COPPA Privacy Notice

Spektra Systems is committed to protecting the privacy of children who use our Platforms — CloudLabs & CloudEvents — for learning purposes. This Children’s Online Privacy Policy (“COPPA Notice”) explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”), and uses terms that are defined in our general Privacy Policy. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices in the United States regarding children’s personal information. As per COPPA, Spektra Systems (“Company”) is required to inform parents and legal guardians about our practices for collecting, using, and disclosing personal data from children under the age of 13.

This COPPA Notice only applies to the data collection practices of Spektra Systems’ CloudLabs and CloudEvents (collectively, “Services”) that are directed to children under the age of 13, and supplements the Privacy Policy. Terms not defined in this COPPA Notice are otherwise defined in our Privacy Policy. We encourage you to review our Compliance Policy in conjunction with this notice.

In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

CloudLabs is an online learning platform and does not encourage use by children under 13 years without parental notice, consent, and supervision.

Who We Are and What We Do

CloudLabs helps to run hands-on labs, test drives, and POCs for various scenarios at large scale. CloudLabs is designed for organizations and educational institutes of all sizes to offer an impactful learning experience with zero to minimal management overhead. The following is a handful of the services that CloudLabs offers to its partners and users:

• CloudEvents (Hackathons): Organize impactful technology events with live progress tracking.
• HOL Platform: Build, deliver, and consume custom technology labs at scale. Users can build their desired lab configuration once and deploy it thousands of times with a few clicks.
• Trainings & Workshops: Leverage our pre-built hands-on labs or bring your own custom labs for trainings and workshops.
• Demonstrations: Showcase tech products with impactful scenarios.
• Events Support: Managed support for in-person and virtual events for hands-on labs.
• Cloud Orchestrator: Automate your cloud environments’ provisioning and lifecycle.
• 24×7 Live Support: Instant support for any technical and non-technical problems.

Pre-built labs. Virtual delivery experience: CloudLabs is optimized to support virtual lab deliveries in today’s remote world, with features such as the ability to shadow cloud and VM environments, providing a watch-over-the-shoulder experience for instructors.

Skill validation. Our latest feature addition helps you validate whether learners have completed the labs correctly, to ensure skill validation and quality assessments.

If you are a user of CloudLabs, please refer to the data collection section under our FERPA Privacy Notice. If you are a user of CloudEvents wishing to participate in hackathons organized by our partners, please refer to the data collection section for CloudEvents under our FERPA Privacy Notice.

How We Protect Children’s Privacy

We take special precautions to protect the privacy of children using our platforms. If you have a question about whether a particular Service is directed to children, please contact us at privacy@spektrasystems.com, or write to us at:

Attention: Privacy
Spektra Systems LLC
8201 164th Ave NE, Suite 200
Redmond, WA 98052-7615, USA

Registration

A. School accounts. For children accessing our services via a school (educator/educational agency) account with whom Spektra Systems has a contract, we rely on school consent for school accounts created with us. Each teacher is responsible for proper account creation for each student. CloudLabs does not encourage children to share their data publicly — teachers and the school control the visibility of the data.

B. Individual accounts. In other cases, during registration we may ask the child/user to provide certain information for age validation and sign-up, including a parent or guardian’s email address, date of birth (MM/YYYY), the child’s first name and last name (optional), country, and school name. An account is created with the given information (name and email address); the user/child is then prompted to provide their month and year of birth to confirm that the user’s age is above 13. If it is determined that the user is under 13, further proceedings are restricted, and they must provide their parent/guardian’s email address to obtain parental consent. A notification email with a consent link is sent to the provided address seeking parental consent. The link is valid for seven days, during which the child cannot access any functionality of our portals. By providing consent, the parent agrees to our Terms of Use and Privacy Policy, as communicated in the email notification they receive from us for parental consent.

Please note that it is up to the user to choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary to participate in an online activity.

Collection of parent email address. Consistent with the requirements of COPPA, or in any instance where we ask for age and determine the user is 13 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you (or another parent/guardian) have not received an email providing notice or seeking your consent, please contact us at privacy@spektrasystems.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

About Verifiable Parental Consent

Email consent. In the event we wish to collect personal information from a child under 13, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within seven days, we will delete the parent contact information and any other information collected from the child at the time of account creation (name and email address).

Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act instead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please see our FERPA Privacy Notice.

What Data We Collect From Children

We only collect the minimal amount of personal data necessary for children to use our Services — specifically, first name, last name (optional), email address, country, and date of birth during initial registration. Date of birth (MM/YYYY) is collected only to determine the age of the signing user; if the user is determined to be under 13, the parent’s email address is collected to obtain parental consent. We use the username (created by the child under parental guidance) and email address only to track a child’s progress in our courses or to reset passwords — we will not contact a child using their email address or username.

We may ask for certain information that is not personally identifiable, such as school name, school address, school city/district, or school grade, in connection with your child’s use of our services and to help us improve their quality; we do not associate this with the child’s name or other personal information, and we use it only to compile aggregate and de-identified information about participants in our courses. We may also collect the IP address from which the child accesses the Services in connection with the child’s use of the Services.

Parents may ask us to stop collecting personal information from their child by emailing privacy@spektrasystems.com; however, in such cases the child will not be able to take or complete our courses. If a parent directs us to stop collecting and using a child’s personal information, we must disable their use of our courses to ensure that no information is collected.

We use cookies and similar technology to collect information when children use our Service, such as the amount of time children spend on learning activities available through the Services, the actions performed by children such as logging in and out, and the pages children visit. Please see our Cookie Policy for details. Data collected will not, at any time, be:

• Utilized to target advertising.
• Used to create advertising profiles on any users.
• Sold, traded, or rented.

Children’s personal information will not be shared or otherwise transferred to any third parties for advertising or marketing purposes.

Chat. A chat feature is designed into our lab environments based on the agreements we may enter into with schools. Only instructors/trainers approved by the educator can create groups to interact with students. Students are not permitted to directly create a group and discuss with fellow members. Trainers/instructors are selected by the schools themselves — our Services do not engage in the selection of instructors/trainers for any lab environments. We strongly encourage children to never provide personal information about themselves or any third party, and to raise any concern about inappropriate content or abuse directly to privacy@spektrasystems.com. We also recommend that parents carefully supervise their children when they participate in such activities.

Third Parties

Spektra Systems may engage third-party service providers on our behalf to improve the quality of our services and for internal operations. However, our Services do not share any personal information of children or their users with third-party service providers. In the event we do so, it will be notified to the concerned party to obtain consent prior to disclosure. Please refer to the third-party service providers section under our Compliance Policy for more detail.

Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information

Parents have the right to review the information we have collected about their children and students, to delete it, and to tell us to stop using it. To exercise these rights, contact us at privacy@spektrasystems.com. You will be required to authenticate yourself as the child’s parent to receive information about that child. All requests will be responded to within 72 hours. We encourage you to review our Data Retention practices under our Privacy Policy.

Disclosure of Children Information

Please refer to the “When We May Disclose Your Personal Information” section under our Privacy Policy.

Changes to This COPPA Notice

We may revise this Notice from time to time. You can see when it was last updated by looking at the “Last updated” date at the top of this page. We won’t reduce your rights under this Notice without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service and notifying you by email (30 days in advance, using the email address you provided), so you can review and make sure you know about them.

We encourage you to review this Notice from time to time to stay informed about our collection, use, and disclosure of personal information through the Services. If you don’t agree with any changes, you may terminate your account. By continuing to use the Services after a revised Notice becomes effective, you acknowledge that you accept and agree to the current version.

Contacting Spektra Systems

If you become aware of a breach, the current protocol is to notify Spektra Systems Support, which will interface with our engineering teams for more information. Our engineering teams are committed to providing customers the information they need, through their support contact, in a timely fashion. Customers should reach out to Spektra Systems at privacy@spektrasystems.com for any scenario that constitutes a breach under this policy.

If you believe that our Services have not adhered to this Notice, please contact us electronically at the email address below, and we will use commercially reasonable efforts to promptly determine and remedy the problem.

Spektra Systems LLC
8201 164th Ave NE, Suite 200
Redmond, WA 98052-7615, USA
Phone: 1-844-773-5872
Email: legal@spektrasystems.com