CANDIDCOMMENT™ PRIVACY POLICY
Effective Date: 1 August 2026
Operator: CandidComment™ a Virginia Sole Proprietorship (“Company,” “we,” “us,” or “our”).
This Privacy Policy explains how the Company collects, uses, discloses, and protects personal data in connection with the CandidComment™ website, mobile applications, and related online features (collectively, the “Service”). It is designed to comply with the Virginia Consumer Data Protection Act, Virginia Code § 59.1-575 et seq. (“VCDPA”), including the social-media provisions of Virginia Code § 59.1-577.1; the Children’s Online Privacy Protection Act, 15 U.S.C. §§ 6501-6506, and its implementing Rule, 16 C.F.R. Part 312 (“COPPA”); and other applicable federal and Virginia law.
By using the Service, you acknowledge this Privacy Policy. If you do not agree, please do not use the Service.
1. Scope
This Privacy Policy applies to personal data we process about Users of the Service who are residents of the Commonwealth of Virginia and, except where a right is limited by law to Virginia residents, to Users generally. “Personal data” means information that is linked or reasonably linkable to an identified or identifiable natural person, and does not include de-identified or publicly available information.
2. Information We Collect
2.1 Information You Provide. We collect information you provide when you register and use the Service, such as your username, email address, password, date of birth or age, profile information, and the Content you post, share, or send.
2.2 Information Collected Automatically. When you use the Service, we automatically collect certain information, including your IP address, device and browser type, operating system, device identifiers, general (non-precise) location inferred from your IP address, pages and Content viewed, and dates and times of access. We collect this information using cookies and similar technologies (see Section 8).
2.3 Age-Screening Information. As required by Virginia Code § 59.1-577.1, we use commercially reasonable methods, including a neutral age-screening mechanism, to determine whether a User is a Minor (younger than sixteen). Information collected for the purpose of determining a User’s age is used only for age determination and to provide age-appropriate experiences, and is not used for any other purpose.
2.4 Sensitive Data. We do not seek to collect “sensitive data” as defined by the VCDPA, which includes personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; genetic or biometric data processed to uniquely identify a person; personal data collected from a known Child; and precise geolocation data. We will not process any sensitive data you voluntarily provide without first obtaining your consent, and, for a known Child, only in accordance with COPPA.
3. How We Use Personal Data
We use personal data to:
create and manage your account and authenticate you;
provide, operate, maintain, and improve the Service;
display, transmit, and store your Content;
determine age and provide age-appropriate experiences and the Minor time-limit and parental-consent features described in Section 6;
communicate with you about the Service, including service-related notices;
maintain the safety, security, and integrity of the Service, and detect, investigate, and prevent fraud, abuse, and violations of our Terms; and
comply with legal obligations and enforce our agreements.
4. How We Share Personal Data
We may share personal data with:
Processors / service providers who process personal data on our behalf under written contracts and only on our instructions (for example, hosting, security, and analytics providers);
Other Users and the public, to the extent you post Content or profile information that is public or semipublic on the Service;
Legal and safety recipients, when we believe in good faith that disclosure is necessary to comply with law or legal process, enforce our Terms, or protect the rights, property, or safety of the Company, our Users, or others; and
Successors, in connection with a merger, acquisition, financing, or sale of assets, subject to this Privacy Policy.
We do not sell personal data for monetary consideration, and we do not process personal data for targeted advertising or for profiling in furtherance of decisions that produce legal or similarly significant effects, except with your consent where required by law. If our practices change, we will update this Policy and provide any opt-out or consent mechanism required by the VCDPA.
5. Children Under 13 (COPPA)
The Service is not directed to children, and we do not knowingly collect personal information from any Child under the age of thirteen (13). Users must be at least thirteen (13) years old to register.
If we learn that we have collected personal information from a Child under thirteen without verifiable parental consent, we will delete that information promptly and in accordance with COPPA. A parent or legal guardian who believes we may have collected information from their Child may contact us at admin@candidcomment.com, and may request to review the child’s information, direct us to delete it, and refuse to permit further collection or use. We maintain a written data-retention policy and retain any personal information collected from a Child only as long as reasonably necessary for the purpose for which it was collected, after which we securely delete it.
6. Minors Under 16 (Virginia Code § 59.1-577.1)
Because the Service is a social media platform, the following protections apply to any User determined to be a Minor (younger than sixteen):
6.1 Age Screening. We use commercially reasonable methods, including a neutral age-screening mechanism, to determine whether a User is a Minor.
6.2 Daily Time Limit. We limit a Minor’s use of the Service to one (1) hour per day, per service or application, unless a parent or legal guardian provides verifiable parental consent to increase or decrease that limit.
6.3 Verifiable Parental Consent. A parent or legal guardian may provide, modify, or withdraw verifiable parental consent to adjust the daily time limit by contacting us at admin@candidcomment.com or through the in-Service consent mechanism. Granting such consent does not entitle a parent or legal guardian to any additional or special access to, or control over, the Minor’s data or account, except as required by law.
6.4 Device Signals. We treat a User as a Minor where the User’s device communicates or signals that the User is, or is to be treated as, a Minor, including through a browser plug-in, privacy setting, device setting, or other recognized mechanism.
6.5 Limited Use of Age Data. Information collected to determine a User’s age is used only for age determination and to provide age-appropriate experiences.
6.6 Data Minimization for Known Minors. We do not process the personal data of a known Minor except as reasonably necessary to provide the Service or as otherwise permitted by law, and we do not process such data for purposes that were not disclosed at collection or that are not reasonably necessary for and compatible with the disclosed purposes.
7. Your Virginia Privacy Rights (VCDPA)
If you are a resident of the Commonwealth of Virginia, you have the following rights regarding personal data we control, subject to the VCDPA’s exceptions:
Access. To confirm whether we are processing your personal data and to access that data;
Correction. To correct inaccuracies in your personal data;
Deletion. To delete personal data provided by or obtained about you;
Portability. To obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format; and
Opt Out. To opt out of the processing of your personal data for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
7.1 How to Exercise Your Rights. You may submit a request by contacting us at admin@candidcomment.com or by U.S. Mail to CandidComment™, 7556 Mountain Valley Road, Keezletown, Virginia 22832. We will authenticate your request using commercially reasonable means before acting on it. We do not charge a fee for your first request in a twelve-month period.
7.2 Response Time. We will respond without undue delay and within forty-five (45) days of receipt. We may extend that period once by an additional forty-five (45) days when reasonably necessary, and will notify you of any extension and the reason for it.
7.3 Right to Appeal. If we decline to act on your request, we will inform you of the reason. You may appeal our decision within a reasonable period by contacting us at admin@candidcomment.com. We will respond to your appeal in writing within sixty (60) days and explain the reasons for our decision. If your appeal is denied, you may submit a complaint to the Virginia Attorney General through the Office of the Attorney General’s website (www.oag.state.va.us).
8. Cookies and Tracking Technologies
We use cookies, web beacons, and similar technologies to operate and secure the Service, remember your preferences, authenticate you, and understand how the Service is used. You can control cookies through your browser settings; disabling some cookies may affect the functionality of the Service. Where your browser or device transmits an opt-out preference or a signal indicating that you are, or are to be treated as, a Minor, we will honor that signal as described in Sections 6.4 and 9.
9. Opt-Out Preference and Minor Signals
We honor recognized device or browser signals indicating that a User is, or is to be treated as, a Minor, consistent with Virginia Code § 59.1-577.1. Where we process personal data for any purpose for which the VCDPA requires an opt-out, we will provide a clear and conspicuous method to exercise that opt-out.
10. Data Retention
We retain personal data only for as long as reasonably necessary to provide the Service, fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. We maintain a written data-retention policy for information collected from Children and delete such information securely when it is no longer needed.
11. Data Security
We maintain a written information security program with administrative, technical, and physical safeguards designed to protect personal data appropriate to its volume and sensitivity. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Where we engage third parties to process personal data, we require by written contract that they implement and maintain reasonable security measures.
12. De-Identified Data
We may create and use de-identified data. Where we possess de-identified data, we will maintain and use it in de-identified form, will not attempt to re-identify it except as permitted by law, and will contractually obligate recipients to comply with applicable law.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the revised Policy with an updated Effective Date and, where required by law, provide additional notice. Your continued use of the Service after the revised Policy takes effect constitutes acknowledgment of the changes.
14. Governing Law and Venue
This Privacy Policy is governed by the laws of the Commonwealth of Virginia and applicable federal law. Any suit, action, or proceeding arising out of or relating to this Privacy Policy shall be brought and maintained exclusively in the General District Court of Harrisonburg-Rockingham County, the Circuit Court of Rockingham County, or the United States District Court for the Western District of Virginia at Harrisonburg, according to their respective jurisdictional limits, consistent with the dispute-resolution provisions of our Terms and Conditions of Use.
15. Contact Us
To exercise your rights, ask questions, or raise concerns about this Privacy Policy or our data practices, contact:
CandidComment™ Attn: Privacy, 7556 Mountain Valley Road, Keezletown, Virginia 22832, Email: admin@candidcomment.com.