A. What Is COPPA?
Congress enacted the Children’s Online Privacy Protection Act (COPPA) in 1998. COPPA required the Federal Trade Commission to issue and enforce regulations to allow parents to have control over what information is collected from their young children online. The Commission’s original COPPA Rule became effective on April 21, 2000. The Commission issued an amended Rule on December 19, 2012, which took effect on July 1, 2013. This amended Rule applies to operators of commercial websites directed to children under age 13 that collect, use, or disclose personal information from children.
This policy tells you, the visitor, how we, the website HorrorHouseParty.com, are complying with the requirements of COPPA.
1. HorrorHouseParty.com is a general audience website and does not target children as its primary audience.
As a general audience website, HorrorHouseParty.com does not target children as its primary audience. Although we may at times discuss content of interest to children under age 13, this content is presented for adults and teens over age 13 to discuss with younger fans. Under federal law, however, a general audience website may, depending on the content of the individual website involved, be considered to be “directed to children under 13.” While HorrorHouseParty.com does not believe that it is a website “directed to children under age 13,” we take the privacy of our younger visitors very seriously. Consequently, we have chosen to voluntarily follow the direction of the Federal Trade Commission. A 2015 FTC publication advised:
“In circumstances where children are not the primary audience of your child-directed service, the amended Rule allows you to employ an age screen in order to provide COPPA’s protections to only those visitors who indicate they are under age 13. . . . Once you identify child visitors, you may choose to . . . [d]irect child visitors to content that does not involve the collection, use, or disclosure of personal information.”
2. HorrorHouseParty.com employs an age screen to identify and re-direct visitors under the age of 13.
At this time, there are only two areas of HorrorHouseParty.com that collect personal information. One is the registration area; the second is the newsletter sign-up page (discussed in detail below, beginning at paragraph 5). At this time, registration is not necessary to use any of the features or read any articles on HorrorHouseParty.com. ALL VISITORS who choose to register with HorrorHouseParty.com must be 13 years of age or older. An age screen requiring any person attempting to register to provide his or her age must be successfully navigated to register. If any registered visitor is, or becomes at some later date, known to us to be under age 13, that person’s account (and any post, photograph, comment, or information generated by that person) will be deleted and not stored in any manner. Registration by a visitor certifies the visitor is age 13 or older.
3. Visitors under the age of 13 are directed to visit the remaining sections of the website without registering. No personal information from children under age 13 is collected or shared with third parties.
4. HorrorHouseParty.com contains external links to websites which may collect personal information from children under the age of 13.
HorrorHouseParty.com contains links to independently-owned external websites with content of interest to our visitors. Such content may include, but is not limited to, articles, book and movie trailers, and stores where items may be purchased. We DO NOT control the content of the websites accessed by these links.
5. The Middle School Horror Club Newsletter Sign-Up Page collects certain personal information as permitted by COPPA.
This website offers all visitors (adults, teens, and children under age 13) the opportunity to “join” the Middle School Horror Club and receive club newsletters with information about the characters, giveaways, contests, and new books in the series. A 2017 FTC (Federal Trade Commission) publication provided guidance on how websites must proceed regarding newsletters which collect personal information from children under age 13. This website acts in accordance with those regulations as follows:
. . . . 1. This website may, and will, collect the “child’s and parent’s online contact information.”
. . . . 2. This website may not, and will not, “combine this information with any other information collected from the child.”
. . . . 3. The website must, and will, send an email to you, the parents, to:
. . .. . . . . .(a) “tell [you that this website] collected [your] online contact information to let [you] know [your] child has asked for multiple online communications [a newsletter]”;
. . . . . . . .(b) “tell [you that this website] collected [your] child’s online contact information to provide the multiple communications [newsletters] they asked for”;
. .. . . . . . .(c) “tell [you] the online contact information won’t be used for any other purpose and won’t be disclosed or combined with other information”;
. .. . . . . . .(d) “tell [you] that if [you] don’t opt out, [this website] may use the child’s online contact information for that purpose [to send the newsletter]”; and
C. Additional FTC-Required Disclosures
1. List of all operators collecting personal information.
……No third-party operator collects or maintains children’s personal information through this site or service except to the extent this site uses the newsletter services MailChimp and Constant Contact to send email newsletters to subscribers. The email provider MailChimp collects the name, email address, and parents’ email address on behalf of HorrorHouseParty.com and provides it to this website for the sole purpose of activating the COPPA notification provisions. The email provider Constant Contact collects the name and email address of newsletter subscribers and uses them to send newsletters to the subscribers. This provider monitors whether newsletters are opened and whether internet links in the newsletter are clicked by the recipient, and provides that information back to us at HorrorHouseParty.com.
……For the purposes of the newsletter registration, the sole person collecting information is:
……………Susan Morton / 11923 NE Sumner St / STE 725167
……………………./ Portland, Oregon, 97210
……………Dreaditor [at] HorrorHouseParty [dot] com.
……No other personal information of a person under age 13 is collected through this website.
2. A description of the personal information collected and how it’s used.
……For the purposes of the newsletter only, the items of personal information collected from children are name, email address, and parent’s email address;
……This personal information is collected directly from the child via a newsletter sign-up form;
……The personal information will be used to comply with COPPA parental notification and send the requested newsletter to the child; and,
……This website does NOT disclose personal information collected from children to third parties, other than the two newsletter mailing services MailChimp and Constant Contact (for the purposes of mailing the newsletter only).
3. A description of parental rights.
……This website does not require a child to disclose more information than is reasonably necessary to (1) comply with COPPA parental notification, and (2) send the requested newsletter to the child;
……Parents can review their child’s personal information, direct this website to delete it, and refuse to allow any further collection or use of the child’s information;
……Parents can agree to the collection and use of their child’s information, but still not allow disclosure to third parties. However, because this website does not share with third parties other than the newsletter services MailChimp and Constant Contact, the child can not and will not be sent a newsletter unless the information is permitted to be shared with those providers; and
……Parents may exercise these rights by contacting this website at the address below.
D. Contact Us About Our COPPA Policy
If you require any more information or have any questions about our COPPA Compliance Policy, please feel free to contact us:
1. By email at Dreaditor [at] HorrorHouseParty [dot] Com. (Yes, you know how to type this, but – hopefully – spambots don’t)
2. By using the contact form to the right of this document;
3. By United States Mail at the following address:
……………11923 NE Sumner St
……………Portland, Oregon, 97210;
4. By telephone at the following number: