(Effective September 21, 2020)
The American Printing House for the Blind (“APH”, “we”, “us”, and “our”) offers children access to some of its interactive online websites, applications and services. 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 personally identifiable information from children under the age of 13 (“children” or “child”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personally identifiable information. Depending on your child’s activities when using or accessing our website or applications (collectively, “Services”), you may from time to time be required to agree to additional terms and conditions.
- 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 personally identifiable information from children, including how a parent may revoke consent.
- All operators that collect or maintain information from children through these Services.
Information We Collect from Children
Children can access many parts of the Services and its content and use many of its features without providing us with personally identifiable information. However, some content and features are available only to registered users or require us to collect certain information, including personally identifiable information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or 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 personally identifiable information than is reasonably necessary.
If we learn we have collected personal information from a child in a manner inconsistent with COPPA’s requirements, we will either delete that personal information or seek parental consent.
Information We Collect Directly
A child may provide us with the following information to register with the Services:
- Registration Information: Children may be able to register with an online service to view content, download apps, and more. We may ask the child to provide a screen name (that does not include the child’s name) and password. We may also request information for notification purposes, such as a parent or guardian’s email address, the child’s first name. We may ask for a child’s email address for purposes of generating a password reminder. In such cases, unless we otherwise obtain consent or notify the parent of ongoing communications (as discussed below), we will hash such email address such that it can only be used as a password reminder and cannot be used to contact the child.
- Email Address for One-Time Response: We may ask for a child’s email address or other online contact information in order to respond to a question or request from a child. We will delete this information after responding to the question or request. If an online service allows children to create accounts by providing name and email address, we will first seek parental consent as required by COPPA.
- Information to Obtain Parental Consent: We may ask a child for a parent’s email address or other permissible contact information in order to request consent. If we do not receive parental consent within a reasonable time, we will delete the contact information and any other related information collected from the child. We may conduct other methods of parental consent permitted by COPPA, including asking a parent to speak to a customer service representative by phone or video, or requiring submission of a signed consent form.
- Social Features: We enable registered users to communicate with others on or through these Services through chat, email, games, other social features, and posting to public areas of the Services (“Social Features”). The nature of these features allows children to disclose personally identifiable information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.
- Persistent Identifiers: Our online services may automatically collect persistent identifiers for internal operations, including to provide and improve our online services, conduct analytics, authenticate users, personalize content, maintain the security and integrity of the service, and to ensure legal or regulatory compliance. Specifically, we may collect Internet protocol or IP address, pages and content visited, the type and version of operating system or web browser, device ID. We, or our third-party service providers, may collect this information using HTTP cookies, flash cookies, HTML5 and Flash local storage, web beacons/GIFs, embedded scripts, and ETags/cache browsers (“Cookies”).
How We Use Your Child’s Information
We use the personally identifiable information we collect from your child to:
- register him or her with the Services;
- communicate with him or her about activities or features of the Services that may be of interest;
- track his or her performance in lessons, games or other activities;
- provide technical support for our Services.
We may use the information we collect automatically through technology and other non-personally identifiable information we collect to improve our Services and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about the child’s preferences, allowing us to customize the content according to individual interests.
- Speed up your searches.
We use geolocation information we collect only to provide our Services.
Our Practices for Disclosing Children’s Information
We do not share, sell, rent, or transfer children’s personally identifiable information other than as described in this section.
We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children’s personally identifiable information:
- To third parties we use to support the internal operations of our Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
- Upon request, we disclose personally identifiable student data information only to administrators designated by the state or local education agency that is responsible for collecting its respective Federal Quota student census information submitted to APH.
- 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.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of APH, 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.
- To law enforcement agencies or for an investigation related to public safety.
In addition, if APH is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of APH’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personally identifiable information we have collected or maintain to the buyer or other successor.
Social Features. The Services may offer social features, including instant messaging, chat, email, posting on message boards, and any other features, that enable children communicate with others on or through the Services. We do not control the types of information your child can send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of social features to ensure they do not disclose their personally identifiable information through them.
Accessing and Correcting Your Child’s Personally Identifiable Information
At any time, you may review the child’s personally identifiable information maintained by us, require us to correct or delete the personally identifiable information, and/or refuse to permit us from further collecting or using the child’s information.
If: (a) you have questions or comments about our Policy; (b) wish to make corrections to any personally identifiable information provided by you or your child; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our affiliated companies; (d) wish to withdraw your consent to sharing your child’s personally identifiable information with others; or (e) you have other privacy related questions or concerns. You can review, change, or delete your child’s personally identifiable information by contacting us at:
American Printing House for the Blind
ATTN: Office of Technology/CIO
1839 Frankfort Avenue
Louisville, KY 40206
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.
Operators That Collect or Maintain Information from Children
A list of all operators that may collect or maintain personally identifiable information from children through the Services is available below. Please direct your inquiries about any operator’s privacy practices and use of children’s information to the operator at its contact information provided.
410 Terry Ave North, Seattle, WA 98109-5210
Attention: Legal Department
1600 Amphitheatre Parkway
Mountain View, CA 94043 USA
Phone: +1 855 696 1131 (USA)
St John’s Innovation Centre
Cowley Road, Cambridge, CB4 0WS
One Microsoft Way, Redmond, WA 98052
Or contact Privacy at Microsoft.
1 Curiosity Way
San Mateo, CA 94403
Or contact to submit a Personal Data Rights Request.
Zoom Video Communications, Inc.
Attention: Data Privacy Officer
55 Almaden Blvd, Suite 600
San Jose, CA 95113
One Apple Park Way
Cupertino, CA 95014
Mightily (website vendor)
111 W. Main St. 202
Louisville, KY 40202
Novus Insight, Inc. (website vendor)
222 Pitkin Street
East Hartford, CT 06108