Children’s Privacy Policy

Flinque Children’s Privacy Policy

The short version, so parents and guardians know where we stand

Flinque is a business-to-business platform for brands, agencies, and marketing professionals aged 18 and over. We do not knowingly collect personal information from children under 13, and we apply special protections to information that may relate to minors aged 13 to 17. Our platform is not designed for, marketed to, or intended to be used by children.

Because we index publicly available social media profile data for creator discovery, it is possible that some creator profiles belong to minors. We have specific procedures for identifying, protecting, and removing minor-related data when we become aware of it.

If you are a parent or guardian and believe your child’s data is in our platform, use our contact page with the category “Children’s Privacy”.

1. Scope and Legal Framework
2. Age-Based Policy Positions
3. Platform Intended for Adults
4. Children Under 13 (COPPA)
5. Minors Aged 13 to 15
6. Minors Aged 16 to 17
7. Creator Profiles and Minors
8. Parental and Guardian Rights
9. Age Verification Methods
10. Data Deletion for Minors
11. No Sale or Sharing of Minor Data
12. Customer Responsibilities
13. International Frameworks
14. Reporting Concerns About Minors
15. Contact for Children’s Privacy

1. Scope and Legal Framework

This Children’s Privacy Policy explains how Flinque treats personal information relating to minors in connection with the Flinque influencer marketing platform. It supplements our Privacy Policy and focuses specifically on age-based protections.

This policy is designed to comply with:

• US Children’s Online Privacy Protection Act (COPPA): 15 U.S.C. §§ 6501-6506 and 16 C.F.R. Part 312, protecting children under 13
• GDPR Article 8: requiring parental consent for processing children’s data in information society services
• UK GDPR and UK Age Appropriate Design Code (Children’s Code): UK-specific rules for services likely to be accessed by children
• CCPA/CPRA minor provisions: California’s rules for the sale or sharing of PI of minors under 16
• Other state and international frameworks: including PIPEDA (Canada), LGPD (Brazil), and similar

Where frameworks set different age thresholds or protections, we apply the most protective standard available to the individual.

2. Age-Based Policy Positions

Our policy depends on the age band of the individual:

Note that “a minor” is defined differently across jurisdictions. We apply the stricter threshold where relevant.

3. Platform Intended for Adults

Flinque is a business-to-business software platform used by marketing professionals, brand managers, agencies, and researchers. Key facts:

• Minimum age for account registration: 18 years
• Not marketed to children: our marketing, webinars, and sales efforts target business audiences exclusively
• No child-focused features: the platform has no features designed to appeal to children
• Adult-oriented use cases: campaign planning, influencer research, outreach, analytics, and reporting

Our Terms and Conditions and User Agreement require users to confirm they are at least 18 years old when creating an account.

If we discover an account has been created by someone under 18, we take steps to suspend the account and delete the associated personal information.

4. Children Under 13 (COPPA)

The US Children’s Online Privacy Protection Act (COPPA) applies to operators of websites and online services that collect personal information from children under 13 when the service is directed to children or when the operator has actual knowledge that it is collecting personal information from a child under 13.

4.1 Flinque’s position under COPPA

• Flinque is not directed to children under 13
• We do not knowingly collect personal information from children under 13
• If we become aware that a user is under 13, we delete their information and close their account promptly
• We do not require or request age information beyond confirming users are 18 or older, to avoid creating data profiles of minors

4.2 Inadvertent collection

If you are a parent or guardian and believe your child under 13 has provided personal information to us, contact us immediately through our contact page. We will investigate and delete any such information within the timelines in our Data Removal Policy.

4.3 Parental consent

Because Flinque is not designed for children under 13, we do not operate parental consent mechanisms under COPPA. If this position changes in the future, we will implement COPPA-compliant verifiable parental consent before collecting any information from children under 13.

5. Minors Aged 13 to 15

Minors aged 13 to 15 are subject to additional protections under CCPA/CPRA, GDPR, and other frameworks.

5.1 Account creation

Minors in this age band are not permitted to create Flinque accounts. Our Terms require a minimum age of 18.

5.2 Sale and sharing restrictions

Under CCPA/CPRA, we do not sell or share personal information of consumers we know to be under 16 without affirmative opt-in consent. Because we do not intentionally collect data from minors in this band, no such opt-in has been obtained, and accordingly no sale or sharing occurs.

5.3 Creator profiles in this age band

Where we become aware that a creator profile in our platform belongs to a minor aged 13 to 15, we apply additional protections described in Section 7.

6. Minors Aged 16 to 17

Minors aged 16 and 17 are still considered minors in many jurisdictions, including under the UK GDPR (which sets the “child” age at 13 but applies the Age Appropriate Design Code to users under 18).

6.1 Account access

Minors in this age band are not permitted to create Flinque accounts under our Terms.

6.2 Creator profile treatment

Where we become aware that a creator profile belongs to a minor aged 16 or 17, we apply enhanced protections including careful handling of any sensitive data categories, restricted visibility of certain personal details, and prioritized response to removal requests.

6.3 UK Age Appropriate Design Code

While Flinque is not likely to be accessed by children in the ordinary course, we take the UK Children’s Code principles (default high privacy, transparency, minimization, and the best interests of the child) into account in our general product decisions.

7. Creator Profiles and Minors

Flinque aggregates public social media profile data for creator discovery. Some creator profiles may belong to minors, given that many social platforms allow users aged 13 and over.

7.1 Our safeguards

• Public data only: we only index publicly available profile data; we do not access private accounts or non-public content
• Age signals: where we detect age-related signals (stated age in bio, content categorized as child-focused, explicit minor indicators), we apply heightened protections
• Source platform rules: we respect source platforms’ age policies; where a platform prohibits users under a certain age, we treat published data accordingly
• Priority removal: creator removal requests from or about minors are processed with priority
• No sensitive attribute profiling: we do not use minor profiles to build profiles based on sensitive attributes (race, religion, sexual orientation, etc.)

7.2 How to request removal

Parents, guardians, or minors themselves can request removal of minor-related profile data through our Data Removal and Right to Erasure Policy. Verified requests are typically processed within 48 hours.

7.3 Guidance for customers using creator data

Customers are expected to use creator data responsibly, including taking extra care when a creator is or may be a minor. See our Acceptable Use Policy for customer obligations.

8. Parental and Guardian Rights

Parents and legal guardians have specific rights regarding their children’s personal information.

8.1 Rights available

• Right to review: request disclosure of what information we hold relating to your child
• Right to deletion: request deletion of your child’s personal information
• Right to refuse further collection: direct us to stop collecting or processing your child’s information
• Right to opt out of sale and sharing: for California residents, direct us not to sell or share your child’s PI (already our default position)
• Right to complain: lodge a complaint with a relevant authority (Federal Trade Commission for COPPA, supervisory authorities for GDPR)

8.2 How to exercise these rights

Use our contact page with the category “Children’s Privacy” and include:

• Your relationship to the child (parent, legal guardian, other)
• The child’s age and identifying information (social media username or profile URL if applicable)
• The specific right you wish to exercise
• Your contact information for verification and follow-up

8.3 Verification

We verify the parent or guardian relationship proportionately. For most requests, an explanation of your relationship and reasonable evidence (for example a signed declaration, matching address, or documentation) is sufficient. We do not require more information than is necessary to verify your authority.

9. Age Verification Methods

Because Flinque is a B2B platform requiring users to be 18 or older, our age verification is lightweight but designed to deter underage use.

9.1 Signup verification

• Users confirm during signup that they are at least 18 years old
• Users agree to our Terms and Conditions which include this affirmation
• Signals that suggest a user may be underage (for example language patterns, profile details) trigger review

9.2 Enhanced verification

In cases where we suspect an account holder is underage, we may request additional verification including:

• Verification through the business email domain associated with the account
• A short video or written confirmation
• Identification documents (used only for verification, not retained beyond verification)

9.3 Accounts found to be underage

Accounts confirmed to belong to users under 18 are suspended and their data is deleted per Section 10.

10. Data Deletion for Minors

When we become aware that personal data relates to a minor, we take steps to delete it.

• Account data: deleted from production systems within 48 hours of confirmation that the account belongs to a minor
• Creator profile data: removed from active search results within 48 hours of verified request
• Marketing data: email records of minors are deleted or anonymized
• Backup propagation: residual copies in backups rotate out within 90 days under our Data Retention Policy
• Third-party cascades: we instruct sub-processors to delete minor-related data they may hold on our behalf

Deletion is confirmed in writing to parents, guardians, or the minor (where the minor is the one requesting).

11. No Sale or Sharing of Minor Data

Flinque does not sell personal information of minors under any circumstances. We do not share personal information of minors for cross-context behavioral advertising.

Specifically:

• No sale or sharing of PI of consumers under 13 (prohibited absolutely)
• No sale or sharing of PI of consumers aged 13 to 15 without affirmative opt-in consent (not sought, so not granted)
• No use of minor data in targeted advertising or profiling
• No disclosure of minor data to advertising partners or data brokers

These protections apply in addition to our general position described in our CCPA Compliance Policy.

12. Customer Responsibilities

Flinque customers (brands, agencies, marketers) also have responsibilities when it comes to minors.

• Do not target creators you know or suspect to be minors for campaigns involving age-inappropriate products or content (alcohol, tobacco, gambling, adult services, dating apps, high-risk financial products)
• Comply with FTC endorsement guidelines, which include specific considerations for minors in sponsored content
• Follow applicable child advertising rules in your jurisdiction (for example CARU guidelines in the US, UK CAP Code for children’s advertising)
• When working with minor creators, involve parents or legal guardians in contractual arrangements
• Respect the heightened standards that social platforms apply to minor creators

Violations of these expectations are AUP violations under our Acceptable Use Policy.

13. International Frameworks

Different countries define “minor” differently and apply different protections. We apply the most protective standard available to each individual.

This list is not exhaustive. Where local law requires additional protections, we comply with those requirements.

14. Reporting Concerns About Minors

If you believe a minor is using Flinque, a minor’s data is in our platform without appropriate protection, or a customer is using Flinque in a way that harms minors, please report it.

• Contact page: use our contact page with category “Children’s Privacy”
• Report an issue: use our Report an Issue page with category “Minor Concern”
• Postal mail: write to our Privacy Team at the address in Section 15

Reports involving minors are treated as priority issues. Investigations typically begin within 24 hours of receipt.

Serious concerns that may involve illegal conduct toward minors are reported to appropriate authorities in line with our Acceptable Use Policy and relevant laws.

15. Contact for Children’s Privacy

For questions about this Children’s Privacy Policy, to exercise rights on behalf of a minor, or to report concerns, contact us.