1. Overview
This Children's Privacy Notice explains how PayServices Bank treats accounts and information that involve persons under the age of 18 (or, in some jurisdictions, the local age of majority). It is provided in accordance with the U.S. Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and its implementing regulation 16 CFR Part 312, the EU General Data Protection Regulation Article 8 (consent of children), the UK Age Appropriate Design Code, and equivalent laws in markets where ITAM is available.
2. Minimum age and family/teen accounts
The standard ITAM account is available to persons aged 18 or older. ITAM also offers family/teen accounts for persons under the age of 18, structured so that a parent or legal guardian is identified, notified, and able to oversee the minor's account.
A person under the age of 18 may not open or hold an ITAM account independently. To complete identity verification ("KYC") for a minor, the minor must specify an existing or concurrent parent or legal guardian in the ITAM application. Once identified, the parent or legal guardian is notified that the minor is opening an account and is given the opportunity to consent, oversee, and (where appropriate) take action with respect to the account, in accordance with the parental-consent requirements of COPPA, GDPR Article 8, and analogous laws.
The only exception to the parent/guardian requirement is for a minor who has been emancipated by a court of competent jurisdiction. In such cases, the minor may open an account upon presentation of the relevant court order and successful completion of identity and emancipation-status verification. No other exception applies.
3. Special rules for children under 13 (COPPA)
COPPA imposes additional requirements where an online service knowingly collects personal information from a child under the age of 13 in the United States. Where a person identifying as under 13 attempts to open or use an ITAM account:
- We require verifiable parental consent from a parent or legal guardian before any personal information about the child is collected, used, or disclosed, in accordance with the methods set out in 16 CFR § 312.5(b);
- We do not collect more information from the child than is reasonably necessary to provide the service the parent has consented to;
- The parent retains the right at any time to review the child's information, refuse further collection, or have the information deleted, in accordance with 16 CFR § 312.6;
- We do not condition a child's participation in any feature on the disclosure of more information than is reasonably necessary.
Outside the United States, we apply the higher of (a) the local age of digital consent and (b) age 13, in our determination of when these heightened requirements apply.
4. What we collect about minors
For minor accounts, we collect only the information necessary to:
- Verify the identity of the minor and the parent or legal guardian;
- Operate the account safely (for example, enforce parental-control settings, transaction limits, and minor-appropriate spending controls);
- Comply with our anti-money-laundering, sanctions, tax, and other regulatory obligations;
- Provide notices and statements to the parent or legal guardian.
We do not use minor-account information for marketing, behavioral advertising, profiling, or any purpose unrelated to the operation of the account. Minor accounts are excluded from any sale or sharing of personal information for cross-context behavioral advertising.
5. Parental and guardian rights
The parent or legal guardian identified for a minor's account has the right to:
- Receive notice of the account's existence and the personal information collected about the minor;
- Review the personal information collected about the minor;
- Refuse further collection or use of the minor's personal information;
- Direct us to delete the minor's personal information (subject to legal record-retention obligations);
- Access the minor's transaction history, balance, and other account activity;
- Set or modify limits, controls, and access permissions on the minor's account;
- Close the account, subject to applicable law and any joint-ownership or court-ordered restrictions.
Parents and guardians may exercise these rights from within the ITAM application or by contacting us at the address in Section 8 below. We respond to verified parental requests within thirty (30) days, or sooner where required by law.
6. Transition to adult account at age 18
When a minor account-holder reaches the age of 18 (or the local age of majority), the account transitions to a standard adult account. We notify both the account-holder and the parent or guardian in advance. Upon transition:
- The parent or guardian's oversight rights end (subject to any remaining legal obligations);
- The (now-adult) account-holder must complete a re-verification step, including any updated identity, residency, and disclosure requirements that apply to adult accounts;
- The (now-adult) account-holder must provide the customer acknowledgment required under 12 CFR § 1009.5 regarding PayServices Bank's non-FDIC-insured status before the account continues to receive deposits.
7. Security of minor information
We apply enhanced security and access-control measures to minor accounts and to information about minors, consistent with the Federal Trade Commission's COPPA enforcement standards and the UK Age Appropriate Design Code. Information about minors is segregated, access-logged, and retained only for as long as necessary to provide the service or to comply with legal obligations.
8. How to contact us about a minor account
For all questions about a minor's account, parental rights, or this Notice:
PayServices Bank — Family Accounts
950 W Bannock Street, Suite 1100
Boise, Idaho 83702-6140
United States
info@payservices.com
If you believe your child has provided personal information to us without your consent, please contact us immediately at the addresses above. We will investigate and, where appropriate, delete the information promptly.