Using our service means that you’ve read and agreed to what’s written here, so please take a moment to go over it.
We will never, ever, not in a million years, sell your data to others, or use it for purposes other than our main business!
Keeping your personal information secure is incredibly important to us, and we invest a lot of effort in protecting it.
We only collect information in accordance with the applicable data protection law that we’ll need to conduct our business, improve our products, provide adequate pricing, help us with marketing and prevent fraud.
For that, we may collect data such as general location, network information and other indicators.
And now, for the legal version...
Last updated: August 6th, 2020
Responsibility for the personal data processing falls on
Lemonade Insurance N.V.
Weesperstraat 61, 1018 VN Amsterdam, Netherlands,
Manager: Jonathan Jaffe
Email: [email protected]
Where this data protection declaration speaks of “we” or “us”, this relates in each case to the aforementioned company.
Our Data Protection Officer can be contacted via the email set out above.
We only process your personal data in compliance with the data protection regulations, where a statutory provision allows us to do so, or where you have granted consent. This also applies during the processing of personal data for marketing and advertising purposes.
In the scope of our Internet Services, we may in principle also collect information that, taken as such, does not allow any identification of you in person. In certain cases – in particular in combination with other data – this information may still be regarded as “personal data” in the sense of the data protection laws. Further, we may, by way of the Internet Services, also capture such information that does not allow us to identify you either directly or indirectly; this is e.g. the case for aggregated information on all users of this Website.
When downloading the App, information is transmitted to the App Store. We are unable to influence this kind of collection of data and are not responsible for it. We will only process this data to the extent required for the downloading of the App onto your mobile device.
Further, you may access certain public parts of our Internet Service without providing us with your personal details (such as your name, postal address, or your email address). Also in this case, we need to collect and store certain information in order to enable your access to our Internet Service. On our Website and in our App, we use certain analysis tools and have integrated functionalities via third party providers. Further, we offer certain functionalities on our Internet Service for which we need to collect personal data.
We collect and process personal data on our Internet Service to the following extent:
Logfiles: If you visit our Website, our web server will automatically store data and information relating to the device and browser you use. This could include technical information such as browser,system type, and IP-address . We process this technical information in the logfiles of our systems. We process the technical information in order to enable your access to our Internet Service, to secure the functionality of our Internet Service and the security of our IT systems, and to optimize our Internet Service. The legal basis for this data processing is Art. 6 para. 1 lit. f GDPR.
Registration, quote, application process: Within the scope of our Internet Service, we offer you the option to register. This is necessary in order to obtain a cost calculation for the desired insurance coverage and an offer to conclude an insurance contract. For this, we request your name,email address, and further details about you and in connection with the risk to be insured. This is necessary in order to establish insurability or, as applicable, the level of potential insurance premium for you. The processing of this data is necessary in each case in order to make the desired quote available to you for cost calculation and in order to be able to send you an appropriate offer by email, if necessary, with the provision of further information on the conclusion of an insurance contract. The processing therefore serves as preparation for entering into a possible insurance contract between us. Thus, the legal basis for the data collection and processing is Art. 6 para. 1 lit. b GDPR.
Insurance contract including claims management: If you wish to accept the quote, you have the option to conclude the insurance contract with us directly online as further explained during the application procedure. In this context, you might, upon receipt of our legal offer, also transmit your payment details for the purpose of paying the insurance premiums due and accept our offer online and may ask for your phone number to contact you if needed in relation to your insurance policy. Following the conclusion of your insurance contract, you will be able to access further information on your account at any time – in particular in connection to the insurance taken out – and potentially include further information or, as applicable, ask to book add-ons to your insurance contract. We will subsequently send you the insurance policy by email. To access your account as well as regarding the administration of your insurance contract, e.g. for the purpose of invoicing or handling of claims, we may request entering data already given during the registration and/or application procedure once again (in particular for the purposes of identification). Furthermore, we will ask for additional personal information and supporting evidence of your claim to prevent fraudulent claims. You can submit your claim’s details through the app or by contacting us. The legal basis of conducting the insurance contract between you and us is Art. 6 para. 1 lit. b GDPR.
Policy management: During the period in which your insurance policy is active with us, we might need to process policy changes, and for that, additional personal information might need to be collected.
Contact after the registration process started: If you have already started to enter the details required for your quote, including your email address, but have not completed it, we may contact you to remind you to complete your application, provided you have consented to getting product updates and offers from us. The legal basis for this is therefore your consent according to Art. 6 para. 1 lit. a GDPR. You can always request to unsubscribe from further non-essential emails from us.
Contact support: You can also contact us through the contact form on the website or by calling us. We collect all the data you provide and store it insofar as necessary to process your request. Calls may be recorded for quality and training purposes. If necessary, data will be stored longer after completion of processing for reasons of preservation of evidence. The legal basis is Art. 6 para. 1 lit. a, b, f GDPR.
Fraud Prevention: In certain cases, we will store and process the personal data collected from interested parties even if no insurance contract is concluded. This is to detect and prevent fraud, attempted fraud, and/or other harmful and/or illegal activities. This serves to maintain our justified interests in the prevention of fraud, and illegal and harmful behavior. The legal basis is Art. 6 para. 1 lit. f GDPR.
Advertising information by email: If you have agreed to receive product updates and offers from us, we will process your email address, and potentially, information included in your account based on your corresponding consent, in order to be able to send you information with regard to our services, offers, and activities in the areas of household and liability insurance. You can always request to unsubscribe from further non essential emails from us. Further, we might assess data collected during the delivery and retrieval of our emails for analytics purposes and to improve our communications. Your personal data in connection with an email subscription will not be disclosed to third parties for any purpose other than to allow us to technically send out communications and analyze the results of our communications through our technical providers. We will process your data exclusively for the selection of individualized content and for sending out product updates and offers within the scope of your consent granted. The legal basis is Art. 6 para. 1 lit. a GDPR.
Statistical evaluations: Where necessary, we may assess your personal data for the purpose of evaluating your preferences to enable interest-orientated marketing, individual addressing, and a continuous optimization of our business processes in a statistical form. We do this in order to get a better understanding of what our customers expect from us. Further, these evaluations help us in the detection of fraud, and the revision and maintenance of security; we conduct this data processing in order to maintain our justified interests; the legal basis is Art. 6 para. 1 lit. f GDPR.
Social Plug-ins: On our Website, we may use plug-ins of social network sites that allow you to conduct activities with regard to content on our Internet Service (also "Social Plug-Ins"). If you are registered in the respective social network and logged in to it, you may communicate directly with the social network. You may also prevent the loading of Social Plug-Ins with add-ons for your browser e.g. with the script blocker "NoScript" (http://noscript.net/). The legal basis for the provision of social plug-ins on our Internet Service is in our justified interests regarding the design of our Internet Service, in accordance with the needs of our users, Art. 6 para. 1 lit. f GDPR.
Further justified interests: Where required, we may process your data beyond the purposes mentioned above, for the purpose of maintaining our justified interests or for the interests of third parties; this is based on Art. 6 para. 1 lit. f GDPR. Some of our justified interests are
the assertion of legal claims and defence of legal disputes;
the prevention and the solving of crimes;
the steering and the further development of our business activities including risk management;
the prevention of fraud;
the ability to identify and resolve technical bugs in the system;
the ability to provide customer support (which is also based on the customer's consent pursuant to Art. 6 para. 1 lit. a GDPR); and the possible sharing of information as part of a corporate transaction or merger;
On our Website, we use short-term as well as permanent cookies.
Short-term cookies, such as, in particular, so-called ‘session cookies’ are deleted in an automated manner upon leaving our Website. These store a so-called ‘session ID’ by which different requests may be allocated to the website. By this, your device will be recognized when you use our Website again. The session cookies will be deleted when you log off or close your browser.
Permanent cookies will be deleted after a certain time in an automated manner, which may be different depending on the cookie. You may configure the settings of your operating system, to prevent e.g. the acceptance of third party cookies, or of all cookies.
In our app, we may use different Software Development Kits ("SDKs") that provide us with data about your usage through our third parties providers. If you would like to avoid this data collection, you will need to close the app and use our website instead. In any case you can always contact our customer service through the website as an alternative to performing in app features.
On the Website, you may prevent the use of third party cookies by way of other measures as explained below.
Please note that if you have accessed other websites from the Lemonade Group operating outside of the EU or have agreed to accept cookies from this site in the past, you may have received cookies. If you wish to remove these cookies, please refer to the "manage cookies" section.
Further information on the cookies used by us, their purpose, and legal basis have been compiled by us for you below. Please note that some cookies are necessary for the functioning of our website and therefore cannot be disabled (‘Essential Cookies’). Other cookies are used by us for analytics and marketing purposes and these may be disabled from our cookie banner when you first log into our website. Further information on online advertising cookies, and on how to prevent their use, can be found on the following websites:
- http://www.aboutads.info/choices/ (only available in English)
Advertising Networks: We may in particular use third party providers such as advertising networks and advertising exchange programs which enable us to include advertising for you on the sites of third parties. The operators of these external advertising networks and advertising exchange programs may, in the case of you consenting, use third party cookies, pixel or similar technologies in order to collect data (Art. 6 para. 1 lit. a GDPR). In some cases, we will place cookies or a pixel on our own site in order to identify cases where a user gets to our Website through advertising placed on another website and completes certain activities (e.g. registration, or application for a quote or conclusion of a contract), for the purpose of remuneration of the advertising partner, in which we have a justified interest (Art. 6 para. 1 lit. f GDPR).
On our instruction, Google uses the transmitted data to evaluate your use of our internet presence, compile a report on the activities on the Website, as well as to render further services for us regarding the use of our Websites. (Therefore, there is a commissioned data processing agreement in place between us and Google). The use of Google Analytics therefore serves the purpose of continuously improving our internet presence and to optimise your user experience. These activities are in our justified interest regarding the data processing (Art. 6 para. 1 lit. f GDPR). Further, by clicking a button on our cookie banner on our Internet Service, you expressly agree to the processing of the collected data by Google in the manner, and for the purposes as described above (Art. 6 para. 1 lit. a GDPR).
If you wish to deactivate or change Google Analytics only in respect of the presentation of content tailored to your interests, including advertising, this can be adjusted under “Google adverts on the web” in the settings for Google Adverts.
Further information regarding the purpose and scope of the data collection as well as regarding the further processing and use by Google, including information on your rights or, as applicable, options for configuration for the protection of your personal data can be found under the following links: http://www.google.com/analytics/
Google Tag Manager: We also use Google Tag Manager. With this service, website tags can be administered via an interface. Google Tag Manager solely implements tags. This means that Google Tag Manager does not place any cookies and no personal data is collected. Google Tag Manager triggers other tags that potentially collect data, but Google Tag Manager does not access this data. If, at domain or browser level, a deactivation of certain websites is affected (see details on the deactivation of cookies given above), this remains in place for all tracking tags to the extent that these are implemented with Google Tag Manager.
Google AdWords / conversion tracking: On our Internet Service we also use, having gained your consent, (Art. 6 para. 1 lit. a GDPR) the online advertising program "Google AdWords,” and within the scope of this, its conversion tracking. With this, Google AdWords inserts a cookie or a pixel on your computer or, as applicable, on the storage of your mobile device, if you were directed to our Internet Service via a Google advert. These cookies are no longer applicable after 30 days. They do not serve for any personal identification. If the user visits certain pages of our Internet Service and the cookie is still active, both we as well as Google are able to see that you clicked on the advert and were forwarded to our site. We, as well as all other clients of Google-AdWords, receive different cookies. The cookies affected by our Google adverts can therefore not be followed beyond our Internet Service.
The information obtained from the conversion tracking serves to compile statistics on the conversion for us. With this, we learn about the total number of users who clicked on an advert and were forwarded to a site provided with a conversion tracking tag. However, we do not receive any information that would allow your potential identification.
If you do not wish to take part in conversion tracking, you may deactivate the conversion cookie in the settings of your browser. More information on this can be obtained from the Google Data Protection Statement. > von Google.
You may also adjust your settings for Google Advertising in the Google settings for advertising.
FinanceAds: In the event of your prior consent (Art. 6 para. 1 lit. a GDPR) we also use the conversion tracking program of financeAds GmbH & Co. KG ("financeAds"). financeAds inserts a cookie on your computer or your mobile device, if you were directed to our website via a financeAds advertising network partner (website or mobile app). These cookies are no longer applicable after 30 days and do not serve for any personal identification. The information obtained from the conversion tracking serves to compile statistics, whether you have been referred to our site by a financeAds partner and whether you have actually concluded an insurance agreement with us. This serves to enable us to pay advertising network partners of financeAds a so-called lead or sale commission on successful registrations or conclusion.
Adform: If you agree, Adform cookies will be used on our website. Adform does not collect any personally identifiable information about you when you visit our website, other than information you voluntarily provide. According to Adform, in addition to the applicable data protection law, it observes certain provisions for the online market within the framework of self-regulation, such as the provisions of the World Wide Web (W3) Group, Privacy Preferences Projects (P3P), Internet Advertising Bureau (IAB) Good Practice Principles for Online Behavioural Advertising (OBA).
You have the possibility to object to the storage of cookies on your computer when ads are displayed by the Adform Ad Server system. Adform uses a cookie mechanism to decide which ads to place, such as ads on similar products a visitor has already seen before, but only on an anonymous basis. This means that Adform does not store any personal information such as e-mail addresses, names or addresses in the cookie or cookie-based profile. The cookie does not collect any names, addresses, telephone numbers, e-mail addresses or other data that personally identify the user. Instead, the cookie contains a random identification number, ways to accept or decline it, or information about campaigns/advertising activities on an advertiser's website. Ad-form collects and stores information such as the operating system, browser version, geographical location, URLs on which Adform displays advertisements, or facts about interactions with advertisements (e.g. number of clicks or views) in cookie-based profiles using random cookie identification numbers. During web requests on Adform's web servers, IP addresses of Internet users are accessible to our system. Adform does not share this data with third parties and uses the data exclusively for the purposes of analysis on our behalf.
Further information on Adform data protection and the possibility of opting out can be found at https://site.adform.com/datenschutz-opt-out.
In some instances, Awin may maintain a limited profile which relates to you, but which does not reveal your identity, online behaviour or other personal characteristics. This profile is only used to understand whether a referral is commenced on one device and completed on another device. In some cases, Awin and the referrers of potential customers may receive and process your personal data for the purposes of carrying out affiliate marketing campaigns with us.
We also receive personal data from Awin and the referrers of potential customers, which can be categorised as: cookie data, data relating to the website, app or other technology from which a potential customer was referred to and technical information relating to your device or an ID individually assigned to your transaction, which Awin can assign to the aforementioned data in its system.
These activities are in our legitimate interest regarding the data processing (Art. 6 para. 1 lit. f GDPR) in carrying on an online advertising campaign, paid for on a performance basis.
MCANISM / Conversion Tracking: We are using the conversion tracking from MCANISM Technology GmbH (“Mcanism”) on our website. As soon as you access our website through a Mcanism advertising partner (a website or a mobile app), a cookie will be placed on your computer or mobile device. This cookie is no longer applicable after the cookie duration has ended. The cookie duration for this campaign can be found at https://mcanism.com at the campaign category. We do not save any personal identifications. This information obtained from the conversion tracking serves to compile statistics, whether you have been referred to our side by a Mcanism partner and whether you have completed an action with this partner. This enables us to pay our advertising network partners. More information about our tracking can be found here: https://mcanism.com/en/datenschutz/.
AduP Technology: Our website uses AdUps tracking - a technology- and service provider of Axel Springer Teaser Ad GmbH (Axel-Springer-Straße 65, 10969 Berlin). By collecting anonymous and/or pseudonymous data, AdUp can then display advertising on websites for a certain period of time in accordance with the users’ interests. AdUp is using cookies in order to provide advertisers with so-called conversion tracking, which determines the effectiveness of their ads and keywords. Further information on data protection at Axel Springer Teaser Ad GmbH can be found at https://www.adup-tech.com/datenschutz/.
Facebook Pixel: After gaining your consent, our Website has a re-marketing pixel from Facebook. Via this pixel, a direct connection to the servers of Facebook is provided during your visit to our Website. Through this, it is transmitted to the Facebook server that you have visited this Website and Facebook will assign this information to your personal Facebook user account.
Mixpanel: We also use the web analytics service Mixpanel, in order to obtain data on the use of our Website for internal purposes, operated by Mixpanel, Inc., 405 Howard St, Floor 2, San Francisco, CA 94105, USA ("Mixpanel"). Mixpanel is obliged to maintain appropriate data protection levels. In the event of your consent (Art. 6 para. 1 lit. a GDPR), Mixpanel will insert a cookie on your device which also logs your user behaviour on the Website (retrieval of pages and activities on pages). This data is then analyzed by Mixpanel and forwarded to us.
Bing: On our Website pixels of the Bing Ads are implemented. Data is collected and stored from which anonymous usage profiles are created. This is a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. This service enables us to track the activities of users on our Website when they arrive at our Website through ads from Bing Ads. If you enter our website via such an ad, a pixel is placed on your computer and a Bing UET tag (Universal Event Tracking tag) is integrated into our website. This is a code that is used in conjunction with the pixel to store some non-personal information about your use of the site.
These pixels are stored on the basis of Art. 6 para. 1 lit. f GDPR and on the basis of your respective consent (Art. 6 para. 1 lit. a GDPR). The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. In addition, Microsoft may use so-called cross-device tracking to track your usage patterns across several of your electronic devices and is thus able to display personalised advertising on or in Microsoft websites and apps. Microsoft is obliged to maintain appropriate data protection levels.
Hotjar: We also use in the event of your consent (legal basis Art. 6 para. 1 lit. a) GDPR) the analytics service Hotjar for internal purposes in order to provide a better experience to our customers and assist in diagnosing technical problems. The service is operated by Hotjar Ltd, St Julians Business Centre,3, Elia Zammit Street. St Julians STJ 1000, Malta, Europe.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Amazon: Furthermore, in the event of your consent (legal basis Art. 6 para. 1 lit. a) GDPR), this Website uses the Amazon Conversion Pixel and Amazon Remarketing Pixel web analytics services of Amazon Digital UK Limited of 1 Principal Place, Worship Street, London, EC2A 2FA, UK, ("Amazon"), a company affiliated with Amazon.com, Inc., 410 Terry Ave. North, Seattle, WA, USA.
When you visit the Amazon.de website, Amazon receives information that you have previously visited our Website or other websites and may associate this with any Amazon account you might have, provided that you are logged in at the same time as your Amazon account. In addition, Amazon receives information about any successful conclusion of a contract with us or any visit of our Websites by means of an advertisement on Amazon.de. Your IP address may also be transmitted.
Amazon can recognize you on other websites, in apps and within other Amazon services and can display personalized advertising. You can prevent your data from being processed by Amazon in your ad preferences settings.
An opt-out cookie will then be set in your browser to prevent the future collection of your information by Amazon pixels when you visit our Website. Your opt-out is valid as long as you do not delete the opt-out cookie.
You may object to the use of AppsFlyer at any time and also with future effect by clicking here.
Alternatively, you will need to close the app and use our website instead. In any case you can always contact our customer service through the website as an alternative to performing in app features.
Adroll Retargeting: Through our advertising partner AdRoll Advertising Limited, Level 6, 1, Burlington Plaza, Burlington Road, Dublin 4, Ireland, we advertise this website in search results and on third party websites. If you have given us your consent for this according to Art. 6 Para. 1 S. 1 lit. a DSGVO, a cookie from these providers or from their partners will be automatically set when you visit our website. The cookie enables interest-based advertising through a pseudonymous cookie ID and based on the pages you visit. The collected data will get deleted immediately after we finished using AdRoll Retargeting for the intended purpose and at the end of its deployment.
You can revoke your consent at any time with future effect by deactivating the retargeting cookie and clicking the following link:
The details required for the conclusion of an insurance contract, as well as the registration for information by email, are in the respective areas of the Internet Service (e.g. in an online form) and marked as mandatory information; without providing the mandatory details, we are unable to allow you the use of the respective functionality.
Depending on the type of personal data that is processed by our company, only certain departments / organizational units have access to your personal data. These include, in particular, our expert departments concerned with the provision of our services and our IT department. Based on the concept of roles and entitlements, the access is, within our company, limited to those functionalities and such scope as is required for the respective purpose of processing.
We may also transfer your personal data within the legally-allowed scope to third parties outside of our company. These external recipients may include, in particular
affiliated companies (in particular Lemonade, Inc., USA), to which we transfer personal data for internal administrative purposes, management and servicing of our insurance product, data analytics, marketing, backoffice, the provision of hosting services and IT services required for the operation of this Website;
the service providers instructed by us, such as e.g. in the areas of marketing, IT (in particular hosting or disaster recovery), or payment administration who provide services to us on a specific contractual basis, which may include the processing of personal data (in particular we utilise payment services of the Hyperwallet group for outgoing payments and payment services of the Stripe group for incoming payments, both providers having establishments outside the EU / EEA, in particular in the USA, you may find more information in regard to the processing of your personal data under https://www.hyperwallet.com/
non-public and public agencies to the extent that we have legal obligations to transmit your personal data.
Reinsurance companies ("reinsurers") that reinsure us. In order for our reinsurers to be able to insure us, it may be necessary to provide our reinsurers with information relating to your insurance contract and your claims.
Other parties: we may share your information with other unaffiliated third parties who are not described elsewhere in this Policy with your consent.
We will transfer your data to external recipients only insofar as this processing is necessary for purposes as permitted by law.
We utilize automated decision-making in connection with the provision of our Internet Service. Automated decision-making, as defined in Article 22 of GDPR, may include profiling, which is any kind of automated processing that utilizes personal data in order to evaluate certain aspects of a natural person. The automated decision-making is based, in addition to other factors, on the information you provide during the quote process. We will use automated decision-making to evaluate the information you provide to us to calculate your individual risk profile in order to determine whether we can extend insurance coverage to you, and if so, what your insurance coverage limits and premiums will be, or to process claims you submit.
Under certain applicable laws, you may have the right to certain safeguards as they relate to automated decision-making. Specifically, you may be able to request that the result of the automated decision-making process is recalculated by a human, to express your views related to or contest the result of the automated decision-making process, and receive notification of the contestation outcome. In order to exercise these rights, or for more information about automated decision-making, please contact us at the information provided below. By applying for insurance, you acknowledge that you understand that automated decision-making or profiling may be used as described in this policy and you consent to Lemonade’s use of those methods.
In certain cases, there may be a transmission of information to recipients in so-called “Third Countries.” Third Countries are countries outside of the EU or the EEA, and it cannot automatically be assumed that their data protection levels are in line with those in the European Union.
In general, we will store your personal data only as long as we have a justified interest in this storage, and your interests in discontinuation do not overtake the justified interest.
Additionally, without any justified interest, we may continue to store your data where we are statutorily obliged to do so (e.g. for the purpose of fulfilling archiving requirements). We will delete your personal data without any action from your side, as soon as access to the data is no longer necessary to fulfil the purpose of processing, or the storage is otherwise illegal.
The personal data we need to store for the purpose of compliance with retention duties will be stored until the end of the corresponding retention period. Where we store personal data exclusively for the purpose of fulfilling archiving duties, it is normally blocked so that access is only possible where this is required with regard to the purpose of the retention duty.
Right to object according to Article 21 GDPR:
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, based on Article 6 para. 1 lit. e or f GDPR, including profiling according to Art. 22 GDPR based on those provisions. In the event of your objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing serves for the establishment, exercise or defence of legal claims.
Where we process your personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the concerned personal data shall no longer be processed for such purposes.
You have the possibility, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.
Further rights of affected persons: Based on the following provisions, you as a data subject have the right
to obtain information on your personal data which is stored, Art. 15 GDPR;
to have incorrect or incomplete data corrected, Art. 16 GDPR;
to deletion of personal data, Art 17 GDPR;
to a restriction of the processing, Art 18 GDPR;
to data portability, Art. 20 GDPR.
Further, you are entitled at any time to file a complaint with the responsible supervisory authority for data protection, Art. 77 GDPR.
Our services are not aimed at persons under the age of 16 years and their use is not intended for use by such persons. We do not collect personal data from people we know to be under the age of 16.