This policy is in accordance with the U.S. Federal Trade Commission (FTC) Children’s Online Privacy Protection Act (COPPA), and outlines our practices 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 of a 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.

Our Compliance with COPPA

Human Restoration Project (“Floop”, “HRP”, “Company”) takes all measures reasonably available to protect the privacy of the personal information of children, in compliance with applicable federal regulations. Part of that effort involves fully advising parents regarding the collection, use, or disclosure of personal information from children, including notice of any material change in the collection, use, or disclosure practices to which the parent has previously consented.

Due to the nature of the work that we do, it is necessary that we collect and store information about minors.

The collection and storage of such information is subject to regulation under COPPA (the Childrens’ Online Privacy Protection Rule).

Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 13 years of age outside of the bounds of COPPA.

We understand “Personal information” to mean:

• Full Name (first and last together)
• Online contact (like an email, IM identifier, VoIP identifier, or video chat identifier, screen name, username)
• Home address
• Phone number
• Social Security number
• Persistent identifier (like a cookie number, an IP address, a processor or device serial number, or a unique device identifier)
• Your image or voice (like a photo, video, audio)
• Geolocation (to level of street, city, town)

When Personally Identifiable Information is voluntarily disclosed (i.e. name, email address, etc.) in work samples and feedback, that information, along with any information disclosed in your communication, will be displayed to the students teacher and classmates. Those people could collected and use that information. Such activities are beyond our control and this Policy does not apply to such information. Any text or image submissions made on this site are accepted with the understanding that they are accessible to your teacher and classmates. If a student does not want their comments to be viewed by them, they are advised not to make any such submissions. Ultimately, they are solely responsible for maintaining the secrecy of their password and/or account information.

We strongly recommend that each time a student under the age of 18 uses the site, they do so only under the direct supervision of a Teacher User. Teacher Users should remind Student Users of the risks of including Personally Identifiable Information in their work samples and feedback.

Additional COPPA-Related Provisions

1. Parental Choice

Parents have the choice of consenting to (or declining) our collection and internal use of a child’s information.

2. Disclosure to 3rd Parties Inherent to Service

Our operations, by their nature, may require disclosure of personal student information to third parties. We will exercise reasonable diligence to assure this is restricted to disclosures made for education purposes. We only contract and share student data with third parties that are consistent with our own policies. If we ever contract with a future company we will make sure they are consistent with our policies, otherwise we will seek your consent again before sharing User information. You can learn more about the third-parties we contract with in the FAQ section below.

3. Parental Access to Information, Deletion, Prevention of Further Use or Collection

By arrangement with the company, either via the contact information specified below or via a Teacher User online portal associated with the child Student User’s account, parents or persons acting in loco parentis may:

• have access to their children’s personal information – as collected/maintained by Human Restoration Project;
• have said information deleted;
• have the opportunity to prevent further use or online collection of a child’s personal information;
• arrange for supplemental measures to maintain the confidentiality, security, and integrity of information the company or its agents may collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security;
• retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected; and/or
• delete the information using reasonable measures to protect against its unauthorized access or use.

FAQ

What does in loco parentis mean?

In loco parentis means “in the place of a parent.” COPPA allows schools special permissions for providing consent for services that are strictly educational. If a school or district chooses to act in loco parentis, it is best practice for the school to obtain written consent from parents for such actions, to keep that consent on file, and to provide direct notice of the Terms and Policies of all sites to parents.

What do we currently do to communicate the information required by COPPA?

• We provide this notice, along with our Privacy Policy and Terms of Use, publicly on our website for parents, legal guardians, or persons acting in loco parentis.
• We obtain consent from a school or district representative acting in loco parentis and provide them with this notice directly.
• We do not collect, use, or disclose personal information from a child if the representative acting in loco parentis does not provide consent.
• We advise the representative to notify parents and legal guardians of our policies.

What information do we currently collect from children and why?

• Email address: to serve as a unique username for login purposes and to reset passwords upon request of the student. We do not contact students for any purposes except in response to customer service and technical inquiries initiated by the Student User.
• First and last name of student: to identify the student to the Teacher User. Teacher Users may choose to instruct their students to input a last initial only for additional privacy.
• Persistent Identifiers: we use Cookies to identify users when they visit the site in order to prepare the screen with appropriate content and coordinate the login experience. We use device identifiers with our mobile app to troubleshoot problems with our services.
• We do not require children to make any of this personal information public.

When would we disclose a child’s personal information?

• In compliance with Federal regulations (FERPA), we will disclose any and all Educational Records requested by a parent or legal guardian. We will follow appropriate procedures to verify the identify of the parent before disclosing any information. Parents can request Educational Records by contacting their child’s teacher or by emailing [email protected]
• We might disclose a child’s personal information to third party service providers if the parent has provided verifiable consent. We would only do this for the purpose of providing the educational services on this site.
• We will disclose personal information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation.

How can a parent, legal guardian, or person acting in loco parentis provide consent?

• At this time, our system is designed to allow school or district representatives to provide consent for children under the age of 13 through direct contact with the company.
• School or district representatives wishing to provide consent for a child Student User should first carefully review our Terms of Use, Privacy Policy, and this COPPA Notice.
• A representative acting in loco parentis can email the company at [email protected] to provide verifiable consent for students at their school or in their district, and the domain of the associated Student Users will be whitelisted in our system. When a Student User attempts to register for the site they are asked to enter their date of birth. We do not store this information. If the Student User is under the age of 13, the form will check that their email address includes a whitelisted domain before it allows them to complete registration.

Who collects and maintains the personal information from children on this site?

We only contract with third-party services whose data collection and privacy practices are consistent with ours. As of Jan 2, 2020, we contract with the following third-party services:

• Google Cloud Platform, Firebase, Analytics, Crashlytics: database, authorization, and analytics.
• BugSnag: error logging
• Twilio SendGrid: sending app notifications to users

What rights do parents and representatives acting in loco parentis have regarding children’s personal information?

Parent can review or have deleted the child’s personal information, and refuse to permit further collection or use of the child’s information by contacting their child’s Teacher User and/or contacting us using the contact information below.

Contact Us

If you have any questions about this COPPA Notice, the practices of this site, or your dealings with this site, please contact us:

Human Restoration Project

PO Box 322

Slater, IA. 50244.

(614) 547-3467‬

[email protected]