NextThought Children’s Privacy Policy

Effective July 1, 2013

We at NextThought, LLC (“we,” “us,” or “NextThought”) are dedicated to protecting our users’ privacy, and we recognize the need to provide additional protections when children visit or use the NextThought Service (“Site,” “Platform,” or “Service”). This Children’s Privacy Policy (“Policy”)  is designed to supplement the NextThought Privacy Policy and describes how we handle the personal information of children under 13 on the Sites where posted. Throughout this policy we use the term “child” or “children” to refer to users who are under 13. Also, when we use the term "parent," we include legal guardians.

The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents about how we collect, use, and disclose personal information from children under 13; and that we obtain the consent of parents for children under 13 before we collect any personal information from children or allow them to use certain features of our Service.

Consent

We do not allow children under 13 to have access to features where personal information could be collected, shared, or disclosed, prior to receiving parental consent. For instance, children may register for the Service, read text on the Site, make notes for their personal use, but they will not be able to use chat features or share annotations with their friends or classmates. We will only allow access to these features for children for whom parental consent has been collected, whether directly from the child’s parent or through the child’s school.

Schools

The United States Federal Trade Commission (“FTC”) has published guidance on how schools may satisfy COPPA’s requirements. COPPA provides for schools to obtain parental consent for the collection of students’ personal information. For any qualified school desiring to enable their students under age 13 to use the Service, we rely upon the school’s teachers and/or administrators to collect parental consent for the limited collection of students’ personal information on our behalf. By registering students for the NextThought Service, the school is deemed to provide that consent or to have collected that consent.

If we learn that we have collected personal information from a child without parental consent being obtained by his or her school, district, or teacher, we will delete that information as quickly as possible. If you believe that a child may have provided us personal information beyond what is needed for the Site, or that a child's school, district, or teacher has not received parental consent prior to our collection of any personal information, please contact us at compliance@nextthought.com.

Information Collection and Usage

Registration Information

At the time of registration, children input some information to create an account: birthday, first and last name, username, password, email address, and parent’s email address. To minimize data collected from children, we handle this information in specific ways as outlined below:

Birthday

We ask for children’s birthdays in order to determine which users require parental consent to access the Site’s social features. We do not store this information.

First Name, Last Name, and Username

Children's names are never displayed publicly on the NextThought Site. Instead, each child is known by the username he or she creates when registering for an account. The username should not include any information that could be used to identify a child or contact him or her. Therefore, to protect children’s safety and identities, we do not permit their usernames to contain their personal names, and we ask for first and last names to conduct a screen. This is the only purpose for requesting last names at account registration, and we do not save the last name after the account is created.

Child’s Email Address

We hash (or alter) the email addresses that children provide. They are used only for the purpose of recovering passwords.

Parent’s Email Address

NextThought uses a parent’s email address to send him or her an email about the child's registration. The email will include details on how the parent may (i) provide NextThought with consent to collect the child’s personal information; (ii) prohibit NextThought from any further contact with the child; or (iii) delete the child's account. We only retain parent email addresses after receiving parental consent for the collection of personal information and only for the purpose of providing notification of updates to our Terms of Service and/or Privacy Policies. Parents may opt in to receiving additional communications.

Providing us with this registration information enables children to have an account with limited (non-social) functionality. In fact, we have designed our Service and adopted this Policy so children can access and use aspects of NextThought without disclosing personal information.

Information that Children Provide for Access to Social Features

Access to the Site’s social features requires that we first obtain parental consent to collect personal information from children. Only after we obtain the consent do we ask for and store children’s full names, schools, and email addresses (in non-altered form). We use this information to operate, maintain, and provide the full features and functionality of the Service and to communicate with our users. We may also use it to associate student accounts with appropriate teacher or instructor accounts (where applicable).

We do not ask for more information than is reasonably necessary for children to participate in the Service, and the only information that we require is listed above. However, access to social features means that children may have additional opportunities to provide information about themselves by such means as filling out profile pages, posting blogs or messages, uploading images, or chatting online with other members. Any information or content that children provide through the Service is considered to be publicly disclosed and provided voluntarily. Even if children remove their content, copies may remain viewable in cached and archived pages.

Information Collected Via Technology

In addition to the data that children provide directly (described above), we also collect some technical and usage information via technology (“Platform Collected Information”). This may include IP addresses; the type of computer operating system, devices, and web browsers in use; and the frequency with which users visit parts of the Site. We collect this information through the use of cookies and other software technologies. However, this information is not used to personally identify any users, and we use it only for the internal operations of the Site, such as user authentication, maintaining user preferences, and analyzing the functioning of the Site.

Like other Internet services, we automatically gather this data and store it in log files each time users access the Site. The username used to log in is stored in cookies. Disabling cookies will prevent users from being able to use the Service.

Anonymous Information

We may create Anonymous Data records from personal data and Platform Collected Information by excluding information that makes the information personally identifiable. We may use this Anonymous Data to inform the development of the Service.

Sharing or Disclosing Information

To ensure operability of the Site and delivery of our services, we must share some personal information with third parties who perform services on our behalf. These third parties are required not to use this information other than to provide services requested by us and are bound by confidentiality agreements with regard to any personal information. By signing and returning the consent form, parents expressly consent to the sharing of the necessary personal information of their children with our contractors and third party service providers for the sole purpose of providing our products and services to their children.

We neither rent nor sell personal information to anyone. However, we may share personal information with those education organizations or publishers (“content providers”) whose content users interact with. For example, we may share information with MATHCOUNTS about those users who access and interact with the MATHCOUNTS content through the Service. We have made reasonable efforts to ensure these providers protect the confidentiality, security, and integrity of any personal information that we share with them. For reference, these third-party content providers are listed below.

We may use children’s email information to communicate with them about our Service. They may also opt in to receive promotional information about the Service, such as newsletters or announcements about new features or the availability of Platform content. They may unsubscribe from these commercial emails at any time. If they opt out, they will still receive informational messages about the Service.

In certain situations we may make available services or products from content providers. For example, we may allow users to buy textbooks through the Service, in order to make those materials accessible with all of the interactive features of the Site. These offers may or may not be commercial in nature. We are responsible for the collection of any personal information through such transactions, such as a billing address associated with a credit card transaction. The content providers do not collect personal information directly from our users through these transactions.

Parents may opt to let us collect their child’s personal information for internal use (participation in the Service) without agreeing to the disclosure of personal information to content providers. Parents may opt out of sharing their child’s information with these third-party content providers by sending a request to compliance@nextthought.com.

We may aggregate and disclose Anonymous Data to third parties at our discretion.

We reserve the right to disclose any information posted by any user, including children, as necessary  to enforce our Terms of Use, to ensure the safety and security of our users, to protect our rights and those of our partners, and to comply with the legal process, if we believe in good faith that such disclosure is required by law.

For questions about content or about the privacy practices of a specific content provider, please contact the appropriate party below:

MATHCOUNTS Foundation

1420 King Street

Alexandria, VA 22314

URL: www.mathcounts.org

Email: info@mathcounts.org

Data Retention

We retain the personal information collected on this Site only as long as necessary to provide the services, products, and information associated with their use or to fulfill the purposes for which they are needed.

Parent Notification and Consent

As noted above, we need parental consent before we collect personal information from children or permit them to access the Site’s social features, where personal information may be disclosed. When a child registers, we will send an email notice and a consent form to the parent. Parents can return their signed consent to us via one of the following methods:

By Mail:

NextThought, LLC

Attn: Compliance

301 David L. Boren Blvd, Suite 3050

Norman, OK 73072-7340

By Fax: (405) 308-4310

By Email: compliance@nextthought.com

If users purchase a product or service through NextThought, we may also obtain verified consent through a monetary transaction associated with a credit card.

Account Revisions or Deletions

Parents may review, correct, or update their child’s personal information at any time. Furthermore, they may request that we delete the child’s personal information and/or refuse to permit further collection or use of the information. Doing so will cancel the child’s participation in the Service.

To do this, parents should send their request to compliance@nextthought.com, and we will contact them about reviewing or deleting their child’s information. Please note that we will take steps to ensure that any person contacting us for this purpose is that child's parent.

Children’s Privacy Policy Changes

We may amend our Children’s Privacy Policy at any time. We will post these changes to this Policy on the Site(s) to which they apply. Please check the Site for changes. Continued use of the Service following changes to this Policy will be deemed to constitute acceptance of such changes. If the changes are material, we will also send parents notice of these changes and a request for consent for children under 13. Parents should keep their contact information up-to-date in order to receive such notices and requests for consent.

Contact Information

If you have questions or comments about this Policy, please contact us:

NextThought, LLC

301 David L. Boren Blvd, Suite 3050

Norman, OK 73072-7340

Phone: (405) 872-6181

Email: compliance@nextthought.com