Guardian and COPPA Policy

1. Who This Policy Covers

P3RSON, Inc. ("P3RSON", "we", "us") offers the service in the United States. This policy explains how we treat people under 18, how a parent or legal guardian approves and controls a teen account, and how we follow the Children's Online Privacy Protection Act and the FTC's COPPA Rule, as amended.

2. How We Determine Age

We set an account's age tier from these signals:

1. Declared date of birth. At sign-up you enter your date of birth on a neutral age screen. We do not hint at the answer needed to continue.
2. Apple Declared Age Range. Where your iPhone supplies it, we read Apple's Declared Age Range signal. We use the range only to confirm adult or minor status. We never use it to work out an exact age.
3. Guardian verification. For every 13 to 17 account, a guardian verifies by email code and a signature record (Section 4).
4. Adult verification. Before any adult-only feature (payouts, AI photo analysis, adult-only search), we verify that the user is an adult.

If we learn that an account is under 13 or that the age was misdeclared, we restrict the account and may ask for proof of age. When someone turns 18, the account moves to the adult tier and guardian controls end.

3. What a Minor Account Can and Cannot Do

Read-only by default. A 13 to 17 account can browse and use safety and settings features. It cannot post or submit photos to the P3 Audit until a guardian approves.

With active guardian approval: the minor can post, and can use the private P3 Audit. Audit results (the P3 Index and AI Scout Notes) are visible only to the minor and the verified guardian. They are never public, searchable, shared with brands, used for commercial ranking, or placed in a public Media Kit.

Never available to anyone under 18, with or without approval: bookings, offers, tips, gifts, subscriptions, P3 Coins, P3 Pro, rates, public Media Kits, Stripe accounts, Smart Escrow, payouts, sponsorships, and name, image, and likeness deals. A guardian cannot waive this rule.

Quiet hours. We do not send push notifications to a minor between 10 p.m. and 7 a.m. in the minor's local time.

No ads, no sale. We do not show behavioral advertising to minors. We do not sell or share a minor's personal information. We do not disclose it to third parties for advertising or marketing.

4. Approval Workflow

1. The minor opens Account, then Parental Consent, and enters the guardian's name, email, and relationship.
2. We email the guardian a 6-digit code. The code expires in 24 hours. After five wrong attempts, entry locks for 30 minutes.
3. The guardian enters the code (or opens the link in the email). This proves access to that email address.
4. The guardian reads the current Terms of Service, this policy, and the Privacy Policy, then signs in the app by typing or drawing a signature.
5. We record the approval: guardian email, time, device, document versions, and a hash of the signature (we do not store the raw signature).
6. The minor is told the account is approved for posting and the private P3 Audit.

The guardian then sees the minor's account status, approval status and expiry date, profile information, posting activity, and private P3 Audit results. The guardian cannot see the minor's private messages.

5. Separate Consent for the AI Provider

The private P3 Audit sends the minor's four Digitals photos to an AI provider (Anthropic) and uses Amazon Web Services Rekognition for photo-quality and safety checks. Sending a child's images to a third party is not integral to the basic service, so general approval is not enough.

Before any minor's photo leaves the device for AI analysis, the guardian gives a separate, specific consent that:

• names the providers and what is sent;
• is not bundled with the Terms, the Privacy Policy, or posting approval;
• can be declined without losing read-only access or posting approval; and
• can be withdrawn at any time.

Without this consent, no minor's image is sent to an AI provider. Minors' images go to an AI provider only for the private P3 Audit, never for any other feature. See the AI Features Notice for the full provider table.

6. Approval Length and Renewal

• Approval lasts 1 year from the date the guardian signs.
• We email the guardian a renewal reminder 30 days before expiry, and again 14 days and 7 days before.
• Renewal repeats the workflow in Section 4. A guardian can renew early; the new year starts on the renewal date.
• When approval expires, posting and new Audit submissions stop. Existing data is kept under Section 9 unless the guardian asks for deletion.

7. What Counts as Personal Information

For minors we treat all of the following as personal information, in line with the amended COPPA Rule:

• name, email address, phone number, and date of birth;
• photos and videos, including Digitals;
• voice recordings and audio;
• persistent identifiers, such as device identifiers or account IDs that can recognize a user over time;
• geolocation precise enough to identify a street or city; and
• any other information combined with the items above.

We collect only what a feature needs. We do not collect precise geolocation from minors or build behavioral profiles of them. We use persistent identifiers only for account security, fraud prevention, and keeping the service running.

8. Guardian Rights and How to Use Them

A guardian can, at any time:

Email [email protected] for any request. We reply within 24 hours on business days. We may ask for proof of guardianship if it is disputed. At 18, these rights pass to the user.

Revocation stops posting and new Audit submissions immediately. Drafts are kept and can be reused after re-approval. Re-approval needs the full workflow again, with no penalty or waiting period.

9. Retention and Deletion of Minors' Data

We keep a minor's personal information only as long as needed for the purpose it was collected, and then delete it.

Records needed for safety, disputes, or a legal obligation may be kept for the required period. The Data Retention document has the full schedule.

10. Information Security Program

We keep a written information security program for personal information collected from children. It includes:

• a named security coordinator;
• an annual risk assessment;
• access controls, so that only staff who need minor data for support or safety can see it;
• encryption in transit and at rest;
• oversight of service providers, who must protect minor data and use it only to serve us; and
• an incident response plan, including notice to affected guardians where required by law.

11. Who Receives a Minor's Information

• The minor and the verified guardian.
• Authorized safety and support staff when needed.
• Service providers that host data, send email, secure the service, or run the private P3 Audit (see the Sub-Processors). The AI provider receives images only after the separate guardian consent in Section 5.

Brands, agencies, Stripe, and payment providers do not receive a minor's commercial or payment data, because minors have none.

12. Notifications to Guardians

We email the guardian about approval and rejection, upcoming expiry, policy violations, suspension and how to appeal, and deletion or export confirmations. A guardian may also ask who on our staff has accessed the minor's data. We answer within 7 business days, up to once per quarter.

13. Reporting a Problem

If a minor says "this is not my guardian" or that approval was coerced, email [email protected] or [email protected]. We suspend the approval, verify identity, and may require new approval. We suspend approval that proves fraudulent. Both the minor and the guardian can appeal under the Appeals policy.

14. Contact

Guardian questions and requests: [email protected]. Privacy questions: [email protected]. Mail: Secundino Fulgencio, P3RSON, Inc., P.O. Box 6178, Astoria, NY 11106, USA.