treated securely, with adequate protections when engaging processors on our behalf.
If you are a parent or guardian of a Limited User and become aware that your child has provided personal data to us other than as provided in this privacy policy, or otherwise want to opt-out of ROLI’s limited use of your child’s email address, please contact us via our support page.
Questions, comments and requests regarding this privacy policy are welcomed and should be sent via our support page.