COPPA Compliance Addendum

STATUS: DRAFT. This document has not been reviewed by licensed counsel. It describes how Sparkshed actually behaves today and is published so that behaviour is inspectable, but it is not legal advice and it is not a finished agreement. See the counsel review packet for what is still outstanding.

COPPA compliance statement

Sparkshed is designed to be usable by learners of all ages, including children under 13. We take our obligations under the Children's Online Privacy Protection Act (COPPA) seriously.

Our approach

1. Self-declared age gate: On first visit, users are asked whether they are 13 or older. This is a self-declared gate, not identity verification. We do not collect government IDs or parent contact information through this gate.

2. Under-13 mode: Users who identify as under 13 get no sign-in option, so their projects cannot be uploaded and stay in the browser's local storage. No telemetry events are collected. No personal information is requested or stored. Public community content remains viewable read-only.

3. No persistent identifiers: We do not use cookies, device fingerprinting, or IP-address tracking for analytics on any users. Cloudflare Web Analytics is cookieless and does not track individual users.

4. No behavioral advertising: We do not serve advertisements and do not track users for advertising purposes.

5. Classroom mode: In educator-led classrooms, teachers manage student access. Students use anonymous handles. Teachers cannot see students' personal information beyond the anonymous handle.

Parental rights

Under COPPA, parents have the right to: review the personal information collected from their child, refuse further collection or use, and request deletion of their child's information.

To exercise these rights, contact privacy@sparkshed.dev with the subject "COPPA Parental Request."

Data minimization

For under-13 users, we collect only: (a) the fact that the age gate was answered 'under 13' (stored in browser localStorage, never transmitted), and (b) the circuit designs the user creates (stored in browser IndexedDB, never transmitted).

No email addresses, names, locations, or other personal information is requested from under-13 users.

Teacher/educator consent

For classroom use, we comply with the FTC's guidance on COPPA and schools: teachers may consent on behalf of parents for the use of educational technology in the classroom context, where the tool is used solely for educational purposes and collects only the information necessary for that purpose.