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 would approve and control a teen account if guardian approval is offered, and how we follow the Children's Online Privacy Protection Act and the FTC's COPPA Rule, as amended.
| Age | What happens |
|---|---|
| Under 13 | No account. If we find an account that belongs to a person under 13, we suspend and lock it. We keep only what we need to keep that account locked (Section 9). We delete the child's other personal information when a parent or guardian asks, and as the Data Retention document states. A guardian cannot authorize an under-13 account. |
| 13 to 17 | Read-only. Guardian approval is not available in this version. No monetization of any kind. |
| 18 and over | Full access after adult eligibility checks. |
2. How We Determine Age
We set an account's age tier from these signals:
- 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.
- Apple Declared Age Range. Where your iPhone supplies it, we read Apple's Declared Age Range signal. Apple shares an age range, not a date of birth. We use the range only to confirm adult or minor status and, where the app offers it, to review an account that was locked as under 13 from a date of birth entered on that account. We allow one such review for each account. We never use the range to work out an exact age. Apple's age range prompt needs iOS 26 or later.
- Guardian verification. If guardian approval is offered, a guardian verifies each 13 to 17 account by email code and a signature record (Section 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, we lock it. If we learn that the age on an account was misdeclared, we restrict it. You confirm your date of birth when you create your account, and you cannot change it in the app afterwards. If you entered it by mistake, email support@p3rson.com. A person reviews the request. We cannot promise a result. Where the app offers it, you may also be able to use Apple's age range prompt to review an under-13 lock (item 2 above). 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. Guardian approval is not available in this version of the app. Members aged 13 to 17 have a read-only experience. They can view content and use safety and settings features. They cannot post, like, follow, send messages, buy or hold P3 Coins, buy P3 Pro, or use the private P3 Audit. No one under 18 can use any monetization feature.
If guardian approval is offered later, it will be shown in the app. The terms that describe it apply only from the date the app shows it as available to you.
If guardian approval is offered: a minor with active guardian approval could post and could 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 guardian 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 advertising to minors or accounts whose adult age status is unknown. 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
Guardian approval is not available in this version of the app. This Section and Sections 5 and 6 describe how it would work if it is offered, and they apply only from the date the app shows it as available to you.
- The minor opens the approval screen in the app and enters the guardian's name, email, and relationship.
- We email the guardian a 6-digit code. The code expires in 24 hours. After five wrong attempts, entry locks for 30 minutes.
- The guardian enters the code (or opens the link in the email). This proves access to that email address.
- 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.
- We record the approval: guardian email, time, device, document versions, and a hash of the signature (we do not store the raw signature).
- 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
This Section applies only if and when guardian approval and the private P3 Audit for minors are offered. In this version, no minor's image is sent to an 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:
| Right | How |
|---|---|
| Review the personal information we hold about the minor | Email guardian-support@p3rson.com |
| Delete the minor's information and account | Same |
| Refuse further collection or use | Revoke approval, or email guardian-support@p3rson.com |
| Revoke approval or the AI-provider consent, if guardian approval is offered | Email guardian-support@p3rson.com; takes effect immediately |
Email guardian-support@p3rson.com 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.
| Data | Kept | Then |
|---|---|---|
| Account, profile, posts | While the account is open | Deleted within 30 days of a deletion request; backups within a further 30 days |
| Digitals images and private Audit results | Until the guardian or member deletes them or the account is deleted; always destroyed no later than 3 years after the last interaction with the account, unless a longer period is required by law or a legal hold applies | Deleted on the same schedule as above |
| Guardian invitation codes | Until used or 24 hours | Deleted |
| Guardian approval and consent records | 7 years | Deleted |
| Safety and moderation records | 3 years | Deleted |
| Locked under-13 accounts | We keep the account ID, the date of the lock, a one-way (hashed) form of the sign-in email and phone number so the same details cannot open another account, the date of birth that was entered, and a record of any review, for as long as the lock is in place, or longer where the law requires | Deleted |
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 guardian-support@p3rson.com or moderation@p3rson.com. 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: guardian-support@p3rson.com. Privacy questions: privacy@p3rson.com. Mail: Dino Fulgencio, P3RSON, Inc., 348 West 57th Street #257, New York, NY 10019, USA.