Children's Privacy Notice (COPPA)

EverJoy Children's Privacy Notice (COPPA)

Effective Date: July 1, 2026
Last Updated: July 2026
Version: 2026-07
Entity: EverJoy Memory LLC d/b/a EverJoy

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1. Purpose of This Notice

This Children's Privacy Notice ("Notice") explains how EverJoy collects, uses, and protects personal information about children under 13 years of age in compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, and the FTC's COPPA Rule, 16 C.F.R. Part 312.

This Notice supplements our Privacy Policy and should be read together with the Parent Consent Agreement.

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2. Our Parent-Directed Service Model

EverJoy is designed as a parent-directed online service:

• Parents and legal guardians (18+) create accounts and manage all Child Profiles
• Children do not create accounts or log into EverJoy independently
• All child data is provided by parents or captured through school programs authorized by parents
• Parents control what content is uploaded, shared, and processed

This model is consistent with FTC guidance on parent-directed services where the operator does not collect information directly from children.

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3. Information We Collect About Children

We collect the following categories of personal information about children only from parents or through authorized capture workflows:

3.1 Child Profile Information

3.2 Content and Memories

3.3 AI-Derived Information (With Parent Consent)

When parents consent to AI processing:

3.4 Information We Do NOT Collect From Children

• We do not collect information directly from children through the Service
• We do not require children to enter contact information
• We do not enable children to communicate with other users independently
• We do not use child data for behavioral advertising
• We do not condition participation on disclosure of more information than necessary

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4. How We Use Children's Information

We use children's personal information solely to:

1. Provide the Service — Store, organize, and display memories and growth timelines
2. Enable partner capture — Link scanned schoolwork to the correct Child Profile via Student ID labels
3. Generate yearbooks — Create Personalized Yearbooks for the family
4. Provide AI features — When separately consented, classify, summarize, and generate growth insights
5. Enable Family Circle sharing — Share content with family members the parent invites
6. Ensure security — Protect accounts and detect unauthorized access

We do not:

• Sell children's personal information
• Use children's information for targeted advertising
• Create profiles for non-Service commercial purposes
• Share children's information with third parties except as described in Section 5

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5. Information Sharing

We share children's information only in these circumstances:

5.1 Service Providers

Trusted vendors who help operate the Service under contractual confidentiality obligations:

• Supabase — Storage and database
• OpenAI — AI processing (with parent consent only)
• Stripe — Billing (no child data transmitted)
• Postmark/SendGrid — Email delivery to parents
• PostHog — Analytics (no child content in events)

See Privacy Policy Section 4 for complete subprocessor list.

5.2 Capture Partners

At partner schools, certified Capture Partners scan student work. Partners:

• Access only artifacts for assigned schools
• Identify students via QR/barcode scan only (not handwriting)
• Are bound by confidentiality and training requirements including FERPA/COPPA awareness
• Do not receive parent contact information except for booklet logistics

5.3 Family Circle

Content shared by parents with invited family members is visible per sharing settings. Family members cannot modify Child Profiles.

5.4 Legal Requirements

We may disclose information if required by law or to protect safety, as described in our Privacy Policy.

5.5 No Sale of Information

We do not sell children's personal information as defined under COPPA and state privacy laws.

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6. Parental Consent

6.1 Verifiable Parental Consent

Before collecting, using, or disclosing personal information from children, we obtain verifiable parental consent through:

1. Account registration requiring parent age affirmation (18+)
2. Consent checkboxes during onboarding for:
   • Terms of Service (version 2026-07)
   • Privacy Policy (version 2026-07)
   • Child data storage consent (version 2026-07)
   • AI processing consent (version 2026-07, optional)
3. Email verification of parent account
4. Consent records stored with timestamp, IP address, and user agent

This consent mechanism is documented in the Parent Consent Agreement.

6.2 Separate Consent for AI

AI processing that transmits child content to OpenAI requires separate, explicit consent. Parents may use core storage features without enabling AI.

6.3 Consent for Partner Capture

Partner school capture requires:

• School authorization (capture_authorized flag)
• Parent enrollment in Student ID Booklet program
• Child data storage consent

6.4 Re-Consent

When we materially change our privacy practices or policy versions, we require parents to re-consent through the /re-consent flow before continuing to use consent-dependent features.

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7. Parental Rights

Under COPPA, parents have the right to:

7.1 Review

Request to review personal information collected from their child.

7.2 Delete

Request deletion of their child's personal information.

7.3 Refuse Further Collection

Refuse to permit further collection or use of their child's information.

7.4 Revoke Consent

Revoke previously given consent (e.g., AI processing consent).

7.5 How to Exercise Rights

We will verify your identity as the parent/guardian before processing requests. We respond within the timeframe required by COPPA (typically within a reasonable time, not to exceed 30 days).

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8. Data Retention

We retain children's information according to our Data Retention Policy:

Parents may delete Child Profiles and individual Memories at any time.

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9. Security

We protect children's information using:

• Private, access-controlled storage buckets
• Short-lived signed URLs for file access
• Row-level security in database
• Encryption in transit and at rest
• Append-only audit logging
• Rate limiting on sensitive operations

See our Security Policy for details.

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10. Partner Capture and Student ID Labels

10.1 Privacy by Design

The Partner Capture Network is designed with child privacy in mind:

• Student names are never printed on labels — only anonymous QR/barcode identifiers
• Identity from scan only — partners do not use handwriting or OCR to identify children
• Parent authorization required — capture only for enrolled families at authorized schools
• School agreement required — schools must authorize capture before activation

10.2 Roster Data

At partner schools, schools may upload roster data (name, grade, DOB, student ID) for parent-initiated activation. Parents cannot browse roster records. Date of birth is used only for server-side verification.

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11. School Officials and FERPA

When schools participate in the Partner Capture Network:

• Scanned artifacts are linked to parent-controlled Child Profiles
• Schools do not receive access to parent-uploaded Memories by default
• School roster data is used solely for activation matching
• Formal FERPA arrangements are documented in the School Agreement and District DPA

EverJoy acts as a service provider to parents, not a school official under FERPA, unless otherwise agreed in writing with a school district.

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12. California SOPIPA

For California students, we comply with SOPIPA (Cal. Bus. & Prof. Code §§ 22584–22584.6):

• Student information used only for Service purposes
• No targeted advertising
• No non-educational profiling
• No sale of student information
• Reasonable security procedures

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13. Operator Contact Information

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14. Changes to This Notice

We will notify parents of material changes to this Notice via email or in-app notice and require re-consent where appropriate. The current version is 2026-07.

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Schedule A: COPPA Compliance Checklist

EverJoy's COPPA compliance program includes:

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Schedule B: SOPIPA Compliance (California)

For California students, EverJoy complies with SOPIPA:

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15. Frequently Asked Questions

Q: Does my child need an EverJoy account? A: No. Children do not create accounts. You manage all data as the parent.

Q: How do I consent for my child? A: During onboarding, you confirm the agreements presented for your account. When AI features are enabled, that includes consent for AI processing before the family dashboard can be used. See the AI Usage & Transparency Policy.

Q: Can I revoke consent? A: You can withdraw AI consent by emailing privacy@myeverjoy.com. You can delete a memory or a child profile in the product. There is not currently a Settings control that revokes only AI processing while leaving the rest of the dashboard available.

Q: What if my child's school uses EverJoy? A: Partner schools enable capture with your authorization via Student ID Booklet enrollment.

Q: Who can see my child's photos? A: Only you and Family Circle members you invite. Schools cannot browse your uploads.

Q: Is scanned schoolwork treated differently? A: Scanned artifacts appear in your Memory Inbox. You review and control them like uploads.

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This Children's Privacy Notice complies with COPPA requirements for operators of parent-directed services. Legal review recommended before publication.