Trivialism is committed to protecting the privacy of children. This Children's Privacy Policy supplements our Privacy Policy and explains our practices regarding the collection, use, and disclosure of personal information from children.
1. Age Requirements
- The Service is not directed at children under 13 years of age.
- Users must be at least 13 years old to create an account (or the minimum age of digital consent in their jurisdiction, if higher).
- We implement an age gate during account registration to verify that users meet the minimum age requirement.
2. COPPA Compliance (United States)
In compliance with the Children's Online Privacy Protection Act (COPPA):
- We do not knowingly collect personal information from children under 13 without verifiable parental consent.
- If we become aware that we have collected personal information from a child under 13 without proper parental consent, we will promptly delete that information.
- If the Service introduces features directed at children under 13, we will implement verifiable parental consent mechanisms before collecting any personal information.
3. GDPR / UK GDPR — Children's Data
3.1 Age of Digital Consent
The age of digital consent varies across EU/EEA member states (ranging from 13 to 16 years). In the UK, the age of digital consent is 13. Where a user is below the applicable age of digital consent, we require parental or guardian consent before processing their personal data.
3.2 UK Children's Code (Age Appropriate Design Code)
We are committed to the principles of the UK ICO Age Appropriate Design Code, including:
- Best interests of the child: The best interests of the child are a primary consideration in our Service design.
- High privacy by default: Privacy settings for child users are set to the most protective level by default.
- Data minimization: We collect only the minimum data necessary for child users to use the Service.
- No profiling: We do not profile child users for marketing, content personalization, or behavioral analysis.
- No nudge techniques: We do not use design features that encourage children to provide more data than necessary.
- Transparency: Privacy information is presented in age-appropriate language.
4. What We Collect from Verified Minor Users
If a user is verified as a minor (under 18) with appropriate consent, we limit data collection to:
- Username and age range (not exact date of birth).
- Gameplay data (scores, achievements) necessary for Service functionality.
- Device identifiers necessary for session management and security.
We do not collect from minors:
- Precise geolocation data.
- Contact lists or address books.
- Photos, videos, or audio recordings.
- Persistent identifiers for advertising purposes.
5. Parental Rights
Parents and guardians have the right to review, request deletion of, and refuse further collection of their child's personal information, or withdraw previously provided consent. To exercise these rights, contact us at: [email protected]
6. Chat and Social Features for Minors
- Minor users will have restricted chat by default (e.g., pre-set messages only, no free-text chat).
- Direct messaging between users is disabled for accounts identified as minors unless a parent or guardian explicitly enables it.
7. Third-Party Services
We do not share children's personal information with third parties for advertising purposes. Third-party services used in connection with child accounts are contractually bound to comply with applicable children's privacy laws.
8. Contact Us
Trivialism — Children's Privacy Team
Email: [email protected]