Children's Privacy Notice

1. Introduction

UnlockGenius ("we," "us," or "our") operates the UnlockGenius.io platform, an AI-powered educational tutoring service. We are committed to protecting the privacy of all our users, especially children under the age of 13.

This Children's Privacy Notice supplements our general Privacy Policy and describes how we collect, use, and disclose personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA) and the Federal Trade Commission (FTC) guidelines.

If you are a parent or guardian and have questions about this notice or your child's data, please contact us at support@unlockgenius.io.

2. Information We Collect from Children

We limit the information we collect from children to only what is reasonably necessary to provide our educational tutoring service. We collect:

• First name and age— Used to personalize the learning experience and ensure age-appropriate content. We do not collect a child's full legal name.
• Grade level and learning preferences— Used to tailor curriculum difficulty and teaching approach to the child's educational stage.
• Learning activity data— Including subjects studied, time spent in tutoring sessions, quiz and assessment scores, and progress milestones. This data enables our AI tutor, CereBRO, to adapt and improve the learning experience.

3. How We Use Children's Information

We use the information collected from children exclusively for educational purposes:

• Personalizing the AI tutor (CereBRO) learning experience— Our AI mentor, CereBRO, uses learning preferences and activity data to adapt its teaching style, pace, and content to each child's unique needs.
• Tracking learning progress— We generate progress reports that parents and guardians can review through the Parent Portal.
• Ensuring age-appropriate content— Age and grade level information is used to filter and present only content suitable for the child's developmental stage.
• Safety monitoring— We monitor tutoring interactions to detect and prevent inappropriate content, ensure the AI tutor remains within educational boundaries, and maintain a safe learning environment.

We do not use children's information for advertising, marketing, or any non-educational commercial purpose.

4. Third-Party AI Services Disclosure

Our AI tutor, CereBRO, is powered by the following third-party artificial intelligence services:

• Google Gemini— Primary AI language model used to generate educational responses and explanations.
• Anthropic Claude— Fallback AI language model used when the primary model is unavailable.
• Amazon Web Services (AWS) Bedrock— Cloud-based AI service used for additional AI model access and processing.

What these services process

These AI services process the educational conversation content— specifically, the questions a child asks and the context needed to generate helpful, age-appropriate educational responses. This is necessary to provide the core tutoring functionality of our platform.

What these services do NOT receive

Data use restrictions

• These third-party AI services do not use children's data for advertising or behavioral profiling.
• These services are contractually prohibited from using the data for purposes other than providing AI responses to our platform.
• We do not permit these services to retain children's conversation data beyond what is necessary to generate an immediate response.

5. Parental Consent

We require verifiable parental consent before any child under 13 is permitted to use the UnlockGenius platform. We take this obligation seriously and have implemented the following procedures:

• Consent method— We use the "Email Plus" verification method as approved by the FTC. When a child under 13 attempts to register, a parent or guardian must provide their email address. We send a detailed consent form to the parent's email, which must be actively confirmed before the child's account is activated.
• What consent covers— The consent form clearly describes what information we collect, how it is used, and the third-party AI services that process educational conversations (as described in Section 4 above).
• Annual renewal— Parental consent must be renewed annually. We will notify parents via email before consent expires and provide a simple renewal process through the Parent Portal.
• Restricted access without consent— Until parental consent is verified, the child's account operates in a restricted mode with limited functionality. Full access to CereBRO and all learning features is granted only after consent is confirmed.

6. Parental Rights

As a parent or legal guardian of a child under 13 using UnlockGenius, you have the following rights under COPPA:

• Review your child's personal information— You may request to review any personal information we have collected from your child. We will provide this information within a reasonable timeframe.
• Request deletion of your child's data— You may request that we delete any or all personal information collected from your child. Upon verification of your identity as the parent or guardian, we will delete the requested data.
• Revoke consent at any time— You may revoke your consent for the continued collection and use of your child's information at any time. Revoking consent will result in the deactivation of your child's account.
• Refuse further data collection— You may instruct us to stop collecting additional information from your child while still allowing access to previously collected data.

7. Data Retention & Security

Data Retention

• Learning activity logs (session transcripts, quiz attempts, interaction history) are automatically deleted after 90 days.
• Progress summaries (aggregate scores, milestone achievements) are retained for as long as the account is active to support ongoing learning.
• When parental consent is revoked, all of the child's personal data and learning records are permanently deleted within 30 days.
• Upon account deletion, all associated child data is removed from our systems within 30 days, including any backups.

Security Measures

• All data is encrypted at rest using AES-256 encryption and encrypted in transit using TLS 1.2+.
• Access to children's data is restricted to authorized personnel on a need-to-know basis.
• We conduct regular security audits and vulnerability assessments to maintain the integrity of our systems.
• Our infrastructure is hosted on Amazon Web Services (AWS), which maintains SOC 2 Type II and ISO 27001 certifications.

8. Contact Information

If you have any questions about this Children's Privacy Notice, wish to exercise your parental rights, or have concerns about your child's privacy on UnlockGenius, please contact us:

If you believe we have inadvertently collected personal information from a child under 13 without proper parental consent, please contact us immediately and we will take steps to delete that information promptly.

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