HOMETRAIL CHILDREN'S PRIVACY POLICY (COPPA)

Last Updated: May 6, 2026

Applies to: Children under 13 using Nest, the HomeTrail Student App

Overview

HomeTrail App, Inc. ("HomeTrail," "we," "our," or "us") is committed to protecting the privacy of children. This Children's Privacy Policy ("COPPA Policy") is designed to comply with the Children's Online Privacy Protection Act and its rules ("COPPA").

This policy explains our practices for collecting, using, and disclosing personal information from children under 13 who use the HomeTrail Student App. It also explains how parents can access and control their children's information.

Except as specifically provided in this COPPA Policy, we do not collect any personal information directly from children—only from their parents.

What is the Student App?

Nest, the HomeTrail Student App, is a child-facing interface that allows children to:

• View educational activities ("packs") assigned by their parents
• Complete interactive learning activities
• Submit responses to questions and quizzes
• Create drawings and artwork
• Read or send parent-visible Trail Mail messages

The Student App is used under parental supervision. Children do not create accounts or log in themselves—parents authenticate on the child's behalf. Parent-facing controls such as settings, logout, legal pages, and external links are parent-gated where they are available in the app.

Information We Collect About Children

Information Provided by Parents

Parents provide the following information about their children when setting up their HomeTrail family:

• Child's first name: For identification within the family
• Birth date or age: For age-appropriate content selection
• Grade level: For curriculum alignment
• Profile photo (optional): For personalization

Information Collected Through the Student App

When children use the Student App, we collect:

• Pack activity and progress: Activities viewed, completed, skipped, or submitted, including timestamps
• Pack responses: Answers to questions, quiz responses, drafts, and submitted responses
• Drawings, artwork, and optional attachments: Creative work created within the app and images uploaded through parent-approved pack workflows
• Trail Mail: Student-sent messages to parents and read status for parent-sent messages
• YouTube video references: Parent-curated YouTube video URLs or video identifiers when a parent assigns a YouTube Videos pack
• Limited device and diagnostic information: App version/build, route path, bounded error metadata, operating system version, WebView version, and stack hashes used to diagnose crashes or errors

The Student App device heartbeat updates operating system version and WebView version only, along with the app version/build and last-seen time. Diagnostics are designed not to include raw child content, advertising identifiers, precise location, contacts, or full stack traces.

Information We Do NOT Collect from Children

We do not collect the following from children:

• Email addresses
• Phone numbers
• Social media accounts
• Precise geolocation
• Advertising identifiers or persistent identifiers for tracking or advertising
• Voice recordings
• Microphone recordings

Nest does not use push notifications, ads SDKs, analytics SDKs, or camera, microphone, or location permissions.

We do not collect more personal information about a child than is reasonably necessary to provide the educational services.

How We Use Children's Information

We use children's personal information only for the following purposes:

• Providing the Service: Displaying educational content and recording progress
• Parental Oversight: Allowing parents to view their children's work and progress
• Service Improvement: Understanding how the Student App is used (in aggregate, without identifying individual children)

We do NOT use children's information for:

• Advertising or marketing to children
• Creating profiles for behavioral targeting
• Sharing with third parties for their marketing purposes

How We Protect Children's Information

Technical Safeguards

The Student App includes the following technical protections:

• No outbound navigation from packs: Child-facing pack links are blocked from opening external pages
• No third-party tracking: No analytics or advertising SDKs in child-facing interfaces
• Restricted web content execution: Content Security Policy blocks external scripts, external API calls, iframes, and form posts
• No behavioral tracking storage: We do not use cookies or local storage in child-facing pack experiences for tracking or advertising
• Parent authentication: All data access requires parent's authenticated session
• Parent-gated controls: Settings, legal pages, logout, and external-link actions are parent-gated or blocked in child-facing flows

Data Security

Children's data is protected by:

• Encryption in transit (HTTPS) and at rest
• Access controls limiting who can view data
• Team-based permissions (only family members can access)

Information Sharing and Disclosure

We do not sell, rent, or share children's personal information with third parties for marketing purposes.

We may share children's information only in the following limited circumstances:

• Cloud hosting providers: For encrypted data storage
• AI educational assistance: For parent-initiated educational features, we may send limited educational context (such as grade level and activity descriptions) to generate or organize learning content. We apply safeguards designed to minimize child identifiers, including pseudonymous student aliases in TrailGuide SMS and chat flows.
• YouTube API Services and embedded player: When parents assign YouTube Videos packs, Nest may use YouTube API Services, YouTube's embedded player, and the youtube-nocookie.com domain to display parent-curated videos. We do not allow children to search YouTube from Nest, do not use YouTube for personalized ads, and do not send child profile data to YouTube. YouTube and Google may receive standard technical and playback information from the embedded player. Use of YouTube features is subject to the YouTube Terms of Service and Google Privacy Policy.

We may also disclose children's information:

• If required by law or legal process
• To protect the safety of children or others
• To protect the rights and safety of HomeTrail

Parental Rights

As a parent, you have the right to:

Review Your Child's Information

You can view all information we have collected about your child through your HomeTrail dashboard. Navigate to your Family settings and select your child to see all their data, including educational progress, pack responses, and artwork.

Update Your Child's Information

You can edit your child's profile, including name, age, and grade level, at any time through your account settings.

Delete Your Child's Information

You can delete your child's data by:

• Removing the student from your family (Settings → Family → Remove Student)
• Deleting your entire HomeTrail account (Settings → Delete Account)

When you delete a child's data, we permanently remove it from our active systems.

For security and operations, limited system logs and processing artifacts may be retained for a short period before automatic deletion, consistent with our retention practices.

Refuse Further Collection

You can disable Student App access for any child at any time through your account settings. You can also contact us to request that we stop collecting your child's information while maintaining your own account.

Parental Consent

We obtain parental consent for children's data collection through our "Parent Login" model:

1. Only adults can create HomeTrail accounts (email verification required)
2. Parents explicitly add each child to their family
3. Parents enable Student App access for each child
4. Parents can disable access or delete data at any time

This model ensures parents are aware of and consent to their children's participation before any data is collected.

Changes to This Policy

We will post any changes to this COPPA Policy on this page with a notice that the policy has been updated. If we make material changes to how we handle children's information, we will notify parents by email and obtain new consent if required by law.

The date this policy was last updated is shown at the top of this page. Your continued use of the Student App after changes are posted means you accept those changes.

Contact Us

For questions about this COPPA Policy or our children's privacy practices:

• Privacy Inquiries: [email protected]
• Data Protection Officer: [email protected]
• General Support: [email protected]

We will respond to parental requests within 30 days.