School Download Library (“SDL”) is a product offered by OverDrive, Inc. and its affiliates (“OverDrive”, “we”, “us” or “our”). We are committed to ensuring the privacy of children under the age of 13 years old who utilize our SDL platform and other OverDrive-hosted websites, applications, technologies and services (collectively referred to as “Services”).
The Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) requires us to inform parents about how we collect, use, and disclose personal information from children under 13 years of age and requires us to obtain the consent of parents in order for children under 13 years of age to use certain features of our Services.
What kind of “Personal Information” is covered by COPPA?
Under COPPA, “Personal Information” is defined as individually identifiable information, such as a full name (first and last); a home or other physical address including street name and city or town; an email address; a telephone number; a Social Security number; or persistent identifiers such as customer or processor serial numbers held in a cookie, where the identifier is associated with individually identifiable information.
What information does OverDrive collect?
We request children enter their identification number, library card number, or student ID number and, in some cases, a PIN number or password. Our request for library card numbers is solely for the purpose of communicating with the school’s database to validate the status of a library card. The SDL platform does not access or retrieve any identifying information from the school’s database. Any and all information including, library card numbers and email addresses, are protected from unauthorized disclosure.
In the event a digital eBook and/or audiobook is unavailable for checkout, a child has the option to enter his or her email address to request notification when the digital content becomes available for checkout. Email addresses are considered “Personal Information” under COPPA and parental consent is required for a child to place a hold on a particular title, as discussed more fully below.
OverDrive may also collect information about a child’s online activity, digital content selections, reviews and ratings, as well as Internet Protocol addresses, device types, unique device data, such as device identifiers, and operating systems. This information remains anonymous unless a child explicitly identifies themselves to us by creating and using an account with OverDrive and/or otherwise consenting to the sharing of information with us. Please be aware that some of our Services cannot be offered unless a child, with parental consent, identifies themselves to us.
In any event, OverDrive does not require children to disclose more information than is reasonably necessary to participate in an activity as a condition of participation in the SDL service or other OverDrive Services.
How does OverDrive collect information?
Under COPPA, parental consent is required for the online collection and/or use of individually identifiable information, such as an email address, obtained from a child under 13 years of age. Before we collect an email address from a child under 13 years of age, we will obtain consent from the child’s parent.
As part of the process of putting a title on hold, a child will be asked to enter their date of birth. If the child acknowledges that he/she is under 13 years of age, a parent’s email address will be required in addition to the child’s email address. We will send an email to the parent informing them that their child has supplied us with their email address in order to place a title on hold using the SDL service.
If the parent takes no action in response to the notice email, the parent (a) represents and warrants that he/she is the parent or legal guardian of any child under 13 years of age; and (b) agrees to OverDrive’s collection of their child’s email address solely for the purpose of notifying the child when a title on reserve is available for checkout.
How does OverDrive use information?
Personal Information remains anonymous unless a child explicitly identifies themselves to us by creating and using an account with OverDrive and/or otherwise consenting to the sharing of information with us. Please be aware that some of our Services cannot be offered unless the child, with parental consent, identifies themselves to us.
OverDrive collects Personal Information and other information from a child in order to:
- Determine the child’s current geographic location and/or language so that we may provide localized content and Services;
- Comply with the requirements of our publisher, library, and retail partners;
- Alert the child if digital content becomes available for check-out from a school or library partner;
- Provide recommendations for digital content we think the child may enjoy;
- Integrate with additional service providers for use of the Services;
- Personalize our Services to better reflect particular interests and preferences; and
- Generally improve the user experience.
In the event a child has the option to provide their email address to us, such as for a notification of library hold availability, OverDrive will not use such email address for any other purposes than the specified use. OverDrive will not send a child any other communication without parental consent.
What if a child shares information with others while using the SDL service or other OverDrive Services?
How can parents control their child’s information?
You can also contact OverDrive by calling (216) 573-6886 or mailing us at One OverDrive Way Cleveland, Ohio 44125 USA, Attention: General Counsel.