Children's privacy and parental controls

Last update date: 24 January 2024

The Kooth Website, owned and operated by Kooth USA LLC (“Kooth”, “we”, “us”, “our”) provides young people with access to online mental health support and services.

This privacy notice provides information as to how Kooth collects, uses, and shares information about children aged 12 and under on our website us.kooth.com. Please see our general privacy policy for more information about our collection and use practices in relation to users 13 and older.

Younger users are entitled to additional protections for your information and privacy online. If a user is age 12 or younger when they register an account with Kooth, we will require verifiable parental consent for them to use our service. These additional measures are in place to keep our users as safe as possible online.

When a child creates an account on Kooth, we collect an email address, data of birth and a parent's email address to seek consent. Once parent consent has been obtained, we collect the child's full name, phone number, mailing address, gender, ethnicity, a username, password, and birthdate. This information is used to give the child access to the Service and for account management. The parent email address is used for administrative purposes and to to enable parents to change or withdraw consent. For example, we may use the parent's email to send an email notification about the child's account creation and an invitation for the parent to review, update settings, and approve of their child's account. We will use the birthdate the child provides when signing up for the Service to determine which features on Kooth the child should have access to, and to determine when the child will be given broader access to features on our Service. In general, we will not use or share account information (including Personal Information) from your child's account, except as permitted under the applicable laws.

When a child accesses our 1-to-1 chat or messages one of our specialist teams, we collect and store the transcripts and messages. If we become aware that a child has provided us with Personal Information without parental consent, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate the child's account and/or revert them to the relevant experience, as applicable.We automatically collect the following information from users visiting our website.

• IP Address
• User Agent String (Browser and Device Type)
• Browsing activity (visitor, view, entry, referral, events)
• UTM (Urchin Tracking Module) parameters

Information shared with service providers

We use the following service providers on our website to help us better understand how our users use the site and provide them with the best experience.

• Fathom collects an IP Address, browsing activity, user agent string and UTM parameters to understand how visitors arrive on the website, what they do at a high level and how long they stay. For more information on Fathom see here: https://usefathom.com/privacy
• We use Segment to understand how people navigate around the website and engage with its features. Segment collects an IP address from all users when they arrive on the site. We share the information collected at registration with Segment once parental consent has been obtained.
• We use Sentry to monitor our site for issues and performance. Sentry collects an IP address from all users that visit the site which is not obfuscated before it is stored. Sentry scubs all personal information from the data is collects.
• We use Vimeo to host video content that we provide for our users. Vimeo does not collect any information about users who watch videos.
• We use MixPanel as a reporting and visualisation tool that gets clickstream data from Segment. This helps us better understand how people navigate around the website.
• We work withDevoteam who provide Google Cloud Support. Devoteam have access to some product systems, including some data in BigQuery which may contain Protected Health Information (PHI).
• Our Clinical team uses Egress to share personal data externally, when required to do so i.e. with law enforcement. Data is encrypted so Egress doesn't have access to the data, it will be whatever information or documentation is uploaded to it.

Kooth partners with PRIVO to obtain full verifiable parental consent for children aged 12 or younger. All information collected for verification is stored securely and not used for any other purpose.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification

Kooth USA LLC is a member of the PRIVO Kids Privacy Assured COPPA safe harbor certification Program (“the Program”). The Program certification applies to the digital properties listed on the certification page that is viewable by clicking on the PRIVO Seal. PRIVO is an independent, third-party organization committed to supporting online services to safeguard children's personal information collected online. The PRIVO COPPA safe harbor certification Seal posted on this page indicates Kooth USA LLC has established COPPA compliant privacy practices and has agreed to submit to PRIVO's oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at +44 020 3984 9337 or dpo@kooth.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

Coppa Certification

We may disclose personal information if required by law or in the event of a company sale or proposed change of ownership. We may also disclose it to protect Kooth's rights and properties or to investigate fraud or intellectual property infringement.

If you or your parent(s) have any questions about our use of services providers and how they collect and process information, please contact us at parentalconsent@kooth.com.

Retention Time

Information belonging to a child is kept for as long as necessary to provide our service, or as needed to fulfil the purposes outlined in this document.

Prior to destruction all records are reviewed to determine if a longer retention period is required. Kooth may be required by law to extend the retention period. When child protection / safeguarding interventions have occurred or where Kooth has been involved in multi-agency investigations.

How to update or remove information

To make any requests for changes to a parent or child's account or request the removal of Personal Information collected about a parent or child from our Service (as applicable), or to request that we stop the further collection or use Personal Information in connection with the Service (as applicable), please contact parentalconsent@kooth.com.

Everything a parent or child posts or submits on Kooth is checked by a staff member who moderates what they have written and ensures it does not break any of the community boundaries. We proactively filter all public and comment areas of the Service (such as chat, forums, journals, activities, etc.) to remove references to addresses, emails, phone numbers, or other Personal Information regardless of security and privacy settings. All text is also filtered for profanity, phishing, and adult or suggestive content. However, like all filtering technology, our systems are not 100% effective. We recommend that parents familiarize themselves with all of the community boundaries available in our Terms of use.

Security

Kooth uses generally accepted security measures and safeguards in an attempt to keep the data it collects secure and requires that the service providers it works with agree to do the same.

Links

We may include links to third parties from the website or services. Kooth isn't responsible for these companies and because we have a link doesn't mean we endorse them. Please be sure to check their privacy policies if you decide to visit them.

Privacy Policy Changes

We may update this Privacy Policy from time to time and we ask our users to refer back to this policy on a regular basis. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.

If we make a material change, we will send notice to the child and the child's parent or legal guardian by e-mail and, where required, obtain the prior consent of said parent or legal guardian. We will also post notice at the top of this policy before we make the change.

Contact

If you have questions about our privacy policy or our privacy practices in general, you can contact us: parentalconsent@kooth.com, by phone +44 020 3984 9337, or by mail at 1828 Walnut St, 3rd floor, Kansas City, MO 64108.