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2. 1. INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS

This site offers different activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. 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 Site, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with applicable laws, we will either delete the information or immediately seek the parent’s consent for that collection.

Content Generated by a Child

Certain activities on our Site may allow children to create or manipulate content and save or download it. Some of these activities do not require children to provide any Personal Information, or only require limited Personal Information, necessary to support the internal operations of our Site, and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert Personal Information in their created content, we will either pre-screen the submission to delete any Personal Information, we will not collect (as that term is defined under applicable laws) such data, or we will seek verifiable parental consent for the collection. If, in addition to collecting content that includes Personal Information, Crocs also plans 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.

About Verifiable Parental Consent:

Email Consent. In the event Crocs wishes to collect Personal Information from a child, applicable laws require that we first seek a parent or guardian’s consent by email, subject to certain exceptions. 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 a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.

High-Level Consent. In the event Crocs collects Personal Information from a child that will be posted publicly, or will be shared with a third party for their own purposes, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to 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, email attachment, or fax. 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.

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.

Of course, 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

On occasion, in order to respond to a question or request from a child, Crocs may need to ask for the child’s online contact information, such as an email address. Crocs will delete this information immediately after responding to the question or request.

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 more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. Whenever we collect a child’s online contact information for ongoing 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. 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.

Geolocation Data

If the Site 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 Site more interesting and useful to children and for various purposes related to our business, including supporting the operation of the Site. Examples include the type of computer operating system, the child’s IP address, mobile device or other persistent identifier, the web browser, the frequency with which the child visits various parts of our Site, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, pixels, web beacons, tags, and other unique identifiers. This information may be collected by Crocs or by a third party. This data is principally used for internal purposes only, to:

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• • provide children with access to features and activities on the Site
• • personalize content of the Site
• • conduct network communications
• • conduct research and analysis to address the performance of the Site
• • protect the security or integrity of the child and the Site
• • ensure legal or regulatory compliance; or fulfill a request of a child
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• In the event we collect (or allow others to collect) such information from children on the Site for other purposes, we will notify parents and obtain consent prior to such collection.
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• The third-party operators who collect persistent identifiers on our Sites and Apps, include:
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• • DataDog
• • Amazon Web Services
• • Google Cloud
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• Please contact us at the mailing address or email below with questions about the operators’ privacy policies and collection and use practices:
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• privacy@crocs.com
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• Crocs, Inc.
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• 500 Eldorado Blvd., Bldg. 5
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• Broomfield, Colorado 80021
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2. 2. WHEN INFORMATION COLLECTED FROM CHILDREN IS AVAILABLE TO OTHERS
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4. 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:
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• • 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 or Apps; (iii) to protect the security or integrity of our Sites, Apps, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
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• 3. PARENTAL CHOICES AND CONTROLS
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• At any time, parents can refuse to permit us to collect further Personal Information from their children, if applicable, and can request that we delete from our records the Personal Information we have collected in connection with that child. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
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• If and to the extent applicable, we permit parents to access, change, or delete the Personal Information that we have collected from their children. Parents can contact us to request access to, change, or delete their child’s Personal Information by sending an email to us at privacy@crocs.com. A valid request to delete Personal Information will be accommodated within a reasonable time.
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• In any e-mail correspondence, please include all relevant details about the child, including any 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.
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2. 4. CHANGES TO CHILDREN’S PRIVACY POLICY
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4. We reserve the right to make changes to this Children’s Online Privacy Policy. Please check back from time to time to review these changes. If we change this Children’s Online Privacy Policy in a material way, we will provide appropriate notice to parents and, as appropriate, provide additional choices regarding such change.