The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (both referred to as "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 (referred to as “children” or, individually, as a “child”). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information.
This Privacy Notice for Children Under the Age of 13 (this “COPPA Notice”) notifies parents of:
- The types of information we may collect from children.
- How we use the information we collect.
- Our practices for disclosing that information, including specific information about third parties.
- Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.
- All operators that collect or maintain information from children through our Services.
This COPPA Notice only applies to children under the age of 13 and supplements our general privacy notice, available at GameStrong Privacy Policy (our “General Privacy Notice”). Our General Privacy Notice applies only to teens age 13 and over, and adults.
References to “GameStrong,” “us,” “we,” or “our” in this Notice refer to GameStrong Performance Psychology Inc., and references to “you” and “your” refer to you as a visitor to and user of the Services (including as a parent on behalf of a child receiving our Services) and/or as the party whose personal information we may collect and use in accordance with this COPPA Notice. Other terms that are defined in the General Privacy Notice have the same meanings as used in this COPPA Notice.
1. Information We Collect from Children
Children can browse our Services without providing us with personal information. However, we may use certain technologies, such as cookies, to automatically collect information from our users, including children, when they visit or use our Services, as described in the General Privacy Notice and as described further below. We do not require a child to provide more information than is reasonably necessary to participate in our Services, and we do not condition a child’s participation in our Services on providing us with more personal information than is reasonably necessary.
A. Information We Collect Directly
To receive our content and use our Services, we will be required to collect certain information, including personal information, from children.
As an initial matter, in order to obtain verifiable parental consent (as discussed further below), we will collect the child’s name or nickname, age, and parent contact information.
Subject to receipt of verifiable parental consent, we will collect the following information to allow the child to register with our website:
- The child’s name or nickname
- The child’s unique user identification number, which will be used by the child to sign into our Services so that our Services can identify and remember them without the child providing their name or a password
- Parent name and email address
We will then collect the following information from your child as a registered user:
- Performance, activity, or training-related information
- User-generated content (messages, app activity, session notes); this user-generated content will be used and maintained internally by GameStrong, and will not be posted to public areas of our Services
We may request additional information from your child, but this information is optional. We will specify whether information is required or optional when we request it.
B. Automatic Information Collection and Tracking
We use cookies, pixels, tags, and similar technologies to collect information from our users, including children, when they access and navigate through the Services and use certain of its features. The information we collect through these technologies may include:
- One or more persistent identifiers that can be used to identify a child when he or she signs into our Services
- Information that identifies a device location (geolocation information)
We use the following measures to ensure that no persistent identifier is used or disclosed to contact your child, including through behavioral advertising, to amass a profile on a specific individual, or for any other purpose (except as specifically permitted to provide support for the internal operations of our Services):
- No Advertising Infrastructure. The GameStrong app contains no advertising SDKs, tracking pixels, or third-party advertising networks. We do not share user identifiers with any advertising platforms or data brokers. No integration with social media platforms or external analytics services that could enable behavioral profiling.
- Limited Data Collection: User identifiers are generated solely for authentication and progress tracking within our closed system. We do not collect device identifiers (IMEI, MAC addresses, advertising IDs) beyond what is strictly necessary for app functionality. No geolocation data is collected or stored. No contact information (phone numbers, email addresses) is collected from children
- Database Access Controls: Persistent identifiers are stored in a segregated database with role-based access controls. Only authorized GameStrong personnel and our contracted technology service provider have access to identifiers. Access logs track all database queries involving user identifiers
- Encryption and Security: Persistent identifiers are encrypted at rest in the database that stores them. The Services are served over encrypted connections (HTTPS), and requests made over an unencrypted connection are redirected to an encrypted one.
- That database's encryption key is managed through AWS Key Management Service
- Service Provider Restrictions: Our technology service provider is contractually prohibited from: Using persistent identifiers for any purpose other than operating the GameStrong app. Sharing identifiers with any third party without explicit written authorization. Creating profiles for behavioral advertising or marketing purposes. Retaining data after termination of services
- No Cross-Platform Tracking: We do not use persistent identifiers to track users across different websites, apps, or services. No integration with single sign-on services (Google, Facebook, Apple ID) for child accounts. Session data is not shared outside the GameStrong app environment
- Prohibited Uses: We explicitly prohibit the following uses of persistent identifiers: Building behavioral advertising profiles. Selling or sharing data with data brokers or marketing companies. Cross-referencing identifiers with external databases or services. Using identifiers for any commercial purpose unrelated to delivering the GameStrong program
Users may control or disable cookies through browser or device settings, though this may affect functionality.
Currently, certain browsers, including Firefox, Chrome, Safari, and Edge, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by a user about the user’s DNT preference, if any, set on the browser. If you activate DNT, we cannot currently commit to responding to your browser’s DNT signals, because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.
2. How We Use Children’s Information
We use the personal information we collect directly from your child only to:
- Register him or her with the Services
- Provide performance psychology or training services
- Maintain and improve features of our Services
- Customize the child’s experience
- Communicate with parents
- Support internal operations (analytics, security, functionality)
We use the information we automatically collect through technology to:
- Remember preferences
- Analyze traffic and usage patterns
- Support login sessions
- Improve functionality and performance
We do NOT use children’s information for:
- Marketing
- Targeted advertising
- Selling or renting data
3. How and Why We May Disclose Children’s Information
We do not share, sell, rent, or transfer children’s personal information other than as described in this COPPA Notice.
We may disclose children’s personal information as follows:
A. Service Providers
We may share information with trusted third parties who perform services on our behalf, as follows:
| Identity of Third Party | Purpose of Disclosure |
|---|---|
| Software development and hosting partner | Operates the app infrastructure, maintains the database, and provides technical support. Bound by data processing agreements that require them to maintain confidentiality and use data only for providing GameStrong services |
| Youth Sports/Activities Organization | Coaches and club staff receive aggregated assessment reports to understand team progress and athlete development |
We may also disclose personal information to other service providers who act as professional advisors to us, including lawyers, bankers, accountants, insurers, and others who provide similar services. We provide our service providers only with the information that they need to perform their respective services, and work with them to respect and protect your privacy.
B. Business Transactions
We may disclose personal information of children in connection with, during negotiations of, or as a part of the closing of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company, whether as a going concern or as part of bankruptcy, litigation or similar proceeding, in which personal information about the users of Services is among the assets transferred.
C. Other Disclosures
We may disclose personal Information of children if we believe that such action is appropriate to (1) comply with law, regulations, legal process or governmental request, (2) enforce any terms of use applicable to the Services, including potential violations, (3) detect, prevent or otherwise address fraud, security or technical issues, or (4) otherwise protect the rights, property or personal safety of us, our employees, users of our Services, or others.
4. How Long We Retain Personal Information
We keep children’s personal information only as long as necessary to fulfill the purpose(s) for which it was collected, including as necessary to:
- Provide and maintain the Services;
- Comply with legal, accounting, and reporting obligations; and
- Resolve disputes and enforce agreements.
To determine the appropriate retention period for children’s personal information, we consider the amount, nature and sensitivity of the child’s personal information, the potential risk of harm from unauthorized use or disclosure of the child’s personal information, the purposes for which we process the child’s personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
When information is no longer needed, it is securely deleted or anonymized.
5. Parental Rights
A. Verifiable Parental Consent
Before collecting personal information from children, we obtain verifiable parental consent, which may include:
- Signed consent form
- Confirmation through a parent account tied to a payment method
- Email confirmation with additional verification
- Identity verification or live call (if applicable)
If consent is not provided, the child cannot access features requiring personal information.
In addition, if we discover that a child has provided personal information without parental consent, we will:
- Delete the information promptly
- Notify the parent or guardian (if identifiable)
B. Accessing and Correcting Your Child’s Personal Information
At any time, you have the following rights with respect to your child’s personal information maintained by us:
- Review the child’s information
- Request deletion of the child’s data
- Withdraw consent at any time
- Request that no further data be collected or used
- Update or correct information
To exercise these rights, parents may contact us at support@gamestrong.ai
We may require verification to protect both your and the child’s privacy and security.
6. Operators that Collect or Maintain Information from Children Through Our Services
The following are all of the operators that may collect or maintain personal information from children through the Services: GameStrong
Please direct inquiries about any third party operator’s privacy practices and use of children’s information to GameStrong at:
11468 Marketplace Dr. Suite 600 – 216. Champlin, MN 55316
877-421-8454
No other third-party operators may collect or maintain personal information from children through our Services.