COPPA

“Personal information”

Each of these is considered personal information under COPPA:

• full name;
• home or other physical address, including street name and city or town;
• online contact information like an email address or other identifier that permits someone to contact a person directly — for example, an IM identifier, VoIP identifier, or video chat identifier;
• screen name or user name where it functions as online contact information;
• telephone number;
• Social Security number;
• a persistent identifier that can be used to recognize a user over time and across different sites, including a cookie number, an IP address, a processor or device serial number, or a unique device identifier;
• a photo, video, or audio file containing a child’s image or voice;
• geolocation information sufficient to identify a street name and city or town; or
• other information about the child or parent that is collected from the child and is combined with one of these identifiers.

“Collect”

Under COPPA, you’re collecting information if you:

• request, prompt, or encourage the submission of information, even if it’s optional;
• let information be made publicly available (for example, with an open chat or posting function) unless you take reasonable measures to delete all or virtually all personal information before postings are public and delete all information from your records; or
• passively track a child online.