Children's Privacy Policy

Effective date: May 1, 2020

The Sparky Group ("we" or "Sparky") is committed to protecting the privacy of children who use this website (the "Site"). This children's privacy policy ("Children's Privacy Policy") explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 ("child" or "children"), and uses terms that are defined in our general Privacy Policy.

Sparky takes the privacy of the Site's users very seriously. Accordingly, this policy aims to comply with requirements of the U.S. Children's Online Privacy Protection Act ("COPPA"). We reserve the right to amend this Children's Privacy Policy. Please check this page periodically for changes.

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

Children can register with our Site to create and view associated content and view other's content. 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 instruct children under the age of 13 to input their parent or guardian's email address and to not use their first or last name when creating a username. Sparky will not require a child to provide more information than is reasonably necessary in order to participate in the online activity.

We instruct children under the age of 13 to insert their parent's email address upon registration. An email confirming registration will be sent to the address used. 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 contact us at sparky@zohgroup.com to provide us permission or request that we delete the child's account and any associated information. 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.

Content Generated by a Child

Certain activities and applications on our Site allow children to create or manipulate content and save it with Sparky through the Site. None of these activities require children to provide any personal information and therefore do not result in notice to the parent or require parental consent. We strongly advise children to never insert personal information in their created content.

Aligned with the objective of Sparky, which is to connect children and practice their skills in a group setting, The Site permits all visitors to view content created by children, such as debate topics and/or response, craft projects, etc. If parents don’t want other users to see their child’s work please send such a request to sparky@zohgroup.com so that we can adjust the child’s account status accordingly.

Online Publishing

Certain activities associated with the use of the Site may allow users to publish the content by users. For example, a child can publish his/her view under certain debate topics. In such scenarios, we strongly encourage children never to provide personal information about themselves or any third party. However, it is the responsibility of parents to carefully supervise their children when their children participate in online activities. Sparky is not responsible or liable for its publication of any user-generated content or information or any harm that flows from the dissemination of such content.

Anonymous Information

When children interact with us, certain information may automatically be collected, both to make our Site more interesting and useful, and for purposes of statistical analysis and system improvements. Examples include the type of computer operating system, the user's IP address or mobile device identifier, the web browser, the frequency with which the user visits various parts of our Site, and information regarding the online or mobile service provider. This data is principally used for internal purposes only, in order to:

• determine usage patterns;
• customize content and improve the Site; and
• conduct research and analysis to address the performance of the Site.

In the event we collect such information from children on our Site for purposes other than above, we will notify parents and obtain consent prior to such collection.

When Information Collected From Children Is Available To Others

Sparky will not share or disclose personal information collected from children unless required under the following circumstances:

Sparky 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 our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) to enable us to take precautions against liability.

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 information may lead to deletion of an account and associated content.

Parents can contact Sparky to request access to, change, or delete their child's personal information by sending an email to us at: sparky@zohgroup.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.