Updated September 9, 2020.
Grom Social is designed specifically for children under the age of 16. We are dedicated to protecting their privacy and handling any personal information we obtain with care and respect. COPPA requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 16 years of age. COPPA also requires that we obtain the consent of parents and guardians of children under 16 years of age prior to allowing them to use certain features of our website and mobile app. Below, we explain how we do that for these children. Also, when we use the term “parent” below, we mean to include legal guardians. When we use the terms “personal information,” “personally identifiable information,” or “personal data,” we mean information that can specifically identify you or your child.
Our Commitment to Children’s Online Safety Education
Grom Social is very committed to helping kids learn about proper netiquette and how to protect their privacy. Parents also have the ability to monitor their child’s activity on Grom Social by using the Parent Portal. Should a parent see child-generated content in any area of the app that they deem to be personally identifiable information (PII), they can request removal of the content by contacting us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
As required by General Data Protection Regulation (GDPR), the following identifies the data controller and data protection officer.
- Data Controller: Grom Social Inc
- Data Protection Officer: Dan Putnam
- Address: 2060 NW Boca Raton Blvd Suite 6 Boca Raton, FL 33431
- Email: email@example.com
2. THE INFORMATION WE COLLECT
There are two different methods of collecting data in the Grom Social App. The first is data entered by the user, and the second is data that is automatically obtained public information made available by visiting our website and/or downloading our mobile app.
Children must be registered members to access certain areas of the Grom Social Mobile App.
Automatically collected data
- (1) Internet Protocol (IP) Address – this is a number identifier associated with your computer/device. We use this to verify your host or network interface and location by country origin only.
- (2) Third-Party Advertisers/Analytics – Please refer to our third-party privacy policies listed below to see what information they collect.
Requested information at time of registration sign up for children ages under 16:
- (1) Date of Birth (required): to clarify the age of the person interested in membership.
- (2) Username/“Grom Name” (required): The name the child uses to log into the Grom Social Mobile App and the name that will be visible to other Grom Social members once registration is complete.
- (3) Parent email address (not-required): The parent email address is used to contact and inform the parent about the child’s wish to participate in Grom Social, provides parents info to monitor and control their child’s account with the MamaBear Parenting App, and provides parents access to remove their email and child’s account from our system.
- (4) Password (required): This is secret and only known by the user.
3.DATA SECURITY PRACTICES
Grom Social operates with collecting as little personal information as possible about your child. Even though we only collect limited personal information this information is kept behind firewall and SSL encryption. With this safety infrastructure in place, we still follow data security practices to make sure this data is secure.
Guidelines for Administration and IT teams
- Each user/employee with access is background checked and signs a confidentiality agreement before obtaining their required access.
- Each user shall be identified by a unique user ID so that individuals can be held accountable for their actions.
- The use of shared identities is permitted only where they are suitable, such as training accounts or service accounts.
- Each user shall read this data security policy and the logon and logoff guidelines, and sign a statement that they understand the conditions of access.
- Records of user access may be used to provide evidence for security incident investigations.
- Access shall be granted based on the principle of least privilege, which means that each program and user will be granted the fewest privileges necessary to complete their tasks.
- All employees and contractors shall be given network access in accordance with business access control procedures and the least-privilege principle.
- Segregation of networks shall be implemented as recommended by the company’s network security research. Network administrators shall group together information services, users and information systems as appropriate
a. All users must lock their screens whenever they leave their desks to reduce the risk of unauthorized access.
b. All users must keep their workplace clear of any sensitive or confidential information when they leave.
c. All users must keep their passwords confidential and not share them.
Application and Information Access
a. All company staff and contractors shall be granted access to the data and applications required for their job roles.
- All company staff and contractors shall access sensitive data and systems only if there is a business need to do so and they have approval from higher management.
- Sensitive systems shall be physically or logically isolated in order to restrict access to authorized personnel only.
Access to Confidential, Restricted information
- Access to data classified as ‘Confidential’ or ‘Restricted’ shall be limited to authorized persons whose job responsibilities require it, as determined by the Data Security Policy or higher management.
- The responsibility to implement access restrictions lies with the IT Security department.
4. THE REGISTRATION PROCESS
Once the initial sign up process is completed, the child is granted access to their Grom Account with limited access. Once the parents email is supplied, the parent is emailed for email verification. Parent emails will be stored for 10 days from the day email is sent; however, if parental email verification is not provided within 10 days of the email being sent, the Parent email will be deleted from our system. Children will have the opportunity to resubmit the parent email again. The Parent will have the ability to delete the account by email. Non-Parent-Approved Grom members have limited access to app features as noted below.
5. ACCOUNT TYPES
There are FOUR account types on Grom Social App. Depending on your age and verifiable parental consent, each account type has specific limitations to access within the app. Below are the descriptions of each account type.
This is a user who downloads the app but is not registered as a user. Grom Guest users will be allowed to watch streaming Grom TV content and will not be allowed to enter any data or interact with any Grom users or data. When Grom Guest users try to access these features, they will be prompted to register an account or sign in to an account.
A Non-Parent-Approved Grom is a child under the age of 16 who has registered on the Grom Social App, but parent approval process using our secure in-app payment method has not been completed by the parent. The Non-Parent-Approved Grom features will be limited as shown below in the Feature List Grid.
As a parent you can choose to approve a child to become a Parent-Approved Grom, and are required to activate and/or approve their child’s account by verifiable parental consent. As required and approved by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) parents may provide verifiable parental consent using the secure one-time $1 in-app purchase for parent approval.
6. FEATURE LIST
Grom Social users will be able to participate in the following activities depending on their Account Profile Type. However, once a parent or legal guardian has activated/approved their child’s Grom account, they will receive the information to access, monitor, and control their child’s Grom account from the MamaBear App.
|Add Real NameUsers can add their real name. This will not be seen by the public but will be used for search results when searching for a user in the app.|
|Add SchoolUsers can add the school that they attend. This will help them to connect with other kids from their school.|
Users can follow other users and have users follow them. This lets users see all the public/private friend video posts that their friends post.
|Accept User Follow Request
Users can request to follow your child, and your child has the option to accept or deny their request.
Users can show they like something they find in the app by liking it.
|Stream Grom TV Shows
Stream full-length TV shows that are all curated and collected according to age-appropriate content and age-appropriate Internet safety messaging.
Users can type comments on any public content that allows comments.
All the content in the app can be shared through Direct Message / Chat.
|Record Public 15 Second Video Post
Users can record videos from their phone for 15 seconds and save them for the public or solely their friends to view.
|Record Private 15 Second Video Post
Users can record videos from their phone for 15 seconds and save them, but these will not be viewable by any other users.
|Direct Message / Chat with Users
Users can participate in Direct Message / Chats with other Grom Users.
|Direct Message / Chat with Helpers
Users can participate in Direct Message / Chats with our Grom Helpers staff for support, advise, and Internet safety tips.
Users can create Doodle drawings and send them in Direct Message / Chat.
User can send a photo from their phone in Direct Message / Chat.
|Add Description to Video Post
Users can add a description to their video post.
|Turn Off Funny Face Mask*
Users can turn off the Funny Face Safety Feature. This feature applies a mask to the user’s face, covering it to hide their identity in their video post.
|Access Other Funny Face Masks
Users can access masks that do not cover their face completely and hide their identity.
Grom Premium Subscription is an auto-renewed payment of .99¢ per month per user to remove all advertisements in the app for that user. This is available to both IOS and Android users, but cannot be shared by different platforms. If a subscription is purchased on one platform (ie: IOS or Android) the subscription features will only be available for that user with the same platform device as purchased from. If a newer device is purchased or there is a need to change from one platform to another. You will need to cancel one subscription and sign up with the other platform.
8. GROM MEMBER INFORMATION
Unsolicited Information Shared by Child Users
All personal information that we directly collect is provided by the child’s parent. We will not solicit information from a child other than described above. If a child has not been approved for full access to the Grom Social App because his or her parent has not completed the consent and approval process, the child will be unable to participate in activities that allow for user-generated content.
When a Grom Social Member engages in some of our user-generated online activities, including Profile Bio, Direct Messages, Comments, or Video Posts with descriptions, they may share information that could be considered child-user-generated personally identifiable information (PII). While there is no foolproof system to control child-user-generated PII, Grom Social helpers are monitoring the website 24/7 and are able to address and delete posts and photos immediately should they be determined to contain child user PII. However, you should be aware that any PII your child provides in these areas may be read, collected, or used by other members who access them. The user-generated features within the Grom Social App are: direct messaging, comments, and posting a 15-second video with a description.
Additional Information Shared by Child Users
Invite a Friend: Grom Social’s “Invite a Friend” program allows a Grom Social Member to send an email to friends who are not Grom Social Members to tell them about the Grom Social App. We collect a friend’s email address and a user’s friend’s name for the sole purpose of sending this email. The email addresses are not viewable on the app by members and are not stored in any personally identifiable manner. Child members who have not yet been approved by a parent do not have access to the “Invite a Friend” feature.
General Collection of Non-Personal Information
We collect information through technology to make our mobile app more interesting and useful to you and for various purposes related to our business. For instance, when you come to our app, we collect your IP address. An IP address is associated with the access point through which you access the Internet, and it is typically controlled by your Internet Service Provider (ISP). Standing alone, your IP address is not personally identifiable information. We may use IP addresses to collect information regarding the frequency with and geographic location from which our guests visit various parts of our mobile app.
We may use the information collected through these technical methods for many purposes, including delivering content, tracking, and enhancing our users’ experience on our mobile app. We do not link the information we store in cookies to any personally identifiable information you or your child submit while on our mobile app.
In HTML emails that we send our users, we may use technical methods for a number of purposes, including to determine whether our users have opened or forwarded those emails and/or clicked-on links in those emails, to customize the display of banner advertisements and other messages after a user has closed the email, and to determine whether a guest has made an inquiry or purchase in response to a particular email. These technical methods may enable us to collect and use information in a form that is personally identifiable information.
Grom Social includes kid safe advertising throughout the app. Users have the option to subscribe for a monthly fee to remove all ads. All advertisements are reviewed by staff to confirm they are age appropriate for all Grom Social users.
There are two sources of kid safe advertising in our app.
- Grom Safe Ads are ads sold directly to approved advertisers. These approved advertisers are provided anonymous information when their campaign is complete. These approved third parties will receive a 4-point data analysis of their advertising campaign’s performance in the Grom App. This 4-point data analysis includes the number of views a campaign received, as well as the gender, age and country of the users who viewed the campaign. All data is anonymous and not tied to any specific user or account.
- Third-Party Contextual Ads are based on our Third-Party advertising delivery system which is built to be safe for kids while collecting and utilizing minimal anonymous information. Ads are not based on any content interests of users or any user profile information.
Ads are sold and delivered by views in a country and the only criteria used to deliver ads to a user is their country of residence. Please refer to the next section of Third-Party Data for links to third-party privacy policies to understand more about our third-party contextual advertising.
10. THIRD-PARTY DATA
11. PARENT ACCESS TO INFORMATION
At any time, parents can access and control the information collected on their child by downloading the MamaBear App and logging into their child’s Grom Social App Account. In accordance with COPPA, please contact Grom Social at firstname.lastname@example.org if you would like to access the personally identifiable information that we have collected from you or your child, correct factual errors in such information, request to have this information deleted, or request that we no longer collect, use, or maintain the personal information collected from your child. Please be sure to include your email address and a telephone number where we can reach you. To protect you and your child’s privacy and security, we will take reasonable steps to help verify your identity before granting you access to the personal information that we collect and maintain about you or your child.
12. DATA RETENTION
We will retain your or your child’s information for as long as your child’s account is active or as needed to provide services. We will retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Parents have the right to approve or deny their child’s accounts. They may also request their child’s information or provide their child’s name, Grom Name, and email address in order to create the account. Parents may request to delete their child’s account by emailing us at email@example.com. Please include the child’s username and parent email address.
13. PROMOTIONAL COMMUNICATIONS
By following the unsubscribe instructions in the emails you receive, you may opt out of receiving promotional emails. If you choose to opt out of promotional emails, you may still receive emails about your account, subscription, and membership activity.
14. PUSH NOTIFICATIONS
Your child may receive push notifications relating to activities on the Grom Social App on your child’s mobile device. Push Notifications may be deactivated at any time by changing the notification settings in your child’s Grom Social profile settings or on your child’s mobile device settings.
15. CONTACT GROM SOCIAL
Member Services Grom Social, Inc.
2060 NW Boca Raton Blvd. Suite 6
Boca Raton FL 33431
Please be assured that any personal information that you provide in communications to the above email and postal mail addresses may be used to send you promotional materials, unless you request otherwise.
17. A FINAL NOTE TO PARENTS