Privacy Policy for Children

OTPAM IT HUB. and its affiliates (“OTPAM”, “we”, “us” or “our”) are committed to ensuring the privacy of children under the age of 13 years old who use OTPAM-hosted websites, software, technologies, services such as OTPAM’s school products, and applications such as Libby and the OTPAM app (collectively referred to as “Services”).

Please be sure to read this Privacy Policy for Children with your parent(s) and/or legal guardian(s) (collectively referred to as “parents”) and ask them questions about what you do not understand.

The OTPAM Privacy Policy is incorporated herein by reference.

Why is there a separate Privacy Policy for Children?
The Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) requires us to inform parents about how we collect, use, and disclose Personal Information from children under 13 years of age.

What kind of Personal Information is covered by COPPA?
Under COPPA, “Personal Information” is defined as individually identifiable information, for example, full name (first and last); a home or other physical address including street name and city or town; online contact information such as an email address or screen name; a phone number; a Social Security number; a photograph, video or audio file containing a child’s image or voice; or persistent identifiers such as customer or processor serial numbers held in a cookie, where the identifier is associated with individually identifiable information.

Does OTPAM collect Personal Information from children?
No, we do not knowingly collect Personal Information from children. Children can use most Services without creating an OTPAM account or providing any Personal Information to OTPAM. Children under the age of 13 are not permitted to create, access, or use an OTPAM account.

What information does OTPAM collect?
In order to checkout digital content, we request children enter their library card number, student ID number or, in some cases, a PIN number or password. Our request for such identification number is solely for the purpose of validating the status of the identification number. We do not request, access, or retrieve any additional information. All information, including identification numbers, is protected from unauthorized disclosure.

OTPAM may also collect non-personally identifiable information about a child’s online activity, digital content selections, reviews and ratings, as well as Internet Protocol addresses, device types, unique device data, such as device identifiers, and operating systems.

How does OTPAM collect information?
OTPAM collects information through active participation of the child and passively through the use of “cookies”. For more information on how OTPAM uses cookies, please see our general Privacy Policy. OTPAM does not collect Personal Information through any cookies it utilizes in its Services.

How does OTPAM use information?
OTPAM collects information from a child in order to:

Support the internal operations of the Services, including but not limited to support for: activities necessary to maintain or analyze the Services, network communications, user authentication of users or personalization of content, activities necessary to perform authorized school or educational purposes, and security of users;
Determine the child’s current geographic location and/or language so that we may provide localized content and Services;
Comply with the requirements of our publisher, library, and retail partners;
Provide recommendations for digital content we think the child may enjoy;
Integrate with additional service providers for use of the Services;
Personalize our Services to better reflect particular interests and preferences; and
Generally improve the user experience.
OTPAM never sells a child’s information. We may share anonymized information in aggregated form with third parties and/or business partners in order to analyze Service usage, improve the Services and user experience, or for other similar purposes. The use and disclosure of such anonymous information is not subject to any restrictions under this Privacy Policy for Children. A child’s information is only retained by OTPAM for the time period necessary to support the authorized school or educational purposes.

What if a child shares information with others while using the Services?
While using the Services, children may enjoy opportunities to post reviews, rate digital content, and share digital content information with others in public forums and on social networking websites such as Facebook, Twitter, and Goodreads. When a child shares such information, it is made public and is not subject to this Privacy Policy for Children. We are not responsible for any third party’s use of information a child publicly displays or discloses through our Services.

How can parents control their child’s information?
Parents may email to inquire if their child has submitted Personal Information to OTPAM and to request the review, correction, and/or removal of any such Personal Information from our system.

If you are a teacher or administrator at an educational institution using the school Services, please email to request the review, correction, and/or removal of a student’s Personal Information, and we will facilitate your access to and correction of such Personal Information promptly upon your request.

Changes to this Privacy Policy for Children
This Privacy Policy for Children was last updated in November 2019. Please check this Privacy Policy for Children periodically for updates. Your continued use of the Services after the posting of any changes to this Privacy Policy for Children means that you agree to be bound by such changes.

In the event of a change of control (i.e. sale of sale or merger of OTPAM IT HUB.) the successor entity will be subject to these same privacy commitments.

Contact OTPAM
OTPAM IT HUB. is the operator for the Services. If you have any questions or concerns regarding this Privacy Policy for Children, please contact OTPAM via email at

You can also contact OTPAM by calling (60) 11 1002 1330 or mailing us at OTPAM IT HUB, A-1-03, CYBERSQUARE, JALAN TEKNOKRAT 6, CYBER 5, 63000 CYBERJAYA, SELANGOR, MALAYSIA.