Privacy Policy

Last updated: July 1, 2025

Introduction

At Talents.Kids, we are committed to protecting your privacy and the privacy of your children. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our AI-powered talent discovery platform. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access or use our services.

We reserve the right to make changes to this Privacy Policy at any time. We will alert you about any changes by updating the "Last updated" date of this Privacy Policy and notifying you via email. You are encouraged to periodically review this Privacy Policy to stay informed of updates.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE

This service complies with the Children's Online Privacy Protection Act (COPPA) and similar international regulations. Our platform is designed so that only parents and legal guardians may create accounts and interact with our services. Children do not directly use our platform - all interactions are conducted by parents/guardians on behalf of their children.

Key COPPA Compliance Elements:

Only parents/guardians register accounts and provide consent
No direct collection of data from children under 13
Enhanced security measures for children's data
Right to review, update, and delete child's information
No behavioral advertising directed at children
Transparent data practices with clear parental control

AGE-BASED DATA PROTECTION FRAMEWORK

UNITED STATES (COPPA Requirements):

Under 13: All data collection requires parental account creation and consent
13-17: Parental account required for service access

EUROPEAN UNION (GDPR Article 8):

Under 16 (default): Parental consent required via guardian account
13-15: Varies by Member State - parental consent required
16+: May vary by local implementation - we require parental accounts regardless of age

INTERNATIONAL USERS:

We apply the most protective standards globally, requiring parental account creation for all children's data processing.

INFORMATION COLLECTION

Personal Data Collection

Parent/Guardian Information:

Account Data: Email address and password (all data encrypted and stored by Supabase)
Billing Information: Processed securely through Stripe (we do not store payment details)
Contact Preferences: Email notification settings, communication preferences

Children's Information (Collected Through Parent Accounts Only):

Basic Profile: First name, age/birth year, gender
Interest Data: May be manually entered by parent or automatically inferred through AI analysis of uploaded content
Uploaded Content: Photos, videos, documents, audio files (MP3), artwork, and other digital content submitted for AI analysis
AI Analysis Results: All AI model reasoning and analysis results stored in vector format for service functionality
Progress Data: Assessment results, skill development tracking, achievement records
Usage Analytics: Platform interaction patterns when parent uses services on child's behalf

Content Storage and Management:

Permanent Storage: All uploaded content (photos, videos, documents, audio files) stored in user's personal gallery
User Control: Parents can delete individual content items at any time through the Digital History section
Administrative Rights: We reserve the right to remove content that exceeds storage quota limits or violates our terms of service
Service Independence: Content deletion does not affect service functionality or AI analysis capabilities

AI Analysis Data:

Vector Storage: All AI model reasoning and analysis results converted to vector format and stored permanently
Service Enhancement: Vector data used to improve service recommendations and analysis accuracy
Aggregated Learning: Individual AI insights contribute to overall service intelligence while maintaining privacy
Analysis History: Complete record of all AI evaluations and recommendations maintained for service continuity

Technical Information:

We automatically collect certain technical information:

Device Information: Browser type, operating system, device identifiers
Usage Data: Pages visited, features used, time spent on platform (tracked via Google Analytics)
Location Data: General geographic location (country/state level only)
Security Information: Login attempts, IP addresses for fraud prevention

Third-Party Data Collection:

Google Analytics: We use Google Analytics to understand user behavior and improve our services. Google Analytics processes aggregated, anonymized usage data
No Advertising Networks: We prohibit third-party advertising networks from collecting children's data
Payment Security: Stripe processes payments - we receive only confirmation of successful transactions
No Social Media Integration: No social media plugins or tracking for accounts involving children

CRITICAL DISCLOSURE: AI PROVIDERS AND THIRD-PARTY DATA TRANSFER

MANDATORY DATA TRANSFER TO AI PROVIDERS

IMPORTANT NOTICE:
ALL CONTENT YOU UPLOAD (INCLUDING YOUR CHILD'S DATA) IS TRANSMITTED TO THIRD-PARTY AI PROVIDERS for processing and analysis. This is an essential part of our service functionality.

Data Transmitted to AI Providers Includes:

All Uploaded Content: Photos, videos, documents, audio files of your child
Textual Data: Descriptions, comments, instructions provided to AI systems
Profile Context: Child's name, age, interests when relevant for analysis context
Analysis Requests: Specific talent assessment parameters and instructions

AI PROVIDER SELECTION AND CONTROL

User-Controlled Selection:

Models Section: You independently choose AI providers and specific models in the Models section
Available Providers: OpenAI (GPT), Anthropic (Claude), Google (Gemini), and other leading AI companies
Multiple Selection: Option to use multiple providers simultaneously for comprehensive analysis
Settings Modification: Right to change provider selection at any time

CRITICAL UNDERSTANDING:
BY SELECTING AN AI PROVIDER, YOU EXPLICITLY CONSENT TO TRANSMITTING YOUR CHILD'S DATA TO THAT PROVIDER

LIMITATION OF RESPONSIBILITY

Our Position on AI Provider Data Handling:

No Control: We do NOT control how AI providers use, store, or process data transmitted to them
Independent Policies: Each AI provider operates under their own privacy policy and terms of service
Model Training: Some providers may use transmitted data to train and improve their AI models
Limited Liability: We bear NO RESPONSIBILITY for how AI providers handle your child's data after transmission

Your Responsibilities:

Policy Review: You must review and accept the privacy policies of your chosen AI providers
Risk Assessment: You must understand and accept the risks of transmitting children's data to third parties
Informed Consent: You must provide informed consent for data processing by your selected AI providers
Regular Monitoring: You should regularly check for updates to AI provider policies

AI PROVIDER INFORMATION AND POLICIES

Leading AI Providers and Their Data Practices

OpenAI (GPT Models):

Privacy Policy: https://openai.com/privacy
Data Usage: May use data for model improvement unless specifically opted out
Children's Data: Special restrictions for users under 13
Retention: 30 days for API data (subject to change)
Training Opt-Out: Available for certain plan types

Anthropic (Claude Models):

Privacy Policy: https://www.anthropic.com/privacy
Data Usage: Claims not to use customer data for model training
Security: Enhanced security measures for sensitive data
Retention: Limited retention of API requests
Constitutional AI: Focus on safety and alignment

Google (Gemini Models):

Privacy Policy: https://policies.google.com/privacy
Data Usage: May be used to improve Google services
Integration: Data may integrate with other Google services
Retention: According to general Google privacy policy
Enterprise Options: Different policies for business accounts

⚠️ DISCLAIMER: AI provider policies may change without notice. Always verify current policies on their official websites.

International Data Transfers Through AI Providers

Global Data Processing:

United States: Most AI providers are US-based with primary data processing in the US
Europe: Some providers maintain EU data centers for GDPR compliance
Asia: Certain providers process data in Asian data centers
Global Networks: Your child's data may be processed across multiple jurisdictions

Compliance Through Providers:

GDPR Compliance: Depends on selected provider's GDPR status and implementation
COPPA Compliance: Each provider responsible for their own COPPA compliance
Regional Laws: Providers bear responsibility for compliance with local data protection laws

RECOMMENDATIONS FOR AI PROVIDER SELECTION

Privacy-Focused Selection Criteria

Highest Privacy Protection:

No Training Use: Select providers that do NOT use customer data for model training
Minimal Retention: Choose providers with shortest data retention periods
Children's Policies: Prioritize providers with specific children's data protections
Geographic Preference: Consider providers in your jurisdiction for better legal protection

Current Privacy Rankings:

Most Private: Anthropic Claude (claims no training use)
Moderately Private: OpenAI with training opt-out enabled
Less Private: Providers that actively use data for model improvement

Risk Management Strategies

Data Minimization Approaches:

Essential Content Only: Upload only content necessary for meaningful analysis
Sensitive Content Avoidance: Avoid uploading highly sensitive or identifying information
Provider Rotation: Regularly change AI providers to distribute risk exposure
Policy Monitoring: Track changes in selected providers' privacy policies

ENHANCED PARENTAL CONSENT FRAMEWORK

Comprehensive Consent for Third-Party Processing

Explicit Consent Requirements:

By creating an account and using our services, you explicitly consent to:

Data Transmission: Transfer of your child's data to your selected AI providers
Third-Party Processing: Processing according to AI provider policies and terms
Model Training Risk: Potential use of your child's data for AI model training
International Transfers: Cross-border data transfers according to provider policies
Limited Control: Reduced control over data once transmitted to AI providers

Ongoing Consent Management:

Provider Changes: Right to modify AI provider selection at any time
Content Deletion Limitations: Removing content from our platform does NOT guarantee deletion from AI provider systems
Direct Provider Contact: You must contact AI providers directly for complete data deletion
Service Discontinuation: Stopping our service does not affect data already transmitted to AI providers

Withdrawal of Consent

Partial Withdrawal Options:

Provider Deselection: Remove specific AI providers from your account settings
Content Type Restrictions: Limit types of content sent for AI analysis
Future Processing: Prevent future data transmission while retaining past results

Complete Withdrawal:

Account Termination: Full account closure stops all future data transmission
Provider Contact Required: Contact each previously used AI provider for complete data removal
Vector Data Retention: Our anonymized analysis vectors may be retained for service improvement

INFORMATION USE

Primary Service Functionality

We use collected information for the following core purposes:

Talent Analysis: Processing uploaded content through AI models to identify potential talents, interests, and aptitudes
Personalized Recommendations: Creating customized development plans and resource recommendations
Progress Tracking: Monitoring skill development and achievement over time
Account Management: Maintaining parent/guardian accounts and associated child profiles
Service Delivery: Providing access to platform features, content, and tools

Service Improvement and Development

We use aggregated and anonymized data for:

AI Model Refinement: Improving the accuracy and effectiveness of our talent identification algorithms
Feature Development: Creating new tools and capabilities based on user needs
User Experience Enhancement: Optimizing platform navigation and functionality
Research: Conducting studies on talent development patterns (always with anonymized data)

Communication and Support

We use contact information for:

Service Updates: Notifying parents about new features, tools, and platform changes
Progress Reports: Sending summaries of child's talent development and achievements
Technical Support: Responding to questions and resolving issues
Account Notifications: Sending security alerts, password resets, and account status updates

Legal and Compliance Purposes

We may use information when necessary for:

Legal Requirements: Complying with applicable laws and regulations
Policy Enforcement: Ensuring adherence to our terms of service
Safety Measures: Protecting against harmful or illegal activities
Rights Protection: Defending our legal rights and interests when necessary

Marketing and Promotional Use

With explicit parental consent only, we may use information for:

Service Recommendations: Suggesting additional features or subscription options
Educational Content: Sharing relevant articles and resources on talent development
Opt-Out Available: Parents can decline marketing communications at any time
No Third-Party Marketing: We never share children's data with third parties for marketing purposes

INFORMATION SHARING

Service Providers

We share information with the following types of service providers:

AI Processing Partners: As detailed in the Critical Disclosure section above
Cloud Storage: Secure storage providers for content and data (AWS, Google Cloud)
Payment Processors: Stripe for secure payment processing
Analytics: Google Analytics for anonymous usage statistics
Email Services: SendGrid for communication delivery

All service providers are contractually obligated to use shared information only for designated purposes and in compliance with our privacy policy.

Legal Requirements

We may disclose information when legally required:

Legal Process: In response to a court order, subpoena, or similar legal process
Legal Rights: To protect our rights, privacy, safety, or property
Law Enforcement: To comply with law enforcement investigations with valid legal orders
Emergency Situations: To address fraud, security issues, or technical problems

Business Transfers

In connection with a business transaction:

Merger or Acquisition: If we merge with or are acquired by another company
Asset Sale: If we sell assets or services to another business entity
Bankruptcy: In the event of bankruptcy, insolvency, or reorganization

In such cases, we will notify parents via email and provide choices regarding their data.

With Parental Consent

We may share information with third parties only with explicit parental consent:

Educational Institutions: Schools or programs that may support talent development
Talent Development Partners: Organizations offering specialized training or opportunities
Research Partners: Academic institutions studying talent development (anonymized data only)

Parents will always be informed about what information will be shared, with whom, and for what purpose before consent is requested.

Information We Do NOT Share

We never share the following without explicit parental consent:

Raw Content: Original photos, videos, or documents uploaded by parents
Detailed Profiles: Comprehensive child profiles with identifiable information
Contact Information: Child or parent contact details with third parties
Financial Information: Payment details or financial records

DATA SECURITY

Technical Safeguards

We implement the following security measures:

Encryption: All data is encrypted both in transit (TLS/SSL) and at rest (AES-256)
Access Controls: Strict role-based access controls for all systems
Authentication: Multi-factor authentication for administrative access
Monitoring: 24/7 security monitoring for unauthorized access attempts
Vulnerability Testing: Regular security assessments and penetration testing

Organizational Controls

Our internal security practices include:

Employee Training: Regular privacy and security training for all staff
Limited Access: Need-to-know basis for employee access to personal data
Security Policies: Comprehensive data handling and security procedures
Incident Response: Documented procedures for security incidents

Third-Party Security

We ensure our service providers maintain strong security:

Vendor Assessment: Thorough security evaluation of all service providers
Contractual Requirements: Data protection obligations in all vendor contracts
Compliance Verification: Regular review of vendor security practices
International Standards: Preference for vendors with ISO 27001, SOC 2 certifications

Data Breach Procedures

In the event of a data breach:

Prompt Notification: We will notify affected parents within 72 hours
Detailed Information: Explanation of what occurred and data affected
Remedial Actions: Steps taken to address the breach and prevent recurrence
Support Resources: Guidance on protecting children's information

Security Limitations

Important security considerations:

No Perfect Security: No data transmission or storage system is 100% secure
Shared Responsibility: Account security depends on password protection by parents
Third-Party Limitations: We cannot guarantee the security practices of AI providers
Continuous Improvement: Our security measures are regularly updated

GOOGLE ANALYTICS AND USAGE TRACKING

Analytics Data Collection

Google Analytics Implementation:

Anonymized Data: All personal identifiers removed from analytics data
Aggregated Insights: Usage patterns analyzed at aggregate level only
No Personal Tracking: Individual user behavior not tracked or stored
Standard Analytics: Page views, session duration, and feature usage tracking

Data Protection Measures

IP Anonymization: IP addresses anonymized before processing
Cookie Management: Analytics cookies subject to user consent preferences
Data Retention: Google Analytics data retained according to standard retention policies
GDPR Compliance: Analytics implementation complies with EU privacy requirements

Usage Data Benefits

Service Improvement:

Feature Optimization: Understanding which features are most valuable to families
Performance Monitoring: Identifying and resolving technical issues quickly
User Experience: Improving platform usability based on usage patterns
Safety Enhancement: Monitoring for unusual activity patterns that might indicate security issues

SPECIFIC RIGHTS BY JURISDICTION

Parental Rights Under COPPA

As a parent or guardian, you have the right to:

Review Information: Access all personal information collected from your child
Delete Information: Request deletion of your child's personal information
Discontinue Collection: Refuse further collection or use of your child's data
Consent Management: Revoke previously provided consent at any time

To exercise these rights, contact us at [email protected] with "COPPA Privacy Request" in the subject line.

Rights Under GDPR (European Users)

If you are in the European Economic Area, you have the right to:

Access: Obtain confirmation of whether we process your child's data and request copies
Rectification: Correct inaccurate personal data
Erasure: Request deletion of personal data in certain circumstances
Restriction: Limit how we use personal data in certain scenarios
Data Portability: Receive personal data in a structured, machine-readable format
Objection: Object to processing based on legitimate interests
Automated Decisions: Not be subject solely to automated decision-making

California Privacy Rights (CCPA/CPRA)

California residents have the right to:

Know: Information about personal data collection and purposes
Access: Request specific personal information collected
Delete: Request deletion of personal information with exceptions
Correct: Request correction of inaccurate personal information
Opt-Out: Opt out of the sale or sharing of personal information
Limit Use: Limit use and disclosure of sensitive personal information
Non-Discrimination: Not face discrimination for exercising these rights

How to Exercise Your Rights

You can exercise your privacy rights by:

Email Request: Contact [email protected] with your specific request
Account Settings: Use the Privacy Controls section in your account dashboard
Verification: We may require verification of your identity before fulfilling requests
Response Timeline: We will respond to all requests within 30 days

Limitations on Rights Requests

Please note the following limitations:

Legal Requirements: We may retain certain information as required by law
Legitimate Interests: Some data may be kept for legitimate business purposes
Third-Party Limitations: We cannot delete data already processed by AI providers
Technical Limitations: Some anonymized or aggregated data cannot be specifically identified

ACCOUNT TERMINATION AND DATA RETENTION

Retention Periods

We retain different types of information for varying periods:

Account Information: Maintained for the duration of your active account
Child Profiles: Retained while the account is active or until deletion is requested
Uploaded Content: Stored until manually deleted by the parent or account termination
AI Analysis Results: Maintained indefinitely for service continuity and improvement
Usage Data: Retained for up to 26 months for analytics purposes

Account Closure

When you close your account:

Personal Information: Deleted or anonymized within 30 days
Child Profiles: Completely removed from our active systems
Uploaded Content: Deleted from our servers within 30 days
Backup Retention: May remain in encrypted backups for up to 90 days
Vector Data: Anonymized AI analysis vectors may be retained for service improvement

Legal Holds

Exceptions to our retention policy include:

Legal Obligations: Information retained as required by applicable laws
Dispute Resolution: Data needed to resolve ongoing disputes or investigations
Security Incidents: Information related to security or fraud investigations
Legitimate Business Purposes: Data required for valid business needs

Third-Party Retention

Important considerations regarding third-party data retention:

AI Provider Policies: Each AI provider maintains their own retention policies
Limited Control: We cannot guarantee deletion from third-party systems
Direct Contact Required: Parents must contact AI providers directly for complete deletion
Service Provider Agreements: We require service providers to follow appropriate retention limits

INTERNATIONAL DATA TRANSFERS

Global Operations

Our services operate globally, which means your child's information may be transferred to, stored, and processed in countries outside your country of residence, including the United States, where our primary servers are located.

These countries may have different data protection laws than your country. By using our services, you acknowledge and consent to the transfer of information to countries which may have different data protection rules than your country.

Data Transfer Mechanisms

We ensure compliant international transfers through:

Standard Contractual Clauses: EU-approved contractual clauses for data transfers
Adequacy Decisions: Transfers to countries with adequate protection determinations
Privacy Shield: Compliance with applicable frameworks for certain jurisdictions
Explicit Consent: Your explicit consent for necessary international transfers

European Data Protection

For users in the European Economic Area (EEA):

GDPR Compliance: We process data in accordance with GDPR requirements
Data Transfer Impact Assessments: Regular evaluation of transfer risks
Supplementary Measures: Additional safeguards for sensitive data transfers
EU Representative: Designated representative for EU data protection matters

AI Provider Transfers

Important considerations for AI provider data transfers:

Global Processing: AI providers may process data in multiple countries worldwide
Provider Responsibility: Each AI provider is responsible for their own transfer compliance
Limited Visibility: We have limited visibility into AI providers' internal data flows
Provider Selection: Consider international transfer implications when selecting AI providers

COOKIES AND TRACKING

Cookie Usage

We use cookies and similar technologies for:

Essential Functionality: Cookies required for the platform to function properly
Authentication: Maintaining secure login sessions
Preferences: Remembering user settings and choices
Analytics: Understanding how users interact with our platform

Types of Cookies

We use the following categories of cookies:

Strictly Necessary: Required for basic platform functionality
Functional: Enable enhanced features and personalization
Analytics: Help us understand usage patterns (via Google Analytics)
No Advertising Cookies: We do not use cookies for advertising purposes

Cookie Control

You can manage cookies through:

Browser Settings: Configure your browser to block or delete cookies
Platform Preferences: Adjust cookie settings in your account preferences
Analytics Opt-Out: Disable Google Analytics tracking through our privacy settings
Do Not Track: We honor Do Not Track signals from browsers

Other Tracking Technologies

In addition to cookies, we may use:

Web Beacons: Small graphics for tracking page views and email engagement
Local Storage: Browser-based storage for improved performance
Session Replay: Limited session recording for troubleshooting (no personal data)
Error Monitoring: Automated collection of error logs for platform stability

CHANGES TO PRIVACY POLICY

Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices, service offerings, or legal requirements. When we make significant changes, we will:

Notification: Send email notifications to account holders
Platform Notice: Post prominent notices on our platform
Effective Date: Update the "Last Updated" date at the top of this policy
Prior Versions: Maintain archives of previous policy versions

Material Changes

For material changes that significantly affect your rights or how we use your information:

Advance Notice: We will provide at least 30 days' notice before implementation
Consent Request: We may request renewed consent for significant changes
Opt-Out Options: Clear instructions on how to opt out of new practices
Service Impact: Explanation of how changes may affect service functionality

Continued Use

Your continued use of our services after the effective date of any privacy policy changes constitutes acceptance of those changes. If you do not agree to the revised policy, you should discontinue use of our services and close your account.

Policy Review Recommendations

We recommend:

Regular Review: Periodically reviewing this policy for any updates
Email Monitoring: Ensuring our notification emails are not filtered as spam
Questions: Contacting us with any questions about policy changes
Account Settings: Regularly reviewing your privacy and AI provider selections

DATA MINIMIZATION AND PURPOSE LIMITATION

Data Collection Principles

We adhere to strict data minimization principles:

Purpose-Limited Collection: We only collect data necessary for talent analysis and platform functionality
Minimal Personal Information: We collect only essential personal details (child's name, age, parent email)
No Sensitive Categories: We do not intentionally collect sensitive personal data beyond what is necessary
Time-Limited Storage: Data is retained only as long as necessary for its intended purpose

Prohibited Uses

We explicitly prohibit using collected data for:

Commercial Advertising: No targeted advertising or commercial profiling
Third-Party Sales: No selling or licensing of personal data to third parties
Behavioral Tracking: No cross-platform tracking or behavioral profiling beyond service functionality
Discrimination: No use for discriminatory decisions regarding the child
Unauthorized Research: No use in research studies without explicit consent

Data Quality and Accuracy

We maintain data quality through:

Regular Review: Periodic assessment of data accuracy and relevance
User Updates: Easy mechanisms for parents to update or correct information
Automated Cleanup: Automated removal of outdated or unnecessary data
Quality Controls: Technical measures to ensure data integrity

AI ANALYSIS AND DATA PROCESSING

XAI (Explainable AI) System

Our AI analysis system is designed with transparency and explainability at its core:

Transparent Reasoning: AI models provide clear explanations for their assessments
Human-Readable Results: All AI outputs are presented in understandable language
Confidence Scores: Each assessment includes confidence levels and uncertainty indicators
Bias Monitoring: Regular auditing for potential bias in AI decision-making
Methodology Documentation: Clear documentation of analysis methods and criteria

Processing Methods

Our AI processing includes:

Multi-Modal Analysis: Processing of images, audio, video, and text content
Pattern Recognition: Identification of talent indicators across different media types
Contextual Understanding: Analysis considers child's age, developmental stage, and context
Positive Psychology Framework: Focus on strengths and potential rather than deficits
Educational Standards Alignment: Results aligned with recognized educational frameworks

Content Management and Storage

Uploaded content is managed as follows:

Secure Upload: All content encrypted during upload and storage
Analysis Processing: Content processed by selected AI providers for talent assessment
Result Generation: AI analysis results stored separately from original content
Automatic Cleanup: Original content may be automatically removed after analysis completion
Parent Access: Parents can access and manage all uploaded content and results

Talent Assessment Reports

Our assessment reports include:

Talent Categories: Assessment across multiple intelligence types and talent areas
Developmental Recommendations: Specific suggestions for nurturing identified talents
Progress Tracking: Ability to track talent development over time
Resource Suggestions: Recommendations for books, activities, and educational resources
Professional Referrals: Suggestions for specialists when appropriate

PARENTAL RIGHTS AND CONTROLS

Full Access and Review Rights

As a parent or legal guardian, you have complete control and access rights:

Data Access: View all data collected about your child
Analysis Review: Access all AI analysis results and explanations
Processing History: Review the complete history of data processing activities
Content Management: View, download, or delete any uploaded content
Account Administration: Full control over account settings and preferences

Update and Correction Procedures

You can easily update or correct information through:

Account Dashboard: Direct editing of child information and preferences
Content Replacement: Upload new content to replace outdated materials
Analysis Updates: Request re-analysis with updated information
Profile Corrections: Modify child profile information at any time
Support Assistance: Contact support for complex corrections or updates

Privacy Controls and Settings

Comprehensive privacy controls include:

AI Provider Selection: Choose which AI providers can process your child's data
Analysis Scope: Control which types of analysis are performed
Data Sharing: Manage what information is shared and with whom
Communication Preferences: Control frequency and type of communications
Visibility Settings: Manage who can view analysis results

Consent Management

You maintain full control over consent:

Granular Consent: Provide or withdraw consent for specific processing activities
Ongoing Consent: Modify consent preferences at any time
Clear Documentation: All consent actions are clearly documented and accessible
Easy Withdrawal: Simple processes for withdrawing consent
Impact Explanation: Clear explanation of the impact of consent changes

DATA DELETION RIGHTS AND PROCEDURES

Complete Data Deletion Rights

You have the absolute right to request complete deletion of your child's data:

Full Account Deletion: Complete removal of all account data and associated content
Selective Content Deletion: Delete specific uploads, analyses, or data categories
Historical Data Removal: Delete analysis history and results
Profile Information Removal: Remove child profile and personal information
Communication History Deletion: Remove email communications and notifications

Deletion Process and Timeline

Our deletion process follows these steps:

Request Submission: Submit deletion request through account settings or email
Identity Verification: Verification process to confirm parental authority
Impact Assessment: Review of what data will be deleted and service impact
Confirmation Required: Final confirmation before deletion proceeds
30-Day Processing: Complete deletion within 30 days of confirmed request

Third-Party Deletion Challenges

Important limitations regarding third-party AI providers:

Limited Control: We cannot guarantee deletion from third-party AI provider systems
Provider Policies: Each AI provider has their own data retention and deletion policies
Direct Contact Required: Parents may need to contact AI providers directly for complete deletion
Best Effort Requests: We make best efforts to request deletion from all providers
Documentation Provided: We provide lists of all AI providers that processed the data

Retention Exceptions

Limited exceptions where data may be retained:

Legal Requirements: Data required to be retained by applicable laws
Fraud Prevention: Information necessary for fraud detection and prevention
Security Incidents: Data related to ongoing security investigations
Dispute Resolution: Information needed for resolving ongoing disputes
Financial Records: Payment and billing records as required by law

EMAIL COMMUNICATIONS AND NOTIFICATIONS

Types of Email Communications

We send the following types of email communications:

Service Notifications: Account creation, analysis completion, and system updates
Security Alerts: Login notifications, security warnings, and account changes
Analysis Results: Delivery of completed talent analysis reports
Educational Content: Newsletters with child development tips and resources (optional)
System Updates: Important platform updates and maintenance notifications

Communication Preferences

You can control your communication preferences:

Email Frequency: Choose how often you receive non-essential communications
Content Types: Select which types of educational content you want to receive
Notification Timing: Set preferences for when notifications are sent
Language Preferences: Choose your preferred language for communications
Unsubscribe Options: Easy unsubscribe from non-essential communications

Essential vs. Optional Communications

We distinguish between different types of communications:

Essential Communications: Cannot be disabled (security, service updates, legal notices)
Transactional Emails: Analysis results, account changes, billing notifications
Optional Marketing: Educational newsletters, feature announcements, tips
Research Invitations: Optional participation in research studies or surveys
Community Updates: Platform news and community highlights (optional)

Email Data Protection

Email communications are protected through:

Encryption: All emails transmitted using secure encryption protocols
Limited Personal Data: Emails contain minimal personal information
Secure Delivery: Email service providers selected for security and privacy
Retention Limits: Email communications subject to data retention policies
No Tracking: No tracking pixels or behavioral tracking in emails

STORAGE QUOTA AND CONTENT MANAGEMENT

Storage Limits and Quotas

Your account includes specific storage allocations based on your subscription plan:

Plan-Based Limits: Storage quotas vary by subscription tier
File Size Restrictions: Individual file size limits for uploads
Total Content Limits: Maximum total content storage per child profile
Automatic Cleanup: Older content may be automatically archived or removed
Upgrade Options: Additional storage available with plan upgrades

Content Management Features

Manage your uploaded content through:

Content Library: Organized view of all uploaded materials
Categorization: Automatic and manual categorization of content
Search and Filter: Easy search and filtering of uploaded content
Bulk Operations: Select and manage multiple files simultaneously
Export Options: Download or export your content and analysis results

Automated Content Lifecycle

Content follows an automated lifecycle:

Upload and Processing: Content uploaded and processed for analysis
Analysis Completion: AI analysis generates results and insights
Result Storage: Analysis results stored permanently (unless deleted)
Content Archival: Original content may be archived or removed after processing
Cleanup Notifications: Advance notice before automated content removal

Data Export and Portability

You can export your data in various formats:

Complete Data Export: Download all data associated with your child's profile
Analysis Reports: Export analysis results in PDF or JSON format
Original Content: Download original uploaded files and materials
Account Information: Export account settings and preferences
Structured Formats: Data provided in machine-readable formats when possible

SPECIFIC RIGHTS BY JURISDICTION

European Union (GDPR) Rights

For users in the European Union, you have additional rights under GDPR:

Right to Information: Clear information about data processing purposes and legal basis
Right of Access: Detailed information about personal data we hold
Right to Rectification: Correction of inaccurate or incomplete personal data
Right to Erasure: Complete deletion of personal data under specific circumstances
Right to Data Portability: Receive data in structured, machine-readable format
Right to Object: Object to processing based on legitimate interests
Rights Related to Automated Decision-Making: Rights regarding automated processing and profiling

United States (COPPA) Compliance

For users in the United States, we comply with COPPA:

Parental Consent: Verifiable parental consent required for children under 13
Limited Data Collection: Collect only information necessary for service participation
No Behavioral Advertising: No targeted advertising based on child's personal information
Parental Access Rights: Right to review and delete child's personal information
Data Sharing Restrictions: Limited disclosure of children's personal information
Safe Harbor Provisions: Protection for educational purposes under COPPA

California (CCPA/CPRA) Rights

For California residents, additional rights include:

Right to Know: Information about personal information collection and use
Right to Delete: Request deletion of personal information
Right to Opt-Out: Opt-out of sale of personal information (not applicable to our service)
Right to Non-Discrimination: No discrimination for exercising privacy rights
Right to Correct: Correct inaccurate personal information
Right to Limit Use: Limit use and disclosure of sensitive personal information

Other Jurisdictions

We also respect privacy rights in other jurisdictions:

Canada (PIPEDA): Privacy rights under Canadian federal privacy law
Australia (Privacy Act): Rights under Australian Privacy Principles
Brazil (LGPD): Data protection rights under Brazilian law
Local Laws: Compliance with applicable local privacy and data protection laws
International Standards: Adherence to international privacy best practices

Exercising Your Rights

To exercise any of these rights:

Contact Information: Email [email protected] with your request
Identity Verification: We may require verification of your identity and parental authority
Response Timeline: We respond to valid requests within legally required timeframes
No Fees: Most requests are processed at no charge
Complaint Rights: Right to file complaints with relevant supervisory authorities

ACCOUNT TERMINATION AND DATA RETENTION

Account Termination Process

You can terminate your account and your child's participation in our services at any time:

Self-Service Termination: Close your account directly through account settings
Email Request: Send termination request to [email protected]
Immediate Effect: Account access is terminated immediately upon request
Data Processing Cessation: All ongoing data processing activities are stopped
Confirmation Provided: Written confirmation of account termination provided

Post-Termination Data Handling

After account termination:

Immediate Access Removal: All account access is immediately revoked
Data Deletion Timeline: Personal data deleted within 30 days of termination
Export Opportunity: Opportunity to export data before deletion
Backup Removal: Data removed from backup systems within 90 days
Third-Party Notification: Best effort to notify AI providers of termination

Data Retention After Termination

Limited data may be retained for:

Legal Compliance: Data required by law to be retained
Financial Records: Billing and payment records for tax and audit purposes
Fraud Prevention: De-identified data for fraud detection systems
Security Logs: System security logs for breach detection
Aggregated Analytics: Non-identifiable usage statistics for service improvement

Reactivation Policies

Important information about account reactivation:

Grace Period: 30-day grace period for accidental terminations
Data Recovery: Full data recovery possible within grace period
Post-Grace Period: New account creation required after grace period ends
No Data Recovery: Deleted data cannot be recovered after grace period
Fresh Start: Post-deletion accounts start with no historical data

Service Discontinuation

In the event of service discontinuation:

Advance Notice: Minimum 90-day advance notice to all users
Data Export Period: Extended period for users to export their data
Alternative Services: Information about data migration to alternative services
Deletion Timeline: Clear timeline for final data deletion
Support During Transition: Dedicated support during discontinuation period

IMPORTANT FINAL DISCLAIMERS

AI Technology Limitations

Important limitations and considerations regarding our AI-powered analysis:

Analysis Accuracy: AI analysis provides insights but is not infallible or comprehensive
Professional Assessment: Our service does not replace professional psychological or educational assessment
Developmental Nature: Child development is dynamic; analyses represent a snapshot in time
Cultural Considerations: AI models may have cultural biases that affect analysis accuracy
Individual Variation: Every child is unique; standardized analysis may not capture all aspects

Service Availability and Reliability

Service availability considerations:

No Uptime Guarantee: We strive for high availability but cannot guarantee 100% uptime
Third-Party Dependencies: Service functionality depends on third-party AI providers
Maintenance Windows: Scheduled maintenance may temporarily interrupt service
Feature Changes: Service features may change or be discontinued with notice
Geographic Availability: Service may not be available in all geographic regions

Parental Responsibility and Consent

Important parental responsibilities:

Informed Consent: Ensure you fully understand our data practices before consenting
Child Communication: Discuss with your child what information is being collected and analyzed
Regular Review: Regularly review and update your privacy settings and AI provider choices
Content Screening: Review uploaded content to ensure appropriateness
Results Interpretation: Use analysis results as one input among many in understanding your child

Educational and Developmental Disclaimers

Important educational considerations:

Not Medical Advice: Our service does not provide medical, psychological, or therapeutic advice
Not Educational Diagnosis: Results should not be used for educational diagnosis or placement decisions
Supplementary Tool: Our service is a supplementary tool, not a replacement for professional guidance
Parental Judgment: Parents should use their judgment in interpreting and acting on results
Professional Consultation: Consider professional consultation for significant developmental concerns

Legal and Liability Limitations

Legal disclaimers and limitations:

Service Provided "As Is": Service provided without warranties of any kind
Limited Liability: Our liability is limited as specified in our Terms of Service
Third-Party Actions: We are not responsible for actions of third-party AI providers
Data Security: While we implement security measures, no system is completely secure
Dispute Resolution: Disputes subject to binding arbitration as specified in Terms of Service

Updates and Changes

This privacy policy and disclaimers:

Subject to Change: This policy may be updated to reflect changes in our practices
Notification Required: Significant changes will be communicated with advance notice
Continued Use: Continued use after changes constitutes acceptance
Regular Review: We recommend regularly reviewing this policy for updates
Questions Welcome: Contact us with questions about this policy or any changes

CONTACT INFORMATION AND RIGHTS REQUESTS

Privacy Office Contact

For all privacy-related inquiries, rights requests, or concerns:

Email: [email protected]

Subject Line Formats:

"Child Data Deletion Request"
"Privacy Rights Request"
"Data Access Request"
"AI Provider Information Request"
"Privacy Policy Inquiry"

Mailing Address:
Talents.Kids
Privacy Office
Lisboa, Campo Grande, 28, 7C, 700-093

Response Timeline

Acknowledgment: Within 48 hours
Simple Requests: Completed within 5 business days
Complex Requests: Resolved within 30 days
AI Provider Coordination: Additional time may be required for requests involving AI providers
Extensions: Any delays communicated with explanation

Rights Request Procedures

Identity Verification:

Account Access: Most requests processed through secure account dashboard
Email Verification: Confirmation required from registered email address
Additional Verification: May require additional identity confirmation for sensitive requests
Authorized Representatives: Procedures available for legal representatives

Request Processing:

Automated Responses: Immediate confirmation of request receipt
Status Updates: Regular updates on request processing progress
AI Provider Coordination: We assist with connecting you to relevant AI providers for their deletion procedures
Final Confirmation: Written confirmation upon request completion
Appeal Process: Procedures available for challenging denied requests

POLICY UPDATES AND NOTIFICATIONS

Change Management

Update Procedures:

Notification Timing: Email notification at least 30 days before significant changes
Change Highlights: Clear explanation of what changes and why
AI Provider Updates: Notifications when we add or remove AI provider options
Impact Assessment: Description of how changes affect your family's privacy
Opt-Out Options: Ability to terminate account if you disagree with changes

Version Control:

Date Tracking: Last updated date prominently displayed
Change Log: Detailed record of all policy modifications
Legal Reviews: All changes reviewed by privacy counsel before implementation

Ongoing Compliance

Regular Reviews:

Annual Assessment: Comprehensive annual policy review and update
Legal Monitoring: Continuous monitoring of changing privacy laws
AI Provider Monitoring: Regular review of AI provider policy changes
Industry Standards: Regular assessment against evolving best practices
User Feedback: Incorporation of user suggestions and concerns

Transparency Reporting:

Annual Report: Annual transparency report on data practices
AI Provider Usage: Statistics on AI provider usage (anonymized)
Compliance Updates: Regular updates on regulatory compliance status
Security Reports: Annual security posture and incident reporting
Statistical Data: Anonymized statistics on data practices and user rights exercises

This Privacy Policy represents our commitment to protecting your family's privacy while providing innovative AI-powered talent discovery services.

We balance the need for comprehensive AI analysis with the highest standards of data protection and user control. However, the use of third-party AI providers creates inherent limitations on our ability to control your child's data after transmission to these providers.

By using our service, you acknowledge and accept these limitations and agree to take responsibility for understanding and accepting the privacy practices of your chosen AI providers.

For immediate assistance with privacy concerns, please contact our Privacy Office at [email protected]

For AI provider-specific privacy concerns, please contact the respective AI providers directly using their published contact information.