COPPA Children's Privacy Notice

This notice explains how SHPRD handles personal information from children under 13 in the SHPRD student experience, and how a parent or legal guardian can review that information, ask us to delete it, or refuse to let us collect or use any more of it. It is written to meet the U.S. Children's Online Privacy Protection Act (COPPA) and its rule, 16 CFR Part 312. Our full Privacy Policy covers everyone else.

1. Who operates this service, and how to reach us

The SHPRD service is operated by SHPRD LLC, c/o Northwest Registered Agent Service, Inc., 212 W. Troy St. STE B, Dothan, AL 36303, (251) 273-1466, coppa@shprd.life. A parent may contact us at any time about their child's information using any of these.

SHPRD is the "operator" under COPPA for the SHPRD student experience, including the information a child provides at check-in. SHPRD — not the ministry organization — gives parents the direct notice and obtains verifiable parental consent. A ministry organization cannot give consent on a parent's behalf.

Each participating ministry organization is responsible for the ministry records its own adult leaders and administrators keep (rosters, attendance, pastoral notes, and similar). For those records the organization decides why information is collected and how it is used, and SHPRD handles them only on the organization's instructions. This is the same split described in our Privacy Policy.

2. Information we collect from children under 13

In the student experience (only after a parent gives verifiable consent):

• first and last name, and grade;
• date of birth;
• an optional profile picture (avatar);
• an optional recovery email address, to help the child sign back in;
• a weekly one-tap mood emoji;
• optional written weekly reflections;
• optional prayer-request text the child writes;
• optional lesson ratings;
• event sign-ups.

Collected automatically:

• a hashed session token and a session cookie that keep the child's device signed in to the student experience;
• if the child turns on notifications, an Apple or Google push token, plus the app version and build, time zone, and device platform;
• IP address and browser user-agent, recorded only during account-recovery or security events;
• redacted crash and performance diagnostics, and server request logs.

We use no third-party analytics or advertising software in the student experience, and the automated bot check does not run on the student check-in screen.

Recorded at check-in, before we contact a parent:

When a child checks in at a ministry gathering and we determine the child is under 13, we record the child's first and last name, grade, and date of birth, the fact and time of the check-in, and we create a device session — so the ministry has an attendance record. We then immediately ask for a parent's contact information. The child cannot use any other part of SHPRD until a parent gives verifiable consent. The attendance record is the ministry organization's own record of who attended its gathering, kept on the organization's instructions. If a parent does not consent, we de-identify this information as described in section 7.

Recorded by adult ministry leaders about the child:

Ministry leaders keep attendance and check-in history, follow-up flags, pastoral notes, and see automated "signals" — short summaries of attendance and mood trends, and an indication that a child may be seeking prayer. These are visible only to the child's assigned leaders and the ministry's administrators, and are part of the ministry organization's records.

We do not let a child make information public. The student experience has no public profile and no public-sharing feature; a child's reflections and prayer requests are seen only by the assigned leader.

3. How we use it

We use a child's information to:

• run check-in and the student experience, and record attendance and streaks;
• deliver the weekly reflection and mood check;
• route a child's prayer requests to their assigned leader for pastoral care;
• show lessons;
• send only the notifications the child turned on;
• keep the child's device signed in and help recover access;
• keep the service secure and diagnose crashes.

We do not use children's information for advertising. We do not sell it. We do not use it for cross-context behavioral advertising, and SHPRD shows no third-party advertising. We do not use prayer content for advertising.

4. Who we share it with

We share a child's information only as described here. Each provider acts only on SHPRD's instructions to provide, secure, and maintain the service, and may not use the information for its own purposes. The current named list of providers is in our Privacy Policy.

We also disclose information if the law requires it, to protect someone's safety, and to a successor in a merger or acquisition, with confidentiality protections.

5. We do not require unnecessary information

SHPRD does not make a child give more personal information than is reasonably necessary to check in and take part in ministry activities. A child is counted present by giving only a first name and grade. Writing a reflection or a prayer request, choosing an avatar, adding a recovery email, and turning on notifications are all optional and are not required to participate. We ask for date of birth so we can run the age screen and apply the protections this notice describes; we do not ask a child under 13 for a phone number at check-in. If a child under 13 is locked out of their profile, the one-time recovery code is texted to their parent's phone, not the child's.

6. A parent's rights, and how to use them

A parent or legal guardian may, at any time:

• Review the personal information we have collected from their child;
• Delete or permanently de-identify it; and
• Refuse to allow any further collection or use of it.

To do any of these, a verified parent can use the SHPRD parent portal (Data & Permissions) or write to coppa@shprd.life. We confirm the requester is the child's parent before we act. We carry out verified requests, with the help of the child's ministry, within 30 days. For a review request we provide a copy of the child's information.

Refusing further collection ends the child's use of the SHPRD student experience. A parent can also do this in the parent portal by withdrawing consent. Further collection through the child's own use of SHPRD stops right away. Ministry staff may continue to keep the organization's own attendance and pastoral records unless a parent also asks the ministry organization to stop.

Consent covers the whole SHPRD student experience. A parent gives or withholds it as a whole and may withdraw it at any time; SHPRD does not offer separate per-feature switches.

7. If a parent does not consent

If a parent does not give verifiable consent within 30 days after we first ask, SHPRD deletes or permanently de-identifies the information collected from the child at check-in: the child's name, date of birth, and any phone number are cleared, and the check-in record is scrubbed of the child's name. We keep only a record that consent was requested and what happened. We aim to delete, on the same timeline, the parent contact information we collected solely to ask for consent.

8. How long we keep information

• The check-in information in section 2: de-identified 30 days after the check-in if consent does not follow.
• If consent is withdrawn: the child's personal information is de-identified within a short window (about 7 days), keeping only the record that consent was withdrawn.
• While a child takes part with consent: for as long as the ministry uses SHPRD, plus a limited wind-down period. A parent can ask for earlier deletion at any time (section 6).

When we "delete" a child's information we permanently de-identify it — we remove the name, date of birth, grade, contact details, and anything the child created, and sever the record from the child's group so what remains cannot reasonably be linked back to the child. SHPRD does not attempt to re-identify de-identified records and does not disclose them.

A few records are kept afterward, each for a specific legal reason:

• The consent record — that a parent gave or withdrew consent, when, and how — to show we met our COPPA obligations. The signed consent document is itself emptied of the child's and parent's names and the signature on a delete request; only the fact, date, and method remain.
• The ministry organization's own attendance and pastoral records — the organization's records, kept on its instructions, not SHPRD's to delete.
• Payment, tax, and dispute records — up to seven years under tax and accounting law.

9. How a parent gives consent

A parent gives verifiable consent by completing the consent form in the SHPRD parent portal — providing their name and relationship to the child and signing electronically. SHPRD then sends a confirmation email to the parent's address (the same address the ministry used to invite them, which the parent has already used to sign in). That email states what was consented to and lets the parent withdraw consent at any time. SHPRD records the consent once the confirmation email has been sent.

If a parent cannot receive the confirmation email, a ministry leader who knows the family can verify the parent's signed consent form instead.

A parent can never consent by simply checking a box. SHPRD keeps a signed, dated record of the consent.

10. Changes to this notice

We may update this notice as SHPRD changes. We will post the new version, update the date above, and give parents additional notice before a material change affects information already collected under a prior consent. Questions and requests may be sent to coppa@shprd.life, or to c/o Northwest Registered Agent Service, Inc., 212 W. Troy St. STE B, Dothan, AL 36303, or by phone at (251) 273-1466.