COPPA policy
HARD SKILL EXCHANGE
COPPA POLICY
LAST UPDATED OCTOBER 1, 2023
Introduction
Hard Skill Exchange (referred to as “HSE,” “we,” “our,” or “us”) is committed to ensuring the protection and privacy of our users, especially children under the age of 13. This COPPA Policy has been formulated in adherence to the Children’s Online Privacy Protection Act (“COPPA”) to elucidate our practices concerning the collection, use, and disclosure of information from children below the age of 13.
This policy shall be interpreted and understood in conjunction with the Hard Skill Exchange Refund Policy, Hard Skill Exchange Main Privacy Policy, Hard Skill Exchange Cookie Policy, and the Hard Skill Exchange Terms of Use. All aforementioned policies are hereby incorporated by reference into this policy.
In compliance with the Children’s Online Privacy Protection Act (COPPA), Hard Skill Exchange (HSE) operates as a digital marketplace dedicated to the exchange of sales coaching services between qualified professionals and clients aspiring to enhance their sales acumen. The platform endeavors to provide a secure and streamlined environment for engaging in sales activities like cold calling and email marketing, under the expert guidance of seasoned coaches. The paramount objective of HSE is to foster a proficient marketplace that seamlessly connects individuals keen on augmenting their sales performance with field experts, while stringently upholding the privacy and security of all user information. HSE explicitly prohibits individuals under the age of 13 from utilizing the platform and services, in adherence to COPPA regulations, to ensure the utmost safety and protection of children online.
Definitions
- “We,” “our,” “us,” refers to Hard Skill Exchange.
- “User,” “you,” refers to the user of our services, including parents and guardians.
- “Services,” refers to the website, applications, and services provided by Hard Skill Exchange.
- “Child,” “children,” refers to individuals under the age of 13.
Description of Information Practices
We collect and store personal information from children only as disclosed in this policy. Information collected is used to create an individualized experience, improve our services, and communicate with parents. All personal information is stored securely with appropriate physical, technical, and administrative measures in place to protect against unauthorized access or disclosure.
Any third parties involved in the processing, storage, or management of personal information are bound by contractual agreements to maintain the confidentiality and security of such information, and to use it only for the purposes for which it was disclosed.
Scope
This COPPA Policy applies to all the domains owned by HSE, encompassing our website, applications, products, services, or any other platform (collectively, the “Services”) where this policy is referenced, regardless of how they are accessed or used, including through mobile devices.
Prohibition of Children Under 13
The Services are strictly prohibited for persons under the age of 13. We neither knowingly collect nor solicit personal information from children under 13 or knowingly allow such persons to register as Users. In the event that we discover that we have collected personal information from a child below 13 without verifiable parental consent, we will expunge that information promptly.
In accordance with the Children’s Online Privacy Protection Act (COPPA), Hard Skill Exchange (HSE) strictly prohibits the use of its website and services by children under the age of 13. We do not knowingly collect, use, or disclose personal information from children under 13.
Enforcement Measures
Age Verification
During the account creation process, all users are required to provide their date of birth to verify their age. If a user is identified as being under the age of 13 based on the date of birth provided, they will be unable to create an account and will be directed to a notice explaining our age restriction policy. The following steps detail how age verification is handled during the account creation process:
- Date of Birth Entry – As part of the account registration process, prospective users are required to enter their date of birth in a designated field. This field is mandatory and must be completed before proceeding with account creation.
- Age Calculation – Upon entry, our system automatically calculates the age of the prospective user based on the provided date of birth and the current date.
- Age Verification Result – If the calculated age is 13 years or older, the prospective user may proceed with the account creation process. If the calculated age is under 13 years, the account creation process is halted.
- Notification of Age Restriction – Prospective users identified as being under the age of 13 will be directed to a notification page. This page will clearly explain our age restriction policy, outlining that individuals under the age of 13 are not permitted to create an account or use the services provided by Hard Skill Exchange.
- Recording and Monitoring – Attempts to create accounts that are halted due to age restriction will be recorded for monitoring purposes. This information will help in assessing the effectiveness of our age verification process and may be used in further enhancing our COPPA compliance measures.
- Parental Consent – During account creation, the date of birth must be provided. If the user is under the age of 13, they will be redirected to the Parental Consent Process. An email notification will be sent to the parent or guardian provided by the child, explaining the nature of Hard Skill Exchange, the type of information that will be collected from the child, and how this information will be used and shared.
- Verifiable Parental Consent – Parents or guardians will be required to provide verifiable consent through a secure online form linked in the notification email. This form would require the parent or guardian to provide their full name, relationship to the child, contact information, and electronic signature. Alternatively, they could be directed to print a consent form, fill it out, and send it back via mail or fax.
- Confirmation of Consent – Once verifiable consent has been obtained, a confirmation email will be sent to the parent or guardian, along with an explanation on how they can review, modify, or delete the information collected from their child. The child’s account will be activated, allowing them to proceed with the use of Hard Skill Exchange under the supervision of their parent or guardian.
- Ongoing Communication – Parents or guardians will receive notifications regarding any significant changes to the information collection practices or the Parental Consent Process. Parents or guardians will have the option to revoke consent and request the deletion of their child’s account and any associated information at any time.
- Record Keeping – Records of parental consents, including who consented, when they consented, and the information they were provided at the time of consent, will be maintained as required by COPPA.
Account Deactivation
If we become aware that an account has been created by a child under the age of 13, we will immediately deactivate the account and delete all associated information collected from that account.
Report Handling
Users and course instructors are encouraged to report any suspected underage usage to our Support Team via [email protected]. We will investigate and take appropriate action on all reports.
Routine Audits
Our system will perform routine audits to check for any inconsistencies in age-related information provided during account creation and usage. In case of a discrepancy indicating an underage user, we will take immediate action to deactivate the account and delete all collected information.
Privacy Education
We will provide educational materials on our website to inform visitors about online privacy and security, emphasizing the importance of age restrictions for the protection of children.
Cooperation with Law Enforcement
We are committed to cooperating with law enforcement and other regulatory bodies to ensure the safety and protection of children online.
These measures aim to uphold our compliance with COPPA, ensuring a safe and lawful environment for all users of Hard Skill Exchange.
Information Collection and Use
Hard Skill Exchange (HSE) outlines its practices regarding the collection of personal information. On the account creation stage on the platform, HSE collects personal information from its users including but not limited to their name, email address, phone number, and payment information (such as credit card details and billing address). Additionally, HSE may gather data concerning users’ transactions and interactions within the platform, encompassing the extent and nature of coaching services acquired, ratings, reviews, and communication history with other users. The personal information we may collect from children under the age of 13, under circumstances where parental consent has been verified, include:
- Identifiable Information: First and Last Name, Age, Date of Birth.
- Contact Information: Email address, Telephone number, Postal address.
- Account Information: Username and password for our Services.
- Payment Information: Parents’ credit card details and billing address
We utilize the collected information to:
- Provide, maintain, and enhance our Services.
- Respond to comments, inquiries, and provide customer service.
- Send essential information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- Communicate about promotions, upcoming events, and other news about products and services offered by HSE and our selected partners, only with the verifiable consent of the parent.
Information Disclosure and Sharing
We do not share, sell, rent, or transfer children’s personal information other than as described in this section. We may disclose aggregated or de-identified information, which cannot reasonably be used to identify an individual.
Information collected from children will only be disclosed:
- To Parents – Parents can request access to, or delete the personal information we have collected from their child by contacting us.
- To our service providers – We may disclose information to companies that provide services on our behalf, such as hosting, customer service, technical support, analytics, and marketing assistance. These entities are bound to adhere to strict data privacy and security standards.
- Legal and law enforcement – We may disclose information if we are required to do so by law, or if we believe in good faith that such action is necessary to comply with the law, protect the rights, property, or safety of HSE, our users, or others.
- Merger or Acquisition – In the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties.
- To course instructurs – With parental consent, we may disclose children’s personal information to course instructors for the purpose of facilitating the course learning environment and interactive activities, ensuring a conducive and constructive learning experience.
Information Retention
We retain the personal information collected from a child for as long as necessary to provide the services requested by the child or the child’s parent, or for a reasonably necessary period to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law. We delete personal information we collect from children at the request of the parent or when the account becomes inactive for a considerable length of time, as dictated by our standard retention policy.
Data Security
We prioritize the protection of user information and employ a variety of security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of personal information. We implement standard security protocols and mechanisms to ensure the safety of children’s data, including secure server hosting, encryption technologies, and regular security audits.
However, no system can be entirely secure, and we cannot guarantee the absolute security of the information. Parents are advised to educate their children about online safety and guide them on the type of information to share online.
Third-Party Links and Services
Our Services may contain links to other websites, applications, and services not operated or controlled by HSE. This COPPA Policy does not apply to those third-party services, and we cannot take responsibility for the content, privacy policies, or practices of those third-party services.
Parental Rights and Control
Parents have the right to review, amend, or delete any personal information we have collected from their child. They may also refuse further collection or use of their child’s information by contacting us. To exercise these rights, parents may contact us at [Customer Support Email Address] or through our customer support service on the website.
Changes to this COPPA Policy
We may amend this COPPA Policy from time to time. We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice by sending an email notification or through notifications within our Services.
Legal Compliance and Jurisdiction
This policy and its implementation are governed by the laws of the State of California, without regard to its conflict of law provisions. We comply with other applicable laws and regulations governing the collection and use of personal information from children.
Contact Us
For any questions or concerns regarding this COPPA Policy, or our data practices, parents are encouraged to contact us at:
HYPCCCYCL,Inc (DBA HSE)
223 W. Mason St.
#5, Santa Barbara, CA 93101
United States
Phone: (917) 232-2164