Project Aqua Children’s Privacy Notice

This Privacy Notice applies to the Project Aqua mobile application (the “App”). It explains what information Adobe Inc. (“Adobe”, “our”, or “we”) collects and processes about children, which we consider to be individuals under the age of 13 or the equivalent age as specified by law in the relevant jurisdiction, (a “Child” or “Child User”). This Privacy Notice does not apply to parents and guardians (“Guardian” or “You”, “Your”), or individuals 13 years or older who may download the App and create an account. For information about Adobe’s privacy practices related to such users please see the Adobe Privacy Policy [https://www.adobe.com/privacy/policy.html].

Information we collect from Child Users under Guardian accounts [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html/#info-guardian]

How we use the information we collect [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html#info-collect]

How we disclose information to others [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html#disclose-info]

Guardians’ rights [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html#guardian-rights]

Retention of information about Child Users [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html#retention-info]

Who to contact with questions or concerns [https://www.adobe.com/privacy/project-aqua-childrens-privacy-notice-linkfree.html#who-to-contact]

1. Information we collect from Child Users under Guardian accounts

Information Guardians provide. When setting up a Child’s profile under a Guardian’s account, You will be asked to provide a name and birth year for each Child. Please do not provide any personally identifiable information. Inputting a name simply helps You distinguish between multiple Child profiles under Your account; the birth year allows for age-appropriate content customization. You don’t need to use your Child’s real name—nicknames or made-up names work just as well.

User-generated content. While using the App, Your Child may generate artwork and other creative content. You may also contribute content, such as photos, on behalf of your Child. We refer to all of this content, along with related metadata (such as the creation date of the creative work), as “User Content.”

App usage and device information. We collect information about how You and your Child use the App, as well as certain device information, including:

• How You and Your Child interact with the App, including the activities you engage in, features used, interactions with content in the App, and navigation within the App;
• Browser and device information, such as device model and operating system, software and hardware information, browser and device settings, and unique identifiers (such as IP address or device ID);
• App product information, such as version and build numbers, language setting, and any hardware associated with interaction with the App (for example, use of a stylus or keyboard);
• Crash logs and other error reports.

Persistent identifiers. We associate the information described in this section with persistent identifiers assigned to Your account or Your Child’s profile to support Adobe’s internal operations including, for example, to enable access to the App from multiple devices, to support settings preferences, and to personalize the user experience based on interactions with the App – all as further described below.

2. How we use the information we collect

To provide and operate features of our App, including features designed to enhance creativity such as 3D creation and interactive content generation.

To personalize the user experience in the App. For instance, we may recommend age-appropriate learning content and provide personalized activities for a user’s next visit based on previous selections and preferences, such as brush size and color palettes. We may also use information about interactions with the App to issue credits and rewards that are earned through completing activities in the App.

To better understand, improve, and develop our App. Adobe analyzes usage trends, behaviors, and preferences to improve the way the App works and develop new features and functionality.

To communicate with Guardians about Child Users’ activities and App updates. We may use App usage information to provide important account-related information or to respond to Your inquiries. We may also use this information to deliver push notifications related to App updates, subject to Your notification preferences. Guardians may also receive e-mail progress-based updates about the activities and achievements of a Child, as well as information about new product offerings in the App, based on Your communication preferences.

For legal, compliance or safety reasons. We may use information we collect via the App to comply with applicable laws, rules, or regulations, and to protect the safety and rights of other App users and the public. User Content may undergo limited automated or manual review for safety, legal, or compliance purposes (such as detecting abusive material) as outlined in the Adobe Privacy Policy [https://www.adobe.com/privacy/policy.html]. Additionally, artwork submissions to the in-App gallery may be manually reviewed to ensure conformity to Adobe’s Terms of Use.

3. How we disclose information to others

Unless otherwise required by law, we do not disclose personal information collected from a Child (if any) to third parties without prior consent from a Guardian. Only Guardians can enable User Content sharing from their account—for example, for printing purposes, or through the in-App share menu for SMS, email, or other optional third-party services, which are subject to their own terms and privacy policies. (For details on the circumstances in which Adobe may share personal information about You with third parties, please refer to the main Adobe Privacy Policy [https://www.adobe.com/privacy/policy.html].)

4. Guardians’ rights

Guardians have the right to review, delete, and correct any personal information collected by Adobe via the App. To exercise these rights, please contact us at privacy@adobe.com. Guardians can also delete a Child’s profile through the App settings and/or delete their account entirely. Learn more here [https://helpx.adobe.com/manage-account/using/delete-adobe-account.html] about how to delete Your Adobe account.

5. Retention of information about Child users

Personal information associated with a Child User is retained for as long as is reasonably necessary to fulfill the purposes described above in the “How we use information we collect” section. Specifically, such information is retained until (1) You delete the Child’s profile from Your account in the App; or (2) You delete your entire Adobe account.

6. Who to contact with questions or concerns

Questions and requests regarding this privacy notice should be addressed to:

• Email address: Privacy@adobe.com
• Phone number: 1(800) 833-6687
• Mailing address: (US) Adobe Inc., Attn: COPPA Notice Inquiry, 345 Park Avenue, San Jose, CA 95110
• Mailing address (Canada): Adobe Inc., Attn: Privacy Inquiry, 345 Park Avenue, San Jose, CA 95110