Floating Numbers is concerned about children's privacy. The websites and apps that we operate provide a forum for all family members, including children, to express their views about movies, books, TV, games, websites, apps, and music. While we encourage children to participate appropriately in our Sites, their privacy is extremely important to us.
The Sites are controlled and operated by us from India.
We support the Children's Online Privacy Protection Act (“COPPA") and other frameworks like the General Data Protection Regulation and the so-called UK GDPR (together, the "GDPR"). Our goal is to minimize the information gathered from and disseminated about Children while permitting them active participation in the trustworthy information, education, and independent voice for which we are known.
A. How We Collect and Use Information from Children
- Username (the Child is advised not to use his or her real name);
- Birth month and year; and
- Their parent’s email, which we use, to ask for that parent’s consent
- To create and maintain the Child’s account;
- To determine the child’s current age and post it next to any reviews or comments posted by the child. We do not post the username of any child who is under 13 or any personal information in or alongside their reviews or comments.
- Ensure that the Sites function properly;
- Enable us to conduct research and analysis to understand, address and improve the use and performance of the Sites; and
- Diagnose and respond to problems.
B. What Information Submitted By Children Is Viewable On the Site?
C. What Information About Children Is Shared?
D. How do we get parental consent when we are required to do so?
If parental consent is required in respect of our use of a child’s personal information, when setting up an account, the child must provide their parent’s email address. We use that email address to contact the child’s parent to ask for their consent as required – we also explain to the parent:
- what personal information we collect about their child;
- How we use it and why; and
- How the parent can revoke their consent and/or ask that we delete their child’s account and personal information.
E. How Can Parents Access, Change or Delete Information About Their Children?
If you are a parent, and we need your consent to certain processing of your children’s personal information if you:
- Wish us to cease further collection of personal information from your children;
- Believe your children are participating in an activity on the site that uses their personal information without the parental consent required by law;
- Wish us to make no further use of, or delete, the personal information we have collected online from your children; and/or
- No longer wish for your children to participate as members of the site, we will delete your child’s profile, and any parental contact information we may hold, on request.
Parents of EEA+ Children can exercise these rights through our Privacy Requests Portal.
Parents of non-EEA+ Children can exercise these rights by contacting us at firstname.lastname@example.org
Accessing or changing your Children’s account and any personal information we have collected online.
Parents may at any time:
- Access or make changes to their Children’s account; or
- Make changes to the personal information that we have collected online from their children, by clicking on their Child’s “My Account” link, by contacting us at email@example.com, or by writing to us at the address provided below.
F. How May Parents Raise Other Questions or Concerns?
Under certain circumstances, Children may have certain rights – including those set out below:
- Access. Request access to their Personal Data.
- Correction. Request correction of inaccurate or incomplete Personal Data that we hold about them.
- Erasure. Request erasure of their Personal Data.
- Objection. Object to our reliance on our Legitimate Interests as the legal basis of the processing of their Personal Data
- Restriction. Request the restriction of processing of their Personal Data until we address their request, establish its accuracy, or our reasons for processing it.
- Portability. Request the transfer of their Personal Data in a portable format.
- Withdraw consent. Withdraw their consent to any processing that relies on it as a legal basis. Their parents have the same right to withdraw any parental consents that we have been given.
How to exercise these rights? These rights can be exercised by using our Privacy Requests Portal. Typically, there is no fee for this. However, we may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive – or, in these circumstances, we may refuse to comply with the request. We may need to ask for information in relation to any request to help us confirm the identity of the person making it and to speed up our response.
The right to complain. We would love to be able to resolve all questions, requests, and complaints about Personal Data directly. However, if a child or their parent feels we have not been able to satisfactorily resolve an issue, they may contact their local data protection supervisory authority.
- For the contact information of the Data Protection Authorities for each Member State of the European Economic Area, please visit: https://edpb.europa.eu/about-edpb/board/members_en
- The UK’s Data Protection Authority’s details are below: The Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF Tel. +44 303 123 1113 Website: https://ico.org.uk/make-a-complaint/
What Personal Data do we use?
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Usage Data
Our “Legal Bases” for using Personal Data. The GDPR requires us to have a “legal basis” for each way that we use Personal Data. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with a Child (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and the Child’s interests and fundamental rights do not override those interests (“Legitimate Interests”).
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have specific consent to carry out the processing for the Purpose in question (“Consent”), in these cases we would need to get a Child’s parent’s consent.
Purposes for processing. We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use Children’s Personal Data:
|Purpose||Examples of how we use relevant Personal Data for a Purpose||Our legal basis for this use of data|
|Account set-up and Maintenance||To register a Child’s account on the Sites, and to populate their profile. To provide the core elements of the Sites.||Contractual Necessity.|
|Security||We might use the Personal Data we collect to keep our Sites and associated systems operational and secure.||Compliance with Law. Legitimate Interests.|
|Troubleshooting and Service improvement||We might use the information associated with the Persistent Identifiers above to track issues that might be occurring on our Sites and systems, or to test and improve them. Important note: As described in the “Persistent Identifiers” sub-section above, to protect your Children’s privacy, we restrict the collection of this information from and about logged-in Children.||Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.|
|Anonymized Data creation||We may create ‘Anonymous Data’ – this might include aggregated data such as statistical or demographic data. Anonymous Data may be created or derived from any of the Personal Data we collect, but once in anonymous / aggregated form it will not directly or indirectly reveal a Child’s identity (i.e., it’s no longer Personal Data). We may use or disclose Anonymous Data for any purpose permitted by law, and do not require a legal basis to do so.||Legitimate Interests. It is in our legitimate interests that we are able to ensure that our Sites and how we use information about our users is as un-privacy intrusive as possible.|
|User submitted content||As part of the Sites, we post the reviews, comments and other content submitted to the sites by Children – although we recommend that it is not included, these may contain certain Personal Data. Important notes: We encourage parents to discuss with their Children why they should NEVER include Personal Data in reviews or comments posted to the Site. For all Children who are under 13: we will moderate those Children's postings to remove Personal Data from them; and we will not post such Children's username alongside their reviews or comments.||Contractual Necessity in respect of posting reviews, comments and other submitted content. Legitimate Interests in respect to monitoring the content of Children who are under 13 to remove any Personal Data – we consider this practice to be in the interests of the Children themselves, their parents, and ourselves.|
What happens when you do not provide necessary Personal Data or you withdraw consent? Where we need to process a Child’s Personal Data either to comply with law, or to perform the terms of a contract we have with them, and they fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into. Similarly, if we rely on Consent to process Children’s Personal Data, they or their parent may withdraw that consent, but if this happens, we may not be able to provide certain services or features.
- Data Security – VI. Important Disclosures, Practices and Contact Information
- Retention – V. How Long We Keep Your Personal Information
Personal Data from Third Party Sources. We do not collect any Personal Data about Children from any third parties or publicly available sources, other than from their parents (where they choose to give it to us).