Children’s Privacy Policy

Spacetalk has created special policies for the online collection, use, and disclosure of information from children under 13 years of age (“children” or “child”). The purpose of this Children’s Privacy Policy is to describe what types of personal information we collect from children, the purposes for which we use the information and what rights you have regarding this personal information. This Children’s Privacy Policy applies only to our information collection and use for visitors under the age of 13. Please review our general Privacy Policy for a full description of how we collect and use data.

Information We Collect From Children and How We Use It

When you set up a SpacetalkTM Watch for your child, we collect certain information from your child’s device. This data is required to deliver the core features of the SpacetalkTM Watch and App and includes safe contact lists, safe zones based on the location of the watch wearer, geolocation, steps, calls, text messages, and photos (optional). We use the information collected to provide the Spacetalk services requested and to comply with our legal obligations.

When Information is Available to Others

We only share or disclose personal information collected from Children in a limited number of instances, including the following:

· We may share information with our service providers if necessary for them to support our “internal operations” (as defined by COPPA), including activities necessary for the site or service to maintain or analyze its functioning; perform network communications; authenticate users or personalize content; protect the security or integrity of the user, website, or online service; ensure legal or regulatory compliance; or fulfill a request of a child as permitted under COPPA.

· We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from Children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

· As otherwise permitted or required by COPPA or other applicable law.

Parental Choices and Controls

We will not require a Child to disclose more information than is reasonably necessary to participate in an activity. If you are a parent or guardian, you can review or have deleted your Child’s personal information, and refuse to permit further collection or use of your Child’s

personal information. To exercise any of these rights, please contact us by emailing or calling 1-833-SPACETALK.