COPPA Policy
STOCK-TRAK Inc. COPPA PRIVACY POLICY Effective Date: 3/1/2017 Last modified: 2/14/17
Stock-Trak Inc. (“Stock-Trak”) values the privacy of children and 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 use our virtual trading platform and access content through our various websites including: http://www.StockTrak.com , http://www.HowTheMarketWorks.com , http://www.PersonalFinanceLab.com , http://www.Investing101.net , http://www.Virtual-Stock-Exchange.com , and http://www.NationalSMS.com (the “Websites”) and the services, such as assignments, provided on our Websites (the “Services”).
Stock-Trak develops and makes available a virtual stock market simulation and other educational content (hosted on its own platform). Stock-Trak may partner with foundations, non-profits, or for-profit entities to make these Services available to schools and other educational organizations. In the course of providing these Services, Stock-Trak may come in to contact with information, including personal information, from its users.
Some, but not all, of Stock-Trak’s Services are directed towards children under the age of 13. This COPPA Privacy Policy applies to the information we collect from children under 13 years old. Stock-Trak 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 Stock-Trak Privacy Policy (“Privacy Policy”). The use of our Websites and any dispute over privacy is subject to this COPPA Policy, the Privacy Policy, and our Terms and Conditions, including its applicable limitations on damages and the resolution of disputes. Our Terms and Conditions and Privacy Policy are incorporated by reference into this COPPA Policy.
Who Will Collect Information About Children?
Stock-Trak operates the Websites and Services and will collect children’s personal information as described in this COPPA Policy and our Privacy Policy. We can be contacted at:
3575 Ashby Road
Montreal, Quebec, H4R 2K3
514-871-2222, privacy@stocktrak.com
Even if Stock-Trak’s Services are offered in conjunction with an outside partner, the partner will not receive any individual personal information from users of the site, including children. Stock-Trak may provide 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 provide the Services.
How Information is Collected?
We may collect information about children directly from children, as well as automatically through a child’s use of our Site and 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 years old, we use 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. If a child is under 13, we collect the child’s first name, and the initial of their last name. We do NOT ask children for their full last name. Children must create their own usernames, but are NOT required to provide a valid email. We only use user name and email address (if provided) to track a child’s portfolio values, for class rankings or to reset passwords; we will NOT contact a child using his or her email address or username other than for password reset requests. We may also collect additional demographic information (such as gender) from children; however, we do not associate this with the child’s name or other personal information and we use it only to compile aggregate and de-identified information about participants on our simulations. Parents may ask us to stop collecting personal information about their child by emailing us at privacy@stocktrak.com, however, in such cases the child will not be able to continue using the Services. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our Websites to ensure that no information is collected.
Information We Collect Automatically
We may automatically collect the following information about a child’s use of our Websites through cookies and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Websites; Google Analytics statistics; the referring URL or the web page that led the child to our Websites; language information; device name and model; operating system type, name and version; and activities within our Websites. We may also include IP address, device identifier or a similar unique identifier from users of our Websites, including children; we only use such identifiers to support the internal operations of our Websites and we do NOT use such identifiers to collect information about the child outside of our Websites.
Other Information We Collect About Children
We collect information about children’s performance and activities on our Websites. This information may be reported back their teacher; however, we do NOT use this information in personally identifiable form for our own commercial purposes. Before we analyze or use any activity data for our own commercial purposes, we de-identify and/or aggregate such information.
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 Websites or Services, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Websites and Services. We never use unique identifiers to track users across third-party apps or websites.
Aggregate or De-identified information. We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, email, contact information, and other personal identifiers. We may use aggregated or de-identified information for the following purposes:
- To better understand how users access and use our Websites and Services;
- To improve our Websites and Services and respond to user desires and preferences; and
- To conduct research or analysis, including research and analysis by third parties.
How We Share Children’s Information
We do NOT sell children’s personal 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 Stock-Trak and other users of our Services. 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 may also 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 may also 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 Stock-Trak is involved.
- With Parents. Parents may request information about the information we have collected from their child by contacting us at privacy@stocktrak.com
- Aggregate and De-Identified Information. We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.
- Authorized Entities. If you access the Service through, or are granted access to the Service by a school, school district, college, university, person, institution, employer or other organization (an “Authorized Entity”), we may share the information we collect about you with the Authorized Entity or its representatives. Such information may include, but will not be limited to: portfolio value; class ranking; email address; user ID/identifying tag or username (if applicable); additional aggregated data the Authorized Entity or its representatives requests.
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 tell us to stop using it. To exercise these rights, you may contact us at privacy@stocktrak.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 Websites. 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 by highlighting the change on our Websites.
