Updated: April 19, 2016
Grom Social is designed specifically for children under the age of 17. We are dedicated to protecting their privacy and handling any personal information we obtain with care and respect. COPPA requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age. COPPA also requires that we obtain the consent of parents and guardians of children under 13 years of age prior to allowing them to use certain features of our website. Below we explain how we do that for these children. Also, when we use the term "parent" below, we mean to include legal guardians. When we use the term "personal information" or "personally identifiable information", we mean information that can specifically identify your child.
1. THE INFORMATION WE COLLECT
To ensure that Personally Identifiable Information ("PII") is not collected from your child without your permission, children must be registered as members with parental consent. You or your child may start the registration process by signing up to become a member, but in all cases, the child's Trial Grom account will be pending and the child will have limited access to the website until a parent provides their consent for participation and collection of PII by completing the registration process.
Children must be registered members to access the website.
Requested information at time of registration sign up for children ages 5 - 16:
(1) Date of Birth (required): to clarify the age of the person interested in membership.
(2) Username "Grom Name" (required): The name the child uses to log into GromSocial.com, and the name that will be visible to other Grom Social members once registration is complete.
(3) Parent email address (required): The parent email address is used to contact and inform the parent about the child's wish to participate in Grom Social, provides a way for parents to provide consent, allows parent access to their parent portal, and provides parents access to remove their email and child's account from our system.
(4) Password (required): This is secret and only known by the user.
The Registration Process and Account Types
Once the initial sign up process is completed, the child is granted a Trial Grom Account, and the parent is emailed for account activation and/or approval. Trial Grom accounts are valid for 7 days from the first login; however, if parental consent is not granted by account activation and/or approval within 10 days of account sign up, the Grom Social Profile and all associated information will be deleted. Trial Grom members have limited access to website features as noted below.
Parents provide verifiable parental consent using one of three methods that are approved by COPPA (Child's Online Privacy Protection Act).
1. Phone Call to our registration hotline: A parent or guardian can call 1-866-618-GROM (4766) to speak with one of our trained Grom Social representatives. Our representative will help you verify your Grom account and send you an email when the verification is complete.
2. Parent Signature / Permission Slip: Parents can download, complete and sign a Grom Social Permission Slip and return it by email to support@gromsocial or mail it to: Grom Social, P.O. Box 1851, Myrtle Beach, SC 29578
3. Secure Payment of $1: Parents can make a quick one-time payment of $1.00 using a secure pay wall to authenticate their identity and provide verifiable consent.
Grom Social members will be able to participate in the following website activities depending on their Account Profile Type:
Grom Member Information
Unsolicited Information Shared by Chid Users
All personal information that we directly collect is provided by the child's parent. We will not solicit information from a child other than described above. If a child has not been approved for full access to Grom Social because his or her parent has not completed the consent and approval process, the child will be unable to participate in activities that allow for user generated content.
User Generated Content:
When a Grom Social Member engages in some of our user generated online activities, including posting status updates, chatting, and uploading photos, they may share information that could be considered child user generated "Personally Identifiable Information" (PII). While there is no foolproof system to control child user generated PII, Grom Social helpers are monitoring the website 24/7 and are able to address and delete posts and photos immediately should they be determined to contain child user PII. However, you should be aware that any PII your child provides in these areas may be read, collected, or used by other members who access them.
Grom Social is very committed to helping kids learn about proper netiquette and how to protect their privacy. Parents also have the ability to monitor their child's activity on Grom Social by using the Parent Portal. Should a parent see child generated content in any area of the website that they deem to be PII, they can request removal of the content by contacting us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Additional Information shared by Child Users
Invite a Friend: Grom Social's "Invite a Friend" program allows a Grom Social Member to send an email to friends who are not Grom Social Members to tell them about Grom Social. We collect a friend's email and user's friend name for the sole purpose of sending this email. The email addresses are not viewable on the website by members and are not stored in any personally identifiable manner. Child members who have not yet been approved by a parent do not have access to the Invite a Friend feature.
General Collection of Non-Personal Information
We collect information through technology to make our website more interesting and useful to you and for various purposes related to our business. For instance, when you come to our website, we collect your IP address. An IP address is associated with the access point through which you access the internet, and is typically controlled by your Internet Service Provider (ISP). Standing alone, your IP address is not personally identifiable information. We may use IP addresses to collect information regarding the frequency and geographical location in which our guests visit various parts of our website.
Our website collects information through a variety of technical methods, including but not necessarily limited to cookies. Cookies are pieces of information that a website sends to your computer while you are viewing the website.
We may use the information collected through these technical methods for many purposes, including delivering content, tracking and enhancing our users' experience on our website. We do not link the information we store in cookies to any personally identifiable information you or your child submit while on our website.
Web beacons are small pieces of data that are embedded in images on the pages of a website. We use web beacons to help us better manage content on our website by informing us what content is effective. Cookies, web beacons, and other technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf.
Some business partners (such as tracking utility companies) may place cookies on our website. We do not have any access or control of these third party cookies.
In HTML emails that we send our users, we may use technical methods for a number of purposes, including: to determine whether our users have opened or forwarded those emails and/or clicked on links in those emails, to customize the display of banner advertisements and other messages after a user has closed the email, and to determine whether a guest has made an inquiry or purchase in response to a particular email. These technical methods may enable us to collect and use information in a form that is personally identifiable information.
2. HOW WE USE, DISCLOSE, AND STORE THE INFORMATION WE COLLECT
In addition, we may use an email address and Display Name to ban a member temporarily or permanently from the Grom Social website if that user engages in inappropriate conduct on the website.
If you use the Grom Support page to contact us, we will collect your first name, email address, and comments regarding your concern. We will delete the information immediately once your request has been fulfilled.
We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request, or where we disclose information to service providers or other groups or companies who provide support for the operations of our website and who do not use or disclose the information for any other purpose. To the extent permitted by applicable law, we also may disclose PII in response to a law enforcement agency or other public agency's (including schools or children services) request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our website, protect the security or integrity of our website, or enable us to take precautions against liability.
If you no longer wish to receive emails from us, you may opt-out of receiving them by following the instructions included in each email communication or by emailing us at email@example.com.
3. COLLECTION OF INFORMATION FOR THIRD-PARTY WEBSITES, SPONSORS, AND OPERATORS
We may share a child's personal information with third parties to the extent reasonably necessary to:
Grom Social has no power to enforce or change the policies of third party partners or operators.
Parents have the right to consent to the collection and use of personal information collected from their child, without having to consent to its disclosure to third parties as we do not share information collected from your child for any purpose not stated in this policy.
We provide your personal information to companies that provide services to help us with our business activities such as offering customer service, processing payments or sending out emails on our behalf. These companies are authorized to use your personal information only as necessary to provide these services to us.
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
In order to keep the cost to Members of using the website free or low, we do allow third parties to show third party advertising on the website. In some cases, a Grom Social Member may be shown an advertisement prior to engaging in a selected activity on the website. The foregoing notwithstanding, we do not provide PII to these advertisers or allow third-party advertisers and companies to directly solicit or advertise to our Members, including the email addresses used on member accounts.
If you have any inquiries regarding our partner's privacy practices or how they use your child's personal information, please contact us directly at support@Gromsocial.com.
The security and confidentiality of your information is extremely important to us. While there is no definitive or perfect security process, we have made commercially reasonable efforts to implement technical, administrative, and physical security measures to protect guest information from unauthorized access and improper use. When you enter sensitive information, such as your email, mailing address, and date of birth, we encrypt that information using secure socket layer technology (SSL). Additionally, all user sessions of members are encrypted upon login via SSL.
From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware that despite our best efforts, no security measures are perfect or impenetrable.
5. ACCESS TO INFORMATION AND OBJECTION TO INFORMATION COLLECTION AND RETENTION
Please contact Grom Social at firstname.lastname@example.org if you would like to access the personally identifiable information that we have collected online from you or your child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect, use, or maintain the personal information collected from your child.
Please be sure to include your email address and a telephone number where we can reach you. To protect you and your child's privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.
At any time, parents can access and control the information collected on their child by logging into their parent portal. Parents can also delete their child's account and all personal information collected by logging into their parent portal.
We will retain your or your child's information for as long as your child's account is active or as needed to provide services. We will retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Parents have the right to approve or deny their child's accounts. They may also request their child's information, provide their child's name, grom name and email address in order to create the account or delete their child's account by logging into their account and selecting which account to delete.
Member Services Grom Social, Inc.
2060 NW Boca Raton Blvd. Suite 6
Boca Raton FL 33431
Or call us toll-free at 1-866-618-GROM (4766).
Please be assured that any personal information that you provide in communications to the above email and postal mail addresses may be used to send you promotional materials, unless you request otherwise.
7. A FINAL NOTE TO PARENTS
The Internet offers a world of opportunity for children. Your guidance and involvement are essential to help ensure that children have a safe and rewarding online experience. We encourage you to stay involved in and informed about what your child is doing online. Your efforts to instill responsible information practices will help steer your children to age-appropriate websites and will go a long way toward ensuring that your children have enriching experiences online.
Finally, please be aware that we are not a 24-hour helpline, and we are not trained professionals. Grom Social may refer users to crisis hotlines.
If we make material changes to this policy, we will notify you by email and by means of a notice on our homepage prior to the change becoming effective. If we make material changes to how we use Personal Information collected from children under 13, we will notify parents by email in order to obtain verifiable parental consent for the new uses of the child's personal information.