Children’s Privacy Notice

Aperim Pty Ltd (ABN 46150699737; ACN 150699737) is incorporated in New South Wales, Australia and operates the aicial brand. In this notice, “aicial” refers to that brand; “we”, “us” and “our” refer to Aperim Pty Ltd; and “you” refers to a person reading this notice, including a parent or guardian acting on a child’s behalf.

This notice is a companion to our Privacy Policy, which explains how we handle personal information generally. It applies to our website, waitlist and services, including our planned self-serve software service once it becomes available. Where this notice does not address a topic, the Privacy Policy applies.

aicial provides professional services to social media professionals, brands and organisations, and our planned self-serve software service once it becomes available. Our Terms of Service already require anyone using our website, waitlist or services to be at least 18 years old, and state that our services must not be used by anyone under 18. This notice addresses something narrower within that broader rule: how we treat personal information belonging to a “child”, which for this notice means an individual under 13 years of age — the age threshold already used in our Privacy Policy, and the age used by the United States’ Children’s Online Privacy Protection Act (COPPA), a widely recognisable baseline for children’s online privacy even outside the United States.

Our services are not directed at, marketed to, or intended for use by children, and a child must not use our website, waitlist or services directly.

Separately, Australia’s social media minimum age framework requires certain platforms to take reasonable steps to prevent account holders under 16 from using their services. That obligation sits with the platforms themselves, not with aicial: our services connect to social accounts a customer already holds under each platform’s own age rules, and we do not create, verify or age-assure social media accounts on a platform’s behalf.

We do not knowingly collect personal information directly from a child under 13. Our website, waitlist and services are designed for use by adults acting for themselves or an organisation, and we do not knowingly direct any collection form, account flow or communication channel at a child.

If we become aware that a child is attempting to use our website, waitlist or services directly, we will not knowingly continue to collect personal information from that child and will take the steps described in section 5 below.

A customer’s own connected social account, submitted content, or audience and engagement data may include public content about, or posted by, an individual who is under 13 — for example, a family member, follower or commenter appearing in a customer’s post, comment thread or audience insights. This can occur as an ordinary side effect of operating a social media account, and we do not seek it out or treat it differently from other content data we process on a customer’s behalf.

Consistent with the commitment in our Privacy Policy, we do not deliberately target an individual under 13 for profile-level identification. Except for a customer’s own connected accounts — which remain the customer’s own responsibility, as described in section 7 — or a public figure where we have obtained legal advice supporting that analysis, we present any insight involving such an individual at an aggregate level only, in the same way we treat other third-party content data under that policy.

If we learn that we have collected personal information directly from a child under 13 in breach of this notice, we will take reasonable steps to delete that information promptly and to restrict the associated account or submission, subject to any legal obligation that requires us to retain it.

A parent, guardian or other person who believes we may have collected a child’s personal information directly, in breach of this notice, can contact privacy@aicial.com to request that we review it and, if we confirm collection in breach of this notice, delete it as described in section 5. We may ask for reasonable information to verify the request, and the requester’s relationship to the child where relevant, before acting on it. We handle these requests consistently with the response targets set out in our Privacy Policy’s privacy rights section.

This notice does not apply to a customer’s own management of its connected social accounts and audience data, including any content about or posted by a child (as defined in section 2) within them. That remains the customer’s own responsibility. As described in our Terms of Service, a customer is responsible for its own compliance with each social platform’s terms and applicable law affecting its own accounts and audience. As described in our Privacy Policy, an individual whose information appears in a customer’s connected account or content should direct a privacy request to that customer in the first instance.

We may update this notice to reflect changes to our services, our practices or the law. The version, effective date and last-reviewed date shown at the top identify the current notice. We publish the updated notice on our website and, where a change is material, provide additional notice through the service or by email before the change takes effect.

For a question about this notice, or to make a request described in section 6, contact:

Aperim Pty Ltd, which operates the aicial brand
ABN 46150699737
ACN 150699737
New South Wales, Australia
Email: privacy@aicial.com