LYWL Direct Notice to Parents — Children's Online Privacy Protection Act (COPPA)
This notice is provided pursuant to the Children's Online Privacy Protection Act, 15 U.S.C. §§6501–6506, and the FTC's COPPA Rule, 16 CFR Part 312, as amended (final rule effective June 23, 2025; full compliance required by April 22, 2026). Capitalized terms not defined here have the meanings given in the LYWL Terms of Service and Privacy Policy.
1. Why You Are Receiving This Notice
You are enrolling a child under the age of thirteen in LYWL's online tutoring program. Federal law requires us to give you direct notice of our data practices and to obtain your verifiable parental consent before collecting personal information from your child.
2. Information We Collect From or About Your Child
We collect:
- the child's first name (or initials, at your option);
- age or grade level;
- time zone;
- learning needs you provide so we can teach effectively, which may include a dyslexia or other learning-difference diagnosis you choose to share;
- reading-level placement and assessment scores produced by LYWL;
- session metadata: Zoom join and leave timestamps, attendance, instructor notes, work product (worksheets, reading samples);
- session recordings — recordings of regular instructional sessions are part of LYWL's standard service delivery, used for instructional improvement, parental review, dispute resolution, and tutor training. Enrollment in LYWL programs requires your consent to session recording at the time of enrollment; the consent is captured separately and granularly in the enrollment flow. You may withdraw consent prospectively at any time, in which case LYWL will end the program and refund unused sessions under the Terms of Service; and
- initial Assessment audio — for the initial reading assessment delivered through the LYWL enrollment portal, your affirmative permission grant to the browser microphone allows your child's reading to be captured by your device through the browser and transmitted with the written assessment answers for asynchronous review by LYWL's program lead. No file upload is required of you. You may decline the microphone permission, in which case the Assessment cannot be completed and the Assessment fee is refundable under the Terms of Service.
We do not collect from your child: full name (unless you provide it), street address, phone number, email address, social security or government identifiers, biometric identifiers, geolocation more precise than time zone, or persistent advertising identifiers.
3. How We Use Your Child's Information
Solely to:
- match the child to an appropriate tutor and small-group cohort;
- plan and deliver the tutoring sessions you have purchased;
- track progress and adjust instruction;
- communicate with you about scheduling and progress;
- train and supervise tutors using anonymized excerpts; and
- comply with law.
We do not use your child's personal information for advertising, profiling, sale, or any third-party purpose unrelated to the tutoring service.
4. How We Disclose Your Child's Information
We disclose limited information only to the service providers needed to run the program:
- the assigned tutor (an independent contractor under written confidentiality and Data Processing Agreement terms);
- Stripe (for processing the parent's Assessment and Tuition payments);
- BNPL Provider(s) — currently Affirm, Inc. and Klarna Bank AB; LYWL may add or substitute providers from time to time without renewed notice — to the extent the parent selects buy-now-pay-later financing at the Tuition step (the BNPL Provider collects only parent payment data, not child personal data);
- Zoom (to deliver and record the session);
- TutorBird (post-enrollment intake, scheduling, parent portal, recurring billing — receives child first name, age or grade, learning needs, scheduling data);
- Google Workspace (internal storage; tutors can see assigned students' profiles);
- gamma.app (only the form-submission data); and
- Calendly (parent name and email for scheduling).
These providers may use child data only to deliver service to LYWL under their Data Processing Agreement. We do not authorize their use of child data for their own purposes.
We do not disclose your child's information to advertisers, data brokers, or analytics vendors. We do not sell your child's data. We do not condition the child's participation on collection of any information that is not reasonably necessary.
5. Verifiable Parental Consent — How We Obtain It
Method. LYWL's enrollment funnel begins with a card-only Initial Reading Assessment Checkout session in Stripe ("Assessment Checkout"), which is a prerequisite for any program enrollment. At Assessment Checkout, two conditions are satisfied contemporaneously:
(a) you complete a credit-or-debit-card transaction for the Assessment fee (currently $197 list, with a standard promotional code yielding a $97 effective price). Buy-now-pay-later financing is not offered at this step, so the transaction is always carried on a card of record. This is the FTC's monetary-transaction method of VPC under 16 CFR §312.5(b)(2)(iii); and
(b) you affirm two unbundled consent checkboxes presented in the Assessment Checkout: (i) acceptance of the LYWL Terms of Service and (ii) acknowledgment of this Direct Notice and the LYWL Privacy Policy.
The combination — a card-of-record monetary transaction plus contemporaneous unbundled consents to the disclosed data practices — meets the "reasonable effort" verification standard.
Carry-forward of consent. Under 16 CFR §312.5(a)(1), VPC is required "before any collection, use, or disclosure" of a child's personal information. Once obtained at the Assessment Checkout for the disclosed data practices, the consent extends to all subsequent collection and use of that child's personal information for the same disclosed purposes. A subsequent Tuition transaction — whether by card or by a BNPL Provider — does not require a fresh VPC step, because the same operator (LYWL) is collecting personal information from the same child for the same data practices already disclosed in this Direct Notice.
If LYWL's data practices materially change in a way not disclosed here, LYWL will provide a new Direct Notice and obtain renewed VPC before applying the change (Section 10).
Why this method. The 2025 amendments codified knowledge-based authentication ("KBA") and facial-recognition with human review as additional approved VPC methods. The two-step funnel architecture renders KBA unnecessary at launch because every parent's first transaction with LYWL is a card transaction. KBA is preserved as a deferred contingency for future scenarios. Facial recognition was rejected on data-minimization grounds.
6. Your Rights as a Parent
At any time, by emailing info@learnyourwayliteracy.com with the subject line "COPPA," you may:
a. review the personal information we have collected from your child;
b. correct inaccurate information;
c. delete all or part of the personal information;
d. refuse further collection or use of the child's information (note: refusal may end our ability to continue providing the service, in which case unused sessions are refunded under the Terms of Service); and
e. withdraw consent previously given (for example, revoke recording permission).
We respond to COPPA review and deletion requests within ten business days. We may verify your identity before fulfilling, typically by confirming details from the account of record.
7. Retention
Retention periods are set out in the LYWL Privacy Policy Section 7 and apply equally to children's data, except that a parent's deletion request overrides default retention except where law requires retention (notably, the 7-year payment-records window).
8. No Sale, No Targeted Advertising
LYWL does not sell personal information of children, does not disclose children's personal information to third parties for targeted advertising, and does not allow third parties to use the LYWL platform to track children for advertising. Under the 2025 COPPA Rule amendments, separate VPC would be required for any such third-party disclosure; LYWL does not engage in those disclosures.
9. Safe Harbor Program
LYWL has evaluated enrollment in an FTC-approved COPPA Safe Harbor program (kidSAFE Seal Program; iKeepSafe). LYWL's substantive COPPA-compliance posture currently captures most of the diligence benefit. Safe Harbor enrollment will be revisited prior to application for state-funded education-spending-account vendor approval (target 2027–28 cycle) or as the operator otherwise determines.
10. Changes to This Notice
If LYWL materially changes its information practices for children under thirteen, LYWL will provide a new direct notice and obtain renewed VPC before applying the change.
11. Where to File a Complaint
If you believe we have violated COPPA, you may contact:
- LYWL: info@learnyourwayliteracy.com
- Federal Trade Commission: ftc.gov/complaint or 1-877-FTC-HELP
Citations
- COPPA statute: 15 U.S.C. §§6501–6506
- COPPA Rule: 16 CFR Part 312
- VPC methods: 16 CFR §312.5(b)
- Monetary-transaction VPC: 16 CFR §312.5(b)(2)(iii)
- Direct Notice content: 16 CFR §312.4(c)
- Privacy Policy content for children's data: 16 CFR §312.4(d)
- Retention limit: 16 CFR §312.10 (as amended 2025)
- Separate VPC for third-party disclosures: 16 CFR §312.5(a)(2) (as amended 2025)