Version: DRAFT v0.1 — 14 October 2026 Rule basis: 16 CFR Part 312 as amended (published 22 April 2025; compliance required from 22 April 2026) — §312.4(b)–(d), §312.5, §312.6, §312.10.
This file contains:
- Part A — the direct notice shown to the parent on screen when they create the first child profile, and sent to them by email at the same time (§312.4(b), (c)(1));
- Part B — the confirmation email sent after consent (“email plus” second step, §312.5(b)(2)(viii));
- Part C — the checklist of online-notice elements required by §312.4(d) and where each lives in the Privacy Policy;
- Part D — our verifiable parental consent (VPC) approach in brief (full reasoning is in NOTES.md);
Part A — Direct notice (screen + email)
Where it appears: in the parent dashboard, as a step before the first child profile is saved; the same text is emailed to the account address at that moment. The “Create profile” button is disabled until the checkbox is ticked. No child data is stored or synced until consent is recorded.
Email subject: Before we set up your child’s profile on kids51.com
Your consent is needed before your child can use a kids51.com profile
Hi,
You (the account holder for [ACCOUNT EMAIL]) are setting up a child profile on kids51.com. U.S. law (the Children’s Online Privacy Protection Act) requires us to get a parent’s permission before we collect any information about a child under 13. We apply these same rules to every child profile.
If you do not give consent, we will not collect, use or share any information about your child. Your child can still play the games on our public pages without a profile; progress then stays only on that device.
What we will collect if you consent
- The nickname you choose (letters and numbers only — please don’t use your child’s real full name), an avatar from our fixed set, and, if you want, an age band (5–6, 7–8 or 9–11).
- A device link when you pair your child’s tablet or computer with a code, so that device can open the profile.
- Practice results while your child plays: which fact or skill was practiced, whether the answer was right, how long it took, the game mode and the time.
What we will never collect: your child’s real name, photo, voice or any recording, birthdate, school, address, location, phone number or email. Our games never turn on the microphone, camera or location. Children cannot chat, post, or share anything publicly.
How we use it — only to run kids51.com for your family: adapting questions to your child, syncing between your devices, showing you progress in your dashboard, building “practice your mistakes” worksheets, keeping the service secure, and meeting legal obligations. No ads, no selling, no sharing, no third-party trackers, and no use of your child’s information to train AI.
Who else can see it — no one outside our company, except our hosting provider, Cloudflare, which stores the data only on our behalf under a written agreement. We send nothing about your child to our payment provider (Stripe) or our email provider. We do not disclose your child’s information to third parties, so there is no separate “third-party sharing” consent to give.
How long we keep it — practice results: 90 days, then deleted automatically. Profile and skill-progress summary: until you delete the profile or your account. A paired device that is not used for 90 days is unlinked automatically. If your account is inactive for 24 months, we will email you and then delete it 30 days later. Full schedule: https://kids51.com/privacy/#retention
Your rights, at any time — in your parent dashboard you can view your child’s information, download everything as a file (JSON), delete a profile (immediately), unlink devices, withdraw your consent (collection stops, devices are unlinked and practice data is deleted, while your account stays and you can consent again later), or delete your account. If you cannot sign in, use https://kids51.com/delete-my-data/ or write to hello@kids51.com. Deleting a profile also withdraws your consent for that child.
How to give consent — tick the box “I am this child’s parent or legal guardian, I have read this notice, and I consent” and press Create profile. You are already signed in through a link we sent to [ACCOUNT EMAIL]. We will send a short confirmation email to that address [TO CONFIRM: about 24 hours] later. If you did not give this consent, the confirmation email has a link to withdraw it without signing in.
Full privacy policy (including our children’s privacy notice): https://kids51.com/privacy/
Questions: Dzmitry Pliachko, ul. Stanisława Drabika 63/19, 52-131 Wrocław, Poland · hello@kids51.com · +48 699 810 680
Checkbox text (dashboard): ☐ I am this child’s parent or legal guardian. I have read the notice above and I consent to kids51.com collecting and using my child’s information as described.
(Separate, optional, unticked, not on this screen: marketing emails. Consent to the Terms of Service is collected at sign-up, not here.)
§312.4(c)(1) cross-check of Part A
| Element | Where in Part A |
|---|---|
| (i) online contact info collected from the child | N/A — we never collect contact info from a child; the parent signs up directly |
| (ii) consent required; nothing collected without it | “If you do not give consent…” |
| (iii) items collected, use, potential disclosure | “What we will collect”, “How we use it”, “Who else can see it” |
| (iv) third parties + option to consent without disclosure | “Who else can see it” — no disclosure to third parties; Cloudflare is a service provider for internal operations, not a third party under §312.2 |
| (v) hyperlink to the online notice | “Full privacy policy” link |
| (vi) means of giving consent | “How to give consent” |
| (vii) deletion of contact info if no consent within reasonable time | N/A — not collected for that purpose (we hold the parent’s email because the parent opened an account under our Terms, §312.5(c)(1) not used) |
Part B — Confirmation email (email-plus second step)
When: [TO CONFIRM: 24 hours] after consent is recorded. Logged in email_log (confirmation_sent_at). The consent is marked confirmed_at only when the parent opens the confirm link and presses the confirm button on that page (a link scanner opening the URL does not confirm). Both links are single-use, stored only as hashes, and valid for 30 days.
Subject: Confirmation: you gave consent for [NICKNAME]‘s profile on kids51.com [TO CONFIRM — if R1 rule “no child data in emails” is applied strictly, replace with: “Confirmation: you gave consent for a child profile on kids51.com”]
Hi,
On [DATE] at [TIME UTC], the account [ACCOUNT EMAIL] gave consent for kids51.com to collect and use information for a child profile, as described in our notice to parents.
If this was you, please confirm: [Confirm my consent] — opens a page where you press “Yes, I confirm” (link valid for 30 days, works once).
If this wasn’t you, or you have changed your mind, you can withdraw your consent at any time:
- [Withdraw consent] — link valid for 30 days, no sign-in needed; you confirm on the page. It stops all collection right away: your child’s devices are unlinked, practice results and skill progress are deleted, and the profiles are paused (only nickname and avatar remain). Your parent account and any subscription stay, and you can give consent again later; or
- use “Withdraw consent” or delete the profile in your dashboard at any time; or
- write to hello@kids51.com.
Here is a reminder of what you agreed to: [REPEAT PART A FROM “What we will collect” TO “Your rights, at any time” — VERBATIM]
Dzmitry Pliachko · ul. Stanisława Drabika 63/19, 52-131 Wrocław, Poland · hello@kids51.com · +48 699 810 680
Additional profiles. For the 2nd–4th profile the same Part A screen is shown and a new consent record is created; one Part B email may cover all profiles created within the same 24 hours [TO CONFIRM].
Material changes. Any change to what we collect from children, how we use it, or whom we disclose it to → new direct notice + new consent before the change applies (§312.4(b), §312.5(a)(1)). Until a parent re-consents, the old practices continue for that child or the new feature stays off for that child.
Part C — Online notice (§312.4(d)) checklist
| §312.4(d) element | Where |
|---|---|
| Prominent, clearly labeled link on home page | Footer link “Privacy (incl. Children’s Privacy)” on every page [TO CONFIRM design: visible without scrolling on home] |
| Link on children’s area landing page | /play/ and /kid/ landing: a “For parents: privacy” link placed behind the parental gate is NOT enough — §312.4(d) requires the link on the children’s area landing page. [TO CONFIRM implementation: plain text link to /privacy/#children on the kid landing page, opening in the parent zone; kid-zone CSP allows same-origin links] |
| Link near each point of collection from children | Profile-creation screen and device-pairing screen (parent zone) |
| (1) Name, address, phone, email of all operators | Privacy Policy §1 and §11 |
| (2) What is collected from children; whether children can make PI public; use; disclosure practices incl. third parties; retention policy | Privacy Policy §4.1–4.6, §7; Data Retention Policy |
| (3) Internal operations for which persistent identifiers are collected; means to prevent misuse | Privacy Policy §4.4 |
| (4) Audio files of a child’s voice | N/A — never collected (stated in §4.2) |
| (5) Parent’s right to review, delete, refuse further collection, and procedures | Privacy Policy §4.8 |
| §312.10 written retention policy published in the online notice | Privacy Policy §7 + link to Data Retention Policy |
Part D — Our VPC approach in brief
- What counts as children’s personal information here. A nickname alone is not personal information under §312.2 (it does not function as online contact information — children cannot be contacted through it). But the profile ID and device-link token are persistent identifiers that recognize a user over time, and practice events are “information concerning the child … collected online from the child and combined with an identifier” (§312.2, item 11). We therefore treat synced profile data as personal information and do not rely on the internal-operations exception (§312.5(c)(7)) for profiles — that exception only applies when a persistent identifier is the only personal information collected.
- Method: “email plus” (§312.5(b)(2)(viii)). Permitted because we do not “disclose” children’s personal information (§312.2 — giving it to Cloudflare, a service provider supporting internal operations, is not a disclosure). Step 1: the parent, authenticated by a one-time link to their email, receives the direct notice (on screen + email) and affirmatively consents. Step 2: a delayed confirmation email repeats the notice and explains revocation. Same method in the free trial, on the free tier, and for paying families.
- On subscription: the Stripe card payment by the account holder is an additional enumerated method (§312.5(b)(2)(ii) — card used “in connection with a transaction” with per-transaction notice to the primary account holder). We record it as reinforcing evidence, but our practices do not depend on it, so non-paying families are not treated differently.
- Anonymous play (no profile): no personal information beyond transient IP processing for content delivery and anonymous counts without identifiers → covered by §312.5(c)(7) support-for-internal-operations; disclosed in the online notice (§312.4(d)(3)).