The Children’s Online Privacy Protection Act (COPPA) requires that Waterford Institute™ (WI) informs parents and legal guardians about how WI collects, uses, and discloses the personally identifiable information of children under 13 years of age. It also requires that WI obtains the consent of parents and guardians in order for children under 13 years of age to use certain products, services, or programs. In this document, the term parent refers to both parents and legal guardians.

Collection and Use of Personally Identifiable Information

Verifiable Parental Consent Prior to registering a child in the UPSTART program, WI requires a parent to provide consent to collect their child’s personally identifiable information. WI collects an e-mail address that is used to contact the parent to obtain parental consent. The parent may also choose to print and mail the UPSTART Parental Consent Form. WI does not knowingly collect personally identifiable information relating to children under 13 years of age without verified parental consent. If this inadvertently occurs, WI promptly deletes the information. Information the UPSTART Program Collects During the pre-registration or registration process, UPSTART requires certain information to create an account. This account is used by WI personnel to administer the UPSTART program. WI collects the following information about the child directly from the parent during the pre-registration and registration process in the UPSTART program:

• Name
• Gender
• Birth date
• Year entering kindergarten
• Primary language

When a visitor to http://www.waterfordupstart.org is under the age of 13, WI does not condition a child’s participation in an activity based on the child disclosing more personal information than is reasonably necessary to participate in such activity. Third-party Companies, Affiliates, and Disclosure WI recognizes the importance of protecting the personally identifiable information of every child. WI does not, under any circumstances, sell or rent this information to any party. WI may engage affiliates or third-parties to improve products and services. WI, affiliates, or third-party companies may share personally identifiable information with each other and use it consistent with this policy. WI, affiliates, or third-party companies may also combine personally identifiable information with other information to provide and improve products and services. Affiliates and third-parties are under legal agreements with WI and are obligated to maintain the confidentiality, security, and integrity of the personally identifiable information they obtain from WI. The parent has the option to consent to the collection and use of their child’s personally identifiable information without consenting to the disclosure of this information to WI affiliates or third-parties. WI may disclose a child’s personally identifiable information in special cases when there is reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) the rights or property of WI, other users, or anyone else who could be harmed by such activities. WI may also disclose a child’s personally identifiable information when they believe in good faith that the law requires it. Access to a Child’s Personal Information A parent can review their child’s personally identifiable information by calling WI User Support. The parent can opt-out, have their child’s personally identifiable information deleted, or refuse to permit further collection of their child’s personally identifiable information at any time. The UPSTART program provides a personalized learning path to meet the unique learning needs of each child through a learner profile. A child’s personally identifiable information is integral to the learner profile. Removing this information prohibits the UPSTART program from providing a personalized learning path and positive experience for the child. Links to Other Websites WI provides links to third-party Websites solely as a convenience. Clicking any third-party link takes the user away from the WI Websites. These third-party companies have their own privacy, COPPA, and data collection policies. WI has not reviewed these third-party Websites and does not control nor is responsible for any of these Websites or their content. Thus, WI does not endorse or make any representations about them; any information, software, or other products or materials found there; or any results that may be obtained from using them. If the parent or child decides to access any of the third-party Websites linked by WI, they do so entirely at their own risk.

Commitment to Privacy

To ensure all personally identifiable information is secure, WI communicates their privacy, COPPA, and security guidelines to WI employees and strictly enforces privacy safeguards within the company.

Updates to COPPA Policy

WI may update its COPPA policies. When WI changes a policy in a material way, a notice is posted on http://www.waterfordupstart.org along with the updated COPPA policy.

Contact Information

Parents can contact WI User Support with any questions at: Waterford Institute Attn: UPSTART User Support 1590 E 9400 S Sandy, UT 84093 1-800-669-4533 support@waterford.org