The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents.
JAM offers to its users a service primarily targeted at children. Our sites and applications offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Children can, in many cases, register with our sites and applications to view content, share content, and engage in social features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at firstname.lastname@example.org.
Content Generated by a Child
Certain activities on our sites and applications allow children to create or manipulate content and save it with JAM. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. If, in addition to collecting content that includes personal information, JAM also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
About Verifiable Parental Consent
Consent by Purchase. In order to participate in JAM, a parent or guardian must purchase access and grant us permission to collect necessary personal information from a child. If we do not receive a parent purchase in conjunction with child registration within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
In the event JAM collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Teacher consent in lieu of a parent
With regard to school-based 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. 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.
Certain activities that are directed to children allow users to communicate directly with other users by means of a comment system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
Where JAM employs a comment system that does not filter all or nearly all personal information, we will first seek high-level consent from the parent.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission. Please see Content Generated by a Child above for more information on our collection, notice, and consent policies.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, JAM may need to ask for the child’s online contact information, such as an email address. JAM will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about an activity. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a purchase access before the child can receive push notifications from our child-directed applications that collect a device identifier. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
If a JAM site or application collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
When children interact with us, certain information may automatically be collected, both to make our sites and applications more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by JAM or by a third party. This data is principally used for internal purposes only, in order to:
- provide children with access to features and activities on our sites and applications
- customize content and improve our sites and applications
- conduct research and analysis to address the performance of our sites and applications
- generate anonymous reporting for use by JAM
In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.
Please contact us at the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices:
- When Information Collected From Children Is Available To Others
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- 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 public agency’s (including schools or children services) 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 child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
- Parental Choices and Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has registered for a JAM account, we use one method to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
Parents can contact JAM Help to request access to, change, or delete their child’s personal information by sending an email to us at email@example.com or call us at 1–844-TALK-JAM.
In any correspondence such as e-mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
What Personal Information Does JAM Collect?
The information we gather from users enables us to provide, personalize and improve our services, and allows our users to set up a user account and profile that can be used to personalize their experience on JAM and interact with other users through the site. In connection with JAM, we request and display some personal information to other users and visitors of JAM, which allows users to identify one another. We collect the following types of information from our users:
Personal Information You Provide to Us:
We ask the child to pick an “avatar” which will represent them on the service; We ask the child to pick a nickname to identify them on the service. We encourage children to use our nickname generator. We ask the child to provide a password.
During the parental account registration process, we receive and store the following information: full name of the parent, parent’s email address, a password for the parental account, as well as any other information necessary for us to provide our services. We ask for a credit card for verification purposes but do not store that information on our servers. In addition, if a parent elects to subscribe to any paid features of our service, we may collect additional billing information such as a mailing address.
We’ve partnered with Stripe to help make verification and payments easier and safer. Stripe meets and exceeds the most stringent industry standards for security. You can learn more about the technical details of Stripe's secure infrastructure here. JAM does not store full credit card numbers, but instead, only the last four digits and expiration date.
JAM does not intentionally collect any personal information from children other than the information set out above. However, as part of the functionality of our service, we allow child accounts to upload certain content to the site, including photos, videos, and comments. We take measures to prevent children from communicating personal information through these features, but we cannot guarantee the effectiveness of these measures. If you use these features to disclose personally identifiable information, you should be aware that such information could be read, collected, or used by other users and/or third parties. You agree not to provide any personally identifiable information through these features, and we are not responsible for any personally identifiable information that you provide using these features.
You can choose not to provide us with certain information, but then you may not be able to create an account or take advantage of many of the JAM’s special features. The Personal Information you provide is used for such purposes as obtaining parental consent as set forth above, providing parents with notice of our privacy practices, answering questions, improving the content of the JAM, responding to your requests for certain information, products and services, attribution for content you submit, customizing the advertising and content you see, allowing you to communicate with other users, and communicating with you about JAM’s products and services, including specials and new features.
Personal Information Collected Automatically:
- We receive and store certain types of information whenever you interact with JAM or use our services. JAM automatically receives and records information on our server logs from your browser including your IP address, cookie information, browser information, operating system, timestamps, the pages you request, and the actions and path you take on JAM.
- Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to JAM and how they use its various components. JAM only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how users use parts of JAM or services so that we can make JAM appealing to as many users as possible, and improve those services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use JAM or services. We share this type of statistical data so that our partners also understand how people use JAM or services, so that they, too, may provide you with an optimal online experience. Again, JAM never discloses aggregate information to a partner in a manner that would identify you personally.
What About Cookies?
Will JAM Share Any of the Personal Information it Receives?
Personal Information about our users is an integral part of our business. We neither rent nor sell your Personal Information to anyone; To be absolutely clear, we do not and will not sell your, or your child’s data.
With respect to a child’s Personal Information:
- JAM will not send Personal Information about a child to other companies or people, except when: we have a parent’s consent to share the information or we are required to do so to comply with the law, including for example, to comply with a court order or subpoena; to enforce our Terms of Service, or site rules; or to protect the safety and security of our users and site.
- If JAM, or substantially all of its assets were acquired, or in the unlikely event that JAM goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. As set forth below, you acknowledge that such transfers may occur, and that any acquirer of JAM may continue to use your Personal Information as set forth in this policy.
With respect to Personal Information other than a child’s Personal Information, we share such Personal Information only as described below.
Advertisers: As discussed above, we may allow advertisers to choose the demographic information of users who will see their advertisements and you agree that we may use any of the information we have collected from you (including, without limitation, information you may have decided not to show to other users) to select or allow the advertiser to select the appropriate audience for those advertisements. For example, we may allow an advertiser to target an ad to you based on your query history.
Affiliated Businesses We Do Not Control: We anticipate that we may become affiliated with a variety of businesses and work closely with them. In certain situations, these businesses may sell items to you through JAM. In other situations, JAM may provide services, or sell products jointly with affiliated businesses. You can easily recognize when an affiliated business is associated with your transaction, and we will share your Personal Information that is related to such transactions with that affiliated business.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, JAM’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.
User profiles: User profile information including users’ name, email address, and other information you enter (“User Submissions”) may be displayed to other users to facilitate user interaction within JAM. Email addresses are used to add new User Submissions to user profiles and to communicate through User Submissions. Users’ email addresses will not be directly revealed to other users by JAM, except, when the user is “connected” to another user via a shared group membership, or an invitation, or if the user has chosen to include their email address in their User Profile.
Communication in response to User Submissions: As part of JAM and services, you will receive email and other communication relating to your User Submissions. You acknowledge and agree that by posting such User Submissions, JAM may send you email and other communication that it determines in its sole discretion relate to your User Submissions.
Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that are transferred. Moreover, if JAM, or substantially all of its assets were acquired, or in the unlikely event that JAM goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of JAM or its assets may continue to use your Personal Information as set forth in this policy.
Protection of JAM and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the any applicable law, regulation or other legal requirement; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of JAM, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
Is Personal Information About me Secure?
Your child’s JAM account Personal Information is protected by a password for your privacy and security. You need to ensure that there is no unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer (or other device) and browser by signing off after you have finished accessing your account. JAM endeavors to protect user information to ensure that user account information is kept private, however, JAM cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Please be aware that whenever you voluntarily post information to public areas on JAM or any other public forums, such information can be accessed by the public.
What personal information can I access?
JAM allows you to access the following information about you for the purpose of viewing, and in certain situations, updating or deleting that information. This list will change as JAM changes.
- Real name
- Account and user profile information
- User e-mail address
- Username and password
- User preferences
- Billing preferences
- Shipping preferences
- Phone Number
Moreover, parents may review, edit, and delete information relating to their child’s account at any time. We use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
- A parent can access, change, or delete his or her child’s Personal Information by logging on to the website and following the instructions set forth above in “What Personal Information Can I Access.”
- A parent can contact our customer service department to access, change, or delete the child’s Personal Information by sending an e-mail to firstname.lastname@example.org. Please include the child’s member name and the parent’s e-mail address in the e-mail so that we can better assist you with your inquiry or request.
Please note that Personal Information about a child may remain in back-up storage for some period of time after a request for deletion of that child’s account. This may be the case even though no information about that account remains in our active user databases.
So what do we keep private?
This data will not be publicly displayed or revealed to other users:
- you, or your child’s, ‘Real’ or ‘Full’ name
- your child’s age
- any payment information you provide
- your password details
- your IP address
- your phone number
- your physical address
- communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem)
We do reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect JAM’s legal rights.
Questions or Concerns
If you have any questions or concerns regarding privacy on JAM, please send a detailed message to JAM’s CEO Zach Klein via email at email@example.com, write to us at
3360 20th Street
San Francisco, CA 94110
We will make every effort to resolve your concerns. Please note that if you are not 18 years of age or older, then you must have your parent or legal guardian’s permission to call us.
Effective Date: May 1, 2016