Effective date: [EFFECTIVE DATE]
Last updated: [LAST UPDATED DATE]
Version: 1.0
This policy is written in plain English on purpose. Where a legal term matters, we explain it. If anything here is unclear, email us at privacy@smartmins.com and we will answer.
SmartMins is operated by [COMPANY NAME], located in Ontario, Canada ("SmartMins", "we", "us", "our"). [LAWYER: Confirm the legal operator — sole proprietor's legal name or Ontario corporation name, and whether a business address must appear here. Quebec Law 25 and COPPA both expect a physical address to be available to parents.]
We are the "organization" responsible for personal information under Canada's PIPEDA and the "operator" under the US Children's Online Privacy Protection Act (COPPA). Our Privacy Officer can be reached at privacy@smartmins.com.
SmartMins is a paid mobile app for iOS and Android used by families in Canada and the United States. Two people use it:
Because children under 13 use SmartMins, we follow COPPA for US families and treat every child user, regardless of age or country, with the same protections. We also follow PIPEDA and, for families in Quebec, Quebec's Law 25.
We collect as little as we can. Here is the complete list.
| Information | Why we need it |
| Email address | To create your account, send transactional emails (receipts, consent confirmation, security notices), and verify you are the parent |
| Password (stored only as a one-way hash; we cannot read it) | To secure your account. If you use Sign in with Apple or Google, we receive a token from them instead of a password |
| Subscription status (active, trial, expired, plan type) from Apple or Google | To know what to unlock. We never see your card number or payment details |
| Consent record: your email, timestamp, IP address, and app version at the moment you gave parental consent | COPPA requires us to keep proof that a verified parent consented |
| Your child's nickname and age band (7–9, 10–12, or 13–14) | To personalize the child's experience and pick age-appropriate content |
| Device push-notification identifier (Apple/Google push token) | To send you notifications you turn on, such as "your child has a pitch for you" |
| Information | Why we need it |
| Nickname (chosen by the parent; it does not need to be a real name) | So the app can greet the child |
| Age band (7–9, 10–12, 13–14) | To select age-appropriate Discoveries |
| Which Discoveries were completed, and when | To show progress and avoid repeating content |
| Quiz answers (recorded only as right or wrong) | To award Joules and show progress to the parent |
| Joules ledger (earned and spent) | Joules are the app's in-app reward currency; the ledger is how the app works |
| Companion ("Mini") and cosmetic items chosen | So the child's companion looks the way they chose |
| "Pitch" requests: the title of a Discovery the child wants to explain to you | So we can notify you and show it on your parent sheet |
What we do NOT collect about the child: no real name, no birthdate, no photo, no voice, no precise or approximate location, no contacts, no messages, no browsing history, no free-text input, and no persistent identifier used for advertising or profiling.
We do not collect the list of apps you limit. On iOS, Apple's Screen Time / Family Controls framework keeps your app selections on the device and we cannot see them. On Android, the selection is stored on the device only and is never uploaded.
We do not use third-party analytics SDKs, advertising SDKs, tracking pixels, or cross-app tracking. We do not use cookies in the app. Our website may use strictly necessary cookies only. [LAWYER: Confirm the website's cookie situation once built.]
| Purpose | Legal basis (Canada) | Legal basis (US / COPPA) |
| Provide the service you bought (account, content, Joules, screen-time unlocks, companion) | Your consent and performance of our agreement with you; PIPEDA requires purposes a reasonable person would consider appropriate | Verifiable parental consent for the child; our Terms of Service for the parent |
| Send transactional emails and push notifications you turn on | Consent; necessary to provide the service | Same |
| Keep records of parental consent | Legal obligation (COPPA, PIPEDA accountability principle) | Legal obligation |
| Security, fraud prevention, and debugging | Legitimate operational need; a reasonable person would expect it | Support for internal operations (a COPPA-recognized purpose) |
| Comply with law, respond to lawful requests | Legal obligation | Legal obligation |
We never use personal information to:
This section is our online notice under COPPA. US law requires us to tell parents clearly what we collect from children under 13, how we use it, and the rights parents have. We apply these same rules to all children using SmartMins, up to age 14.
Exactly what is listed in Section 3.2, for the purposes listed there. The only personal information in the COPPA sense that we hold about a child is the nickname (which might be a real first name if you choose one), the age band, and the activity data tied to your account. Everything is linked to your account, not to a child identity.
We use the "email plus" method of verifiable parental consent, which COPPA permits when an operator uses children's information only internally and does not disclose it to third parties for their own purposes (which is our case).
1. You create the account with an email address (or Sign in with Apple / Google, which gives us a verified email).
2. We send a verification link or code to that email. You must confirm it.
3. In the app, before any child data is collected, we show you the consent statement (reproduced in our Parental Consent document) and you must actively tick the box and tap Agree.
4. We record your email, the timestamp, your IP address, and the app version as proof of consent.
5. We then send a confirmation email to you restating what we collect, your rights, and how to revoke consent. If the confirmation email bounces or you reply to say you did not consent, we stop collection and delete the child data.
[LAWYER: Confirm that "email plus" remains an approved method under the amended COPPA Rule (compliance date April 22, 2026) for internal-use-only collection, and confirm the "additional step" we use (confirmation email with delay/opt-out) satisfies the "plus" requirement. Also confirm whether any of the data in Section 3.2 could be considered "disclosed" to a service provider in a way that disqualifies email-plus; our position is that hosting and email providers acting on our instructions are not third-party disclosures.]
At any time, you may:
We will not condition your child's participation on disclosing more information than is reasonably necessary.
The amended COPPA Rule requires us to publish a written retention policy. It is in Section 9 and applies to children's information. In short: we keep a child's information only as long as needed to provide the service, delete it within 30 days of your request, delete it 12 months after an account goes inactive, and never keep it indefinitely.
See Section 10. We maintain a written security program appropriate to the small amount of data we hold. [LAWYER: The amended COPPA Rule requires a written children's-data security program with a designated responsible person and annual review. Confirm the founder has one documented internally.]
Only our service providers listed in Section 7, who process it on our behalf and on our instructions. We do not permit them to use it for their own purposes. [LAWYER: The amended COPPA Rule requires the online notice to identify, by name or by category, the third parties/service providers that receive children's information and the purposes. Confirm the level of specificity needed once [HOSTING PROVIDER] and [EMAIL PROVIDER] are chosen.]
*COPPA requires us to deliver this notice directly to you (not just publish it) before we collect information from your child. We show it in the app at the consent step and include it in the consent confirmation email. It is reproduced here so you can find it again.*
> SmartMins — Direct Notice to Parents
>
> Who we are. [COMPANY NAME], Ontario, Canada. privacy@smartmins.com. [MAILING ADDRESS]. [PHONE NUMBER, if any]
>
> Why you are receiving this. You gave us your email address when you created a SmartMins account. We need your verifiable consent before we collect any personal information from your child. If you do not consent within [7] days, we will delete your email address from the child-consent flow. [LAWYER: Confirm the deletion window for an unconfirmed consent request.]
>
> What we will collect from your child, and how we use it. A nickname and age band you choose; which science Discoveries your child completed and when; quiz answers (right or wrong); a ledger of Joules earned and spent; the companion and cosmetic items your child picks; and the titles of Discoveries your child asks to "pitch" to you. We use this only to run the app, show your child's progress to you, and send you notifications you turn on. We collect nothing else about your child: no name, birthdate, photo, location, contacts, messages, or browsing.
>
> Who we share it with. No one, except service providers who host our servers and send our emails under our instructions. We do not sell it, use it for advertising, or build profiles.
>
> How long we keep it. While your subscription or trial is active. Deleted within 30 days of your request, or 12 months after your account goes inactive. Backups purged within 90 days after that.
>
> Your rights. You can review everything we hold about your child, export it, delete it, and refuse further collection at any time from the parent sheet in the app or by emailing privacy@smartmins.com. Refusing further collection closes your child's profile.
>
> How to consent. Tick the box and tap Agree in the app. We will send you a confirmation email. If you did not consent, reply to that email or contact us and we will delete the information.
>
> Full Privacy Policy: smartmins.com/privacy
We do not sell, rent, trade, or "share" personal information. We disclose it only to:
| Recipient | What | Why |
| Apple (App Store, Sign in with Apple, Apple Push Notification service) | Your Apple account handles payment; we receive a subscription status and, if you use Sign in with Apple, a user identifier and email (which may be an Apple private relay address). Push tokens for notifications | Billing, sign-in, notifications. Governed by Apple's privacy policy |
| Google (Google Play, Sign in with Google, Firebase Cloud Messaging for push on Android) | Same as Apple, for Android and Google sign-in | Same |
| [HOSTING PROVIDER] | Everything we store, in encrypted form, on servers located in [HOSTING REGION — Canada or United States] | To run the service. They act only on our instructions |
| [EMAIL PROVIDER] | Your email address and the content of transactional emails we send you | To deliver account, consent, and receipt emails. They act only on our instructions |
| Law enforcement, courts, regulators | What the law requires | Only when legally compelled, or to protect the safety of a child or others. We will tell you unless we are legally barred from doing so |
| A buyer of the business | Account data | If SmartMins is sold or merged, personal information may transfer to the new owner, who must honour this policy. For children's data, we will provide notice and, where required, obtain fresh parental consent. [LAWYER: Confirm the children's-data successor-notice obligation under the amended COPPA Rule.] |
Apple and Google are independent businesses; their handling of payment and sign-in data is under their policies, not ours.
We are in Ontario, Canada. Our hosting provider stores data in [HOSTING REGION]. If that region is in the United States, your and your child's information will be stored and processed in the US, where it is subject to US law, including lawful access by US authorities. We choose providers that contractually commit to use the data only on our instructions and to maintain strong security.
For families in Quebec: before transferring personal information outside Quebec we have carried out a privacy impact assessment as required by Law 25 and concluded the information receives adequate protection. [LAWYER: Confirm a Law 25 PIA for the cross-border transfer has actually been completed and documented, and whether the hosting region is in Canada or the US.]
For families in the United States: your data may be processed in Canada, which has its own privacy laws.
This is our written retention policy, which also serves as the retention policy COPPA requires us to publish for children's information.
| Data | How long |
| Active account (parent and child data) | For as long as your subscription or free trial is active, plus any time we are legally required to keep specific records |
| Inactive account (no active subscription and no sign-in) | Deleted automatically 12 months after the account becomes inactive. We will email you before deletion |
| Deletion request from you | All personal information deleted within 30 days of your request |
| Backups | Encrypted backups are rotated and purged within 90 days after deletion from live systems |
| Consent record (email, timestamp, IP, app version) | Kept for as long as the child profile exists, then deleted on the same schedule. We may keep a minimal, de-identified record that consent existed for legal defence purposes. [LAWYER: Confirm whether a limited consent record may/should be retained after deletion for defence of claims, and for how long, under COPPA and PIPEDA.] |
| Server logs (including IP) | [30] days [LAWYER / TECH: Confirm actual value] |
| Crash reports | [90] days [LAWYER / TECH: Confirm actual value] |
| Purchase and tax records | As required by Canadian tax law (generally 6 years), but these are held by Apple/Google; we keep only subscription status |
We review this schedule at least once a year. We do not keep children's information indefinitely, and we do not keep it for any purpose other than the ones we told you about.
We take security seriously but no system is perfectly secure. What we do:
If we discover a breach affecting your personal information that creates a real risk of significant harm, we will notify you and the relevant regulators as required by law (PIPEDA, Quebec Law 25, and applicable US state breach-notification laws). [LAWYER: Confirm breach-notification obligations in the US states where you expect most users, which may apply in addition to Canadian law.]
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), which applies to our commercial activities across Canada. Ontario does not currently have its own general private-sector privacy statute, so PIPEDA is the governing federal law for us. [LAWYER: Confirm no Ontario private-sector privacy law has come into force by the effective date.]
Quebec families. Quebec's Law 25 applies in addition to PIPEDA. In particular:
All Canadian families may also complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca). Residents of Alberta and British Columbia have substantially similar provincial laws; we honour the same rights regardless of province.
Most US state privacy laws (such as California's CCPA/CPRA) apply only to businesses above certain revenue or data-volume thresholds, which SmartMins does not currently meet. [LAWYER: Confirm, and revisit annually.] Regardless, we honour the following for all US families:
Every parent, in every region, can:
| Right | How |
| See everything we hold about you and your child | Parent sheet in the app, or email us |
| Export it as a JSON file | Parent sheet in the app: "Export my data" |
| Correct the nickname, age band, or your email | Parent sheet in the app |
| Delete your child's data (keeping your parent account) | Parent sheet: "Delete child profile" |
| Delete everything (child and parent) | Parent sheet: "Delete account", or email us |
| Revoke consent / refuse further collection | Same as deleting the child profile; or email us |
| Turn off push notifications | Device settings or the parent sheet |
| Complain | Email us first; or contact the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, or the US Federal Trade Commission (ftc.gov) |
When you contact us by email, we will ask you to write from the email address on the account so we know we are talking to the parent. We respond within 30 days (and usually much faster). There is no charge.
Deleting your account does not cancel your App Store or Google Play subscription. You must cancel that separately in your Apple or Google account settings, otherwise you may continue to be billed.
If we change this policy in a way that materially affects how we collect, use, or share children's information, we will not apply the change to children's information without getting your consent again. For other changes, we will email you and show a notice in the app at least 14 days before the change takes effect. The "Last updated" date at the top tells you when the policy last changed. Older versions are available on request.
[COMPANY NAME]
[MAILING ADDRESS]
Ontario, Canada
Email: privacy@smartmins.com
Support: support@smartmins.com
Website: smartmins.com
[LAWYER: COPPA requires the notice to include a telephone number as well as address and email. Confirm whether a phone number must be published, and whether a virtual number is acceptable for a sole proprietor.]