Children's Online Privacy Protection Act (COPPA) Compliance Statement

Effective Date: February 17, 2026

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1. Overview and Commitment

American Digital Education ("we," "us," or "our") is committed to protecting the privacy of children who use our K-12 educational technology platform. We comply fully with the Children's Online Privacy Protection Act of 1998 (COPPA), 15 U.S.C. sections 6501-6506, and the implementing regulations issued by the Federal Trade Commission (FTC), 16 C.F.R. Part 312.

American Digital Education provides AI-powered, standards-based K-12 video lessons in 32 languages. Our platform is designed to be used under the direct supervision of schools, districts, and teachers. Students access the platform only through their educational institution, and all student interactions are mediated by educators -- not directly by students acting independently.

2. Applicability of COPPA

COPPA applies to the online collection of personal information from children under the age of 13. Because American Digital Education serves K-12 students -- many of whom are under 13 -- we treat all student users as subject to COPPA protections, regardless of age.

3. School-Based Authorization (School Official Exception)

American Digital Education operates under the "school official" exception provided in the FTC's COPPA Rule. Under this model:

• Schools and school districts act as intermediaries and authorize student access to the platform on behalf of parents.
• By entering into an agreement with American Digital Education, the school or district represents that it has the authority to provide consent on behalf of parents for the educational purpose of using our platform.
• American Digital Education collects and uses student information solely for the educational purpose for which it was provided, and does not use it for any commercial purpose.

4. Student Data: What We Do Not Collect

By design, students do not have direct access to our support system or any data submission mechanisms. American Digital Education does not collect the following personal information directly from students:

• Full name or contact information
• Home address, phone number, or personal email address
• Social Security Number or government-issued ID
• Geolocation data beyond the school or district level
• Photos, videos, or audio recordings of individual students
• Persistent identifiers used to track students across third-party websites or online services

5. Information Collected Through Educational Institutions

To provide our educational services, American Digital Education may receive limited information through authorized school administrators and teachers, including:

• Student usernames or identifiers assigned by the school
• Grade level and class roster information
• Lesson completion and assessment performance data

This information is used exclusively to deliver, personalize, and improve the educational experience within the platform. It is never sold, rented, disclosed to third parties for commercial purposes, or used to build advertising profiles.

6. Support System Design and Student Privacy

Our enterprise-grade support system is architected to prevent student data from ever entering the support environment:

• Students cannot access the support system. All support requests are submitted by teachers or administrators on behalf of students.
• Automated scanning detects and warns against inclusion of student names, ID numbers, or other personally identifiable information in support tickets before submission.
• Required acknowledgment: Submitters must confirm that support tickets contain no student PII prior to submission.
• Administrator redaction tools are available to remove any student information inadvertently included in support records.

7. Data Security

American Digital Education employs industry-leading security measures to safeguard all data, including any information related to students:

• AES-256 encryption at rest for all stored data
• TLS 1.3 encryption in transit for all communications
• Multi-factor authentication and NIST 800-63B compliant authentication standards
• Role-based access controls ensuring organizational data isolation
• OWASP 2025 compliance protecting against SQL injection, cross-site scripting, and other known web security threats
• Comprehensive audit logging of all data access events

8. Data Retention and Deletion

American Digital Education retains student-related information only for as long as it is necessary to fulfill the educational purpose for which it was collected, or as required by applicable law. Upon termination of a school's or district's agreement with American Digital Education, student data associated with that institution will be securely deleted or returned to the institution in accordance with the terms of the applicable agreement.

9. Parental Rights

Parents and legal guardians of students under 13 retain the following rights under COPPA:

• Review any personal information collected from their child
• Request correction or deletion of their child's personal information
• Refuse to permit further collection or use of their child's information

To exercise these rights, parents should first contact their child's school or district, which administers platform access on their behalf. Parents may also contact American Digital Education directly using the contact information provided in Section 11 below.

10. Third-Party Disclosure

American Digital Education does not sell, rent, lease, or disclose student personal information to third parties for commercial or advertising purposes. We may share information with service providers who assist in platform operations only under strict contractual obligations to use data solely for the specified educational purpose and to maintain equivalent privacy protections.

11. Contact Us

For questions, concerns, or to exercise your rights under COPPA, please contact us:

We will respond to all COPPA-related inquiries within a reasonable timeframe and no later than 30 days from receipt.

12. Updates to This Statement

American Digital Education may update this COPPA Compliance Statement from time to time to reflect changes in our practices or legal requirements. We will post the updated statement on our website with a revised effective date. Schools and districts will be notified of material changes. Continued use of the platform following notice of changes constitutes acceptance of the updated statement.