# COPPA Compliance Policy
**Effective Date:** April 1, 2026
**Last Updated:** April 1, 2026
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## 1. Overview
This document sets out the Children's Online Privacy Protection Act (COPPA) compliance framework for Auditions Manager, LLC ("Auditions Manager"). It is intended for **subscribing Companies** (theater companies, casting offices, and other performing arts organizations) who use the Auditions Manager platform and who may collect data from actors under the age of 13.
COPPA, 15 U.S.C. § 6501 et seq., applies to operators of websites and online services that collect personal information from children under 13. The FTC's COPPA Rule (16 C.F.R. Part 312) requires verifiable parental consent before any personal information is collected from a child under 13.
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## 2. Platform Role and Responsibility
### 2.1 Auditions Manager's Role
Auditions Manager is a **data processor** and a **platform operator**. We provide the technology; we do not operate any individual audition portals or direct any data collection from actors. We do not independently decide whether to collect data from minors, what data to collect, or for what purpose.
### 2.2 Companies' Responsibility
Subscribing Companies are the **data controllers** for actor data collected through their audition portals. When a Company creates an audition that may attract minor actors (those under 18, and particularly those under 13), that Company is responsible for:
1. Determining whether their audition may attract participants under 13
2. Implementing appropriate age-verification or parental consent mechanisms before collecting any personal information from actors under 13
3. Obtaining **verifiable parental consent** prior to registration if minors under 13 will participate
4. Retaining records of parental consents obtained
**By accepting Auditions Manager's Terms of Service, Companies agree to comply with COPPA and all applicable child privacy laws.**
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## 3. What Is Personal Information Under COPPA
COPPA defines "personal information" to include:
- First and last name
- Home or physical address
- Online contact information (email, IM handle)
- Screen name or username that allows individual identification
- Telephone number
- Social security number
- A persistent identifier (IP address, device identifier, cookie) that can be used to recognize a user over time
- A photograph, video, or audio file containing a child's image or voice
- Geolocation information sufficient to identify a street name or city
The Auditions Manager platform collects many of these categories on behalf of Companies. A Company audition that accepts registrations from actors under 13 therefore implicates COPPA.
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## 4. Age Gating and Parental Consent
### 4.1 Recommended Approach for Companies
Companies who believe their auditions may attract actors under 13 should implement one of the following approaches on their audition registration page (which can be configured in the Auditions Manager form settings):
**Option A — Hard Age Gate (Recommended)**
Add a date-of-birth field and block registration for anyone under 13, with a message directing them to have their parent or guardian contact the company directly.
**Option B — Guardian Consent Flow**
For auditions that require actor registrations from those under 13 (e.g., youth productions), require:
1. The guardian name field (already available in Auditions Manager forms)
2. Guardian email address
3. An affirmative checkbox in which the guardian certifies they are the parent or legal guardian and consent to their child's registration and data collection
4. A confirmation email to the guardian's email address (double opt-in)
### 4.2 What Constitutes Verifiable Parental Consent
The FTC accepts several methods of verifiable parental consent. For digital platforms, acceptable methods include:
- A signed consent form sent and returned via email, fax, or postal mail (with verification of parental identity)
- Credit card transaction with parental notice (though this alone is not always sufficient)
- An email coupled with a follow-up confirmation step to the parent's separate email address
A checkbox alone, without additional verification, is generally **not** sufficient verifiable parental consent under COPPA.
### 4.3 Auditions Manager's Built-In Capabilities
The Auditions Manager platform provides:
- A **Guardian Name** field that Companies can enable on registration forms
- Custom question capability allowing Companies to add guardian email and consent checkbox fields
- Email notification capabilities allowing confirmation emails to guardian addresses
It is the **Company's responsibility** to configure these fields appropriately and to ensure that any consent mechanism they implement meets COPPA's verifiable consent standard.
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## 5. Data Minimization for Minors
Consistent with COPPA requirements to collect no more information than necessary, Companies operating auditions that accept minor participants should:
- Enable only the registration fields strictly necessary for the audition
- Not require personal photographs unless genuinely necessary for the casting process
- Limit data collection to what is reasonably required to manage the audition
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## 6. Data Retention for Minor Data
Companies should establish and communicate a clear retention policy for data collected from minors. Auditions Manager's standard retention practices (data deleted 90 days after subscription cancellation) apply equally to minor actor data.
Companies may also request deletion of specific actor records (including minor actor records) at any time through the platform's data management tools or by contacting **support@auditionsmanager.com**.
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## 7. Parental Rights
Parents and guardians of actors under 13 have the right to:
- Review the personal information collected from their child
- Request correction of inaccurate information
- Request deletion of their child's personal information
- Refuse further collection or use of their child's information
To exercise these rights, parents or guardians should:
1. **First** contact the Company that hosted the audition their child registered for — that Company controls the data.
2. If the Company is unresponsive or no longer active, contact Auditions Manager at **privacy@auditionsmanager.com** and we will assist within 30 days.
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## 8. Operators Acting as Agents
To the extent Auditions Manager is considered an "operator" under COPPA (because we operate the platform on which Companies collect data), we operate as an agent of the Companies that use our Service. Our processing of minor data is solely for the purpose of providing the Service to Companies, and we do not use minor data for any independent commercial purpose.
We do not knowingly collect personal information from children under 13 for our own purposes. If we discover that personal information of a child under 13 has been submitted without proper parental consent, we will:
1. Notify the relevant Company
2. Work with the Company to remediate the situation
3. Delete the information if the Company cannot demonstrate valid parental consent
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## 9. Contact
For COPPA-related questions or reports:
**Auditions Manager, LLC**
Email: **privacy@auditionsmanager.com**
Parents or guardians with immediate concerns about their child's data should email privacy@auditionsmanager.com with the subject line "COPPA - Minor Data Concern" and include the name of the theater company or audition involved.