COPPA Notice: Direct Notice to Parents

Last Updated: July 16, 2020

This COPPA NOTICE: Kansas Center for Entrepreneurship, Inc. doing business as NetWork Kansas (“NetWork Kansas,” “we”, “our” or “us”) Direct Notice to parents (“COPPA Notice”) of children using Website or the VentureDash platform and related services (“Services”) gives parents additional information on NetWork Kansas practices in collecting and using personally identifiable information from children under 13 years of age.

For purposes of this COPPA Notice, (i) “child” or “children” mean a child or children under 13 years of age that is/are child(s) and (ii) “you” or “your” refers to the authorized parent that is authorized to enter into contracts on behalf of such child(s), as an agent of parents and legal guardians of children using the Website or Services that collect and use of such child personal data.

NOTICE

Your consent is required before we will collect, use or disclose your child’s personally identifiable information. Subject to your consent, in order to allow your child to use the Website and Services, NetWork Kansas would like to collect, use and disclose your child’s information as set forth in this COPPA Notice and in our COPPA privacy policy located at https://goventuredash.com/coppa-privacy-policy.

How does the Website get consent from parents for the collection of personally identifiable information?

For all children who are going to utilize the Website and Services, the parent must complete the online parental consent verification form located at https://goventuredash.com/parental-consent for the child. In order to determine if a user is under the age of 13, we preliminarily request the birth date of the user. Any user who is under the age of 13 is immediately directed to our online parental consent verification form. During the verification the parent must mark that they have reviewed and approve the usage of the Website and Services by their child and that they have agreed to this COPPA Notice.

It is not permitted for a child to be registered to use the Website and Services unless the parent has agreed to the terms of this disclosure. If a child circumvents the online parental consent verification or has otherwise gained access to the Website and Services without parental authorization that child will be removed from the Website and Services immediately.

What information does the Services and Website collect and use?

Personally identifiable information of children under 13 is only collected from such children with your consent, and if NetWork Kansas becomes aware of a child under the age of 13 providing personal without your consent, we will attempt to delete that information.

While we may receive personally identifiable information directly from you about your children, NetWork Kansas may directly collect from your children the following:

• your child’s name
• address
• phone number
• mobile phone number
• email address
• username, and
• birth date
• Student’s school and grade
• Parent or guardian information
• Food Allergies

In limited circumstances in connection with NetWork Kansas events, we may also collect:

• W9 related information, including social security number (if you receive a gift)
• Medical insurance information (for event emergencies), and
• Demographic information (for surveys)

On our Website and Services, we use session cookies to make it easier for your child to navigate the Website and Services. For our Website and Services, we set a persistent cookie to store your child’s general usage behavior and IP addresses but not personally identifiable information. Persistent cookies enable us to track, store and target the interests of our users to enhance the experience on our Website. If your child rejects cookies, your child’s ability to our Website and Services may be limited.

NetWork Kansas also collects the following information automatically:

• The Internet Protocol (IP) address of the device from which a child accesses the Services (this can sometimes be used to derive the country or city from which a child is accessing the Services).
• The specific actions that children take on the Services, including the buttons clicked on in the app, the tasks they complete, loans they apply for, requests for money they submit, trophies they earn, progress on trophies, allowance earned, allowance dates and frequency, allowance amount, card limits, card transactions they perform, PIN number configured, invalid PIN attempts, the child’s photo, budget entered, and loan payments made.
• The time, frequency and duration of a child’s visits to the Services.
• The child’s unique device identifier.
• The child’s unique push notification ID for sending device notifications.

How will NetWork Kansas use this information?

We use the information that we collect about your child for the following educational purposes as more specifically described in our Privacy policy. We use personal information collected from children for the following purposes:

• To provide our Services;
• To respond to customer service and technical support issues and requests;
• Verifying your identity (such as when you access your account information);
• Preventing fraud and enhancing the security of your account or our online services;
• Responding to your requests and communicating with you;
• Managing your preferences;
• Performing analytics concerning your use of our online services, including your responses to our emails and the pages you view;
• Providing you tailored content and communications on topics and developments we believe will be of interest you, including program related activities, including text messages if you have opted in to receiving SMS communications;
• Operating, evaluating and improving our Website, Services, programs and online service platforms (including performing data analytics and accounting, auditing and other internal functions);
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
• Coordinating event activities; and
• For any other purposes that we may specifically disclose at the time you provide or we collect your information.

We de-identify and/or aggregate the information we collect from children under 13 before we use it for any other purposes, as noted below.

Unique Identifiers. We only collect and use unique identifiers, such as IP addresses, as necessary to operate our Website or Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Website and Services. We never use unique identifiers to track users across third-party apps or websites.

Aggregate or De-identified Information. We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, e-mail, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:

• To better understand how users’ access and use our Website and Services;
• To improve our Website and Services and respond to user desires and preferences; and
• To conduct research or analysis, including research and analysis by third parties.

Does NetWork Kansas share this information with any third parties?

NetWork Kansas does not sell or share children’s personal information, and a child may not make his or her personal information public through our services. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect NetWork Kansas and other users of our Services. For example, we may share children’s personal information as follows:

• Other network partners in order to provide you information on additional related programmatic opportunities;
• Other organizations we work with to provide services, research, products or programs;
• Other similar charities;
• Third-party service providers (for example, website hosting and operational services or a travel management company to assist in booking travel) who are only authorized to use your data as directed and necessary to perform services on our behalf; and
• Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our constituents or third parties.

With Parents. Parents may request information about the information we have collected from their child by contacting us at hello@goventuredash.com.

Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.

Can a parent review, change or delete the information collected by the Website and Services about his or her child?

Parents have a right to review the information we have collected about their children, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, the parent may contact us at hello@goventuredash.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it. Parents may login to the product at any time and review the information entered by their children.