Child Privacy Policy

Last updated: July 9, 2026

TerminalStreet LLC ("TerminalStreet," "we," "us," or "our") is committed to protecting the privacy of children. This Child Privacy Policy states the practices TerminalStreet would apply if it ever operated a website or service directed to children under the age of 13, in compliance with the Children's Online Privacy Protection Act (COPPA) and the FTC's 2025 COPPA Rule amendments. TerminalStreet does not currently operate any child-directed service, and does not knowingly collect personal information from children under 13 on this website.

1. Applicability of this Policy

This Child Privacy Policy applies to:

• Any TerminalStreet website, application, or service that is directed to children under 13
• Any TerminalStreet website, application, or service that has actual knowledge that it is collecting or maintaining personal information from a child under 13
• Educational technology services that we provide to schools for the school's educational purposes, where such services may be used by students under 13

This policy supplements our general Privacy Policy. In the event of any conflict between this Child Privacy Policy and our general Privacy Policy with respect to children's personal information, this Child Privacy Policy will take precedence.

2. Information We Collect from Children

2.1 Limited Collection Principle

TerminalStreet follows a "data minimization" approach when it comes to children's personal information. We only collect personal information from children that is reasonably necessary to:

• Provide the specific service or functionality that the child has requested
• Maintain the security and integrity of our services
• Fulfill our legal obligations

2.2 Types of Information

Depending on the service, we may collect the following types of information from children under 13:

• Account Information: If we allow children to create accounts (with verifiable parental consent), we may collect a username, password, and parent's email address.
• Usage Information: Information about how a child uses our services, including log data, device information, and approximate location (never precise location).
• Content: Content that a child creates, uploads, or submits while using our services.
• Educational Information: For educational technology services, we may collect information related to a child's educational progress, such as performance data, completed activities, and learning outcomes.

We do NOT collect:

• Precise geolocation information from children
• Photos, videos, or audio files containing a child's image or voice without verifiable parental consent
• Contact information other than a parent's email address without verifiable parental consent
• Information for behavioral advertising purposes

3. Parental Consent and Rights

3.1 Verifiable Parental Consent

Before collecting, using, or disclosing personal information from a child under 13, we will obtain verifiable parental consent. The consent mechanisms we use may include:

• Providing a consent form to be signed by the parent and returned via email, mail, or electronic scan
• Requiring a parent to use a credit card, debit card, or other online payment system that provides notification of each transaction
• Having a parent call a toll-free telephone number staffed by trained personnel
• Verifying a parent's identity by checking a form of government-issued ID
• Using knowledge-based authentication verification techniques

In accordance with the 2025 COPPA Rule amendments, we implement enhanced verification methods to ensure that consent is genuinely provided by the parent or guardian.

3.2 Exceptions to Prior Parental Consent

We may collect a child's personal information without prior parental consent only in the limited circumstances permitted by COPPA, such as:

• Collecting a parent's email address to provide notice and seek consent
• Collecting limited information for the sole purpose of authenticating a user to maintain the security or integrity of our service
• Collecting information for the sole purpose of responding to a one-time request from a child and then deleting the information
• Collecting information to protect the safety of a child user
• Collecting information in accordance with the "school official exception" for educational technology services used in the educational context

3.3 Parental Rights

Parents have the right to:

• Review Information: Review the personal information we have collected from their child
• Request Deletion: Request that we delete their child's personal information
• Refuse Further Collection: Refuse to allow further collection or use of their child's personal information
• Revoke Consent: Revoke their consent at any time
• Update Information: Request updates or corrections to their child's personal information
• Granular Consent: Under the 2025 COPPA Rule amendments, provide separate consent for different data collection purposes

To exercise these rights, parents can contact us using the information provided in Section 8 below.

4. How We Use Children's Information

We use children's personal information only for the purposes for which it was collected, as disclosed to the parent in our notice, and as permitted by law. These purposes may include:

• Providing and improving our services
• Communicating with parents about their child's account or use of our services
• Protecting the safety and security of our users and services
• Supporting educational activities when providing services to schools
• Fulfilling our legal obligations

We do NOT use children's personal information for:

• Behavioral or targeted advertising
• Profiling for commercial purposes
• Selling to third parties
• Any purpose incompatible with the purpose for which it was collected

In line with the 2025 COPPA Rule amendments, we implement strict limitations on data monetization and enhanced transparency around our data processing activities.

5. Disclosure of Children's Information

We may disclose children's personal information to third-party service providers who help us operate our services, but only if these third parties:

• Are contractually obligated to use the information only for the purposes for which we disclose it
• Implement reasonable security measures to protect the information
• Do not use the information for their own commercial purposes
• Delete the information when no longer needed or upon our request

We may also disclose children's personal information if required by law, such as in response to a court order or valid legal process.

Under the 2025 COPPA Rule amendments, we implement enhanced contractual requirements for our service providers, including data deletion obligations and prohibitions on secondary data uses.

6. Educational Technology Services

When we provide educational technology services to schools for educational purposes, we:

• Collect, use, maintain, and disclose student personal information only for an authorized educational purpose
• Do not engage in targeted advertising based on any information acquired through our provision of educational services
• Do not build student user profiles except for authorized educational purposes
• Do not sell or rent student personal information
• Implement enhanced data security measures specific to educational data
• Comply with the "school official exception" under COPPA, which allows schools to consent on behalf of parents
• Adhere to the 2025 COPPA Rule amendments specifically addressing educational technology providers

Our educational technology services are also designed to comply with other applicable education privacy laws, such as the Family Educational Rights and Privacy Act (FERPA) and applicable state student privacy laws.

7. Data Security and Retention

7.1 Data Security

We implement reasonable technical, administrative, and physical safeguards to protect children's personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and penetration testing
• Employee training on data protection
• Incident response plans
• Enhanced security measures as required by the 2025 COPPA Rule amendments

7.2 Data Retention and Deletion

We retain children's personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, unless a longer retention period is required by law.

We will delete children's personal information:

• When it is no longer necessary for the purpose for which it was collected
• Upon request from a parent
• When required by applicable law or regulation
• In accordance with our internal data retention policies

When we delete personal information, we use methods designed to ensure that the information is irretrievably destroyed, in compliance with industry standards and the 2025 COPPA Rule amendments regarding data deletion.

8. Contact Information

If you have any questions about our Child Privacy Policy or would like to:

• Review the personal information we have collected from your child
• Request that we delete your child's personal information
• Withdraw your consent for the collection, use, or disclosure of your child's personal information
• Request that we no longer collect or use your child's personal information

Please contact us at:

[email protected]

9. Changes to This Policy

We may update this Child Privacy Policy from time to time. If we make material changes to this policy, we will:

• Notify parents via email or through a notice on our website
• Obtain new parental consent if required by applicable law
• Update the "Last Updated" date at the top of this policy

We encourage parents to review this policy periodically to stay informed about our information practices regarding children.

10. Parental Dispute Resolution

For disputes related to children's privacy or COPPA compliance:

• Immediate Response (24 hours): Contact our child privacy team at [email protected]
• Management Escalation (48 hours): Unresolved concerns are immediately escalated to senior management
• FTC Reporting: Parents may file complaints with the Federal Trade Commission regarding COPPA violations
• State Attorney General: Parents may contact their state Attorney General's office for additional consumer protection
• Arbitration: Any dispute not resolved through the steps above will be resolved by binding individual arbitration administered by JAMS, with a class-action waiver and a 30-day opt-out right, as set out in the "Dispute Resolution and Arbitration" section of our Terms of Service, which governs disputes under this document. Individual small-claims actions and claims for injunctive relief for intellectual-property violations are excepted, as provided there.

We prioritize rapid resolution of all child privacy concerns and will work immediately with parents to address any issues related to their child's personal information.

11. COPPA Safe Harbor Compliance

In accordance with the 2025 COPPA Rule amendments regarding transparency of Safe Harbor programs, we disclose that:

• TerminalStreet is committed to complying with all aspects of COPPA
• We regularly review our practices to ensure compliance with the most current regulations
• We provide training to our personnel on COPPA requirements and our specific policies
• We conduct regular assessments of our services to identify and address any potential COPPA compliance issues