Last modified: June 12th, 2023
Children’s Online Privacy Protection Act
Crosswalk Technologies, Inc. (“Crosswalk”) values the privacy of children and of all of its users. This COPPA Privacy Policy (“COPPA Policy”) is designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) and contains important information about how we collect, use, and disclose the personal information we collect from children under thirteen years old who take courses provided through our website, https://www.Crosswalk.com/ (the “Site”) and the services, such as data trackers, provided on our Site (the “Services”).
Crosswalk develops and makes available digital consumer insights tracking online (hosted on its own platform). In the course of providing these Services, Crosswalk comes into contact with information, including personal information, from the user.
Some, but not all, trackers are directed towards children under 13. This COPPA Privacy Policy applies to the information we collect from children under 13 through Crosswalk insights derived from children.
Crosswalk will handle children’s personal information as described in this COPPA Policy. Any personal information we collect about other users (e.g., teens and adults) will be treated in accordance with the Crosswalk Privacy Policy (“Privacy Policy”). The use of our Site, products and any dispute over privacy, is subject to this COPPA Policy, the Privacy Policy, and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service and Privacy Policy are incorporated by reference into this COPPA Policy.
Who Will Collect Information About Children?
Crosswalk operates the Site and Services and will collect children’s personal information as described in this COPPA Policy and our Privacy Policy. We can be contacted at:
31 Hudson Yards, 11th floor, New York, Y, 10001
Crosswalk’s clients and partners will not receive any individual personal information from users of the Site, platform or products including children. Crosswalk may provide clients and partners with aggregate or de-identified information about users.
What Information Do We Collect About Children and Why?
As described in further detail below, we collect some personal information from children so that we can track their digital interactions. Data is retained for education insight into user’s behavior and resold to our clients.
How Information is Collected? Upon getting permission from a parent/guardian we may collect information about children directly from children, as well as automatically through a child’s use of our Services. We will not require a child to disclose more information than is reasonably necessary to use our Services.
Information We Collect Directly.
From children under 13, we utilize the date of birth to verify the child’s age but do not store the age. We only store whether or not they are under 13. We do not ask children for their name or other identifiable information and not required to provide any information. We will not contact a child. We collect additional demographic information (such as race and gender) from children; however, we do not associate this with the child’s personal information and we use it only to compile aggregate and de-identified information about participants. Parents may ask us to stop collecting personal information from their child by emailing us at privacy@Crosswalk.com. If a parent directs us to stop collecting and using a child’s personal information, we will ensure that no information is collected.
Information We Collect Automatically.
We may automatically collect the following information about a child’s use of our software through cookies, browser extensions and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Site; the length of time our courses were taken; Google Analytics statistics; the referring URL, or the webpage that led the child to our Site; language information; device name and model; operating system type, name, and version; and activities within our Site. We may also collect IP address, device identifier or a similar unique identifier from users of our Site, including children.
How We Use Children’s Information
We use personal information collected from children for the following purposes:
To provide our Services; and
To respond to customer service and technical support issues and requests.
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 Site or Services, including to maintain or analyze consumer segments; to track users across third-party apps or websites.
Aggregate or De-identified Information. We use aggregate or de-identified information about children for research, analysis, and similar purposes which we then sell to our clients. When we do so, we strip out all personal identifiers. We may use aggregate or de-identified information for the following purposes:
To better understand how users access and use our Site and Services;
To better understand how users access and use our Other Sites and Services;
To conduct research or analysis, including research and analysis for third parties.
How We Share Children’s Information
We do not sell children’s personally identifiable 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 Crosswalk and other users of our Services however we do so only with parental/guardian consent. For example, we may share children’s personal information as follows:
Service Providers. We may disclose the information we collect from children to third-party vendors, service providers, contractors, or agents who perform functions on our behalf.
Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from our users to the other company.
In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.
To Protect Us and Others. We also may disclose the personal information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Privacy Policy, or this COPPA Policy, or as evidence in litigation in which Crosswalk is involved.
With Parents. Parents may request information about the information we have collected from their child by contacting us at privacy@Crosswalk.com
Aggregate and De-Identified Information. We may also use, share, and sell aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.
Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information
Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at privacy@Crosswalk.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.
Changes to This COPPA Policy
This COPPA Policy is current as of the Effective Date set forth above. We may change this COPPA Policy from time to time, so please be sure to check back periodically. We will post any changes to this COPPA Policy on our Site, at www.crosswalknyc.com/coppa. If we make any changes to this COPPA Policy that materially affect our practices with regard to the personal information we have previously collected from a child, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
FOR ASSISTED REMOVAL:
To exercise applicable data protection rights, please contact us by email at privacy@crosswalknyc.com, contact us at +1 (646) 306-9523 or write to us at:
Crosswalk
31 Hudson Yards
11th floor
New York, NY, 10001