Updated March 2021
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:
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;
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.
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:
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.