Children’s Privacy, Minor Account, and Parental Authorization Policy

1. Purpose and Scope

This Children’s Privacy, Minor Account, and Parental Authorization Policy establishes the rules, restrictions, protections, and responsibilities governing access to and use of the Spark Rack Network and all Spark Rack products and Services by persons under eighteen years of age.

This Policy applies to:

1. All Spark Rack websites;
2. The Spark Rack Customer Portal;
3. The Spark Rack Network;
4. All hosting, server, network, storage, backup, domain, DNS, email, messaging, monitoring, security, managed, and support Services;
5. All Account registrations;
6. All Orders and subscriptions;
7. All Customers and prospective Customers;
8. All authorized users;
9. All End Users;
10. All resellers and reseller customers;
11. All parents and legal guardians authorizing a minor’s use of the Services;
12. All information submitted by or concerning a minor; and
13. Any third-party system used to provide, support, secure, or administer the Services.

This Policy is incorporated into and forms part of the Spark Rack Terms of Service, Privacy Policy, Acceptable Use Policy, Artificial Intelligence Policy, and other applicable Service terms.

2. Definitions

2.1 “Account”

Any customer, billing, service, support, administrative, portal, mailbox, domain, hosting, or other account used to purchase, access, manage, or receive the Services.

2.2 “Child”

For purposes of the Children’s Online Privacy Protection Act and this Policy, a person under thirteen years of age.

2.3 “Minor”

A person under eighteen years of age.

2.4 “Minor User”

A person who is at least thirteen years of age but under eighteen years of age and who has been authorized to access or use the Services according to this Policy.

2.5 “Parent or Legal Guardian”

A person who has lawful parental rights, guardianship authority, or other legally recognized authority to act on behalf of a Minor User.

2.6 “Responsible Adult”

The verified Parent or Legal Guardian who provides written authorization for a Minor User, accepts responsibility for the Minor User’s conduct, and agrees to the obligations established by this Policy.

2.7 “Personal Information”

Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual or household.

2.8 “Services”

All products, systems, infrastructure, networks, applications, websites, hosting, servers, virtual machines, containers, domains, DNS, email, messaging, storage, backups, monitoring, security, management, support, software, and related services provided by Spark Rack.

2.9 “Spark Rack Network”

All network, server, storage, routing, switching, firewall, Internet, data-center, address-space, DNS, monitoring, security, management, and related infrastructure operated, administered, controlled, leased, licensed, or arranged by Spark Rack.

2.10 “Written Parental Authorization”

A written, signed, and verifiable statement from a Parent or Legal Guardian expressly authorizing a Minor User to access and use the Spark Rack Network and Services and accepting the obligations described in this Policy.

3. General-Audience Services

Spark Rack provides general-audience technology, hosting, infrastructure, network, domain, email, storage, backup, security, and related Services.

Spark Rack does not design, market, direct, or operate its Services primarily for children under thirteen years of age.

The mere fact that a minor may be capable of accessing a website, viewing public information, or understanding a Service does not mean that the Service is intended for children.

Spark Rack does not knowingly encourage children under thirteen to create Accounts, submit Personal Information, purchase Services, or use the Spark Rack Network.

4. Absolute Minimum Age

No person under thirteen years of age may create an Account, purchase a Service, access a Customer Account, use the Spark Rack Network, or independently use any Spark Rack Service.

A parent, guardian, business, school, organization, reseller, or other person may not create an Account in the name of a child under thirteen for the purpose of avoiding this prohibition.

Parental permission does not override the minimum-age prohibition.

Spark Rack does not accept Accounts or independent Service use by children under thirteen, even when a parent or guardian offers consent.

5. Requirements for Customers Under Eighteen

Any Customer or user who is under eighteen years of age must:

1. Be at least thirteen years of age;
2. Have the prior written permission of a verified Parent or Legal Guardian;
3. Provide the Written Parental Authorization before purchasing, activating, accessing, or independently using a Service;
4. Use the Services only under the oversight of the Responsible Adult;
5. Comply with the Terms of Service, Acceptable Use Policy, Privacy Policy, and all other applicable policies;
6. Use accurate age and identity information;
7. Not conceal or misrepresent their status as a minor;
8. Not access products, content, or functions restricted to adults;
9. Not assume that written permission eliminates any other legal restriction; and
10. Immediately stop using the Services if parental authorization is withdrawn.

A person who is thirteen through seventeen years of age may not use the Spark Rack Network or Services without valid Written Parental Authorization.

6. Written Parental Authorization Is Mandatory

Written Parental Authorization is a contractual requirement established by Spark Rack for every Minor User.

This requirement applies even when:

1. The Minor User can independently pay for a Service;
2. The Minor User has a payment card;
3. The Minor User operates a business;
4. The Minor User has parental permission only through an oral conversation;
5. The Minor User has permission to use the Internet generally;
6. The Minor User has permission to use another hosting provider;
7. The Minor User is employed;
8. The Minor User is acting for a school, club, or organization;
9. The Minor User is technically knowledgeable;
10. The Minor User previously used the Services without permission;
11. The Account was created before Spark Rack discovered the user’s age; or
12. Applicable law would otherwise permit a minor to engage in a particular activity.

General Internet access, device access, payment authorization, or informal family approval does not constitute Written Parental Authorization under this Policy.

7. Required Contents of Written Parental Authorization

Written Parental Authorization must include, at a minimum:

1. The Minor User’s full legal name;
2. The Minor User’s date of birth;
3. The Parent or Legal Guardian’s full legal name;
4. The Parent or Legal Guardian’s relationship to the Minor User;
5. The Parent or Legal Guardian’s current address;
6. The Parent or Legal Guardian’s current telephone number;
7. The Parent or Legal Guardian’s current email address;
8. The applicable Spark Rack Account or prospective Account;
9. A description of the Services the Minor User will access or manage;
10. An express statement authorizing the Minor User to use the Spark Rack Network and Services;
11. An acknowledgment that the Parent or Legal Guardian has reviewed the Terms of Service;
12. An acknowledgment that the Parent or Legal Guardian has reviewed the Acceptable Use Policy;
13. An acknowledgment that the Parent or Legal Guardian has reviewed the Privacy Policy;
14. An acknowledgment that the Parent or Legal Guardian has reviewed this Policy;
15. An agreement to supervise the Minor User’s use of the Services;
16. An agreement to accept responsibility for the Minor User’s conduct;
17. An agreement to accept responsibility for charges incurred through the Account;
18. An agreement to maintain accurate contact information;
19. An agreement to notify Spark Rack if authorization is withdrawn;
20. The Parent or Legal Guardian’s signature;
21. The date of signature; and
22. Any additional information reasonably required to verify the authorization.

8. Form of Written Authorization

Spark Rack may require Written Parental Authorization to be submitted through:

1. A Spark Rack parental-authorization form;
2. A secure Customer Portal process;
3. A signed electronic document;
4. A signed physical document;
5. A verified electronic-signature service;
6. A notarized document where reasonably necessary;
7. A verified support process;
8. A secure identity-verification process; or
9. Another method approved by Spark Rack.

Spark Rack may reject an authorization submitted through an insecure, unverifiable, altered, incomplete, or unauthorized method.

An ordinary email stating “I give permission” may be insufficient if Spark Rack cannot reasonably verify the sender’s identity, parental authority, or control of the stated contact information.

9. Verification of Parental or Guardian Authority

Spark Rack may take reasonable steps to verify the identity and authority of a person claiming to be a Parent or Legal Guardian.

Verification may include:

1. Confirmation through a verified email address;
2. Confirmation through a verified telephone number;
3. Review of government-issued identification;
4. Review of guardianship documentation;
5. Review of a birth certificate or similar record;
6. Review of a court order;
7. A signed declaration under penalty of perjury;
8. A verified payment method held by the Parent or Legal Guardian;
9. A telephone or video verification;
10. A notarized authorization;
11. A third-party identity-verification service that is contractually prohibited from unauthorized use of the information;
12. Confirmation through an existing verified Account;
13. Comparison with existing Account information; or
14. Another reasonable method appropriate to the circumstances.

Spark Rack will seek to collect only the information reasonably necessary to verify age, identity, authority, or authorization.

Providing a document does not guarantee approval. Spark Rack may reject documentation that appears altered, inconsistent, expired, incomplete, fraudulent, or insufficient.

10. Parent or Guardian as Account Owner

Spark Rack may require the Parent or Legal Guardian to be:

1. The primary Account owner;
2. The billing contact;
3. An authorized Account user;
4. A responsible Account administrator;
5. The holder of the payment method;
6. The recipient of legal and policy notices;
7. The recipient of security notifications;
8. The recipient of suspension or termination notices; or
9. Any combination of the above.

Spark Rack may require a minor-created Account to be transferred to the Parent or Legal Guardian before the Account is activated or allowed to continue operating.

The Responsible Adult must maintain sufficient access to supervise the Account and respond to urgent billing, security, legal, or abuse matters.

11. Responsibility of the Parent or Legal Guardian

By providing Written Parental Authorization, the Parent or Legal Guardian agrees to:

1. Review the Services the Minor User will use;
2. Review the Terms of Service and all incorporated policies;
3. Supervise the Minor User’s use of the Services;
4. Educate the Minor User concerning privacy and security;
5. Monitor Account activity;
6. Protect Account credentials;
7. Ensure that multifactor authentication is enabled where available;
8. Ensure that the Minor User uses accurate information;
9. Prevent unlawful or prohibited activity;
10. Respond promptly to Spark Rack communications;
11. Address security incidents;
12. Address abuse complaints;
13. Pay all valid charges incurred through the Account;
14. Maintain accurate billing and contact information;
15. Review the Minor User’s public content and services;
16. Ensure that the Minor User does not collect information unlawfully from other children;
17. Ensure that the Minor User complies with intellectual-property law;
18. Ensure that the Minor User does not operate an age-restricted service;
19. Notify Spark Rack if guardianship authority changes;
20. Notify Spark Rack if the authorization is withdrawn;
21. Notify Spark Rack if the Account is compromised;
22. Remove the Minor User’s access when authorization ends; and
23. Accept responsibility for the Minor User’s actions to the maximum extent permitted by law.

12. Financial Responsibility

A Parent or Legal Guardian who authorizes a Minor User may be required to accept financial responsibility for:

1. Service fees;
2. Recurring charges;
3. Usage charges;
4. Overage charges;
5. Domain-registration charges;
6. Domain-renewal charges;
7. License charges;
8. Restoration charges;
9. Professional-service charges;
10. Third-party charges;
11. Chargebacks;
12. Dispute-related costs where permitted;
13. Damage caused through prohibited activity; and
14. Other valid charges incurred through the Account.

A minor’s lack of authority to enter a contract does not authorize use of the Services without payment.

Spark Rack may require all billing information and payment methods to be held in the Responsible Adult’s name.

13. Age Representation

Every person creating an Account or requesting independent access to the Services must provide accurate age information when requested.

A user may not:

1. Provide a false date of birth;
2. Use another person’s date of birth;
3. Claim to be eighteen or older when the user is a minor;
4. Alter identity documents;
5. Use another person’s identification;
6. Use another person’s payment information without authorization;
7. Ask another person to create an Account to evade this Policy;
8. Create multiple Accounts to avoid age verification;
9. Misrepresent parental authority;
10. Forge a parental signature;
11. Submit a false authorization;
12. Interfere with age-verification controls; or
13. Conceal information showing that the user is a minor.

Age or identity misrepresentation is a material violation of this Policy and may result in immediate Account restriction, suspension, or termination.

14. Neutral Age Screening

Spark Rack may use a neutral age-screening process that allows a user to provide an accurate date of birth or age without encouraging the user to misrepresent that information.

Spark Rack may prevent a person from repeatedly changing age information after receiving an age-based restriction.

Information collected solely to determine age may be:

1. Used only for age verification, security, fraud prevention, legal compliance, or Account administration;
2. Disclosed only to authorized parties necessary to complete verification;
3. Protected using reasonable safeguards;
4. Retained only as long as reasonably necessary; and
5. Deleted or reduced when continued retention is no longer necessary, subject to legal, security, and fraud-prevention requirements.

15. No Account Activation Before Authorization

A Minor User’s Account or access may remain pending, restricted, or disabled until Spark Rack has:

1. Received Written Parental Authorization;
2. Verified the Parent or Legal Guardian’s identity where required;
3. Verified parental or guardianship authority where required;
4. Confirmed acceptance of applicable terms;
5. Confirmed billing responsibility;
6. Confirmed accurate contact information;
7. Completed any required security review; and
8. Approved the Minor User’s access.

Spark Rack is not required to reserve inventory, domain names, promotional pricing, IP addresses, server capacity, or other resources while authorization is pending.

16. Discovery of an Unauthorized Minor Account

If Spark Rack learns or reasonably suspects that a person under eighteen is using the Services without required Written Parental Authorization, Spark Rack may:

1. Restrict Account access;
2. Suspend the Account;
3. Disable new Orders;
4. Disable administrative access;
5. Disable public services where necessary;
6. Request age verification;
7. Request parental authorization;
8. Contact the listed Parent or Legal Guardian;
9. Require transfer of the Account to a Responsible Adult;
10. Cancel pending Orders;
11. Prevent further collection of information;
12. Preserve records reasonably necessary for security, fraud prevention, or legal compliance;
13. Delete information where appropriate or legally required;
14. Terminate the Account; or
15. Take another reasonable protective action.

Spark Rack may impose a deadline for providing acceptable documentation.

Failure to respond by the stated deadline may result in termination and deletion according to applicable retention policies.

17. Discovery of a User Under Thirteen

If Spark Rack learns that a user is under thirteen years of age, Spark Rack will not permit the user to continue independently using the Services.

Spark Rack may:

1. Immediately restrict or suspend the Account;
2. Prevent additional information collection;
3. Prevent additional purchases;
4. Disable the child’s credentials;
5. Contact the Parent or Legal Guardian where reasonably possible;
6. Cancel the child’s independent access;
7. Transfer necessary business assets to a verified Responsible Adult where lawful and appropriate;
8. Delete Personal Information associated solely with the child where required or appropriate;
9. Preserve limited records needed for fraud prevention, security, dispute resolution, or legal compliance;
10. Terminate affected Services;
11. Notify appropriate authorities if a safety concern exists; and
12. Take other actions required by applicable law.

Parental consent obtained after discovery does not require Spark Rack to permit the child to continue using the Services.

18. Limited Contact With a Child Under Thirteen

Nothing in this Policy prevents Spark Rack from receiving or using limited contact information when reasonably necessary to:

1. Respond once to a specific question;
2. Notify a parent or guardian;
3. Protect the child’s safety;
4. Prevent fraud;
5. Investigate unauthorized Account use;
6. Investigate a security incident;
7. Comply with law;
8. Respond to legal process;
9. Delete improperly submitted information; or
10. Take another action legally permitted without prior parental consent.

Spark Rack will not use limited information collected for one of these purposes for unrelated marketing, profiling, advertising, artificial-intelligence training, or commercial exploitation.

19. Information Spark Rack May Process Concerning a Minor User

For an authorized Minor User, Spark Rack may process information reasonably necessary to provide and secure the Services, including:

1. Name;
2. Date of birth or age confirmation;
3. Email address;
4. Telephone number;
5. Account identifiers;
6. Username;
7. Authentication information;
8. Service selections;
9. Service configurations;
10. Assigned IP addresses;
11. Domain information;
12. DNS information;
13. Support communications;
14. Security records;
15. Login records;
16. Technical logs;
17. Network metadata;
18. Usage records;
19. Abuse reports;
20. Billing records associated with the Responsible Adult;
21. Parental-authorization records;
22. Verification records;
23. Consent history;
24. Account-change history; and
25. Other information reasonably necessary to administer the Account.

20. Information Minimization

Spark Rack seeks to limit information concerning a minor to what is reasonably necessary for:

1. Age verification;
2. Parental-authorization verification;
3. Account administration;
4. Service delivery;
5. Billing;
6. Security;
7. Fraud prevention;
8. Support;
9. Abuse prevention;
10. Legal compliance;
11. Dispute resolution; and
12. Protection of the minor, Spark Rack, Customers, and third parties.

Spark Rack does not intentionally request unnecessary medical, biometric, genetic, educational, precise-location, or similarly sensitive information from Minor Users.

21. Children’s Data Is Not Sold

Spark Rack does not sell Personal Information belonging to children or Minor Users.

Spark Rack does not rent Personal Information belonging to children or Minor Users.

Spark Rack does not lease Personal Information belonging to children or Minor Users.

Spark Rack does not disclose Personal Information belonging to children or Minor Users to data brokers.

Spark Rack does not share Personal Information belonging to children or Minor Users for cross-context behavioral advertising or targeted advertising.

22. No Artificial-Intelligence Training

Spark Rack does not use information belonging to children or Minor Users for artificial-intelligence training, machine-learning training, model development, model evaluation, model improvement, data labeling, embedding generation, synthetic-data generation, profiling, or automated prediction.

Spark Rack does not authorize any Service Provider, contractor, partner, vendor, or other third party to use information concerning a child or Minor User for:

1. Model pretraining;
2. Model training;
3. Fine-tuning;
4. Model testing;
5. Model benchmarking;
6. Model evaluation;
7. Human review for model improvement;
8. Data annotation;
9. Creation of training datasets;
10. Creation of synthetic datasets;
11. Behavioral profiling;
12. Emotion recognition;
13. Facial recognition;
14. Voice-model training;
15. Advertising optimization; or
16. Any substantially similar purpose.

23. No Targeted Advertising or Behavioral Profiling

Spark Rack does not use a Minor User’s information to:

1. Create an advertising profile;
2. Track activity across unrelated websites;
3. Target advertisements;
4. Create lookalike audiences;
5. Predict purchasing behavior;
6. Infer sensitive characteristics;
7. Analyze emotional state;
8. Infer political or religious beliefs;
9. Infer sexual orientation;
10. Infer health information;
11. Personalize prices;
12. Score financial condition;
13. Score social behavior;
14. Determine educational suitability; or
15. Perform similar profiling.

24. No AI-Based Decisions Concerning Minors

Spark Rack does not use artificial intelligence or machine-learning models to make final decisions concerning a Minor User’s:

1. Account approval;
2. Service eligibility;
3. Pricing;
4. Payment acceptance;
5. Support priority;
6. Security status;
7. Fraud status;
8. Policy compliance;
9. Account suspension;
10. Account termination;
11. Privacy rights;
12. Legal rights; or
13. Any similarly significant matter.

25. Public Content and Personal Safety

A Minor User must not publish unnecessary personal or identifying information through a website, application, forum, domain, email service, or other public-facing Service.

Minor Users should not publicly disclose:

1. Home addresses;
2. School names;
3. Class schedules;
4. Daily routines;
5. Precise real-time location;
6. Personal telephone numbers;
7. Private email addresses;
8. Government identification numbers;
9. Financial information;
10. Passwords;
11. Recovery codes;
12. Private keys;
13. Authentication tokens;
14. Travel plans;
15. Private family information;
16. Medical information;
17. Intimate images;
18. Information that could facilitate stalking or harassment; or
19. Other information that creates an unreasonable privacy or safety risk.

The Responsible Adult is responsible for supervising public content created or hosted by the Minor User.

26. Prohibited Services and Activities for Minor Users

A Minor User may not use the Services to operate, host, administer, purchase, sell, distribute, advertise, or facilitate:

1. Adult sexual content;
2. Dating services intended for adults;
3. Sexual services;
4. Gambling or wagering;
5. Alcohol sales;
6. Nicotine or tobacco sales;
7. Controlled-substance sales;
8. Firearm or regulated-weapon sales;
9. Unlawful financial services;
10. Age-restricted goods or services;
11. Human trafficking;
12. Sexual exploitation;
13. Nonconsensual intimate content;
14. Child sexual abuse material;
15. Phishing;
16. Malware;
17. Credential theft;
18. Denial-of-service attacks;
19. Unauthorized security testing;
20. Harassment or stalking;
21. Fraud or impersonation;
22. Illegal marketplaces;
23. Services requiring a license the Minor User cannot lawfully hold;
24. Contracts or transactions the Minor User is not legally authorized to perform; or
25. Any other activity prohibited by the Acceptable Use Policy or Applicable Law.

27. Minor-Operated Websites and Applications

A Minor User who operates a website, application, forum, community, game server, mailing list, or other online service is responsible, together with the Responsible Adult, for complying with all applicable privacy and child-safety laws.

The Minor User and Responsible Adult must determine whether the service:

1. Is directed to children under thirteen;
2. Has actual knowledge that it collects information from children under thirteen;
3. Collects names, usernames, contact information, images, audio, video, location, persistent identifiers, or other Personal Information;
4. Requires a privacy policy;
5. Requires parental notice;
6. Requires verifiable parental consent;
7. Requires age screening;
8. Requires parental access or deletion procedures;
9. Uses third-party plugins, analytics, advertising, or payment systems;
10. Allows public communication between users;
11. Allows image, audio, or video uploads;
12. Creates child-safety or moderation risks;
13. Requires reporting to authorities;
14. Requires special security safeguards; or
15. Is lawful for a minor to operate.

Spark Rack’s approval of a Minor User’s Account does not certify the Minor User’s website or application as COPPA-compliant.

28. No Assumption of Customer Compliance

Spark Rack provides general-purpose infrastructure and does not automatically monitor or control every Customer website, application, database, mailbox, or communication.

Spark Rack does not represent or warrant that a Customer-operated service complies with:

1. COPPA;
2. State children’s privacy laws;
3. Student privacy laws;
4. Educational privacy requirements;
5. Age-appropriate-design requirements;
6. Parental-consent requirements;
7. Advertising restrictions;
8. Content-moderation requirements;
9. Child-safety reporting requirements;
10. International children’s privacy laws; or
11. Any other law or regulation.

Customers remain responsible for their own legal obligations.

29. Parent or Guardian Access

A verified Responsible Adult may request information concerning the Minor User’s Account, including:

1. Account ownership;
2. Authorized users;
3. Services purchased;
4. Billing status;
5. Account contact information;
6. Parental-authorization status;
7. Security events;
8. Support history;
9. Suspension or enforcement status;
10. Categories of Personal Information maintained by Spark Rack;
11. Correction of inaccurate information;
12. Removal of the Minor User’s access;
13. Cancellation of Services; or
14. Deletion of information where legally and technically permitted.

Spark Rack may require identity and authority verification before disclosing Account or Personal Information.

30. Limits on Parental Disclosure

Spark Rack may limit, delay, or refuse disclosure when reasonably necessary to:

1. Protect another person’s privacy;
2. Protect Account security;
3. Prevent fraud;
4. Prevent harm to the Minor User;
5. Comply with law;
6. Comply with legal process;
7. Protect privileged information;
8. Protect confidential security information;
9. Protect an active investigation;
10. Protect another Customer’s information;
11. Address conflicting guardianship claims; or
12. Respond to another legally recognized restriction.

31. Correction of Minor Information

The Minor User or Responsible Adult may request correction of inaccurate Account information.

Spark Rack may require additional verification before changing:

1. Date of birth;
2. Legal name;
3. Primary email address;
4. Account ownership;
5. Parent or guardian information;
6. Billing information;
7. Authorized contacts;
8. Domain registrant information;
9. Authentication settings;
10. Recovery information; or
11. Other security-sensitive information.

32. Withdrawal of Parental Authorization

A Parent or Legal Guardian may withdraw authorization by submitting a verified written request through an approved Spark Rack channel.

Withdrawal may result in:

1. Immediate removal of the Minor User’s access;
2. Credential revocation;
3. Transfer of the Account to the Responsible Adult;
4. Suspension of affected Services;
5. Cancellation of affected Services;
6. Disabling public services;
7. Preservation of limited records required for legal or security purposes;
8. Deletion of information where appropriate;
9. Loss of access to Customer Content;
10. Loss of promotional pricing;
11. Loss of nontransferable licenses;
12. Expiration of domains or Services if not assumed by the Responsible Adult; and
13. Other consequences associated with suspension, cancellation, or termination.

Withdrawal does not cancel valid charges already incurred or eliminate obligations that arose before withdrawal.

33. Change in Guardianship

The Responsible Adult must notify Spark Rack promptly if:

1. Guardianship authority ends;
2. Custody changes;
3. A court limits the Responsible Adult’s authority;
4. Another guardian assumes responsibility;
5. The Responsible Adult dies or becomes incapacitated;
6. Contact information changes;
7. The Minor User is emancipated where legally recognized; or
8. Another circumstance affects the validity of the authorization.

Spark Rack may suspend access while conflicting authority claims are reviewed.

Spark Rack is not required to resolve private custody or guardianship disputes and may require a court order or other authoritative documentation.

34. Minor Reaching Eighteen

When a Minor User reaches eighteen years of age, Spark Rack may require the user to:

1. Confirm the user’s date of birth;
2. Accept the current Terms of Service;
3. Accept current incorporated policies;
4. Confirm Account ownership;
5. Confirm billing responsibility;
6. Update payment information;
7. Update contact information;
8. Complete identity verification;
9. Remove or retain the former Responsible Adult as an authorized user;
10. Assume direct contractual responsibility; and
11. Complete any other reasonable Account-transition requirement.

Parental authorization may remain effective for Account administration until the transition process is completed or the user requests its removal.

35. Security Requirements for Minor Accounts

Spark Rack may impose additional security requirements on a Minor User’s Account, including:

1. Mandatory multifactor authentication;
2. Mandatory Responsible Adult access;
3. Restricted billing permissions;
4. Restricted Account-transfer permissions;
5. Restricted access to adult-oriented products;
6. Restricted domain-transfer permissions;
7. Restricted API access;
8. Restricted administrative functions;
9. Restricted communication functions;
10. Additional identity verification;
11. Additional fraud review;
12. Additional transaction confirmation;
13. Additional security notices;
14. Lower spending limits;
15. Manual review of unusual activity; or
16. Other safeguards reasonably designed to protect the Minor User and the Services.

36. Account Credentials

A Minor User and Responsible Adult must protect:

1. Passwords;
2. Multifactor-authentication devices;
3. Recovery codes;
4. API keys;
5. Access tokens;
6. Private keys;
7. Domain-transfer codes;
8. Service credentials;
9. Database credentials;
10. Email credentials;
11. Control-panel credentials; and
12. Other authentication information.

Credentials must not be publicly posted, shared with untrusted persons, reused across unrelated services, or stored through insecure methods.

37. Support Communications With Minor Users

Spark Rack may communicate directly with an authorized Minor User concerning routine technical, security, operational, or Account matters.

Spark Rack may copy, notify, or require participation from the Responsible Adult when the communication concerns:

1. Billing;
2. Recurring charges;
3. Account ownership;
4. Identity verification;
5. Parental authorization;
6. Security incidents;
7. Abuse complaints;
8. Policy violations;
9. Legal requests;
10. Privacy requests;
11. Service suspension;
12. Service termination;
13. Account transfers;
14. Sensitive Customer Content;
15. Potential personal danger; or
16. Another material issue.

38. Safety and Emergency Disclosures

Spark Rack may disclose information to a Parent or Legal Guardian, emergency service, child-protection organization, law-enforcement agency, or other appropriate person when Spark Rack reasonably believes disclosure is necessary to:

1. Prevent death or serious physical injury;
2. Protect a child from exploitation;
3. Address grooming or enticement;
4. Address sextortion;
5. Address trafficking;
6. Address credible threats;
7. Address stalking or harassment;
8. Address self-harm risk;
9. Address a missing-child concern;
10. Report apparent child sexual abuse material;
11. Comply with law;
12. Respond to valid legal process; or
13. Protect the safety of the Minor User or another person.

39. Child Sexual Exploitation

The Spark Rack Network and Services may not be used to create, possess, store, transmit, distribute, solicit, advertise, facilitate, conceal, or access child sexual abuse material or any material involving the sexual exploitation of a minor.

Prohibited activity includes:

1. Actual child sexual abuse material;
2. Computer-generated or synthetic depictions of child sexual abuse;
3. Sexualized depictions of persons presented as minors;
4. Grooming;
5. Online enticement;
6. Sextortion;
7. Child trafficking;
8. Solicitation of sexual content from a minor;
9. Threats to publish intimate content involving a minor;
10. Links or credentials facilitating access to prohibited material;
11. Communities organized around sexual interest in minors;
12. Instructions for concealing or distributing prohibited material; or
13. Attempts to evade child-safety detection or reporting.

Apparent violations may result in immediate suspension, preservation of relevant records, termination, and reporting to the National Center for Missing & Exploited Children, law enforcement, or another appropriate authority.

40. Third-Party Services

The Services may rely on third parties for functions such as:

1. Payment processing;
2. Domain registration;
3. Data-center services;
4. Network connectivity;
5. Email delivery;
6. Software licensing;
7. Identity verification;
8. Fraud prevention;
9. Security services;
10. Storage;
11. Backups;
12. Certificate issuance; and
13. Other operational functions.

Spark Rack may disclose information concerning a Minor User only as reasonably necessary for an authorized purpose, as directed by the Responsible Adult, or as required or permitted by law.

Spark Rack does not authorize third parties acting on Spark Rack’s behalf to sell Minor User information, use it for targeted advertising, or use it for artificial-intelligence training.

41. Customer-Selected Third Parties

A Minor User and Responsible Adult may independently configure Customer-controlled systems to interact with third-party services.

The Responsible Adult is responsible for reviewing:

1. The third party’s privacy policy;
2. The third party’s minimum-age requirements;
3. The third party’s parental-consent requirements;
4. The third party’s data-retention practices;
5. The third party’s advertising practices;
6. The third party’s artificial-intelligence practices;
7. The third party’s security practices;
8. The third party’s billing practices;
9. The third party’s terms of service; and
10. Whether the integration is appropriate for a minor.

Spark Rack is not responsible for an independent third party selected, installed, configured, or authorized by the Customer or Minor User.

42. Data Retention

Spark Rack retains information concerning a Minor User only for as long as reasonably necessary for:

1. Providing the Services;
2. Maintaining the Account;
3. Verifying parental authorization;
4. Processing billing;
5. Maintaining security;
6. Preventing fraud;
7. Investigating Abuse;
8. Resolving disputes;
9. Enforcing agreements;
10. Complying with tax and accounting requirements;
11. Complying with legal obligations;
12. Responding to legal process;
13. Maintaining legal holds; and
14. Protecting Spark Rack, Customers, Minor Users, and third parties.

Information may remain temporarily in backups, logs, caches, security systems, and disaster-recovery copies until removed through ordinary retention and deletion processes.

43. Deletion Requests

A verified Responsible Adult may request deletion of information concerning a Minor User.

Spark Rack may retain limited information when reasonably necessary to:

1. Complete a transaction;
2. Maintain financial records;
3. Prevent fraud;
4. Prevent repeat policy violations;
5. Protect Account security;
6. Comply with law;
7. Comply with legal process;
8. Maintain a legal hold;
9. Establish or defend legal claims;
10. Maintain suppression or restriction records;
11. Protect another person’s rights; or
12. Complete ordinary backup-deletion cycles.

Deletion of information necessary to provide a Service may require suspension or cancellation of that Service.

44. Data Security

Spark Rack uses reasonable administrative, technical, and physical safeguards appropriate to the nature of the information and Services.

Safeguards may include:

1. Access controls;
2. Role-based permissions;
3. Multifactor authentication;
4. Encryption where appropriate and supported;
5. Network segmentation;
6. Firewalls;
7. Authentication logging;
8. Security-event logging;
9. Rate limiting;
10. Patch management;
11. Malware filtering;
12. Spam filtering;
13. Vendor restrictions;
14. Confidentiality obligations;
15. Incident-response procedures;
16. Data-minimization procedures;
17. Secure deletion procedures;
18. Restrictions on artificial-intelligence tools; and
19. Other appropriate safeguards.

No security system can guarantee absolute protection. The Minor User and Responsible Adult remain responsible for securing Customer-controlled systems, applications, content, and credentials.

45. Security Incidents

If Spark Rack becomes aware of a security incident affecting a Minor User, Spark Rack may:

1. Restrict Account access;
2. Reset credentials;
3. Revoke tokens or keys;
4. Require multifactor authentication;
5. Notify the Minor User;
6. Notify the Responsible Adult;
7. Preserve relevant records;
8. Investigate the incident;
9. Coordinate with Service Providers;
10. Notify authorities where required;
11. Require remediation;
12. Suspend affected Services; or
13. Take another reasonable protective action.

46. Parental Monitoring

The Responsible Adult acknowledges that Spark Rack is not a substitute for active parental supervision.

The Responsible Adult should:

1. Review the Minor User’s Account activity regularly;
2. Review active Services;
3. Review public websites and applications;
4. Review billing activity;
5. Review authorized users;
6. Review security settings;
7. Review domain registrations;
8. Review email accounts;
9. Review third-party integrations;
10. Review publicly disclosed information;
11. Review privacy settings;
12. Discuss online safety with the Minor User;
13. Respond to suspicious activity;
14. Maintain independent backups; and
15. Remove access when continued use is no longer appropriate.

47. Account Review

Spark Rack may periodically require renewed verification or authorization for a Minor User.

Renewed verification may be required when:

1. The Minor User’s age information changes;
2. The Account owner changes;
3. The billing contact changes;
4. The Parent or Legal Guardian changes;
5. Contact information becomes invalid;
6. Authorization appears outdated;
7. A security incident occurs;
8. A payment dispute occurs;
9. A policy violation occurs;
10. A legal concern arises;
11. A new high-risk Service is ordered;
12. The Account is transferred;
13. Spark Rack reasonably suspects misrepresentation; or
14. Applicable law or policy requirements change.

48. Suspension and Termination

Spark Rack may restrict, suspend, or terminate an Account when:

1. The user is under thirteen;
2. A Minor User lacks Written Parental Authorization;
3. Authorization cannot be verified;
4. The authorization is withdrawn;
5. Age information is false;
6. Parental information is false;
7. Documents appear forged or altered;
8. The Responsible Adult cannot be contacted;
9. The Responsible Adult refuses responsibility;
10. The Minor User violates the Terms of Service;
11. The Minor User violates the Acceptable Use Policy;
12. The Account creates a safety or security risk;
13. The Account is used for age-restricted activity;
14. The Account is used to exploit another minor;
15. Continued service would violate law; or
16. Suspension or termination is otherwise permitted under applicable terms.

Immediate action may be taken without advance notice when reasonably necessary to protect a child, another person, the Services, the Spark Rack Network, or legal compliance.

49. Effect of Suspension or Termination

Suspension or termination may result in:

1. Loss of Account access;
2. Loss of administrative access;
3. Website unavailability;
4. Email interruption;
5. DNS interruption;
6. Domain-management restrictions;
7. Loss of stored Customer Content;
8. Loss of backups;
9. Loss of licenses;
10. Loss of promotional pricing;
11. Deletion according to retention policies;
12. Continued responsibility for valid charges;
13. Preservation of records required for legal or security purposes; and
14. Other consequences described in the Terms of Service.

The Responsible Adult is responsible for maintaining independent copies of important Customer Content.

50. No Guarantee That Every Minor Will Be Identified

Spark Rack may use age screening, Account review, identity verification, parental-authorization requirements, and other safety measures.

Those measures cannot guarantee that every person will provide accurate information or that every unauthorized minor will be identified immediately.

A user’s successful registration does not mean that Spark Rack has certified the user’s age, legal capacity, identity, or parental authorization unless Spark Rack expressly confirms that verification.

Users and Responsible Adults remain obligated to provide accurate information regardless of whether Spark Rack independently detects an inconsistency.

51. No Waiver

Spark Rack’s failure to request age verification or Written Parental Authorization at a particular time does not:

1. Waive this Policy;
2. Approve unauthorized minor use;
3. Confirm that a user is eighteen or older;
4. Prevent Spark Rack from requesting verification later;
5. Prevent suspension or termination;
6. Create a right to continue using the Services; or
7. Transfer responsibility away from the Minor User or Responsible Adult.

52. COPPA and Spark Rack’s Additional Minor Protections

The Children’s Online Privacy Protection Act and its implementing rule generally govern certain online collection, use, and disclosure of Personal Information from children under thirteen.

Spark Rack’s requirement that users thirteen through seventeen obtain Written Parental Authorization is an additional contractual and safety requirement adopted by Spark Rack.

The parental-authorization requirement for Minor Users does not mean that COPPA itself applies identically to every person under eighteen.

Spark Rack may provide protections beyond the minimum requirements of COPPA or other Applicable Law.

53. International Users

Additional or different age, consent, privacy, or contractual requirements may apply outside the United States.

A Minor User and Responsible Adult are responsible for complying with the laws applicable to their location.

Spark Rack may:

1. Apply a higher minimum age;
2. Require additional parental documentation;
3. Require local legal authority;
4. Restrict Services in certain locations;
5. Require additional privacy notices;
6. Decline an Account when local requirements cannot be reasonably supported; or
7. Take other steps needed for legal compliance.

54. Reseller Responsibilities

A reseller providing Spark Rack-supported Services to minors must:

1. Establish and enforce an appropriate minimum-age policy;
2. Prohibit use by children under thirteen;
3. Obtain Written Parental Authorization for users thirteen through seventeen;
4. Maintain verifiable authorization records;
5. Provide appropriate privacy notices;
6. Comply with COPPA and other Applicable Law;
7. Respond to parental requests;
8. Protect Minor User information;
9. Prevent targeted advertising to minors;
10. Prevent AI training using Minor User information;
11. Report suspected child exploitation;
12. Respond promptly to Spark Rack inquiries;
13. Remove unauthorized Minor Users;
14. Not misrepresent Spark Rack’s Services as child-directed; and
15. Remain responsible for all End Users under the reseller Account.

A reseller may establish stricter requirements but may not establish a lower minimum age for use of the Spark Rack Network or Services.

55. School and Organizational Accounts

A school, business, nonprofit organization, club, or similar entity may permit a Minor User to access Services only when:

1. The organization has authority to provide or arrange the access;
2. The organization complies with Applicable Law;
3. The organization obtains any required parental permission;
4. The organization provides appropriate supervision;
5. The Account is controlled by an authorized adult representative;
6. The Minor User is at least thirteen years old;
7. The Minor User’s access is limited to authorized purposes;
8. The organization protects Account credentials;
9. The organization responds to privacy and security concerns; and
10. The arrangement is approved by Spark Rack where required.

An organization may not assume that its authority automatically replaces Written Parental Authorization unless Spark Rack expressly approves the arrangement and Applicable Law permits it.

56. Enforcement Cooperation

Spark Rack may cooperate with:

1. Parents and legal guardians;
2. Courts;
3. Law-enforcement agencies;
4. Child-protection agencies;
5. The Federal Trade Commission;
6. State attorneys general;
7. The National Center for Missing & Exploited Children;
8. Schools;
9. Emergency services;
10. Data centers;
11. Registrars and registries;
12. Network providers;
13. Security providers;
14. Other affected service providers; and
15. Other appropriate authorities or organizations.

Cooperation may include preserving records, restricting access, disclosing information where legally permitted, and taking steps to prevent continuing harm.

57. False or Fraudulent Authorization

Submitting false, forged, altered, stolen, or misleading parental-authorization information may result in:

1. Immediate Account suspension;
2. Immediate Account termination;
3. Cancellation of pending Orders;
4. Revocation of access;
5. Preservation of relevant evidence;
6. Fraud investigation;
7. Notification of the actual Parent or Legal Guardian;
8. Notification of a payment provider;
9. Notification of law enforcement where appropriate;
10. Recovery of losses or costs where permitted; and
11. Other action available under contract or law.

58. Policy Changes

Spark Rack may update this Policy to reflect:

1. Changes in COPPA;
2. Changes in state children’s privacy laws;
3. Changes in international privacy law;
4. Changes in age-verification guidance;
5. Changes in the Services;
6. Changes in security risks;
7. Changes in child-safety practices;
8. Changes in parental-consent methods;
9. Changes in third-party services;
10. Operational experience;
11. New forms of online exploitation; or
12. Other legal, technical, or business developments.

Spark Rack may apply immediate changes when reasonably necessary to protect minors, comply with law, or address an urgent safety or security risk.

59. Conflict With Other Documents

If another Spark Rack document appears to permit a person under thirteen to create an Account or independently use the Services, this Policy controls.

If another Spark Rack document appears to permit a user thirteen through seventeen to use the Services without Written Parental Authorization, this Policy controls.

A separately signed written agreement may establish additional protections but may not authorize conduct prohibited by Applicable Law.

60. Severability

If any provision of this Policy is found invalid or unenforceable, that provision will be modified or severed only to the minimum extent necessary.

The remaining provisions will continue in effect.

The invalidity of one provision does not eliminate:

1. The prohibition against users under thirteen;
2. The requirement for Written Parental Authorization;
3. The obligation to provide accurate age information;
4. The Responsible Adult’s supervisory responsibilities;
5. Spark Rack’s child-safety rights; or
6. Any protection independently required by law.

61. Contact Information

Questions, parental authorizations, revocations, privacy requests, or concerns regarding a minor’s Account should be submitted through the appropriate privacy, legal, safety, account, or support channel in the Spark Rack Customer Portal.

Written correspondence may be mailed to:

Spark Rack
Attn: Children’s Privacy and Parental Authorization
PO Box 2215
Valdosta, GA 31604
United States

62. Customer, Minor User, and Parent Acknowledgment

By creating, authorizing, accessing, or using an Account or Service, the Minor User and Responsible Adult acknowledge and agree that:

1. No person under thirteen years of age may create an Account or independently use the Spark Rack Network or Services.
2. Parental permission does not override the prohibition against users under thirteen.
3. Every user thirteen through seventeen years of age must have prior Written Parental Authorization.
4. Oral, assumed, implied, or informal permission is insufficient.
5. Written Parental Authorization must be verifiable and acceptable to Spark Rack.
6. Spark Rack may require the Parent or Legal Guardian to own or control the Account.
7. The Responsible Adult must supervise the Minor User’s use of the Services.
8. The Responsible Adult accepts responsibility for Account charges and the Minor User’s conduct to the maximum extent permitted by law.
9. The Minor User and Responsible Adult must provide accurate age, identity, contact, and authorization information.
10. False age or parental information may result in immediate suspension or termination.
11. Parental authorization may be withdrawn, but withdrawal may require suspension, transfer, or cancellation of the Account.
12. Spark Rack may contact the Responsible Adult concerning billing, security, legal, safety, privacy, or policy matters.
13. Spark Rack does not sell Minor User information.
14. Spark Rack does not use Minor User information for targeted advertising.
15. Spark Rack does not use Minor User information for artificial-intelligence or machine-learning training.
16. Spark Rack may take immediate action when reasonably necessary to protect a minor or another person.
17. Spark Rack’s Services are general-audience Services and are not directed to children under thirteen.
18. Approval of an Account does not certify that a Customer-operated website or application complies with COPPA or another law.
19. The Responsible Adult remains responsible for determining whether the Minor User’s activities are lawful and appropriate.
20. Spark Rack may require renewed verification at any time reasonably necessary to protect the Minor User or the Services.

63. Regulatory References

This Policy is intended to operate consistently with the Children’s Online Privacy Protection Act and the Children’s Online Privacy Protection Rule.

• Federal Trade Commission: Children’s Online Privacy Protection Rule
• Federal Trade Commission: COPPA Compliance Questions and Answers
• Federal Trade Commission: Children’s Online Privacy Protection Act