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COPPA Disclosure

Children's Online Privacy Protection — our commitments to children under 13

Effective Date: May 17, 2026
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This disclosure is required under the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, and the FTC's implementing regulations at 16 C.F.R. Part 312. Color Coded Kids LLC is committed to full compliance with COPPA and considers the protection of children's privacy a core obligation of our educational mission.

1. Our COPPA Compliance Model

Guiden serves K–12 students, which means some users are children under 13. We use the School Consent Model authorized under COPPA Rule §312.5(b)(1). Under this model:

  • Schools act as intermediaries between Color Coded Kids LLC and parents
  • By providing students with Guiden access codes, schools represent that they have complied with COPPA's notice and consent requirements
  • Schools are responsible for providing parents with notice of our data collection practices
  • The data we collect from children is used only for the educational purpose for which the school contracted with us — no other purpose

This model is commonly used by educational technology providers and has been recognized by the FTC as compliant with COPPA when schools have genuinely provided parental notice. We do not accept student registrations from children under 13 who arrive independently through our public website.

2. What We Collect from Children Under 13

We apply strict data minimization principles to all users, and particularly to children under 13. The following is a complete inventory of personal information we collect:

First and Last NameDisplayed within the platform to the student's teachers; not shared externally
Email AddressUsed for authentication only; may be a parent-provided or school-provided address
Password (hashed)Never stored in plaintext; bcrypt hash only
Grade Level (integer)Used to calibrate AI tutor language and difficulty — no names associated
School NameUsed to associate the account with the correct School Partner
Chat MessagesConversations with AI tutors; visible to the student's teacher; processed by OpenAI API
Assignment SubmissionsChat history submitted for AI grading; visible to the student's teacher
AI Grades and FeedbackGenerated by AI grader; visible to student and teacher
Login TimestampsLast login date for security monitoring
Usage CountersDaily message/chat counts for rate limiting — not shared externally
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We do NOT collect: home addresses, telephone numbers, photographs, videos, audio files, Social Security numbers, payment information, geolocation data, social media handles, persistent identifiers tied to advertising, or any information beyond what is listed above.

3. How We Use Children's Information

Information collected from children under 13 is used exclusively for the following educational purposes:

  • Providing AI-assisted tutoring in the student's enrolled subjects
  • Grading assignment submissions using AI and displaying results to the student and teacher
  • Generating learning analytics (KPIs) for the student's teacher to support individualized instruction
  • Authenticating the student's account and maintaining session security
  • Enforcing usage limits set by the School Partner
  • Content safety moderation of all student messages

We do not use children's information for:

  • Advertising or marketing of any kind
  • Sale to third parties
  • Building profiles for commercial purposes
  • Training AI models
  • Any purpose not directly related to providing the tutoring service

4. Data Sharing with Third Parties

4.1 OpenAI (AI Processing)

When a student sends a message or submits an assignment, the content of those messages is transmitted to OpenAI's API to generate tutor responses and grades. We do not transmit the student's name, email address, school name, or any directly identifying information to OpenAI. Only the content of messages and contextual data (grade level as an integer, subject name) is shared.

OpenAI operates under a Data Processing Agreement that prohibits using API inputs to train its models. See OpenAI's API data usage policy.

4.2 Infrastructure Providers

Children's data is stored on cloud infrastructure with encryption at rest and in transit. These providers act as data processors under our direction and have no independent right to use children's data.

4.3 School Partners

Teachers and administrators of the School Partner that enrolled a student have access to that student's chat history, grades, and learning analytics. This access is limited to educational personnel with a legitimate educational interest and is consistent with FERPA's school official exception.

4.4 No Other Sharing

We do not share children's personal information with any other third parties. We do not sell, rent, or license children's data to anyone.

5. Parental Rights Under COPPA

Parents and legal guardians of children under 13 have the following rights under COPPA:

5.1 Right to Review

Parents may request a complete copy of all personal information we have collected about their child. We will provide this information within 10 business days of receiving a verified request.

5.2 Right to Delete

Parents may request the deletion of all personal information about their child. We will permanently delete all such information within 30 days of a verified request, except where retention is required by law (e.g., for fraud prevention or legal compliance) or where the school has a legitimate educational interest in retaining the data.

5.3 Right to Refuse Further Collection

Parents may refuse to permit further collection or use of their child's information. Exercising this right will require deactivation of the child's account, as we cannot provide the tutoring service without collecting the information described in Section 2.

5.4 How to Exercise Parental Rights

To exercise any of these rights, contact us at:

Emailprivacy@colorcodedkids.com
Subject Line"COPPA Parental Rights Request"
Required InfoChild's full name, school name, your name, your relationship to the child, and a description of your request
VerificationWe may ask for reasonable verification of your identity and relationship to the child
Response Time10 business days

Parents may also contact their child's school administrator, who can request deletion or data access on the parent's behalf through the school's administrative account.

6. No Behavioral Advertising to Children

Color Coded Kids LLC does not engage in behavioral advertising, interest-based advertising, or targeted marketing directed at children under 13. This prohibition is absolute and applies regardless of any other business considerations. We do not permit advertising networks of any kind to access data from student-facing pages of our platform.

7. Data Retention for Children

We retain children's personal information only for as long as necessary to provide the educational service:

Active Student DataRetained while the student account is active
Chat History & GradesRetained for 3 years after last login, then permanently deleted
Upon Parent RequestDeleted within 30 days of a verified parental deletion request
School TerminationDeleted within 60 days of School Partner account termination

8. Security Measures for Children's Data

We apply heightened security measures to children's data:

  • All children's data is encrypted at rest (AES-256) and in transit (TLS 1.3)
  • Access to children's data is restricted to teachers of the student's enrolled classroom and platform administrators
  • All student messages pass through a content safety filter before reaching the AI
  • Authentication uses HttpOnly, Secure cookies resistant to JavaScript-based attacks
  • We conduct regular security reviews of our data handling practices

9. Contact for COPPA Matters

For all COPPA-related inquiries, including parental rights requests, questions about our data practices, or to report a concern:

Email: privacy@colorcodedkids.com

Subject: "COPPA Inquiry"

Color Coded Kids LLC · St. Louis, MO

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