littleBits Electronics Inc. d/b/a JAM (“we,” “us,” “our,” or “JAM”) knows that you care about how your Personal Information is used and shared, and we take your privacy seriously. We are committed to protecting the privacy of children who use our site and applications, and have drafted this policy in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”). For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.
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:
During the account registration process, we receive and store the following information: full name of the parent or guardian, full name of the child, parent’s email address, a password for the parental account,a password for the child account, and the child’s birthdate (to verify their age).
In addition, children choose an “avatar” and username (“nickname”) which will represent them on the service. We encourage children to use our anonymous nickname generator. Consistent with the requirements of COPPA, we collect a parent or guardian email address before we collect any Personal Information from a child.
We collect credit card information for verification purposes but do not store that information on our servers. 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.
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 (such as a mailing address) for prize-fulfillment purposes when the child wins the contest or sweepstakes.
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 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 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, timezone, device ID, 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.
- We may receive a confirmation when you open an email from JAM if your computer or device supports this type of functionality. JAM uses this confirmation to help us make emails more interesting and helpful and to improve JAM and our services. You can opt out of these communications by sending us an email at both firstname.lastname@example.org and email@example.com.
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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.
- User profile information including users’ nickname and avatar, email address, and other information you enter (“User Submissions”), may be displayed to other users to facilitate user interaction within JAM.
With respect to Personal Information other than a child’s Personal Information:
We share such Personal Information only as described below.
- Advertisers: 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.
- Service Providers: We engage third party companies and individuals to perform services on our behalf (e.g., software maintenance services, advertising serving technologies, e-mail service providers, delivery services, database management, web analytics, payment processing and other services). These third parties have access to your information so that they may perform these tasks on our behalf and they are prohibited by us from using or disclosing your information for any purpose other than to provide this assistance, except to the extent required by law. We may permit our service providers to use aggregate information which does not identify you or de-identified data for other purposes.
- 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.
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 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 (full) name of parent and child
- Account and user profile information
- User e-mail address
- Username and password
- User preferences
- Billing preferences
Parents may review information relating to their child’s account at any time by logging on to the Parent Portal section of the website.
A parent can also contact our customer service department to access, change, or delete Personal Information by sending an e-mail to firstname.lastname@example.org.
Please note that Personal Information about a child may remain in backup storage for up to two weeks after a request for deletion of that child’s data. This may be the case even though no information about that account remains in our active user databases.
When does JAM obtain Parental Consent?
Consent by purchase
In order to participate in JAM, a parent or guardian must purchase access by providing their credit card information (note: “Free Trials” are considered “purchases” for the purpose of consent). In so doing, the parent or guardian grants us permission to collect necessary Personal Information from their child. This kind of credit card verification is in compliance with COPPA and ensures an adult is the one signing a child up for JAM.
Content generated by a child
Certain activities on our sites and applications allow children to create or manipulate content (like photos, videos and comments) and save it within JAM. By registering and creating an account for your child on JAM, you grant us permission to share your child’s content within JAM, and to share your child’s content publicly on our social media channels as long as it does not contain Personal Information.
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 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 out Personal Information, we will first seek high-level consent from the parent.
When will JAM e-mail me?
We may use your contact information to send emails to you about JAM and other related topics that may be of interest to users of JAM. You can opt out of these communications by sending us an email at email@example.com.
As part of JAM’s services, you will receive email and other communication relating to your child’s 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 to be related to your User Submissions.
When will JAM e-mail my 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.
Questions or Concerns
If you have any questions or concerns regarding privacy on JAM, please send a detailed message via email to firstname.lastname@example.org or contact us at
JAM.com c/o littleBits Electronics Inc.
601 W. 26th Street, Suite M274
New York, New York 10001
Legal Department – Privacy
Please note that if you are not 18 years of age or older, you must have your parent or legal guardian’s permission to call us.
Last Updated: January 25, 2019 to reflect the acquisition of DIY Co. by littleBits Electronics Inc. and corresponding updates in address and contact information.
Prior version may be found here.