Last updated: 2026-05-19 · Designated security personnel: Galen Oakes — privacy@guardnilu.com
COPPA Direct Notice
Effective date: 2026-05-08 · Version 1.0
This notice is provided to parents and legal guardians under the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506, and the FTC's implementing rule (16 C.F.R. Part 312), as amended effective April 22, 2024.
Who We Are
GuardNIL (operated by GuardNIL, LLC) is a family technology platform that enables parents to fund and manage simulated NIL (Name, Image, Likeness) allowance contracts for their student-athletes. Our designated privacy contact is Galen Oakes — privacy@guardnilu.com.
What Information We Collect from Children Under 13
- First name (entered by parent)
- Date of birth (entered by parent, used for age-gating only)
- Athletic performance data (entered by coach or parent)
- Academic performance data (entered by parent or coach)
- XP, streaks, achievements, and daily recovery logs (generated by platform use)
- Education module completion status
We do not collect school name for athletes under 13. We do not allow athletes under 13 to have direct login credentials. All access is parent-mediated.
How We Use This Information
- To operate the GuardNIL platform on the child's behalf
- To calculate incentive completions and payment eligibility
- To display progress to the parent and coach (within the platform only)
- To maintain records required by applicable law
We do notuse children's personal information for advertising. We do notsell children's personal information.
How We Share This Information
Information about children under 13 is shared only with:
- The parent or legal guardian (full access)
- The athlete's coach (limited to performance and schedule data)
- Supabase (database hosting, encrypted)
- Stripe (payment processing — no child data)
- Resend (email delivery — notification content only, to parent email)
AI features (Anthropic, Google) are not used for children under 13 without explicit parental consent obtained during onboarding.
We collect first-party page-view and form-interaction analytics on all platform pages (anonymous visitor ID, device fingerprint, country/city, page URL, scroll/dwell, form-field completion). This data is stored in our own Supabase instance, is not shared with third-party advertisers, and is auto-deleted after 90 days. See our Privacy Policy section 3 for the full field list. We are evaluating scoping the page tracker to marketing-only routes so it does not run on dashboard pages used on behalf of children under 13; track that work in our internal TODO 2026-05-10-analytics-privacy-alignment.
Parental Rights and Controls
As a parent or legal guardian, you have the right to:
- Review your child's personal information at any time by logging into your dashboard
- Correct inaccurate information through the dashboard or by contacting us
- Delete your child's information by requesting account deletion in Settings
- Refuse further data collection by closing the account (required records are retained per law)
- Revoke consent for specific third-party processors through the Privacy Settings page
Verifiable Parental Consent
Before creating an athlete profile for a child under 13, GuardNIL obtains verifiable parental consent via credit card micro-charge ($0.50) as permitted under the COPPA 2024 amendments. This charge is retained as a consent record and is not refunded.
Data Retention
Personal information collected from children is retained only as long as necessary to fulfill the purpose for which it was collected. Upon account deletion, child data is soft-deleted immediately and permanently deleted within 30 days, except for consent records (3 years) and financial records (7 years) as required by law.
Contact
To exercise parental rights or ask questions about this notice:
- Email: privacy@guardnilu.com
- Subject line: COPPA Parental Rights Request
- Response: within 45 days