Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1 – Interpretation and Definitions

1.1 – Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in the singular or in the plural.

1.2 – Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
• Application means the software program provided by the Company or Operator downloaded by You on any electronic device, named Todaydream.
• Business refers to the Company or Operator as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Todaydream, Inc., 1 East Erie St, Suite 525-4233, Chicago, IL 60611. For the purpose of the GDPR, the Company or Operator is the Data Controller.
• Consumer refers to You.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to United States of America.
• Data Controller, for the purposes of the GDPR, refers to the Company or Operator as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• DreAmbassador refers to a professional who shares their story with youth through our platform.
• DreamU™ refers to our AI-powered career development service that combines personalized career guidance with AI literacy education.
• Educational Institution means a school, school district, or other formal educational entity that contracts with Todaydream to provide services to students.
• Minor refers to anyone under the age of 18. Our services have different age requirements: 18+ for the main platform and 13+ for DreamU™ (with appropriate consent for users 13-17).
• Operator (referred to as either "the Operator", "We", "Us" or "Our" in this Agreement) refers to Todaydream, Inc.
• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• ProVision® refers to our community of DreAmbassadors—professionals envisioning a brighter future together.
• Sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Application or the Website or both, including all Todaydream®, ProVision®, and DreamU™ initiatives.
• Service Provider means any natural or legal person who processes the data on behalf of the Company or Operator.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Todaydream® refers to our core initiative that connects youth with diverse, inspiring professionals.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• Website refers to Todaydream, accessible from https://www.todaydream.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2 – Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: contact@todaydream.com
• By mail: Todaydream, Inc., 1 East Erie St, Suite 525-4233, Chicago, IL 60611

3 – Collecting and Using Your Personal Data

3.1 – Types of Data Collected

3.1.1 – Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Bank account information (for DreAmbassadors)
• Credit card number and expiration date (for paid services)
• Educational information (for students, such as grade level, school, interests)
• Professional information (for DreAmbassadors, such as industry, job title, experience)
• Usage Data

3.1.2 – Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

3.1.3 – Information from Third-Party Social Media Services

The Company or Operator may allow You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Facebook
• Twitter
• LinkedIn
• Apple

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

3.1.4 – DreamU™ AI-Generated Data

When you use our DreamU™ AI services, we collect additional information to provide and improve personalized career guidance, including:

• Interactions with our AI systems
• Career interests and goals
• Responses to AI-generated content
• Learning progress and engagement data
• AI session history
• Content you create or upload during AI sessions

This information helps personalize your experience and improve our AI services. While we strive to provide accurate, appropriate, and helpful AI-generated content, you acknowledge that:

• AI technology is evolving and may not always produce complete or accurate information
• Todaydream does not guarantee the suitability of AI-generated content for any particular educational purpose
• Users (or parents/guardians/educators for minor users) are responsible for reviewing AI-generated content and determining its appropriateness
• Users should exercise independent judgment when acting on AI-generated advice or guidance

We take particular care to protect data from users between 13-17 years of age and implement additional safeguards for these users. For users under 13, we only collect information through educational institutions that have executed our Educational Institution Data Privacy Addendum, or with verifiable parental consent in compliance with COPPA.

Our AI systems utilize technical processes to analyze your interactions and generate personalized responses. This processing includes:

• Natural language processing to understand your queries and provide relevant career guidance
• Pattern recognition to identify career interests and learning preferences
• Recommendation algorithms to suggest career pathways aligned with your interests
• Personalization models that adapt content complexity based on your age and educational level

We utilize services from companies such as Circle and Pickaxe to help deliver our DreamU™ features. These are established AI service providers that we have selected after evaluating their privacy practices and security measures. When we use these services:

• We only share the data necessary to provide the specific AI functionality
• We maintain control over user data and how it is processed through our configuration of these services
• We regularly review their privacy policies and terms of service to ensure compatibility with our privacy commitments
• We implement appropriate technical and organizational measures to protect data processed through these services

3.1.5 – Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company or Operator to count users who have visited those pages or opened an email and for other related application or website statistics.

Cookies can be "Persistent" or "Session" Cookies. We use both Session and Persistent Cookies for the purposes set out below:

3.2 – Use of Your Personal Data

The Company or Operator may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication.
• To provide You with news, special offers and general information about other goods, services and events which we offer.
• To manage Your requests: To attend and manage Your requests to Us.
• To deliver targeted advertising to You.
• To support and improve DreamU™ AI services.
• For business transfers.
• For other purposes: data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service.

3.2.1 – Special Considerations for DreamU™ AI Services

When you use our DreamU™ AI services, we process your information to:

• Provide personalized career guidance based on your grade level, interests, and background
• Adapt content complexity based on your age group (13-15, 16-18)
• Generate career exploration recommendations through our AI systems
• Create simulated mentorship experiences through the Dream You™ AI Mentor
• Improve our AI models through anonymized and de-identified data
• Deliver age-appropriate content and guidance

IMPORTANT DISCLAIMER: While we strive to provide accurate, appropriate, and helpful AI-generated content, you acknowledge and agree that AI technology is evolving and imperfect.

3.2 – Information Sharing

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service.
• For business transfers: We may share or transfer Your personal information in connection with any merger, sale of Company or Operator assets, financing, or acquisition.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With educational institutions: For student users, we may share information with authorized educational institutions.
• With other users: when You share personal information or otherwise interact in the public areas with other users.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We implement additional safeguards for users aged 13-17, including:

• Age-appropriate content filtering
• Limited data collection and retention
• Parental/guardian consent mechanisms
• Educational institution supervision options
• Restricted third-party data sharing

3.3 – Retention of Your Personal Data

The Company or Operator will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

For minor users (13-17) of DreamU™, we implement shorter retention periods for personal data beyond what's necessary for providing the service.

3.4 – Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's or Operator's operating offices and in any other places where the parties involved in the processing are located. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

3.5 – Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. For underage users (13-17), parents or legal guardians may request the deletion of personal information about their child or ward by contacting us directly.

3.6 – Disclosure of Your Personal Data

3.6.1 – Business Transactions

If the Company or Operator is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

3.6.2 – Law Enforcement

Under certain circumstances, the Company or Operator may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

3.6.3 – Other Legal Requirements

The Company or Operator may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing, protect the personal safety of users or the public, or protect against legal liability.

3.7 – Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

We implement enhanced security measures for information related to minor users (13-17) and take additional precautions when processing data through our DreamU™ AI services, including encryption, access controls, and regular security audits.

3.7.1 – Data Breach Notification

In the event of a data breach that affects your Personal Data, we will notify you and the appropriate regulatory authorities in accordance with applicable law. We will:

• Promptly investigate the breach and take measures to contain and mitigate any potential harm
• Notify affected users within 72 hours of discovering a breach that is likely to result in a high risk to their rights and freedoms
• Provide clear information about the nature of the breach, the types of data affected, the potential consequences, and the measures we are taking to address the breach
• Offer appropriate guidance to help protect you from potential adverse effects of the breach

3.8 – Educational Privacy and FERPA Compliance

When we collect or maintain student education records in connection with educational institutions that receive federal funding, we comply with the Family Educational Rights and Privacy Act (FERPA). The following terms apply:

1. Use of Education Records

• We only use education records for legitimate educational purposes authorized by the partnering educational institution.
• We collect, use, maintain, share, and retain student personal information only for purposes for which we were authorized.
• We maintain student education records with appropriate administrative, technical, and physical safeguards.

2. Responsibilities and Compliance

• Educational institutions bear primary responsibility for FERPA compliance.
• Educational institutions are responsible for obtaining any necessary consents or providing any required notices under FERPA.
• Educational institutions are responsible for responding to parent/eligible student requests to access, correct, or delete education records.

3. Parental/Student Rights Implementation

• We acknowledge that parents/eligible students have the right to access and review their education records.
• Upon request from the educational institution, we will facilitate access to student records.
• We will work with educational institutions to correct inaccurate or misleading information when properly requested.
• Parents/eligible students may request deletion of student data through their educational institution.

4. Disclosure Controls

We do not disclose education records to third parties except:

• As authorized by the educational institution.
• To our service providers, who must protect education records subject to their confidentiality and security requirements.
• As required by law or valid legal process.
• In connection with a health or safety emergency, in accordance with FERPA provisions.

5. "School Official" Designation

When partnering with educational institutions, we may be designated as a "school official" with a "legitimate educational interest" in accordance with FERPA when we:

1. Perform an institutional service or function for which the school would otherwise use employees
2. Are under the direct control of the school with respect to the use and maintenance of education records
3. Use education records only for authorized purposes and do not redisclose personally identifiable information without consent

4 – Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

4.1 – Analytics

We may use third-party Service providers to monitor and analyze the use of our Service, including:

• Google Analytics – a web analytics service offered by Google that tracks and reports website traffic. Privacy Policy
• Matomo – a web analytics service. Privacy Policy
• Fathom – a web analytics service. Privacy Policy

4.2 – Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

• Mailchimp – an email marketing sending service provided by The Rocket Science Group LLC. Privacy Policy

4.3 – Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect Your payment card details. These payment processors adhere to the standards set by PCI-DSS.

• Stripe – Privacy Policy
• PayPal – Privacy Policy

4.4 – Behavioral Remarketing

The Company or Operator uses remarketing services to advertise to You after You accessed or visited our Service. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites or apps
• Measure and analyze the performance of Our advertising campaigns

You can use the following third-party tools to decline the collection and use of information for interest-based advertising:

• The NAI's opt-out platform: networkadvertising.org
• The EDAA's opt-out platform: youronlinechoices.com
• The DAA's opt-out platform: aboutads.info

The third-party vendors We may use include:

• Google Ads (AdWords) – Privacy Policy
• Twitter – Privacy Policy
• Facebook / Meta – Privacy Policy
• Pinterest – Privacy Policy

4.5 – Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service, including:

• Intercom – Privacy Policy
• Facebook Messenger – Privacy Policy
• Zendesk – Privacy Policy
• Circle – Privacy Policy
• Pickaxe – Privacy Policy

5 – Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

6 – GDPR Privacy

6.1 – Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation.
• Vital interests: Processing Personal Data is necessary to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task carried out in the public interest.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company or Operator.

6.2 – Your Rights under the GDPR

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data.
• Request correction of the Personal Data that We hold about You.
• Object to processing of Your Personal Data.
• Request erasure of Your Personal Data.
• Request the transfer of Your Personal Data.
• Withdraw Your consent.

6.3 – Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

7 – CCPA, CalOPPA, and California Privacy Rights

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

7.1 – Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months:

• Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers. Collected: Yes.
• Category B: Personal information (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, address, telephone number, education, employment, bank account number, credit card number, etc. Collected: Yes.
• Category C: Protected Classification Characteristics. Examples: Age, race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, sex, sexual orientation, veteran or military status, genetic information. Collected: Yes, but only if voluntarily provided.
• Category D: Commercial Information. Examples: Records and history of products or services purchased or considered. Collected: Yes.
• Category E: Biometric Information. Limited to behavioral patterns and interaction data used by our DreamU™ AI systems. We do not collect traditional biometric identifiers such as fingerprints or facial recognition data. Collected: Yes.
• Category F: Internet or Other Similar Network Activity. Examples: Interaction with our Service or advertisement. Collected: Yes.
• Category G: Geolocation Data. Examples: Approximate physical location. Collected: Yes.
• Category H: Sensory Data. Examples: Audio, electronic, visual, or similar information (such as recorded sessions from DreAmbassadors when permission is granted). Collected: Yes.
• Category I: Professional or Employment-Related Information. Examples: Current or past job history or performance evaluations. Collected: Yes, specifically for DreAmbassadors.
• Category J: Non-Public Education Information (FERPA). Examples: Education records directly related to a student maintained by an educational institution. Collected: Yes, when provided by educational institutions with appropriate consent.
• Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: Yes, particularly for DreamU™ AI service personalization.

7.2 – Sources of Personal Information

We obtain the categories of personal information listed above from the following sources:

• Directly from You
• Indirectly from You (e.g., from observing Your activity on our Service)
• Automatically from You (e.g., through cookies)
• From Service Providers
• From Educational Institutions
• From DreAmbassadors

7.3 – Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include:

• To operate our Service and provide You with our Service
• To provide You with support and respond to Your inquiries
• To fulfill or meet the reason You provided the information
• To deliver personalized career guidance through our DreamU™ AI services
• To connect students with appropriate DreAmbassadors
• To respond to law enforcement requests and as required by applicable law
• For internal administrative and auditing purposes
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity

7.4 – Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes: Categories A, B, C, D, F, G, H, I, J, and K.

7.5 – Sale of Personal Information

We may sell and may have sold in the last twelve (12) months the following categories of personal information: Categories A, B, D, and F.

7.6 – Share of Personal Information

We may share Your personal information with the following categories of third parties:

• Service Providers
• Payment processors
• Our affiliates
• Our business partners
• Educational institutions
• DreAmbassadors (only information necessary for mentorship connections)
• Third party vendors to whom You or Your agents authorize Us to disclose Your personal information

7.7 – Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 13 through our Service. For users between 13-16 years of age who use our DreamU™ services:

• We do not sell the personal information of users between 13-16 years of age unless we receive affirmative authorization ("right to opt-in") from the user, or in the case of users under 16, from their parent or guardian.
• If a minor opts-in to the sale of personal information, they (or their parent/guardian) may opt-out of future sales at any time.
• We implement additional safeguards to protect the privacy of these young users.

7.8 – Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information, including:

• The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
• The right to request. Under the CCPA, You have the right to request that We disclose information about Our collection, use, sale, disclosure for business purposes and share of personal information.
• The right to say no to the sale of Personal Data (opt-out).
• The right to delete Personal Data.
• The right not to be discriminated against for exercising any of Your consumer's rights.

7.9 – Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By email: contact@todaydream.com
• By mail: Todaydream, Inc., 1 East Erie St, Suite 525-4233, Chicago, IL 60611

7.10 – Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

7.10.1 – Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: networkadvertising.org
• The EDAA's opt-out platform: youronlinechoices.com
• The DAA's opt-out platform: aboutads.info

7.10.2 – Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

7.11 – "Do Not Track" Policy as Required by CalOPPA

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities.

7.12 – Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

7.13 – Other State Privacy Laws

In addition to California privacy rights, residents of Colorado, Connecticut, Virginia, and Utah may have additional rights under their respective state privacy laws. These rights may include:

• The right to confirm whether we are processing your personal data
• The right to correct inaccuracies in your personal data
• The right to delete personal data
• The right to data portability
• The right to opt out of targeted advertising, profiling, or the sale of personal data

If you are a resident of one of these states and wish to exercise your rights, please contact us at privacy@todaydream.com.

8 – Children's and Minor Users Privacy Rights

8.1 – Children Under 13

Todaydream takes children's privacy seriously and complies with the Children's Online Privacy Protection Act (COPPA). We collect personal information from children under 13 only:

1. Through educational institutions that have established formal partnerships with Todaydream and executed our Educational Institution Data Privacy Addendum, where the educational institution facilitates the collection of verifiable parental consent; or
2. With verifiable parental consent obtained directly from a parent or guardian.

8.1.1 – Educational Institution Access

When providing services through educational institutions to children under 13, we rely on the educational institution to:

• Act as the intermediary between Todaydream and parents/guardians
• Obtain verifiable parental consent through their established procedures
• Provide appropriate notices to parents/guardians
• Facilitate parent/guardian rights to review and request deletion of their child's information

8.1.2 – Direct Access

When providing services directly to children under 13 outside of educational institutions, we obtain verifiable parental consent through legally-recognized methods, which may include:

• Credit card verification with an additional confirmation step
• Signed consent forms (electronic or physical)
• Government-issued identification verification
• Other methods recognized as reasonably calculated to ensure consent is provided by the parent/guardian

8.1.3 – Information We Collect from Children Under 13

When providing services through educational institutions to children under 13, we may collect:

• First name and last initial (or other identifier provided by the school)
• Grade level and school
• Educational activity data and progress within our platform
• Content created by the student when using our services
• Session usage data (time spent, features used, activities completed)

We do not collect more information than is reasonably necessary for children to participate in our educational activities.

8.1.4 – How We Use Children's Information

Information collected from children under 13 is used solely to:

• Provide our educational services
• Maintain and improve the functionality of our services
• Respond to school administrative requests
• Analyze aggregated, de-identified usage to improve our educational offerings
• Fulfill our contractual obligations to the educational institution

We do not use children's personal information for commercial purposes, targeted advertising, or profiling unrelated to educational purposes.

8.1.5 – Disclosure of Children's Information

We may share information collected from children under 13 with:

• The child's school or school district
• Service providers who help us deliver our services (subject to confidentiality and security requirements)
• As required by law or to protect the safety of children

We do not share or sell personal information collected from children under 13 for marketing purposes.

8.1.6 – Parental Rights

Parents/guardians of children under 13 have the right to:

• Review the personal information we have collected from their child
• Request deletion of their child's personal information
• Refuse further collection or use of their child's information

To exercise these rights, parents/guardians should contact their child's school, which will work with us to fulfill these requests. Parents/guardians may also contact us directly at contact@todaydream.com.

8.1.7 – Data Retention and Deletion

We retain personal information collected from children under 13 only as long as necessary to fulfill the purpose for which it was collected. We typically delete or de-identify children's personal information:

• Upon request from a parent/guardian or eligible student
• Upon request from the educational institution
• When no longer needed for the purpose it was collected
• According to the terms of our contract with the educational institution

8.2 – California Privacy Rights for Minor Users

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

8.3 – Verifiable Parental Consent Procedures

For users between 13-17 years of age, we require parental or guardian consent before collecting personal information. We obtain this consent through the following methods:

1. Direct Consent Options:
   • Email consent with follow-up verification
   • Electronic consent form with identity verification measures
   • Signed consent form returned via electronic upload or mail
   • Credit card verification (for paid services only)
   • Video conference verification in special circumstances
2. School-Based Consent: Educational institutions may facilitate parental consent through their existing procedures, school-maintained documentation, or Todaydream's educational institution consent forms.
3. Consent Verification and Documentation: We verify all consent is provided by parents/guardians and maintain records of when consent was received, the verification method used, and what was consented to.
4. Consent Withdrawal: Parents/guardians may withdraw consent at any time by contacting us at contact@todaydream.com.
5. Information Accessible to Parents: Upon verification of identity, parents/guardians of minor users may access their child's information.

For questions about our parental consent procedures or to request access to your child's information, please contact us at contact@todaydream.com or call our parent support line at 312-651-6624.

9 – Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.