Our Services are designed for and marketed to both adults and children aged 8 and above. Protecting the children who use our App is our priority. In relation to any proposed use of our Services by a child under the age of 13 years, we require the express consent of parents or guardians (referred to throughout as “parent”) of any child who wishes to use our Services to observe, participate in, and/or monitor and guide your child’s use of our Services.
Please therefore read this policy carefully as parents will be legally contracting on behalf of, and responsible for, your designated child.
i. Special App registration procedures for children under age 13
When any user (including a child) chooses to create a Registered Account to use our App, we will ask them to provide their date of birth. If a child self-identifies as being under 13 years old, the child will be required to complete a parental notice, verification and consent process before they can create a Registered Account. To initiate the parental notice, verification and consent process, we will ask the child to provide the email address of their nominated parent. We will also collect an FCM token (ie. a unique identifier) from the child’s device in order to respond to the child’s request for parental consent.
The parent will be directed to our “parent portal” operated by “Kids Web Services”/SuperAwesome, where they will be asked to verify their identity as an adult and to consent to the following permissions for basic App features on behalf of their child. As detailed below, the parent may agree to the collection and use of their child’s information, but still not allow disclosure of their child’s information to third parties, except to the extent such disclosure is part of the Services.
The following permissions are required to activate the child’s Registered Account:
In addition to permissions for the basic App features, the child’s parent will also be asked to manage the child’s permissions for the following extra, optional App features:
Until we receive parental permission for the basic permissions stated above, the child can only use the App in Guest mode. While the App is being used in Guest mode, we will not collect any personal information from the child, and the child will continue to be blocked from accessing any features that allow them to provide personal information to us or to other users of the App.
If the parent does not provide permission for the basic permissions stated above within 7 days, we will delete the parent’s contact information and any data provided by the child.
If the parent does provide the basic permissions stated above within 7 days, we will ask the child to provide us the information required to create a Registered Account for the child and to create a user Profile in the same way as an individual over the age of 13 years. We will not seek consent from the child following their 13th birthday, so any consent given at this stage will be deemed to be consent from the child for so long as they continue to hold a Registered Account.
ii. Parent notifications and control over in-App permissions via parent portal
We will notify the parent of the child’s in-App activity using the email address provided to us by the child at the point of registration. Such notifications will include when the child:
The parent can manage the child’s access to both the basic and extra App features at any time (including revoking access) via the “Kids Web Services” parent portal managed by SuperAwesome.
If the parent chooses to revoke access to any basic App features, we will delete the child’s Registered Account. If the parent chooses to revoke access to any extra App features, we will disable any such feature for the child and we will change any relevant privacy settings for content previously uploaded by the child.
iii. Description of parent rights
Where we ask you for information, we will provide clear notice to you explaining what information we are requesting and why we are asking you to provide it to us. We do not require users of the Services, including children under 13 years old, to disclose more Personal Data or other information than reasonably required to use our Services.
If you are a child under 13 years old, we will seek consent from a verified parent before we collect data from you via the App, with the exception of some limited data that we require in order to facilitate the parental consent and verification process. Until we obtain such consent from a verified parent we will not use this data for any other purpose and will not collect any further data from you via the App.
All App users will be prompted to create a “Registered Account” if they attempt to access further features in the App while using the App in Guest Mode. For children under 13 years old, parental permission as outlined above will be required. If a user wishes to sign up for a Registered Account, we will invite them to create a user Profile as well. For a Registered Account with a user Profile, we will collect the following personal data:
In addition to the information that we collect during the registration process, as part of the child’s use of the App’s interactive, community and personalised features, all children with Registered Accounts may choose to upload content to the App which contains further personal data relating to the child. This content may include:
PLEASE NOTE THAT YOU MUST HAVE PERMISSION TO USE THE PERSONAL DATA OF ANYONE ELSE FEATURED IN ANY CONTENT YOU PROVIDE TO US (INCLUDING IN ANY VIDEO AND/OR PHOTO).
USERS ARE NOT PERMITTED TO USE THE PERSONAL DATA OF ANY CHILDREN UNDER 13 YEARS OLD WHO ARE NOT REGISTERED USERS IN ANY CONTENT YOU PROVIDE TO US (INCLUDING IN ANY VIDEO AND/OR PHOTO).
If you register for the App via “Social Login Providers” (currently Apple, Facebook or Google), those platforms may share your public profile information (including your profile image, email address, Apple ID and first/last name) with us. When you register for the App via such platforms, you may be notified by those platforms of the data we will have access to. If you register for the App via a Social Login Provider, we will not disclose any of your personal data to the Social Login Provider.
On our Site, we will also use Google Analytics (GA4) to collect some aggregated, anonymised user data related to your website behaviour (eg. what pages you looked at, for how long, etc.) using automated technologies i.e., cookies or similar technologies. We run GA4 only in an anonymised version for statistical reporting purposes and have disabled all other data-sharing features. This information is important to us for improving the user experience and determining the effectiveness of our website. Our Cookies Policy provides further details of such collection and use.
This section explains the purposes for which we use the personal data we collect from you. For individuals in the EU, UK, and other regions with privacy laws that require us to specify our legal basis for processing, this section also lists the legal bases we rely on when processing your personal data.
Other App Users
When a child becomes a Registered Account user, the child’s username, player position, nationality flag, and, if the child is over 13 years old, profile picture (if any), will be visible to other App users. For users aged 18+, their Followers/Following lists will also be visible to other app users initially (however this can be adjusted in profile settings.)
Followers and Following
For users aged 13 years and over:
For children aged under 13 years old:
Personal data that may be visible to other App Users depending on user activity
In addition, as part of the child’s use of the App’s interactive, community and personalised features, the child may also make certain other personal data accessible to others both within and outside the App as outlined in the table below. The precise personal data that is disclosed, to whom it is disclosed, and where it is disclosed, will depend on the child’s activity within the App, the age of the child, and (if the child is under 13 years old), the specific permissions set by the parent.
For children under 13 years old:
For children aged over 13 years old and adults:
Users of all ages, including children aged under 13 years old, children aged over 13 years old, and adults, may also choose to download their own videos (featuring the user’s image) to their device.
In the course of using your personal data for the purposes identified in Section C, your personal data may also be disclosed to the following entities:
We contractually obligate our service providers to collect, process, and disclose personal data solely for the purposes of providing services to us as permitted under our agreements with them. We do not permit our service providers to collect, process, or disclose personal data received from us or collected on our behalf for their own purposes.
We may from time to time engage other service providers to whom we may transfer personal data, subject always to ensuring that they are engaged to do so on terms that meet the requirements of applicable law as processors. These service providers will perform functions on our behalf, e.g., providing technical support for the systems where your personal data is held. They may need access to your personal data to perform their functions but will not use your personal data for any other purpose. We contractually obligate such service providers to at all times adhere to applicable data protection laws, and we will only ever disclose your personal data in accordance with the protections mandated by law.
We will not share, sell or licence your personal data to any other third parties without your express prior consent. We may from time to time share anonymised, aggregated data sets with third parties for research and development purposes, but such data will not be capable of identifying any individual.
We may also disclose personal data to comply with our legal or regulatory obligations, in response to a non-mandatory request for information made by a governmental or state body, or as part of an investigation of unlawful activity. We may also disclose personal data to third parties in conjunction with merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), and in such circumstances we will seek assurances that such personal data will be processed in accordance with this policy.
In the case of App users or Site visitors based outside the UK, or where service providers and third parties to whom we disclose personal data (including storage) require access to your personal data outside of the UK, your personal data may be transferred to countries located outside the UK, including to countries that may not provide a similar or adequate level of protection to that provided by your country of residence, in which case we will only do so subject to the necessary protections mandated by UK data protection laws. This may include the standard data protection clauses currently adopted by the UK supervisory authority, the Information Commissioner’s Office (ICO), or such others as may be applicable to the UK from time to time. The specific measures we use to secure international data transfers will be made available on request. Google Analytics data collected through our cookies will be stored in the USA and all appropriate measures will be taken to manage that data transfer and processing in compliance with applicable data protection laws.
We follow a standard procedure of using log files. These files log visitors when they visit websites. Hosting companies do this as part of hosting services' analytics. The information collected by log files include anonymised internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. The purpose of the information is for analysing trends, administering the site, and analysing users' use of the Site.
The Services may, from time to time, contain links to external websites or apps operated by third parties. We do not disclose personal data collected through the Services to these third parties. We are also not responsible for these third-party websites or apps, or the content of such third-party websites or apps. Once you have left the App, we cannot be responsible for the protection and privacy of any personal data which is provided. Please consult the privacy information provided by such third parties. We are not liable for any acts or omissions of such third parties, including in relation to data protection laws.
The security of personal data is important to us. We take all reasonable steps, including technical, administrative and physical safeguards, designed to protect the personal data we collect from loss, misuse and unauthorised access, disclosure, alteration and destruction. We will ask any agents and service providers to whom we may transfer your personal data to take comparable steps to protect that security. However, no method of security or method of transmission over the Internet is entirely secure.
We, and our service providers, may retain personal data for as long as a Registered Account is active, or as needed for the specific business purpose for which it was collected. In some cases, we may be required to retain personal data to comply with laws or regulations or other legal obligations, resolve disputes and enforce our agreements.
This section provides details regarding data subject rights available under the GDPR and UK GDPR to residents of the EU and UK. This section may not apply to residents of other countries, depending on whether those countries have data protection laws that afford the same or similar rights to individuals as the GDPR and UK GDPR.
Under certain circumstances, residents of the EU and UK have the right to:
You also have the right to lodge a complaint in relation to any processing which we undertake in relation to your personal data with the UK supervisory authority, the Information Commissioner's Office (ICO) at https://ico.org.uk/.
We may need to update this Policy at any time and without notice and where we do this we will ensure that such changes are appropriately published and notified through the App and Site.
Last updated: 27 February 2023