COPPA Privacy

Mighty Children’s Online Privacy Policy

My Lemonade Stand, PBC d/b/a Mighty (“Mighty,” "we,” “us,” or “our") is the operator of the Mighty service available at www.mighty.business and other associated websites and mobile applications that link to this Policy, which provide an interactive, e-commerce platform through which kids can be their own CEOs and sell products (collectively the "Services").  

The purpose of this Children's Online Privacy Policy (“Policy”) is to describe what types of “personal information” (as defined by the Children’s Online Privacy Protection Act (“COPPA”)) we collect from children under the age of 13 (“child” or “children”) through the Services, the purposes for which we use the personal information, the rights parents and children have regarding this personal information, and to whom and under what circumstances we disclose personal information.

For more information about our information collection, use, and disclosure practices for users 13 years of age and older, please see our Online Privacy Notice. If you have any questions about this Policy, please contact us using the information provided at the end of this Policy.

Collection of Children’s Information and How We Use It.

We will only collect and use a child’s personal information that is not subject to an exception under COPPA when we have the consent of the child’s parent or guardian.  If we discover that we’ve unintentionally collected personal information from a child in a way that does not meet applicable legal requirements, we will delete the information promptly. This section discusses the types of information we collect directly from children, and the information we collect as children use the Services.  Please note that we do not make a child's participation in the Services contingent on that child's disclosure of more personal information than is reasonably necessary to participate in the Services.

A. Information we Collect Directly From Children

In order to collect and use a child's personal information, we are required by COPPA to obtain verifiable consent from the child's parent or guardian.  We obtain this consent by requiring a Shop CEO’s parent or legal guardian to pay the applicable fee indicated on the Services to launch the shop through the use of a valid payment account number and to review and agree to our COPPA Notice, privacy policies, and Terms of Service.  We will also collect and retain the parent’s email address to send important communications about the Services and the child’s participation in the Services. We may also use the parent’s email address to inform the parent about promotions, sweepstakes, contests, and other marketing activities.

Once consent has been obtained, for the child to set up a shop and participate in the interactive, e-commerce features of the Services, we collect the following information about the child: name, email address, password), and a unique username.  In accordance with applicable legal requirements, we may also collect the child’s or parent’s phone number to communicate about the Services via SMS.

In setting up their shop, children are able to add a cover image, draft text to introduce themselves and their shops to their potential buyers, select the products they want to sell, and provide descriptions of the products that they are selling.  The child can edit this information at any time. To sell products through the child’s shop to provide e-mail addresses of individuals that the child wants to market his or her shop to, and the child will be able to subsequently update this list from time to time.  Children may also have the ability to interact with other users on the Services to share information about their shop and offer feedback on the products they sell and their shop’s success. Children also have the ability to participate in forum and group features.  Given the interactive nature of the Services and the various features the child can edit, please review your child’s shop and related activity periodically to review this information together with your child.

B. Information we Collect as Children Use the Services

When your child uses the Services, we also collect information about the devices used to access the Services, and information about how they interact with the Services.  

• Information we collect about the device used to access the Services includes: persistent identifiers such as IP addresses and other device identifiers, system operating system (e.g., Windows or Macintosh), and the type of browser being used (e.g., Google Chrome, Internet Explorer).  
• Information we collect about interactions with the Services includes: the number and frequency of visits to the Services, the websites users were on before using the Services, the parts of the Services used, products selected and viewed, whether email communications we have sent have been viewed and/or content within them clicked, and the frequency and duration of use of the Services.

We use this information for a variety of business operations purposes, such as to recognize users, analyze use of the Services, market the Services, improve the Services, and secure and troubleshoot the Services. Note that a child may be able to browse the Services without registering for the Services.  In such instances, the only information that will be collected from the child will be persistent identifiers associated with the device and usage data discussed above for use for our own analysis, statistical, and other internal purposes.  However, once we have received parental consent, we may link the device and usage information to the child’s account.  This combined information allows us to further personalize your child’s experience on the Services, and the communications we send to your child about the Services (including communications about new features, how to set up their shops, and stories about other users’ successes).  Your child can opt out of any of these communications that are commercial in nature by using the unsubscribe mechanism at the bottom of those emails, or you can contact us to request that we no longer send commercial marketing communications to your child.  Even if an opt out is received, we will continue to send transactional communications about the Services that are not marketing in nature.

The Service Providers that assist us in collecting usage data for our internal operations are:
‍
· Google Analytics
· Heap
· Full Story
· Stripe
· MailChimp

· Customer.io

· Sendgrid

To collect the information discussed in this section, we, and our service providers, use cookies and other online technologies such as web beacons.  You have the ability to disable or block cookies through your Internet browser settings.  For more information about how we use cookies and other online technologies to collect information, please see our Privacy Notice.

Disclosure of Information.

Please note that we do not share or disclose your child’s personal information for marketing purposes.

Because Mighty is designed to be an interactive e-commerce platform through which children can sell products and interact with other users, your child’s shop information, profile, and forum and group postings are public and can be seen by other users, visitors to the Services, and contacts provided by your child.  

In addition, we may share or disclose personal information collected from your child in the following circumstances:

• With our service providers so they can perform services on our behalf (such as hosting providers, analytics providers, and customer service providers)
• As permitted or required by law, including in response to a court order or a subpoena
• To protect the safety of a child, to prevent a crime, or to facilitate a public safety investigation
• To take precautions against liability
• To protect the security or integrity of our Services
• If we are involved in a merger, acquisition, or asset sale, a child’s information may be among the information shared, and in such a situation, we will comply with applicable legal requirements

We may share aggregated, de-identified information relating to activity on the Services with third parties or the general public. For example, this may include the provision of reports regarding child engagement with the Services to improve the Services, or analysis of use of the Services or its features.  Such aggregated, de-identified data will not contain any personal information from your child and can be freely shared at our discretion.

Parental Controls and Choices.

Parents or guardians may also contact us using the “Contact Us” information below to alter permissions, access the personal information that we have collected about their child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect, use, or maintain such information. To protect the privacy and security of our users, we will take reasonable steps to verify the identity of the parent or guardian before granting the parent or guardian access to the personal information that we collect and maintain about the parent or guardian and his or her child.

Changes to This Policy.

By using the Services, you agree to the practices described in this Policy. On occasion, it may be necessary for us to change the terms of this Policy due to changes in the law, technology, or our practices. We will do so by posting updated text on the Services, and your continued use will constitute acceptance of those changes. To ensure that you are aware of current privacy practices, we recommend that you review the Policy periodically. If required by COPPA or other applicable legal requirements, we will provide additional notice and/or ask for your agreement to certain changes.  

Contact Us.

If you have any questions, or would like to express any controls discussed above, please contact us via e-mail at support@mighty.business or via mail at Mighty, attn: Privacy Info, 6 W 18th St. 8th Floor NY, NY 10011