James Scott Brown Foundation
Compliance

Children's Privacy Policy

Effective Date: April 20, 2026

1. Scope of Document

This Children's Privacy Policy ("Policy") describes the specific protections the James Scott Brown Foundation ("JSBF," "Foundation," "we," "us," or "our") implements when processing personal data of individuals under the age of eighteen (18) ("Minors" or "Children") through the JSBF Legal Intelligence Platform at jamesscottbrownfoundation.com (the "Platform"). This Policy supplements the Foundation's general Privacy Policy and applies specifically to data collected from or about Children, including individuals who are the subject of child protection cases processed through the Platform.

2. Definitions

  • "Child" or "Minor" refers to any individual under the age of eighteen (18) years. For the purposes of data collection requiring parental consent under the Children's Online Privacy Protection Act (COPPA), this includes any individual under the age of thirteen (13).
  • "Parent or Guardian" refers to a child's parent, legal guardian, or other individual with legal authority to consent on behalf of the child.
  • "Verifiable Parental Consent" refers to consent obtained from a Parent or Guardian through a method reasonably calculated to ensure that the person providing consent is the child's parent or guardian.
  • "Child Protection Data" refers to personal data related to child abuse or exploitation cases processed through the Platform's legal intelligence services, which may include information about child victims.

3. Age Restrictions and Parental Consent

The Platform is not directed at children under the age of thirteen (13). The Foundation does not knowingly collect personal information directly from children under thirteen without Verifiable Parental Consent. If the Foundation becomes aware that it has collected personal information from a child under thirteen without appropriate parental consent, it will take prompt steps to delete such information.

For Minors between the ages of thirteen (13) and seventeen (17), the Foundation requires parental or guardian consent before the Minor may submit personal information through the Platform. For Minors located within the European Economic Area, the applicable age of digital consent is sixteen (16) years, and parental consent is required for individuals below that age.

Parental consent may be obtained through the following methods:

  • A signed consent form submitted by the Parent or Guardian through the Platform.
  • Electronic consent provided by the Parent or Guardian through a verified email address.
  • Other methods reasonably calculated to ensure that the consenting individual is the child's Parent or Guardian.

4. Information Collected from or About Children

The Foundation may collect the following categories of information from or about Children in the course of its operations:

4.1 Child Protection Case Data

In the course of providing legal intelligence services to nonprofit organizations working on child protection cases, the Platform may process information about child victims. This information is submitted by authorized organizational users, not by Children directly. The Foundation implements enhanced security and access controls for all Child Protection Data.

5. Use of Children's Data

The Foundation uses Children's personal data only for the following purposes:

  • Providing legal intelligence services related to child protection cases, as requested by authorized organizational users.
  • Communicating with Parents or Guardians regarding their child's interactions with the Platform, where applicable.
  • Complying with applicable legal obligations, including mandatory reporting requirements related to child abuse and exploitation.

The Foundation does not use Children's personal data for marketing, advertising, behavioral profiling, or any purpose unrelated to the specific service for which the data was collected.

6. Parental and Guardian Rights

Parents and Guardians have the following rights with respect to their child's personal data:

  • Right to Review: Parents or Guardians may request to review the personal information the Foundation has collected from their child.
  • Right to Deletion: Parents or Guardians may request deletion of their child's personal information, subject to legal retention requirements (including mandatory reporting obligations).
  • Right to Refuse Further Collection: Parents or Guardians may refuse to permit further collection of their child's personal information. This may result in the child's inability to participate in certain programs.
  • Right to Withdraw Consent: Parents or Guardians may withdraw their consent for the processing of their child's personal data at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.
  • Right to Portable Copy: Parents or Guardians may request a copy of their child's personal data in a structured, machine-readable format.

To exercise any of these rights, Parents or Guardians should submit a request through the Contact page. The Foundation will verify the identity and authority of the requesting party before processing the request.

7. Foundation Rights and Enhanced Protections

The Foundation implements the following enhanced protections for Children's data:

  • Restricted Access: Access to Children's personal data is limited to authorized Foundation personnel with a legitimate need to access the data for the purposes described in this Policy.
  • Enhanced Security: Children's data is subject to additional encryption, access logging, and monitoring measures beyond those applied to general user data.
  • Data Minimization: The Foundation collects only the minimum amount of Children's personal data necessary for the stated purpose.
  • Retention Limits: Children's personal data is retained only for the minimum period necessary to fulfill the purpose for which it was collected, subject to legal retention requirements.
  • No Third-Party Sharing: Children's personal data is not shared with third parties except as necessary to provide the requested services, comply with legal obligations, or protect the safety of a child.
  • Mandatory Reporting: The Foundation complies with all applicable mandatory reporting laws regarding suspected child abuse or exploitation. Where the Foundation becomes aware of information indicating that a child is at risk of harm, it will report such information to the appropriate authorities regardless of other privacy obligations.

8. Compliance

This Policy is designed to comply with applicable laws governing the privacy of children's personal data, including the Children's Online Privacy Protection Act (COPPA) in the United States, the General Data Protection Regulation (GDPR) provisions regarding children's data in the European Economic Area, and other applicable child data protection laws. The Foundation regularly reviews its practices to ensure ongoing compliance with evolving legal requirements.

9. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, JSBF SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM THE PROCESSING OF CHILDREN'S PERSONAL DATA IN ACCORDANCE WITH THIS POLICY. THIS LIMITATION DOES NOT APPLY WHERE PROHIBITED BY MANDATORY CHILD PROTECTION OR DATA PROTECTION LAWS THAT PROVIDE FOR SPECIFIC LIABILITY STANDARDS.

The Foundation is not liable for the accuracy or completeness of information submitted by Parents, Guardians, or authorized organizational users on behalf of Children.

10. Governing Law and Jurisdiction

This Children's Privacy Policy shall be governed by and construed in accordance with the laws of the United States of America, including the Children's Online Privacy Protection Act (COPPA), and the applicable laws of the jurisdiction in which the Foundation is organized. For Children located within the European Economic Area, this Policy is intended to comply with the applicable provisions of the GDPR regarding children's data.

11. Updates and Modifications

JSBF reserves the right to update this Children's Privacy Policy at any time. Changes will be reflected by an updated "Effective Date" at the top of this page. Where material changes affect the processing of Children's data, the Foundation will make reasonable efforts to notify Parents or Guardians of affected Children.

12. Contact Information

For questions regarding Children's privacy, parental consent, or this Policy, please contact the Foundation through the Contact page on our website. The Foundation is committed to addressing all inquiries related to Children's privacy promptly and thoroughly.