How is Information Collected?
As a parent or legal guardian, you will create the
account, register the child, and provide
information about the child. This includes creating a
username and password and registering the child’s device.
After you register the child, we will track the mobile device
they are utilizing so that notifications can be sent from
the child to the parent. We may also collect additional
demographic information (such as race and gender) from the parent.
In addition, 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. A copy of
a notice of our privacy policies practices is
posted at the bottom of all pages within
FamPay. From children under 13, we
use the date of birth to verify the child’s
age. We collect the child’s first name. We do not
ask for the child’s last name.
Parents may request that we stop collecting information by
contacting us via email at NCUMemberService@numericacu.com. However, this will prevent
the use of the service. Upon termination of
services all children’s data will be permanently
deleted from the solution.
Information We Collect Automatically
We may automatically collect the following
information about a child’s use of our Site
through cookies and other technologies: domain name;
browser type and operating system; web pages
viewed; links clicked; buttons clicked; the length
of time spent on our Site; the length of time our
solution was utilized; Google Analytics statistics;
the referring URL, or the webpage that led the
child to our Site; device name and model; operating
system type, name, and version; and activities
within our Site. We may also collect IP addresses,
push notification ID, device identifier or a
similar unique identifier from users of our
product, including children. We use such
identifiers only to support the internal operations of
our product and we do not use such identifiers to
collect information about the child outside of our
Site.
Other Information We Collect About Children
We collect information about children’s performance
and activities on our Site, including financial
performance. This information is for internal use
only and will not be disclosed to other entities;
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:
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 Site
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
Site 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 aggregate or de-identified
information for the following purposes:
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To better understand how users access and
use our Site and Services;
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To improve our Site and Services and
respond to user desires and preferences;
and
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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
Numerica Credit Union 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 to third-party vendors
contractors, or agents who perform
functions on our behalf.
-
Business Transfers. If we are acquired by
or merged with another Credit Union, if
substantially all of our assets are
transferred to another Credit Union, or as part
of a regulatory merger proceeding, we may transfer
the personal information we have collected
from our users to the other Credit Union.
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In Response to Legal Process. We also may
disclose the personal information we
collect in order to comply with the law, a
judicial proceeding, court order, subpoena,
or other legal process.
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To Protect Us and Others. We also may
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 FamPay Agreement and Disclosure, Privacy
Policy, or this COPPA Privacy Policy, or as
evidence in litigation in which Numerica Credit Union is involved.
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With Parents. Parents may request information about the information we have collected from their child. Contact us via email at NCUMemberService@numericacu.com.
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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.
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, respectively, and to delete it,
and to tell us to stop using it. To
exercise these rights, contact us via email at NCUMemberService@numericacu.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. Parents may login to the
product at any time and review the information
entered by their children.
Changes to This COPPA Privacy Policy
This COPPA Privacy Policy is current as of the Effective
Date set forth above. We may change this COPPA
Privacy Policy from time to time, so please be sure to
check back periodically.
We will post any changes to this COPPA Privacy Policy on
our Site, at . If we make any
changes to this COPPA Privacy Policy that materially
affects our practices with regard to the personal
information we have previously collected from a
child, we will provide you with notice in advance
of such change by highlighting the change on our
Site.
