Verifiable parental consent method
FTC-approved credit-card $0.01 authorization (refunded immediately) + signed digital acknowledgment. Consent record stored with timestamp + IP address + browser fingerprint. Alternative methods (notarized form, video conference) available for parents without credit cards.
Data minimization scope
Collected from under-13 learners: display name, age band (NOT exact birthdate), preferred name + pronouns (optional), target language, learning goals (parent-reviewed free text), lesson recordings (only when parent + tutor explicitly opt in). Never collected: exact birthdate, home address, phone, photo, geolocation, social media handles, real-name school identifier.
Parental access + visibility
Parents see every lesson, every homework, every gradebook entry, every parent-tutor message thread via the /parent multi-child portal. Single sign-in covers all children. Real-time visibility, not after-the-fact reporting.
Annual re-affirmation flow
Consent re-affirmed annually using the same credit-card + acknowledgment method. Reminders at 30/14/1 days before expiry. If consent lapses, lessons auto-pause within 24 hours of expiry; resume immediately on re-consent.
Data deletion + right to be forgotten
Parents can revoke consent at any time via /parent/consent. Revocation pauses lessons within 24h; PII deletion completes within 30 days. Aggregate de-identified metrics that have lost the identifier are retained for accreditation/longitudinal purposes.
Direct notice flow
On first sign-up, parents receive a direct notice (separate page from the privacy policy) covering: what data we collect, why we collect it, who sees it, how to delete it, and the FTC complaint URL (https://www.ftc.gov/complaint). Direct notice exists so parents who skim the privacy policy still see the COPPA-specific terms.
Audit trail + FTC inquiry response
All consent + revocation + access events logged in a tamper-evident audit log. In the event of an FTC inquiry, Koydo can produce the full consent + access + deletion timeline for any specific learner within 24 hours of request.