We at Spheros Corp (“Spheros,” “we,” “us,” or “our”) are committed to protecting the privacy of children. This Children’s Privacy Notice supplements and should be read in conjunction with our main Privacy Notice, which details how we collect, use and protect information for all users.

We are committed to complying with applicable privacy laws, such as the Children’s Online Privacy Protection Act (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children to access and/or use our Platform.

Currently, we do not target or directly collect information from children or teens under the age of 18. However, our Services allow parents and guardians to provide their children’s information through our Individual Sphere Accounts, which are described in detail in our Terms of Use.

How We Collect Children’s Information

Our services require parents or guardians to create Individual Sphere Accounts, which allows the Account holder to provide information relating to their children. The types of information collected may include:

• Identifiers, such as child’s name, user name, phone number, email address, and mailing address
• Profile information, such as date of birth, gender, avatar, and interests
• Student information
• Parent contact information
• Device and usage information via cookies and other technologies of the device used to access our Platform

Individual Sphere Account holders represent that they have authority to provide information about children to our Platform. We also collect information from parents or guardians that can be used to provide verifiable parental consent for the purposes of sharing children’s information with authorized Connections. Please see our Terms of Use for more information about how our Platform works.

How We Use Children’s Information

We only use children’s information with consent of the parent or guardian (the Individual Sphere Account holder). Such purposes may include:

• To respond to your requests and to provide you with access to the Platform;
• To contact you about changes to the Site, Services, or Platform;
• To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are using;
• To enhance and improve the Platform;
• To analyze the use of the Platform;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
• For any other purposes disclosed at the time the information is collected or to which you consent; and
• As otherwise specifically described in this Privacy Policy.

Disclosure of Personal Information to Third Parties

Spheros only discloses children’s information to authorized Connections with the consent of a parent or guardian Individual Account holder. We do not disclose Children’s Information to third parties for direct marketing purposes.

We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information.

We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company with a potential purchaser and their legal and financial advisors and others, as appropriate, as part of any such actual or contemplated transaction.

We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of this Site, or anyone else that could be harmed by such activities.

How We Protect Your Information

We take commercially reasonable steps to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Accessing and Modifying Account Information

Individual Account holders have the ability to make modifications to the information they provide in their accounts in accordance with our policies. For example, age or other identifiers necessary for us to comply with applicable laws may require additional documentation to support any modifications.

We strive to help parents ensure that their children have a safe experience with our Platform. Parents or legal guardians can review any Personal Information collected about their child, have this information deleted, request that there be no further collection or use of their child’s Personal Information, or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties.

Important Notice to Users Outside the U.S.

The Platform is operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through our Platform, you consent to this transfer.

Changes to This Privacy Policy

This Children’s Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Children’s Privacy Policy from time to time and will post any changes on the Site as soon as they go into effect. By accessing our Platform or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at privacy@spheros.io, and include “CHILDREN’S PRIVACY POLICY” in the subject line.