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SAM Labs Ltd. (“Sam Labs”, “we”, or “our”) is committed to protecting the privacy of children who use our sites and applications. This Child Privacy Policy (“Policy”) explains our information collection, disclosure, and parental consent practices with respect to information provided online by children (under the age of 13 in the US, or as determined by applicable local law) (each a “child” or “children”) and other users of the Services (defined below). This Policy applies to SAM Labs website site and “SAM Blockly” located at blockly.samlabs.com (the “Sites”), together with the associated SAM Labs application (the “Application” and together with blockly.samlabs.com, the “Services”), and outlines our practices regarding your child’s information. For more information about SAM Labs general privacy practices, please review our main Privacy Policy, which controls over subjects not explicitly dealt with herein. For more information about the Children’s Online Privacy Protection Act (COPPA) and general tips about protecting children’s online privacy, please visit the FTC’s website.

What do we collect on children and how do we communicate this?
If we collect information from a child online through the website, we will keep that information for the purpose of providing the child access to the service. In the event we believe we have collected data on a child unlawfully, we will either delete the data immediately or request permission from the parent. We collect only the information required to provide the service to the child. The data we collect is:

Registration Information
Users can initiate registration with our Application to view Content (defined below), create programs, and engage in special features, among other activities. During the registration process, users are asked their birthdate to validate age, and users who indicate they are children will not be able to activate an account on the services themselves without parental permission. Children are required to provide their first name, user name, password, and a parent’s email address so the parent can approve a child-created account. If the parent does not complete the approval process within 21 days, we will delete the information the child provided (unless the parent has separately signed up using that email address for marketing emails or otherwise provided that information on another SAM Labs site or in connection with another SAM Labs service). We ask that adults never provide any personal information about their child, including using names or email addresses in a screen name, and that children avoid using any part of their name or email address in their screen name. If a parent user creates the child account, the parent can provide access to the child for the child’s use of the Services.

Non-child users may create an account on the Application without parental consent.

If at any point you wish to remove your child’s data from our systems please email info@samlabs.com

User-Generated Content
We provide the ability for the user to share projects on our platform. If such a user submits content to the platform, that Content may include personal information, such as the user’s image, voice, or name. A user should not include personal information in the Content he or she uploads to the Application. Examples of uploaded Content that may include personal information are programs, activities, images, videos, comments, and ratings generated from the SAM Blockly (“Content”). The projects will be moderated and at any time SAM Labs reserve the right to delete the projects. This is to ensure safety and privacy at all times.

Collecting Information Automatically
To operate and improve our website and platforms we use tracking. The methods we use to automatically collect information on the Site are described in our main Privacy Policy.

Email Consent
In the event SAM Labs wishes to collect personal information from a child online, for internal purposes, we will first seek a parent’s consent by email. In the email, we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will remove the parent contact information (unless the parent has separately signed up using that email address for marketing emails or has otherwise provided that information on another SAM Labs site or in connection with another SAM Labs service) and any other associated information from our active servers.

How do we verify parental Consent?
By default only a child’s parent, or if the child’s account is linked to an instructor, the instructor, can view the Content submitted by the child. If the child wishes to share Content publicly on the Application, we will seek verified consent from the parent first. If a school or teacher wishes to publish a user’s Content on the Application inside of the classroom, we will seek consent from the instructor and verify their identity as outlined below; except that only a child’s instructor and classmates can view a child’s Content. Children inside the classroom may not share Content publicly outside the classroom at this time.

If a parent wishes to allow a child to share Content publicly outside of the classroom, we will send the parent an email outlining the verification process. To obtain verifiable parental consent, a parent may use one of two forms of verification: credit card or signed form. If the parent uses the credit card option, Workbench, a third party service provider, will process a $.50 charge on the credit card and donate the full amount to an educational charity. If the parent uses the form option, he or she must download, print, sign, and upload the form to us. After we or Workbench have verified the parent’s identity, the child under the parent’s account will be able to upload and share Content publicly. To withdraw consent or delete the child’s account, email us at Info@samlabs.com

Teacher, Instructor, Or Other Adult Consent In Lieu Of A Parent
With regard to school activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. We use a one-part verification process for teachers, where they download, print, complete, and upload a verification form. There is also a two-part verification option: electronically signing the verification form and uploading a photo of their teacher ID, which Workbench verifies. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

How We Use Your Child’s Information
We may use the child’s information to:

  • operate and improve our Services
  • provide the services you or your child request;
  • improve the quality of our Services;
  • understand you and your child’s preferences to enhance your experience of our Services;
  • protect, investigate, and deter against fraudulent or illegal activity

We do not:

  • permit behavioural targeting of advertisements towards children on the Services;
  • sell any child’s information collected by the Services;
  • create or keep student profiles for non-educational purposes.

Sharing Information with third parties

In addition to those instances where a user account posts Content publicly, as described above, we may also share, receive, or disclose information collected from users in a limited number of instances, including the below. The third parties with whom we contract, Workbench, share our commitment to our security and data retention principles.

  • We share all information collected by the Application with Workbench, whose platform hosts the Application. Workbench also provides development and other back end support for the Application. Workbench uses this information to help us provide the Application to you. Workbench’s platform stores user data (e.g. programs, activities, and other media) in Amazon’s RDS Database & S3 Storage. Workbench also processes your email address, teacher identification badge (if applicable), and credit card information (if applicable) if you choose to undergo the consent processes described in Section 1 above. For more information about how Workbench handles information, please see the Workbench Privacy Policy. If you have questions or concerns about Workbench’s privacy practices, please contact them at 410-212-6835 or privacy@workbenchplatform.com. You may also write them at 101 W. Dickman St., Ste. 300, Baltimore, MD 21230. Workbench does not share user information with any other third parties, except as disclosed in their Privacy Policy. Workbench must adhere to confidentiality and security obligations in a way that is consistent with this Policy.
  • We may allow users to sign into the Application through Google’s single sign-on process or Google Classroom. For more information, please see Google’s privacy policy and this article. We receive a Google user’s email address and username from Google, which we use in accordance with Section 1 of this Policy. We do not share personal information back to Google.
  • If a user’s school district or educator uses Google Classroom, we may permit users to sign into the Application using a Google Classroom-connected account. For more information on the data collected by Google Classroom, please see the G Suite for Education Privacy Notice. We receive student email addresses, first and last names, and email address from Google Classroom. If a user or an instructor provides a user’s birthday or grade, we receive that information as well but do not use grade information. We use the information we receive from Google Classroom in accordance with Section 1 of this Policy, but not to advertise to users under 13 via email. Classroom also tells us the classes in which a student has enrolled; we use this information to sort students into the appropriate class. We do not share personal information back to Google Classroom.
  • We share public videos on YouTube, after they have been moderated in accordance with this Policy. For more information on YouTube’s privacy policy, please see the YouTube Privacy Guidelines. If you as a parent have enabled your child to post publicly by providing verified consent, you may revoke this consent by disabling the “Publish Public Content” slider in the Application settings.
  • We may also share information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. Any such transfer will require the receiver to uphold this Policy.
  • We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or government agency’s request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety, or protect the safety of a user of Services; (iii) to protect the security or integrity of our Services, and other technology, as well as the technology of our service providers; or (iv) to enable us to take precautions against liability.

Parental Choices and Controls
At any time, a verified parent an request to see the information on a child. We will also at the request of the parent delete any data, this can be done by emailing info@samlabs.com. It is also possible for a parent to log into the account and change the childs information.

Data Retention
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or allowed by law.

In addition to the retention policy above that applies to all users, we only keep a child’s personal information as long as necessary to deliver services or for school purposes, unless we are required by law to retain it.

Encryption, Retention, and Security
We use SSL to encrypt data in transit between your device and the Application servers. We encrypt passwords, but not other data, at rest. We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at the address below.

Changes to this Policy; Notice
We may amend this Policy at any time by posting the amended version to the Site or by providing such notice or obtaining consent to changes as may be required by applicable law. For material changes in this Policy, we will e-mail the last e-mail address you provided to us (if any) and/or prominently post notice of the changes on blockly.samlabs.com. Your continued use of the Services constitutes implied consent to such amended Policy.