All Capstone Products comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) , and prior to its acquisition by Capstone, Buncee LLC was a signatory of the Student Privacy Pledge and participated in the iKeepSafe Safe Harbor program. COPPA requires us to inform parents and legal guardians (“parents”) and teachers, administrators, schools, districts and other educators (“educators”) about our practices for collecting, using and disclosing personal information from children under the age of 13. It also requires us to obtain verifiable consent from a child’s parent for certain collection, use and disclosure of the child’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.
Capstone also takes its responsibility to support educators with their obligations under the Family Educational Rights and Privacy Act (“FERPA”) seriously. The collection, usage, access, and transparency practices described in this Policy reflect Capstone’s commitment to support its customers’ FERPA compliance efforts. Please review the Capstone Product End User License Agreement for more details regarding Capstone’s rights and responsibilities with respect to its customers’ FERPA obligations.
We understand and are committed to respecting and protecting children’s privacy online. We urge parents and educators to instruct their children/students to never give out their real names, addresses, phone numbers, or any other information that would allow someone to identify or contact the child. If you believe that your child/student has gained access to a Capstone Product without your consent, or if you have any questions or concerns, please contact us at firstname.lastname@example.org.
For more information about Capstone Corporate privacy practices, visit here.
PebbleGo (Excluding the PebbleGo Create with Buncee Tool), Capstone Interactive, Capstone Connect, and Raintree (Including Raintree Online and Engage Literacy)
The only information collected from or about children via or in connection with the PebbleGo, Capstone Interactive, Capstone Connect, or Raintree products available at pebblego.com, mycapstonelibrary.com, or online.raintree.co.uk is the IP address associated with the access and use of the Product by a child user. Such information may be used and shared by Capstone as described in this Policy.
This section does not apply to PebbleGo Create with Buncee, which is described in more detail below.
What Children’s Personal Information We Collect
This section describes the Personal Information collected from or about children via or in connection with the Products. For the purposes of this Policy, “Personal Information” means any personal information relating to an identified or identifiable individual that is collected online.
We collect the following categories of Personal Information in connection with use or access of Buncee via buncee.com or the Buncee mobile application:
- Account and contact information. When an account is registered for a child to become a user of Buncee, we may collect the child’s first and last name, email address, birthdate in order to comply with applicable laws, and designated username and password.
- Device and usage information. We also collect a child-user’s IP address, which includes general location information such as the zip code, state or country from which a child accessed the Buncee product, details regarding how and when a child accessed or used Buncee, the geolocation data of the device a child used to access Buncee, the frequency and duration of usage, the pages viewed and related pageview activity, and other information about a child’s access of or interaction with Buncee.
- Classroom, school, or district information. We may collect a child’s school address, grade, educator, assignment grades and feedback, and instructional progress and engagement.
- Communication information. We may collect a child’s reactions, comments, and replies to educators’ or other users’ communications when using the Product.
- Parental information. We may collect information concerning a child’s parents or legal guardians, such as name, e-mail address, or payment card information that can be combined with the information described above.
This information is collected directly by Capstone in connection with the creation of an account for a child user, as described in more detail below:
- Under a Buncee Classroom subscription, a student account (“Student Account”) can only be created by educators under their subscribers of the Buncee Classroom plan, and do not require the submission of email, gender or birth data.
- Under a Buncee Schools & Districts subscription, only school or district administrators can subscribe to an account. Educator and student accounts are created by syncing Google Classroom roster data with Buncee, by syncing Microsoft Office 365 roster data with Buncee, or by manual upload via CSV.
- Free and Premium Buncee accounts (“Child Account”) created by parents or a non-educator require parent/guardian verifiable consent permission for those under 13 years of age under COPPA, or under 16 years of age under GDPR, to hold an account, and submission of any Personal Information such as contact information, gender or birth data is not required.
We also collect this information directly when a child uses the features and functionality of Buncee to engage in educator managed or distributed materials, and to create, share, and post Buncees.
PebbleGo Create with Buncee
We collect the following categories of Personal Information in connection with use or access of PebbleGo Create via pebblego.com:
- Account and contact information. When an account is registered for a child to become a user of PebbleGo Create with Buncee, we may collect the child’s first and last name, email address, birthdate, and designated username and password.
- Device and usage information. We also collect a child-user’s IP address, which includes general location information such as the zip code, state or country from which a child accessed the PebbleGo Create product, details regarding how and when a child accessed or used PebbleGo Create, the geolocation data of the device a child used to access PebbleGo Create, the frequency and duration of usage, the pages viewed and related pageview activity, and other information about a child’s access of or interaction with PebbleGo Create.
- Classroom, school or district information. We may collect a child’s school address, grade, educator, assignment grades and feedback, and instructional progress and engagement.
- Communication information. We may collect a child’s reactions, comments, and replies to educators’ or other users’ communications when using the Product.
Parental information. We may collect information concerning a child’s parents or legal guardians, such as name or e-mail address that can be combined with the information described above.
This information is collected by Capstone in connection with the creation of an account, as described in more detail below:
- Under a PebbleGo Create with Buncee subscription, only school or district administrators can subscribe to an account. Educator and student accounts are created by syncing Google Classroom roster data with Buncee, by syncing Microsoft Office 365 roster data with Buncee, or by manual upload via CSV.
We also collect this information when a child uses the features and functionality of PebbleGo Create to engage in educator-managed or distributed materials, and to create, share, and post information in PebbleGo Create.
Your decision to consent to the provision of a child’s Personal Information is voluntary, but if you choose not to provide any requested information, you or your child may not be able to take advantage of all the features of the Products. We will not require a child to provide more information than is reasonably necessary in order to use the Products.
The Buncee and PebbleGo Create Products allow users to submit, transmit, share, create, or post information. Such information may include personal information, such as photographs, video or audio files, or recordings of a child’s voice. While this information may be submitted by a user to the Product, Capstone does not specifically collect this information about any user. Further, Capstone does not decide or control how any user-submitted information is used, published, or shared by users.
Information that is Automatically Collected
We may combine the information we collect through these technologies with personal information about you or your child that we collect online.
Information Collected from Third Parties
In connection with a school, district, or administrator subscription, we may collect information about you or your child from the applicable school, district, or administrator by syncing Google Classroom roster data with the Products, by syncing Microsoft Office 365 roster data with the Products, or by manual upload via CSV.
How We Use Children’s Personal Information
We use children’s Personal Information we collect from or about your child for the following purposes:
- verify if a child is under the age of 13 in the United States and under the age of 16 in the European Union;
- verify parental or educational institution consent for the collection and use of a child’s information;
- allow them to create and access their accounts;
- allow them to use the Products in accordance with the products’ specifications and documentation;
- provide updates about their work or the Products;
- track performance in quizzes or other activities;
- estimate our audience size and Capstone Product usage patterns;
- facilitate the functionality of our websites and mobile applications, including payment-related functionality;
- store information about a child’s preferences, allowing us to customize the content according to a child’s individual interests;
- to comply with legal and regulatory obligations, respond to lawful subpoenas or governmental requests, as needed;
- to maintain, improve, and analyze our Sites, ads, and the products and services we offer;
- detect, prevent, or investigate suspicious activity or fraud;
- maintain appropriate records for internal administrative purposes;
- maintain a safe, secure, and trusted environment for a child uses a Capstone Product;
- enforce our terms, policies, and agreements with you and any applicable third parties; and/or
- allow interaction with an educator or school administrator or other users
We do NOT use or sell children’s Personal Information for any of the following purposes:
- Advertising purposes; and
- We do not collect geolocation information
In any case 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 our services, or as required by law. If we learn that we have received Personal Information from a child that is inconsistent with this Policy, we will delete the data. If you believe that we have received Personal Information from a child in error, please contact us at email@example.com to request deletion of that information.
How We Share Children’s Personal Information:
We may share or disclose Personal Information collected from children in a limited number of cases, including the following:
- with our service providers and vendors if necessary for them to perform a business, professional, or technology support function for us;
- to comply with the law;
- to respond to claims or comply with legal process served on Capstone (e.g., a lawful subpoena, warrant, or court order);
- to enforce or apply our policies or agreements;
- to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
- in connection with an acquisition, liquidation, divestiture, restructuring, reorganization, dissolution, merger, or sale or transfer of some or all of our assets (including the negotiation of the same), whether as a going concern or as a part of bankruptcy, liquidation, or a similar proceeding, where the information is among the items being transferred;
- if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
- to any other parties for any purpose we disclose to you before a child’s information is collected or to which a child’s parent otherwise consents.
The Products also offer social features, including posting on Buncee Boards, sending invitations, or other communication features that allow and enable children to communicate with others through the Products. We do not control the types of information a child can send or post through them. We encourage parents and educators to educate children about safety online and to carefully monitor their children's use of social features to ensure they do not disclose their personal information through them.
Parents must complete the registration process for their children with respect to Child Accounts, and educators must complete the registration process for their students with respect to Student Accounts. When we receive a request from a child to register for a Child Account or from a district/school or an educator to register a child for a Student Account, we will provide direct notice (the “COPPA Notice”) to the parent, administrator, or educator, as applicable, via email in accordance with COPPA to, among other things, notify the parent/administrator/educator of the following:
- that, with respect to Child Accounts, we have collected the parent’s online contact information and the child’s name from the child for the purpose of getting the parent’s consent to collect, use or disclose personal information from the child;
- that verifiable consent from the parent is required for the collection, use or disclosure of the child’s personal information;
- that we will not collect, use or disclose personal information from the child if the parent does not provide consent;
- what additional personal information we intend to collect from the child and how we may disclose the information to others;
- how the parent can give verifiable consent; and
- that if the parent does not give consent within a reasonable time, we will delete the parent’s and child’s online contact information from our records.
With respect to Child Accounts, before the collection, use or disclosure of personal information from children, we will request verifiable consent from parents. To provide us with verifiable consent, the parent must, among other requirements,
- click on the registration verification link contained in the COPPA Notice;
- provide or confirm information, including limited, basic, personal information about themselves and their children, as prompted by our registration processes;
- agree to abide by our Product End User License Agreement and to ensure that any use of our services by their children does not violate our Product End User License Agreement;
- review and edit their child’s username to ensure that no personally identifiable information is present in the child’s username;
- review and consent to Capstone’s practices with respect to collecting and using personal information from children under 13 in the United States and under the age of 16 in the European Union; and
- print and sign our consent form and return it to us by (1) mailing the signed consent form to Coughlan Companies LLC d/b/a Capstone, ATTN: Data Privacy Administrator, 1710 Roe Crest Drive North Mankato, MN 56003, (2) faxing the signed consent form to 1- 888-262-0705, or (3) scanning and emailing the signed consent form to firstname.lastname@example.org.
Children may not use Buncee or other products until we receive and process this verifiable consent. If we determine that a user is under 13 and we have not received a signed consent form from this child’s parent, we will take steps to delete all or virtually all content posted by the user and take reasonable technical measures to delete all or virtually all stored user information about the user from our records, in compliance with applicable laws.
Where a district/school administrator or an educator registers its students for Student Accounts, we will not obtain verifiable consent directly from parents, and will instead obtain consent from the district/school administrator on the parents’ behalf. In doing so, we presume that the district/school administrator’s or educator’s registration for such accounts and authorization for the collection, use and disclosure of students’ personal information is based upon the district/school administrator or educator having obtained the parents’ consent. In this regard, the district/school administrator or educator will act as the parent’s agent and consent to the collection, use and disclosure of children’s personal information on the parent’s behalf.
Accessing and Correcting A Child’s Personal Information
At any time, a parent, educator, school and/or district may review the child’s personal information maintained by us, require us to correct or delete the personal information and/or refuse to permit us from further collecting or using the child’s information.
A parent, educator, school and/or district can review, change or delete their child’s personal information by:
- Logging into their child’s account and visiting his or her account profile page.
- Sending us an email at email@example.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
Additional Steps We Take to Protect Children’s Personal Information
When we intend to collect Personal Information from children, we take additional steps to protect children’s privacy, including the following:
- In accordance with applicable law, and our practices, we obtain consent for the collection of Personal Information from their children, or for sending information about our Products and Services directly to their children;
- We notify parents or schools, as appropriate, about our information practices with regard to children, including the types of Personal Information we may collect from children, how we may use the Personal Information collected, and whether and with whom we may share that information;
- Some of the features on our Products are age-gated so that they are not available for use by children, and we do not knowingly collect Personal Information from children in connection with those features.
- We limit our collection of children’s Personal Information to no more than is reasonably necessary to use our Products; and
- We give parents access or the ability to request access to Personal Information we have collected from their children and the ability to request that the Personal Information be changed or deleted.
Operators that Collect or Maintain Information from or about Children
Other than Coughlan Companies, LLC, no other operators may collect or maintain personal information from or about children through the Products. All inquiries about our privacy practices and use of children’s information can be directed to the “Contact Us” information below.
If you have any questions or suggestions regarding this Policy, please contact us at:
Coughlan Companies, LLC dba Capstone
Data Privacy Administrator
1710 Roe Crest Drive
North Mankato, MN 56003
Contact number: 888-262-0705
If in the United Kingdom:
264 Banbury Road
Oxford, OX2 7DY