Children's Online Privacy Protection Act (COPPA) Policy

Last updated July 30, 2015


A. Direct notice to children

Hello and welcome to Hooktheory. We need to tell you a few things before you give us your username, name and any other information. If you are under 13, we must get one of your teachers to agree to your giving us your name and other personal information. Hooktheory gets this permission from your school when they sign up to use Hooktheory. If you are under 13, you can only use Hooktheory as part of a school activity. It is a violation of our Terms of Service to register for a non-educational Hooktheory account if you are under the age of 13.

B. Direct notice to parents

As part of Hooktheory's educational service, students can participate in certain areas of our website with the permission of their instructor. Prior to collecting personal information from any student, we obtain authorization from the school, acting in loco parentis (in the place of a parent).

Hooktheory is committed to protecting the privacy of children who use our site. This Children’s Online Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13. This policy is in accordance with the U.S. Federal Trade Commission (FTC) Children’s Online Privacy Protection Act (COPPA), and outlines our practices in the United States and Latin America regarding children’s personal information.

For information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

For information about school consent a of website or app’s collection, use, or disclosure of personal information from students, please visit the "COPPA and Schools" section of the FTC's "Complying with COPPA: Frequently Asked Questions" webpage.

1. The information we collect from children, how we use it, and how and when we communicate with parents

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.

Registration

As part of Hooktheory’s educational service, students register with our site to allow their teacher or administrator to manage their participation in their class. During the registration process, we ask the student to provide their first and last name as well as a username and password. We strongly advise children never to provide any personal information in their usernames. We do not require a child to provide more information than is reasonably necessary in order to participate.

Prior to collecting personal information from any student, we obtain prior authorization from the school (acting in loco parentis) for the collection of students’ personal information outlined above. Consistent with the requirements of COPPA, Hooktheory only collects personal information from students for the use and benefit of the school, and for no other commercial purpose. Students can only register for a course by using a code given to them by their instructor after this authorization has been given.

Content generated by a child

Certain activities on our sites and applications allow children to create or manipulate content and save it with Hooktheory. These activities potentially allow a child to insert personal information in their created content. We strongly advise instructors to tell their students to never provide any personal information in their content. Instructor’s are responsible for screening content created by their students for personal information. Examples of created content that may include personal information are lyrics in songs created with Hooktheory’s software or other open-text fields. If personal information is found, please contact us at support@hooktheory.com and it will be deleted.

Persistent identifiers

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

  • provide students with access to features and activities on our sites and applications
  • customize content and improve our sites and applications
  • conduct research and analysis to address the performance of our sites and applications
  • generate anonymous reporting for use by Hooktheory

In the event we collect (or allow others to collect) such information from students on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.

The third-party operators who collect persistent identifiers on our sites and applications are:

  • Google
  • Linode
  • Amazon
  • AddThis
  • Facebook
  • Twitter

Please contact us at the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices:

Hooktheory, LLC.
77A Tamalpais RD
Berkeley, CA 94708
P: (209) 800-HOOK
E: support@hooktheory.com

About teacher consent in lieu of a parent

With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

2. When information collected from children is available to others

We 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:
    1. in response to a law enforcement or public agency’s (including schools or children services) request
    2. 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 our sites or applications
    3. to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers
    4. enable us to take precautions against liability.

3. Parental choices and controls

At any time, parents can refuse 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. Please keep in mind that a request to delete records will lead to a termination of an account. Parents can contact us directly to request access to, change, or delete their child’s personal information by sending an email to us at support@hooktheory.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.