CHILDREN’S ONLINE PRIVACY POLICY

StelloGirls LTD (“StelloGirls”) is committed to protecting the privacy of children who use our website and mobile application (“Application”) (collectively, “StelloGirls Services”). This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children (who, for the purposes of this policy are persons under the age of 13 in the United States, and under the age of 18 in all other countries), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

1.              The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents

The StelloGirls Services are targeted at children ages 9-16. The StelloGirls Services offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

In collecting personal information from children, we take certain additional steps to protect children’s privacy, as further explained below, including:

  • Notifying parents about our information collection, retention, and sharing practices.
  • Obtaining the necessary consent from parents under applicable law for the collection, retention, and sharing of children’s personal information.
  • Limiting our collection of personal information from children to that which is necessary to participate in a particular activity.
  • Permitting parents to access information we have collected from their children and allowing them to request that the personal information be changed or deleted.

2.              Registration

Children can register with some of the StelloGirls Services to view and create content, play games, interact with other users, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s account username, and password. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.

Children over the age of 13 may be able to connect and sign-in to a third-party social network account (such as Facebook) via StelloGirls, to perform social-network actions such as “share,” with respect to content available and/or created using the StelloGirls Services. For this purpose, we will collect the child’s email address associated with that third party, and any information the child has made public in connection with that service or which the third party shares with partner services. The social network’s use of information related to such actions is governed by that social network’s privacy policy and controlled by the social network, not by this policy or StelloGirls. You or your child may disconnect your child’s StelloGirls account from your child’s social network account at any time.

About the collection of parent email address: We will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at info@stellogirls.com. 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.

3.              Content Generated by a Child

Children who register an account with StelloGirls will be able to create or manipulate content and save it with StelloGirls. Some of this content may include personal information. Examples include audio recordings (which may include your child’s voice) and stories or open text fields written or filled in by your child. Children may have the option to export content they create and save it to their mobile device.

Other activities available through the StelloGirls Services do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent.

4.              Comment

Certain StelloGirls games and activities allow users to communicate directly with other users by means of a comment system. We strongly encourage children who use these interactive features on StelloGirls Services never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.

5.              Contests and Sweepstakes

For contests and sweepstakes, if we require only the information that the parent has already consented to StelloGirls collecting from your child (such as username and email address), we may not request additional consent. We will, however, contact the parent for more personalized information for prize-fulfillment purposes if the child wins the contest or sweepstakes.

Some contests and sweepstakes ask the child to submit her own created content as part of the child’s entry. Please see Content Generated by a Child above for more information on our collection, notice, and consent policies.

6.              Email Contact with a Child

On occasion, in order to respond to a question or request from a child, StelloGirls may need to ask for the child’s online contact information, such as an email address, when the parent has not already provided consent to collect this information. In these instances, StelloGirls will delete this information immediately after responding to the question or request. If StelloGirls collects a child’s e-mail address for other purposes, StelloGirls will contact the parent and obtain verifiable parental consent as required by law.

7.              Push Notifications

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will obtain verifiable parental consent if we collect your child’s identifier in order to send a push notification.

8.              Geolocation Data

If any StelloGirls Services collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek verifiable parental consent.

9.              Persistent Identifiers

When children interact with us, certain information may automatically be collected, both to make the StelloGirls Services more interesting and useful to children and for various purposes related to our business. Examples include the type of device operating system, the child’s mobile device identifier, the IP address of the computer, the frequency with which the child visits various parts of the StelloGirls Services, and information regarding the online or mobile service provider. This information is collected using technologies such as unique identifiers. This information may be collected by StelloGirls or by a third party. This data is principally used for internal purposes only, in order to:

  • provide children with access to features and activities on StelloGirls Services.
  • customize content and improve the StelloGirls Services.
  • conduct research and analysis to address the performance of the StelloGirls Services.
  • generate anonymous reporting for use by StelloGirls.

In the event we collect (or allow others to collect) such information from children through the StelloGirls Services for other purposes, we will notify parents and obtain consent prior to such collection.

Please contact Guest Services at the mailing or email address below with questions about the operators’ privacy policies and collection and use practices:

StelloGirls
8 Hasadnaot St., Herzeliya, Israel
Email: info@stellogirls.com

10.           When Information Collected From Children Is Available To Others

In addition to those instances where a child’s personal information is posted publicly (after receiving parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:

  • We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
  • We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using the StelloGirls Services; (iii) to protect the security or integrity of the StelloGirls Services, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

11.           Parental Choices and Controls

StelloGirls offers parents a number of ways to protect their child’s privacy. At any time, parents can access and alter the privacy settings on their child’s account through the StelloGirls Application. This setting enables parents to limit the kind of information obtained by StelloGirls and the ways in which it can be used. Please be aware that certain personal information may need to be shared with third parties for use of certain features or areas of StelloGirls, and if you opt out of allowing us to share such information with third parties, certain features or access to StelloGirls may be disabled.   

Parents also can refuse at any time to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Once we complete processing your request, the StelloGirls account and the account information provided during registration will be removed from our servers. When processing your request, we may require that you provide us with additional information to verify your identity.

Where a child has registered for a StelloGirls account, we use two methods to allow parents to access the privacy settings, change, or delete the personally identifiable information that we have collected from their children:

A.            Parents can request access to the privacy settings on their child’s account and to change or delete their child’s personal information by logging on to the child’s account through the StelloGirls Application. Parents will need their child’s username and password. 

B.             Parents can contact StelloGirls Guest Services to request access to the privacy settings on their child’s account or to change or delete their child’s personal information by sending an email to us at info@stellogirls.com.

Your mobile device may enable you to further restrict your child’s ability to use and/or make purchases through StelloGirls.

Mobile application stores through which the StelloGirls Application may be available generally require an adult mobile device owner to register to download or make purchases. The Application may offer options to visit an online store to make a product purchase within the Application. You should familiarize yourself with the policies of the mobile application store through which you download the StelloGirls Application.

We encourage you to spend time with your children when they are online or using any mobile device so you understand StelloGirls and the activities your children are engaged in, and to adopt available device and browser controls that reflect your preferences about your children’s ability to access StelloGirls or to make purchases online.

Parents of StelloGirls users may contact StelloGirls directly at:

StelloGirls Ltd.
8 Hasadnaot St., Herzeliya, Israel
Email: info@stellogirls.com

In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.