Children’s Privacy Notice

Last updated: October 24, 2024

Overview

Our Privacy Notice explains how Dailies Inc. (doing business as “DailiesPods”) collects and uses personal data when you and your child use our online services, such as classes, groups, and other activities, including apps (collectively, our “Services”). This Children’s Privacy Notice specifically addresses the U.S. Children’s Online Privacy Protection Act (COPPA). In general, this information applies to all learners where local law regulates activities related to children under certain ages. For COPPA, this is under 13 years.

For more information about COPPA and general tips for protecting children’s online privacy, please visit the U.S. Federal Trade Commission’s (FTC’s) consumer information site at
FTC Consumer Information.

Data Collection Practices

We collect almost all personal data about children directly from Parents/Guardians, but we do collect some information directly from children. Here’s how it works:

  • Parental Consent Required:
    Before collecting any personal data from children, we require verifiable parental consent. Once verified, we collect information directly from children on our platform.
  • Limited Consent Accounts:
    When children attempt to sign up directly, we collect limited information while notifying parents/guardians. Full access is only granted after verified parental consent.
  • Parental Control:
    Parents/Guardians can set up child accounts, provide optional details such as time zone, learning preferences, and more. These child accounts are set to “Learner Mode,” with restrictions and fewer permissions than the parent/guardian level.

How Children Use DailiesPods

Children should use our platform only in “Learner Mode.” This mode allows children to:

  • Attend classes, join groups, and participate in challenges.
  • Engage in free challenges or Learner groups but cannot enroll themselves in paid activities.
  • Mark activities they like or want to attend, allowing us to recommend activities using AI based on these interests.
  • Participate in activities through video, audio, and chat, with recordings made for safety and quality purposes.

Parents/Guardians will receive notifications via email for all Services, whether paid or free, and can un-enroll their children at any time. Parents/Guardians can view child accounts but cannot participate in Learner activities.

Mobile App Permissions

Parents/Guardians can control permissions for push notifications, camera access, and photo uploads through our mobile apps. We encourage enabling parental controls to prevent changes to these settings by children.

Verified Accounts

Once we obtain verified parental consent, we may use and share personal data collected from children as described in our general Privacy Notice and emphasized in this Children’s Privacy Notice. We may:

  • Send recommendations about activities and new features to children and parents/guardians.
  • Send notifications about class schedules or updates within our platform, through push notifications, or email (only to parents/guardians).
  • Ensure that no marketing emails are sent to children. If a child mistakenly receives one, please notify us immediately.

Video Recordings and Online Interactions

Our activities involve video, audio, and chat interactions between children, teachers, and other participants. Here’s how we handle these interactions:

  • Video Recordings: We record video, audio, and chat during classes for safety, compliance, and feedback purposes. Recordings are shared with the class participants and their parents/guardians. Teachers may access recordings as part of their feedback process.
  • Use of Recordings: Recordings are used to ensure compliance, provide feedback, and support customer service. Additional parental consent will be sought if recordings are used for promotional purposes.
  • Privacy Expectations: We request that recordings not be shared outside of the intended group, but we cannot control the actions of parents/guardians or other participants who may access the recordings.

Third-Party Sites and Tools

Teachers may sometimes ask child learners to use third-party sites or services. Parents should review the privacy practices of these third-party services before use. DailiesPods is not responsible for the privacy practices of these services.

Limited Consent Accounts

Children may attempt to sign up with an account on their own. If this occurs, we will notify parents/guardians via email to verify agreement for limited activities. The information we collect in these instances is limited. For example, children can mark classes they like or choose an avatar, but they cannot enroll in classes, and their information is not shared with teachers or other learners.

Parents/Guardians have the option to “upgrade” the account to full access. Once parents provide verified parental consent for their children to enroll in classes, groups, or other activities, this includes agreement to carry over information from these limited activities to the full child learner account. This may include information such as classes they liked or free challenges they participated in.

If parents/guardians do not agree with carrying over this information, they can notify us at
privacy@dailiespods.com.

Parental Consent and Rights

We send a direct notice with privacy disclosures and obtain verifiable parental consent from parents/guardians before collecting, using, or sharing personal data from their children, as described in this COPPA Notice. We follow the necessary processes to obtain verified parental consent before setting up full accounts. If activities are paid for by an organization, other verification methods may be used to verify a parent’s identity, or the school may be qualified to grant consent.

No Consent/Withdraw Consent: If parents/guardians do not consent or withdraw consent, we will not collect, use, or disclose any personal data about their child, except as needed for legal compliance or enforcement purposes. In such cases, their child will not be able to use DailiesPods in any way.

Deletion

Parents/Guardians can request the deletion of personal data we have collected in connection with their child’s account. Please note that a request for deletion may result in the termination of the account, membership, or other services.

However, if we need to retain certain information for valid reasons such as fraud prevention, compliance, or safety, we will not delete the information immediately. Instead, we will continue to protect it and delete it when appropriate.

We will use commercially reasonable efforts to delete personal data collected from children when it is no longer needed for the purpose for which it was collected. Please note that we may not be able to guarantee deletion from backup storage, but we will attempt to do so when feasible. If backups are restored, we will re-delete the requested records based on the initial deletion request.

Review and Update Information

Parents/Guardians may review and update certain information about their child by logging into their account. Through the parent/guardian account, they can review topics of interest inferred from their child’s interactions with classes or activities. Parents can opt out of recommendations based on their child’s history of participation and instead manually select learning topics.

About Teachers

DailiesPods partners with approved adult teachers to lead classes and, occasionally, other activities like groups. These teachers work with us as independent contractors rather than employees. In some cases, a teacher may be an organization, group, or team of teachers.

DailiesPods employees may also engage with or moderate certain classes or activities to ensure compliance with our standards and policies.

Contact Us

If you have any questions or concerns about this COPPA Notice, our privacy practices, or your rights as a parent/guardian, please reach out to our Legal Office:

Email: legal@dailiespods.com
Mailing Address: Dailies Inc, 2700 S Oak Knoll Ave, San Marino, CA 91108, USA
Phone: +1 (833) 324-1366

This Children’s Privacy Notice was last updated on October 24, 2024. The previous version included updates for mobile apps, limited consent accounts, and formatting improvements.