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 section, “Parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (a “Child” or “Children”). COPPA also requires us to obtain verifiable consent from a Child’s Parent for certain collection, use, and disclosure of the Child’s personal information. We also apply the same privacy protections to all users 15 or under. This section supplements our main Privacy Notice, applies to all Personal Information collected by PROHIT, including through the use of its website at https://prohittraining.com (the “Website”) or the PROHIT Mobile App (the “App”) (collectively, the “Services”), and takes priority with respect to Children’s information in the event of any conflict.
This section notifies Parents of:
Scope
This section only applies to Children under the age of 16 and supplements the other provisions of this privacy policy.
Information We Collect from Children
Children can access many parts of the Services and our content and use many features without providing us with personal information. However, some content and features require us to collect certain information, including personal information, from them. Once full, verifiable parental consent has been obtained, children may share personal information with coaches and share their swing videos with other platform users. We may use limited automatic collection technologies strictly for the Service’s internal operations (for example, to maintain or analyze the functioning of the Services, perform network communications, authenticate users, or personalize content) without creating profiles for behavioral advertising. We do not use such technologies or any automatically collected information to build a profile of a child or serve targeted advertising to Children.
We collect only as much information about a Child as is reasonably necessary for the Child to participate in an activity, and we do not condition the Child’s participation on the disclosure of additional personal information.
Information We Collect Directly
To obtain parental consent when a child wishes to register for an account, we collect the Child’s first name, date of birth (to establish age), the Parent’s name, and the Parent’s email address. We may also collect a Parent’s mailing address or phone number as needed to complete verifiable parental consent.
The following information is collected from a child with full, verified parental consent:
A non-personal username, state, and Zip Code.
Athletes can enter their education information and write a short biography.
The following will be visible on the platform to other users:
Height, weight, and graduation year will be visible only to coaches.
Athletes can upload videos of their swing to receive AI metrics and feedback on their performance. These are visible on the platform but not disclosed to any third parties or used to train any third-party AI models. They can also receive push notifications related to the service.
To obtain full, verifiable parental consent, we have partnered with PRIVO, a leading privacy solutions expert and an FTC-approved COPPA Safe Harbor. All information collected for verification is stored securely and used only for that purpose. For more information on PRIVO, please see here: https://www.privo.com/platform-privacy-policy.
All users must also verify their identity with our privacy partner during registration.
Information collected prior to consent is used solely to contact the Parent and complete verifiable parental consent.
Children cannot participate in messaging or chat features.
Automatic Information Collection and Tracking
We automatically collect limited information when Children use the Services strictly for the Services’ internal operations (for example, to maintain or analyze the functioning of the Services, authenticate users, or protect the security and integrity of the Services). We do not use this information to track Children across third-party websites or to serve targeted advertising to Children.
We store data in AWS and use Firebase Analytics in our app to better understand Children’s use of the service. These providers do not use the data for any other purpose and do not disclose it further.
Firebase Analytics collected the following information from users:
For more information on these providers, please contact us here: <insert contact email address>.
Geolocation.
We do not collect precise geolocation information from Children without verifiable parental consent and a clear, limited purpose necessary for the feature requested by the Parent or Child. Any permitted use will be limited to internal operations and security and will not be used for behavioral advertising.
How We Use Your Child’s Information
We use a Child’s personal information only as reasonably necessary to: (1) register and maintain the Child’s account; (2) provide requested features and Services; (3) communicate with the Parent about the Child’s account and parental controls; (4) ensure the security and integrity of the Services; and (5) conduct internal analytics to maintain or improve the Services. We do not use Children’s personal information for targeted advertising or for advertising-related profiling.
Our Practices for Disclosing Children’s Information
We do not share, sell, rent, or transfer Children’s personal information except as described in this section. We may disclose aggregated or de-identified information that does not identify any individual or device.
In addition, we may disclose Children’s personal information:
No Sale or Sharing of Children’s Personal Information.
We do not “sell” or “share” (for cross-context behavioral advertising) Children’s personal information. We do not permit third-party behavioral advertising on any child-directed features of the Services.
Parental Consent and Controls
At any time, a Parent may refuse to permit our further collection or use of the Child’s information, and may direct us to delete the Child’s information, as described below.
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 to collect any further information or otherwise use the Child’s information.
You can review, change, or delete your Child’s personal information by:
To protect your privacy and security, we will require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
Data Retention.
For information about our data retention, deletion, and destruction practices, please see our Data Retention Policy, available here.
Data Security.
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U.S. State Privacy Rights
California.
We do not sell or share (for cross-context behavioral advertising) Children’s personal information. Parents may exercise rights to know/access, delete, and correct their Child’s information by contacting us as described above. We will verify the parents’ identity and authority before processing requests. Our website honors Global Privacy Control signals for applicable browsers and devices. No sale/sharing applies to Children’s data regardless of GPC settings.
Other U.S. States.
For residents of other U.S. states with applicable privacy laws, Parents may exercise available rights regarding the Child’s information using the methods in our Main Privacy Notice. We will apply child-protective defaults and will not process Children’s personal information for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.
Changes to This Children’s Policy
We may update this Children’s policy from time to time. Please see the “Last Updated” date above and our Main Privacy Notice for information about changes. Material changes will be notified to Parents where required by law.
Contact Us
If you have questions about our Children’s privacy practices or this policy, please contact us at app@prohittraining.com
