Privacy Statement

Data We Collect From Children, How We Use It, And How And When We Communicate With Parents and Guardians

Where we know that a user is under 13 years old, we will:

• ask for a parent or guardian email address before we collect personal data from the child, or
• offer an age-appropriate experience for the child as described below, which in particular does not require registration, consistent with legal requirements, or
• not allow access to those sections or features of the application directed to a general interest audience (those age 13 and over).

 
Registration

Where an application is appropriate for use by children under 13 years old, children can register to (among other things):

• view, interact with and download content
• take tutorials, create, edit, and import content
• like or follow other creators and their content
• comment on others’ content
• upload a photo
• participate in contests
• view in-application notifications

During the registration process, we will ask the child to provide certain personal data, including:

• a parent or guardian’s email address
• the child’s name (only in the case of parent moderation)
• the child’s member or account username, and password
• the child’s birthdate to validate age.

We will not require a child to provide more data than is reasonably necessary to use Children’s applications. If a child chooses not to share certain personal data (such as a parent or guardian’s email for purposes of gathering consent) with us, we may limit their access to account creation and certain features, such as publishing content publicly.

We use the information provided during registration for security purposes and to send notices to or gather consent from parents or guardians. We also use this personal data to provide the Children’s application, as described in Autodesk’s Privacy Statement. We retain data consistent with our retention practices. If we do not receive parental consent within reasonable time, we will delete the parental contact information provided by the child.

Some activities, such as completing tutorials, do not need personal data from children, and we may not notify parents or guardians or seek their consent if we are not collecting or otherwise processing personal data from their child.

 
Parental or guardian consent

Our Children’s applications sometimes allow children to create, share and publically post content. Before allowing children to use certain features and functionality that collect personal data from them, we seek further parental or guardian consent:

• by asking for a credit card or other payment method for verification (with a nominal charge involved), or
• by requiring a signed consent form to be submitted by mail or email attachment.

We also require parents or guardians to open their own account so that they can view and moderate their child’s account. For further details, please see “Moderator Choices and Controls” below.

After providing further parental consent, we may offer parents or guardians the opportunity to use a password in future communications as a way to confirm the parent’s identity.

 
Teacher consent in lieu of a parent

For school-based activities, teachers and school administrators may, where allowed by Applicable Law, act in the place of parents or guardians to provide consent for the collection of personal data from children. Schools should always notify parents or guardians about these activities.

We may ask schools to obtain consent directly from a parent or guardian instead of, or in addition to, the school providing consent so that the parent or guardian can be added as a moderator on the Children’s application. Consent from a parent would also allow a child to continue using a Children’s application outside of school.

For more information on parental rights in the United States with respect to a child’s educational record under the U.S. Family Educational Rights and Privacy Act (FERPA), please see “Education and FERPA” below.

Specific activities

Content Generated by a Child

Our applications include activities that allow children to create or manipulate content and save it. Such content may be accessible by the public depending on the child’s settings when they posted the content.

We honor requests to delete any content that they post on our websites and applications, unless we are required by law to retain it.

 
Forums and comments

Certain activities allow users to communicate directly with other users by means of user forums or comments sections. Depending on the child's settings, which that child's moderator can control, a child may be able to post messages and other communications accessible by the public.

We strongly encourage children who use these interactive features on our websites and in our applications never to provide personal data about themselves or any third-party, and not to attempt to circumvent any moderation features.

 
Contests

In all of our contests for children, we will require only the data necessary to enter the contest, such as user name and parent email address (to notify the parent where required by law). We only contact the parent or guardian for more personalized data for prize-fulfillment purposes if the child wins the contest.

 
Augmented Reality

Our Children’s applications may access device cameras to offer augmented reality functions, such as overlaying 3D models developed in the Children’s application over the image available through the camera. Autodesk does not collect or receive any information captured from the device’s camera. Users can remove applications access to a device’s camera by changing the device’s settings.

 
Email Contact with a Child

In some of our applications, we may collect online contact information, such as an email address, in order to communicate with a child who makes a specific request through customer service. For example, a child may email us to ask for help in understanding how to use a design tool that the child is having trouble with. Or the child may want to sign up for a monthly newsletter.

If we have actual knowledge that we are communicating with a child under the age of 13 without parental consent, we will respond once to the communication, delete their personal data, and will not participate in any ongoing communication.

Here is how we would handle communication requests:

• One-time communication

  After we respond to the child’s question or request, we or our service provider will delete this data immediately after responding to the question or request.

  If a child initiates additional communication, submits additional tickets, or signs up for newsletters, we will delete the child’s personal data in each instance, and will not retain a record. The parent may need to opt-out of each communication separately.

• Communicating more than once

  Where there is an activity or service where we need to communicate with a child more than once and we have not already obtained parental consent:

  If we collect the child’s contact data for ongoing communications, we will also require a parent’s email address (if we have not already obtained verifiable parental consent) so we can notify the parent about the collection and use, and to provide the parent with an opportunity to prevent further contact with the child.

 
Persistent Identifiers

When children interact with us, certain personal data and non-personally identifiable data may be collected automatically, both to make our applications 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 used
• the frequency with which the child visits various parts of our applications
• data regarding the online or mobile service provider

This data is collected using technologies such as cookies, pixel tags, web beacons, and other unique identifiers (“Cookies”). This data may be collected by Autodesk or by a third-party. For a list of third parties that use Cookies on our Children’s applications and links to their privacy policies, please visit the Children’s Privacy Statement - Analytics List. Please visit our Cookie Statement for more information about our Cookie practices and a list of third parties that use Cookies on our general interest applications.

When Data Collected From Children Is Available To Third Parties

In addition to those cases where a child’s personal data is posted publicly (after receiving parental or guardian consent), we also may share or disclose personal data collected from children in a limited and clearly defined number of instances. Please see the “How does Autodesk disclose your personal data?” section of the Autodesk Privacy Statement for the ways in which Autodesk generally discloses personal data. However, Autodesk and its third party providers will not use children’s personal data for advertising purposes, to create a profile about a child and tie it to an Application, to sell the personal data, or for any other purpose prohibited by law or outside the authorization provided by parental, guardian, or school authorization, as may be applicable.

Moderator Choices and Controls

Children’s applications enable parents, guardians, and teachers to “moderate” a minor’s account on the application, giving the minor’s parent or teacher the ability to review how the minor is using the Children’s application and allowing them to make certain choices about how the minor’s personal data is processed. Parent, guardian, and teacher moderators can, at any time:

• refuse to permit us to collect further personal data from their children in association with a particular account
• request that we delete from our records the personal data we have collected in connection with that account

Teachers only have these rights if they are moderators. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service and that any content saved in that account may no longer be accessible. Please note that Autodesk does not have control over third parties (e.g. other users) who may have copied or reposted publicly posted information.

Where a child under 13 has registered for an account, we use two methods to allow parents, guardians, and teachers (when moderators) to access, change, or delete the personal data that we have collected from their children:

• moderators can request access to and delete their child’s personal data by logging into their moderator account
• moderators can contact us to request access, a change, or delete their child’s personal data by sending an email to parents@autodesk.com.

In any correspondence such as email or mail, please include:

• the name of the application
• the child’s username
• the moderator’s email address and telephone number

To protect children’s privacy and security, we will take reasonable steps verify a moderator’s identity before granting access to a child’s personal data. Please visit the “How does Autodesk protect your data“ section in the Autodesk Privacy Statement for additional information.

You have the rights to access, correct, delete, object, restrict, or obtain a copy of your personal data as described in the Autodesk Privacy Statement.

 
Tinkercad Classrooms

Teachers may become a moderator for students in two ways using Tinkercad. First, teachers may link their own account to an account created by a student. Second, teachers may create a Classroom under their own account. When a teacher creates a Classroom on Tinkercad, students may join the Classroom without registering for a Tinkercad account. Autodesk will not collect personal data from the student in these instances, and the student will not be able to communicate or share personal data with Tinkercad members other than the teacher of the Classroom. All other data collection practices are consistent with those described in the Children’s Privacy Statement.

Prior to becoming a moderator, a teacher is responsible ensuring that the student’s parent or guardian has given any consent required by applicable law, either as described in this Children’s Privacy Statement or directly to the teacher or the teacher’s school or school district. For more information, please see the terms located at Education Providers and the Family Educational Rights and Privacy Act (FERPA).

Education and FERPA

If you are using our applications through a school program, your personal data may be subject to the Family Educational Rights and Privacy Act (FERPA). Per the terms located at Education Providers And The Family Educational Rights And Privacy Act (FERPA), Autodesk commits to protect and secure student data in the manner that FERPA requires and, also, agrees to act as a “school official” to the extent our services are used to store regulated student records in accordance with 34 Code of Federal Regulations (CFR) §99.31(a)(1).

For more information about FERPA, please visit the FERPA site and the U.S. Department of Education website.

Will This Privacy Statement Change?

If the way we treat children’s personal data changes, we will update this Children’s Privacy Statement. When we change it, we will make it clear at the top of the Children’s Privacy Statement by indicating when we last updated it. If we make material changes to this Children’s Privacy Statement, we will endeavor to provide you or the parent, guardian, or teacher moderator with notice before such changes take effect, such as through prominent notice on our website or services or by email, and if applicable, we will seek consent from the parent, guardian, or teacher moderator relevant to the changes.

CARU COPPA Safe Harbor

This Privacy Statement and the CARU icon shown on Tinkercad.com confirm that Autodesk, Inc. is a valid licensee and participating member in the CARU Safe Harbor Program (“CARU Safe Harbor”). To protect your privacy, we have voluntarily undertaken this privacy initiative. CARU has reviewed and certified that we meet established online information collection and use practices on all applications where our icon is posted.

As part of the CARU Safe Harbor, we are subject to audits and frequent monitoring of our applications and other enforcement and accountability mechanisms administered independently by CARU.

If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact CARU at:

infocaru@bbbnp.org
CARU Safe Harbor
Attn: Director
112 Madison Avenue, 3^rd Floor
New York, NY 10016