CHILDREN'S PRIVACY POLICY
Effective Date: October 6, 2025
Propel Pro LLC, is committed to protecting the privacy of children under 13 years old who use our Sites, Apps and Services (as defined in our general Privacy Policy). This Children’s Privacy Policy explains our information collection, disclosure, and parental consent practices, must be read in conjunction with our general Privacy Policy, and is in compliance with the U.S. Children’s Online Privacy Protection Act (“COPPA”). For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online. If you are accessing our Services from outside the United States, you must comply with local age-of-consent laws, which may differ from U.S. standards.
INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
Propel Pro offers users a range of Services, some of which are primarily targeted at children, and others that are intended for users of all ages. Our Sites, Apps and Services offer activities that may collect information from children. 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.
Registration
Children can, in many cases, register with our Sites, Apps and Services to search coach profiles, view content, participate in contests, and engage in special features. During the registration process, we may ask a child to provide certain information, including a parent or guardian’s email address, the child’s first and last name, gender, the child’s member or account username, and password, for notification, security and business purposes. We also may ask for birth dates from a child to validate their age. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, a child 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 in order to participate in an online activity on the Sites, Apps or Services.
In compliance with COPPA requirements, on any child-targeted site or application, or in any instance where we ask for age and determine the user is under 13 years of age, we will ask for a parent or guardian email address before we collect any personal information from a 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 feel free to contact us at privacy@propelpros.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.
Content Generated by a Child
Certain activities on our Sites, Apps and Services allow children to create or manipulate content and save it with the Company. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are recorded audio calls, live video calls or recorded video for coach training purposes. If we plan to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent as described below.
Verifiable Parental Consent
Email Consent. In the event the Company wishes to collect personal information from a child under 13, including payment information for transactions such as coaching services or Propel Pro merchandise, COPPA requires that we first seek a parent or guardian’s consent by email. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
Higher-Level Consent. In the event the Company collects personal information from a child under 13 that will be posted publicly, we will seek a higher level of consent than email consent, including methods such as asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail or email attachment. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Chat
Certain activities that are directed to children allow users to communicate directly with others, including coaches, by means of a chat system. We recommend that parents carefully supervise their children when the children participate in online activities.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes. Some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission. Please see Content Generated by a Child above for more information on our collection, notice, and consent policies.
Email Contact with a Child
In connection with certain activities or Services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child. Whenever we collect a child’s online contact information for ongoing communications, as opposed to communications responding to queries, such as ongoing marketing or advertising communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child with respect to such ongoing communications. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually. By the nature of our App and Services, there may be ongoing marketing and advertising communications sent through the App or Services, rather than by email to a child, based on information like the content in the App your child is viewing, the current search query, or general location (such as city or state). When browsing the Sites or Services, your child may encounter ads served by ad providers, including ads personalized by third parties.
Push Notifications
Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed applications that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
Geolocation Data
If a child-directed Site, App or Service collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
Persistent Identifiers
When children interact with us, certain information may automatically be collected, both to make our Sites, Apps and Services more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our Sites, Apps and Services, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers (which we define under the Cookies section of our general Privacy Policy). This information may be collected by the Company or by a third party. This data is principally used for internal purposes only, in order to:
- provide children with access to features and activities on our Sites, Apps and Services;
- customize content and improve our Sites, Apps and Services;
- conduct research and analysis to address the performance of our Sites, Apps and Services;
- generate anonymous reporting for use by the Company.
Please contact us at the mailing address, email, or phone number below with questions about the privacy policies and our collection and use practices:
Propel Pro LLC
217 East 70th Street, Unit 2309
New York, NY 10021
United States of America
Attn.: Privacy Administrator
Email: privacy@propelpros.com
Phone number: (212) 812-1111
WHEN INFORMATION COLLECTED FROM CHILDREN IS AVAILABLE TO OTHERS
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may 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 perform a business, professional, or technology support function for us.
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, Apps or Services; (iii) to protect the security or integrity of our Sites, Apps, Services, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
Your child may be able to share information, including photos, videos, audio, and location, publicly and with others, when signed in with their account or profile. When your child shares information publicly, it may be accessible through search engines.
HOW PARENTS CAN REVIEW OR DELETE THEIR CHILD’S INFORMATION
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account.
Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has registered for an account, we use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
Parents can request access to, or correction or deletion of their child’s personal information by logging on to the child’s account. Parents will need their child’s username and password. The login page explains how to recover a password if the child cannot recall it.
Parents can contact the Privacy Administrator to request access to, change, or delete their child’s personal information by sending an email to us at privacy@propelpros.com. A valid request to delete personal information will be accommodated within a reasonable time.
All queries may be directed to:
Propel Pro LLC
217 East 70th Street, Unit 2309
New York, NY 10021
United States of America
Attn.: Privacy Administrator
Email: privacy@propelpros.com
In any correspondence such as email or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.
