Children's Privacy Policy

Shindig Programs Inc. ("Shindig", "we", "us", or "our") is committed to protecting the privacy of children through compliance with this Children's Privacy Policy ("Policy"). This Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by or about children under the age of 13 ("child" or "children"). By accessing or using the https://shindigprograms.com/ website, or any of its services, features, content, or applications offered from time to time by Shindig in connection therewith and any applicable mobile application (collectively, the "App"), you agree to the practices and policies set forth in this Policy, whether as a registered user or guest ("you" or "your").

This Policy is in accordance with the U.S. Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA"), and informs parents and legal guardians ("parents") about our practices regarding the collection, use, and disclosure of children's personal information. This Policy only applies to children under the age of 13 and supplements Shindig Programs General Privacy Policy, available at https://shindigprograms.com/privacy_policy.php, which should be read alongside this Policy. Only our general privacy policy applies to teens and adults. Terms that are defined in the general privacy policy have the same meanings as used in this Policy. If you have questions about our privacy practices as they relate to information we collect about children, see the "Contact Us" section below.

This Policy notifies parents of:

• The types of information we may collect from children;
• How we use the information we collect;
• Our practices for disclosing that information;
• Our practices for notifying and obtaining parental consent when we collect personal information from or about children, including how a parent may revoke consent; and
• Information concerning operators, if any, that collect or maintain information from children through the App.

1. Parental Consent

Children should always check with their parents before giving out any information about themselves, especially before entering information on any website, mobile application, or online service.

Consistent with the requirements of COPPA, we may collect personal information from or about children with verified parental consent. In cases where parental consent is required, we will take reasonable steps to verify the consent provided by the child's parent. If you believe your child is participating in an activity that collects personal information without your consent, please see the "Contact Us" section below. If we become aware that we have inadvertently collected personal information from a child without parental consent, we will promptly delete such information or immediately seek parental consent for such collection.

2. Information We Collect from Children

Children can access many parts of the App and its contents and may use many of its features without providing us with personal information. However, some content and features are only available to registered users or require use to collect certain information, including personal information, from users. In addition, we use certain technologies, such as cookies, to automatically collect information from our users when they visit or use the App.

We only collect as much information about a child as is reasonably necessary for the child to participate in age-appropriate services and features within the App, and we do not condition the child's participation on the disclosure of more personal information than is reasonably necessary. 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 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.

The types of personal information we may collect from children include the following:

• Name and contact information: We may collect a child's name and parent's email address to enable communication with the parent on the child's behalf and provide support. This information may be provided by your Member's Administrator, or through the Service from your Member's designated account.
• Account information: If a child creates an account through such child's Member account, we may collect a username and password to authenticate their access to the App.
• Content created by the parent or the child: We may collect and store content created by the parent or the child within the App, such as biographies, images, photos, athletic statistics, or user-generated content, for the sole purpose of supporting the App's functionalities.
• Social content: If a child communicates with other users of the App through chat, email, or posting to public areas of the App, we may collect the information contained in such communications. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares information. The Member assumes all reasonability for any content it authorizes to be posted. We encourage parents to educate their children about safe internet use and to monitor their children's use of social features.

3. Use of Personal Information

We may use the personal information we collect from your child for following purposes:

• Provision of services: We use personal information to provide the App's functionalities, services, and personalized experiences suitable for children.
• Safety and security: We employ measures to detect and prevent unauthorized access, protect against potential risks, and ensure a safe and secure environment for children using the App.
• Parental notification and consent: We may use personal information to communicate with parents, provide notices, and obtain verifiable parental consent.
• Customer support: We may use personal information to respond to inquiries, provide technical support, and address issues raised by parents or children.
• Internal purposes: We may use aggregated and identified information for research, analysis, and product development purposes to improve the App.

4. Disclosure of Personal Information

We do not disclose children's personal information except as described in this section. We may disclose aggregated information about many of our users and information that does not identify any individual or device. We may also disclose children's personal information, in each case in accordance with applicable law:

• To other App users: By use of the App, specific information is available to any user of the App, including user generated content such as name, images, videos, bios, and athletic statistics.
• To service providers: We may engage third-party service providers to assist in operating the App and providing support services. These service providers are contractually obligated to protect the confidentiality and security of children's personal information and are prohibited from using it for any other purpose.
• To Shindig affiliates: Where permitted by law, we may share information we collect about your child with the Shindig companies for the purposes described in the "Use of Personal Information" section above.
• For purposes of a business transfer: We may share your child's information in connection with a corporate transaction. We may disclose or transfer your child's information as part of, or during negotiations for, any purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing involving our brands.
• With your consent or at your request: We will share your information with your consent or if you ask us to. We share your information with third parties if you provide your consent or when you ask us to do so and if it is allowed under applicable law. For example, if you ask us to share your information in order for you to participate in an interactive service that is operated by a third party, we will share that information as requested and allowed.
• If required by law or for law enforcement purposes: We may disclose personal information if required to do so by law, regulation, or legal process, in response to a valid court order or government request, to cooperate with law enforcement agencies, or for an investigation related to public safety.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shindig, our customers, or others, including to (i) protect the safety of a child; (ii) protect the safety and security of the App; or (iii) enable us to take precautions against liability.

5. Parental Rights and Control

We encourage parents to actively participate in their child's online activities and monitor their usage of the App. As a parent, you have the right at any time to:

• Review personal information: You can request access to your child's personal information, and we will provide you with such information upon verification of your identity.
• Request deletion: You have the right to request the deletion of your child's personal information from our records. Upon receiving such a request, we will promptly delete the information, subject to any applicable legal requirements.
• Refuse further collection or use: You can withdraw your consent and refuse further collection or use of your child's personal information. In such cases, we may not be able to provide certain services or functionalities within the App.

To exercise these rights, please contact us by sending us an email using the information provided at the end of this Policy OR via our Privacy Right Manager's parents' webform at https://www.shindigprograms.com/parentalrights.

6. Educational and Team Features

Some of our App features are available for teachers, schools, and school districts, city league or pop warner sports teams, dance and theater venues and other venues (collectively, "Members")) to use as part of an educational curriculum or fundraising resource under the oversight of the Member. These features are designed to minimize the collection of personal information from children and to comply with student data privacy laws. When used by Members, usernames, identifiers that may identify a child or a child's device, and other information may be provided to us by a child's Member and associated with a class or grade level. The Member will be able to see information regarding the child's use of the features in connection with a team and make changes to the child's username and other information. In some circumstances, the Member Administrator may create accounts for their students.

The Member is solely responsible for providing notices and obtaining consents required by applicable student data privacy laws, including providing all required notices to parents, obtaining all necessary parent or guardian consents, or complying with applicable requirements of an exemption or exception from parental consent requirements. The Member is also responsible for activities such as removing a child from class roster, deleting a class, or submitting a deletion request when a child's personal information is no longer needed for Member purposes.

If the features are downloaded on a personal device, a parent or guardian may be able to view their child's personal information (such as username and activities completed) by logging into the child's App account. The parent can delete the application providing the features from the child's device, but the child's personal information may continue to be associated with the Member's account until the Member deletes that personal information. If you are a parent and have questions about reviewing, modifying, or deleting your child's personal information, please contact your child's Member directly.

7. Operators That May Collect or Maintain Information from Children

No third-party operators may collect or maintain personal information from children through the App.

8. Updates to the Child Protection Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. We encourage you to review this policy periodically for any updates. We will provide notice of any material changes either by posting a prominent notice on our website or by sending a direct communication to parents.

9. Contact Us

If you have any questions, concerns, or requests regarding this Policy or our practices related to children's personal information, please contact us at:

Shindig Programs Inc.
policy@shindigprograms.com

Please allow a reasonable time for us to respond to your inquiries.