Children's Online Privacy Protection Act (COPPA)

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COPPA Policy


SAG-AFTRA PRIVACY POLICY IN REGARD TO CHILDREN UNDER THE AGE OF 13
Updated and effective as of February 9, 2017

This privacy policy in regard to children under the age of 13 (“Children’s Privacy Policy”) relates to the website at www.sagaftra.org and all related domains - including sag.org, aftra.org, aftra.com, sag-aftra.com, and sagaftra.org – (collectively, the  “Site”).  The Site is provided by Screen Actors Guild-American Federation of Television and Radio Artists (“SAG-AFTRA,” or “ us”) located at 5757 Wilshire Blvd., Los Angeles, CA 90036-3600, ATTENTION: Legal Department/Website Terms of Use and Privacy Policy, email sagaftrainfo@sagaftra.org, and the name of SAG-AFTRA’s agent is Duncan Crabtree-Ireland, General Counsel, located at 5757 Wilshire Blvd., Los Angeles, CA 90036-3600.  This Children’s Privacy Policy is incorporated by reference into the Terms.  Portions of this Children’s Privacy Policy pertain to the iActor online casting area of the Site (also accessible via www.iactor.org and www.iactor.com) and other functionality available only to Guild members in good standing.   

SAG-AFTRA encourages parents and legal guardians to become involved in the online activities of their children and to discuss the child’s use of the Internet and disclosure of information to any parties.  

If you are under the age of 13, you must provide your parent’s or legal guardian’s email address or other contact information from which SAG-AFTRA may obtain your parent’s or legal guardian’s consent before you give out any information on the Site.  Please have your parent or guardian visit sagaftra.org/coppa to fill out the parental consent form.  

Although the Site is not directed at children under the age of 13, we recognize that some of our members are under the age of 13 and that they may want to participate in all of the benefits SAG-AFTRA offers via the Site.  Full participation in the Site requires the collection and submission of personally identifiable data.  Rather than restricting access to the Site to those 13 years of age or older, SAG-AFTRA has opted to make its online services available to all of its members.  In doing so, SAG-AFTRA desires to comply with the requirements of The Children’s Online Privacy Protection Act (COPPA), which was established by Congress to protect children’s online privacy.  COPPA requires that Web site operators adhere to specific guidelines regarding the collection and handling of personally identifiable information about children under the age of 13. For more information about COPPA and your child’s rights to online privacy, visit the Children’s Privacy section of the FTC’s website here (or you may visit FTC.gov and search “Children’s Privacy”).

COPPA requires that website operators provide parents with certain information and obtain parental consent prior to permitting children under the age of 13 to access and use the Site. 

  • A. What types of information do we collect about children?
  1. Children can view content on the public portion of the Site without any personal information being collected. We do not knowingly collect personal information from children unless they register for an account to access the sections of the Site requiring a login.
  2. During our registration process we may collect a child’s first name and last name, parent's e-mail address, parent’s telephone number, child’s birth date, SAG-AFTRA member number, last four digits of the child’s social security number, member category, and password.  The child is also asked to provide a password hint, to be used in the event the password is lost or forgotten.  We may collect birth dates to validate the ages of our guests, including children.  We may also collect a child’s e-mail address for the purpose of sending the child e-mails related to their activity with SAG-AFTRA and on the Site.  Note that all sites that are directed to children under 13 are prohibited by law from conditioning a child’s participation in an online activity on the child providing more personal information than is reasonably necessary.
  3. We may collect personal information from parents in order to allow kids to participate in certain features located on our Sites.  These features may include job boards, instant message chatting, sending e-mail, posting and sending resumes, posting on message boards, submitting videos photographs or other testimonial content, interacting with third parties, and other similar activities. In the course of a child’s participation in these features, a child may also provide us additional information about himself or herself, such as the contents of his or her chat or message board postings. We also allow registered users to update their contact information or other SAG-AFTRA records.
  4. If a parent allows us to collect personal information about their child, the child will have access to and be able to use the iActor online casting area of the Site.  On iActor a child may enter resume data about himself or herself, such as name, address, professional experience, representation, special skills and training, physical characteristics, portrayable age range, head shots, sound clips, video clips, and other data relevant to his or her potential employment as an actor (“Resume Data”).  Resume Data may also include data SAG-AFTRA enters automatically from a child’s member records.  We recommend that our members not disclose their home address, home telephone number, or other personal information they may not want generally disclosed.  This is of particular concern in the case of children.  Consider posting the contact information for your child’s agent or manager or the parent’s office contact information instead.  If you do not have an agent or manager, consider obtaining an alternate phone number and using a dedicated email address.  
  5. If a parent allows us to collect personal information about their child, we will permit the child to access and use the iActor online casting area of the Site.  On iActor a child may enter resume data about himself or herself, such as name, address, professional experience, representation, special skills and training, physical characteristics, portrayable age range, head shots, sound clips, video clips, and other data relevant to his or her potential employment as an actor (“Resume Data”).  Resume Data may also include data SAG-AFTRA enters automatically from a child’s member records.  Please see the iActor Member Guide and Tutorial, as it may be updated from time to time (the “iActor Member Guide”), for more information on the types of data collected in the iActor portion of the Site.  We recommend that our members not disclose their home address, home telephone number, or other personal information they may not want generally disclosed.  This is of particular concern in the case of children.  Consider posting the contact information for your child’s agent or manager instead or the parent’s office contact information.  If you do not have an agent or manager, consider obtaining a post office box and an answering service. 
  • B. How do we use and share the personally identifiable information that we have collected about children?
    1. To personalize communications from SAG-AFTRA to a child (such as news and updates), we may use the child’s name and mailing address or email address. We may collect a child’s e-mail address in order to send communications relating to his or her membership in SAG-AFTRA.  SAG-AFTRA may, from time to time, contract with third parties to perform these communication services on its behalf and may disclose a child’s information to such third parties. In addition, personal information regarding a child may be disclosed in the course of a child’s participation in certain interactive features such as message boards.
    2. Registered users are able to update their contact information of record with SAG-AFTRA. The information collected may include the child’s address(es), phone number(s), and email address(es). This includes the child’s primary contact information, the child’s billing address, and the address to which the child wishes residuals to be sent.  SAG-AFTRA may also, from time to time, share a child’s information with the SAG-AFTRA Health Plan, the SAG-Producers Pension Plan and/or the AFTRA Health & Retirement Plan, or any successor benefit plan. SAG-AFTRA may also, from time to time, disclose a child’s information to affiliates or to third parties it has contracted with to perform certain services on its behalf or to administer certain member benefits. For example, each year, SAG-AFTRA discloses members’ names and contact information, including such information pertaining to members under the age of 13, to its affiliate, Screen Actors Guild Awards, LLC, and associated vendors (including vendors engaged by motion picture and television companies representing prospective or actual nominees in connection with “For Your Consideration” communications and screeners) for purposes of allowing members to participate in activities related to and voting for the Screen Actors Guild Awards and to receive benefits and other communications from Screen Actors Guild Awards vendors. Additionally, SAG-AFTRA may disclose, via its Actors to Locate Service, contact information for the child’s agent, if any, or the child’s business contact phone number. 
    3. In the course of administering claims under its industry agreements (for example, in collecting and distributing unpaid theatrical or television residuals), SAG-AFTRA may use and disclose information relating to the members affected thereby, regardless of the manner by which that information was collected. This may include information provided through the Services.
    4. SAG-AFTRA allows its members to pay their membership dues through the Services. Through the Dues Online feature, SAG-AFTRA collects certain information necessary to complete the transaction, including a credit card number, expiration date and security code, and the billing address associated with the card. This information is shared with the third party credit card processor and is used solely for the purposes of completing the authorized transaction.
    5. The iActor portion of the site is intended to serve as a “job board.”  On the iActor portion of the site, Resume Data is specifically intended to be made available to third parties such as casting directors, producers, directors, agents, and others and may be used by such parties to contact the child and evaluate his or her potential employment.  Such third parties can search and view Resume Data of participating Guild members and Guild members may communicate directly with such third parties, including transmission of resume data to them.  You hereby authorize SAG-AFTRA to make all such disclosures of the child’s Resume Data to third parties as stated above and contemplated in the iActor Member Guide.  Third parties will be required to agree that they may use such information only to contact the child or his or her representative for legitimate employment opportunities and to keep such information confidential and secure, but SAG-AFTRA cannot make any guarantees of compliance by third parties and SAG-AFTRA will not be responsible in any manner should such parties fail to comply with such agreement.   
    6. If a child or his or her representatives opt-in to receive direct deposit of residuals payments, SAG-AFTRA will share information regarding the child to our service provider for the limited purpose of facilitating the direct deposit services for such child. The child and his or her representatives may be required to agree to the service provider’s policies, , including with regard to use of your personal information, as a condition of registering for the service.
    7. We may provide residuals information to a child’s agents, managers, and other representatives as part of our “residuals tracker” feature offered to our franchised agents.
    8. Except as otherwise disclosed in this Policy, we do not share any information about a child with any affiliated entity or with any third parties unless the disclosure is reasonably necessary: to comply with law, including, for example, to comply with a court order or subpoena; to enforce our Terms of Use or site rules; or to protect the safety and security of our guests and our Web sites. 

       

  • C. How do we notify and obtain consent from parents for the collection of information from a child? Before allowing a child to use a feature of our Web sites that might result in the disclosure of the child’s information to third parties on the Internet, we require the parent to consent to this Children’s Privacy Policy, our Terms of Use, and our more general Privacy Policy and to provide us with evidence confirming their identity, as discussed in our consent process.  This information is retained by us as evidence that we received parental consent. 
  • D. How can parents access, change or delete personally identifiable information about their child?
    1. Parents may at any time refuse to permit us to collect further personal information from their child through the Services. We use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their child.
    • (a)A parent may access, change, or delete his or her child’s personal information by logging on to the child’s account located at SAGAFTRA.org. The parent will need to have their child’s member name and password. If your child has forgotten the password, click on ‘Forgot Password?” link on the home page and follow the instructions
    • (b) A parent may contact our Contact Center to access, change, or delete the personal information that we have collected from his or her child by sending an e-mail to sagaftrainfo@sagaftra.org.  Please include the child’s member name and the parent's e-mail address in the e-mail so that we can better assist you with your inquiry or request. 

    Please note that only the parent identified in the child’s records may submit these requests.

    • E. How will we notify parents if our Children’s Privacy Policy changes?

       

      We may amend our Children’s Privacy Policy at any time. We may provide notice to parents by e-mail regarding any material changes in the way we intend to collect, use, and/or share a child’s personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Children’s Privacy Policy only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.   

    • F. Who do parents contact with questions or concerns about our Children’s Privacy Policy?

      If you need further assistance, please contact us at:

      SAG-AFTRA

      5757 Wilshire Blvd.

      Los Angeles, CA 90036-3600,

      ATTENTION: Legal Department/Website Children’s Privacy Policy

      Facsimile: (323) 549-6624

      E-mail: sagaftrainfo@sagaftra.org.

    You may also telephone us at (855) 724-2387. (If you are not 18 years of age or older, you must have your parent or guardian's permission to call this number.