KindCircl Privacy Policy
Effective date: October 20, 2026
KindCircl is an app where kids join interest clubs called "Circls", play games, earn a pretend currency called CirBux, and chat with friends their parents have approved. KindCircl is made for children, so we follow the U.S. Children's Online Privacy Protection Act (COPPA) and the FTC's COPPA Rule (16 C.F.R. Part 312), including the 2025 amendments.
This policy explains what we collect, why, who can see it, how long we keep it, and what rights parents have. It is written for parents. Kids have a short version in our Community Rules.
1. Who we are (operator information)
KindCircl is operated by:
KindCircl.com
700 N. Central Ave., Suite 530, Glendale, CA 91203
Privacy questions and requests: kindcircl@yahoo.com
Support: kindcircl@yahoo.com
Phone: (818) 579-2188
KindCircl.com is the only operator collecting personal information through KindCircl. Parents can send any privacy question or request to kindcircl@yahoo.com.
2. The short version
- A parent sets up every kid account. Kids are not asked for an email, password, real name, birthday, phone number or photo.
- No ads. We do not sell or "share" (for advertising) anyone's personal information. No third-party analytics or tracking tools.
- The app has no way for kids to upload photos, video or voice, and it does not request location, contacts or biometric data.
- Messages go through an automatic kindness filter on our own servers. Messages it stops are not saved.
- Private messages are off by default. A parent can turn them on, and they work only between friends that both kids' parents approved.
- Messages are deleted automatically after 90 days. A parent can delete their kid's account, or their own account and all their kids, at any time.
3. Information we collect
From parents
| Information | Why |
|---|---|
| Email address and password (the password is stored as a secure hash by our login provider, Google Firebase Authentication). The login provider also records account creation time and last sign-in time. | To create and secure the parent account and contact you about your child |
| Consent record: status (not verified, verified, revoked), the method used (card check or signed form), and dates | To meet COPPA's verifiable parental consent requirement. |
| If you verify with a card: Stripe's reference numbers for the checkout session, the payment and the refund, the amount (50 cents) and whether the refund went through | To verify that a parent gave consent (a method allowed by COPPA, 16 C.F.R. 312.5(b)(2)(ii)) and to make sure the 50 cents is refunded. We never receive or store your card number, expiry date or security code. Stripe collects those directly under its own privacy policy. |
| Consent session ID (a reference number for each verification attempt) | To match Stripe's result to your account. Deleted after 30 days. |
| If you use the signed consent form: the photo or scan of the form you upload, which shows your printed name, signature, date, relationship to your child, the email on your account and any child usernames you wrote; the name you type when uploading; and the time you submitted it | To verify that a parent gave consent (a method allowed by COPPA, 16 C.F.R. 312.5(b)(2)(i)) and to keep proof of that consent. Only KindCircl admins can open the form. |
| Your approvals, settings and actions in the parent dashboard, and your activity feed | To run the parent controls |
From kids (only after a parent completes verified consent)
| Information | Where it comes from | Why |
|---|---|---|
| Username (picked with a parent; real names are not allowed) | Parent, at setup | So friends can recognize each other. Our login provider also stores it as the account's display name. |
| Age group: 8 or under, 9 to 12, or 13 to 15 (not a birthday) | Parent, at setup | So kids can only search for kids in their own age group or the one next to it |
| Cartoon avatar ("look": skin tone, hair, outfit and other items picked from a fixed list) | Parent or kid | A profile picture without a photo. It is not a photo or a likeness, and no new personal information is collected for it |
| Friend code (a short random code) | Created by the app | So kids who know each other in person can send a friend request |
| Messages and stickers sent in Circls, Squads and private messages | Kid | To deliver chat |
| Squads a kid starts or joins: the Squad name, emoji and color, who is in it, and when each member last opened the chat | Kid | To run private group chats between approved friends |
| Team Circls a kid is added to by their parent: team name and type, the organizer's display name (for example "Coach Sam"), who is on the team, the first letter of each member parent's email address, team chat messages and announcements, and team challenge progress | Kid and parents | To run private teams for real-world groups. Team chat is deleted after 90 days; the team is deleted when the organizer ends it |
| Squad streaks and weekly challenges: which days members played or chatted together (not what they said), how much each member helped with the week's challenge, and the Squad's trophies | Kid | To run Squad streaks, weekly challenges and the trophy shelf. Kept while the Squad exists |
| Invite link activity: which kid's link a parent signed up from (kept on the parent account until they add a child), and which invited pairs earned a free card pack | Created by the app | To send the friend request and give the free card packs once |
| Founding Member number (for the first 100 kids) | Created by the app | To show the Founder badge and give the Founder Pal |
| Names and descriptions of Circls a kid creates | Kid | To show the club to other kids |
| Live game rooms: who is playing, their username, look and Buddy, answers, picks, card hands, letters and wagers, scores and reactions (no typed chat). Each player's card hand is readable only by that player | Kid | To run live games with Squad, Team, Circl or friend chat members. Deleted 30 minutes after the last activity |
| Game Hub best scores: the highest solo score for each game | Kid | To show "Your best" in the Game Hub. Solo games run on the device; only the final score is sent, and the server limits it to each game's maximum. Deleted with the account |
| Friend list, friend requests, Circl memberships, join requests, and Squad invites | Kid and parents | To run friendships, clubs and Squads |
| CirBux balance, earning history, shop items owned, and the KindCircl Pals card collection (how many of each card, each Pal's Buddy level and XP, and which Pal is the kid's Buddy) | Created by the app | To run the pretend currency, the avatar shop, card packs, selling spare cards and the Pal Buddy |
| Kindness-check counts and Mindful Break times | Created by the app | To run the kindness system and alert parents when needed |
| Reports the kid files (reason, plus optional free-text details the kid types) and blocks the kid makes | Kid | To keep KindCircl safe |
| Reports about the kid, including a short excerpt (up to 300 characters) of a message that was stopped as "serious" or as a sign the kid may need support | Other kids, or created automatically | Safety review |
| Login account ID, sign-in token, account creation time and last sign-in time | Our login provider | To keep the kid signed in securely |
Persistent identifiers
We use account IDs and sign-in tokens only to support the internal operations of KindCircl: signing users in, keeping accounts secure, and delivering the service. We do not use them to contact a specific person, to build a profile of anyone, or for advertising. Our safeguards: database rules limit who can read data, and no advertising or analytics tools are installed in the app.
Technical and security information
- Pairing-code protection: when a kid's device enters a sign-in code, we keep a one-way scrambled version (a keyed hash) of the device's IP address and a counter for up to 1 day to stop code guessing. We never store the raw IP address in our database.
- Server logs: like any online service, our hosting provider (Google Cloud) records request logs that can include IP addresses. These are kept in Google Cloud Logging for about 30 days. Google's required administrative audit logs (which record actions by our staff and systems, not app content) are kept for about 400 days.
- Admin audit log: every action our safety team takes (for example reviewing a report or pausing an account) is recorded, including which kid account it affected.
- We do not request precise or approximate location from the device. An IP address can suggest a general area, but we do not use it for that.
What we do not collect from kids
We do not ask kids for their real name, birthday, email, phone number, home address or school, and the app has no feature to upload photos, video or voice, or to access location, contacts or biometric data. Kids could still type personal details into a message. Our kindness filter helps block common patterns (10-digit phone numbers, email addresses, street addresses, links, and phrases like "what school" or "add me on" another app) before they are sent, but it cannot catch everything, so please talk with your child about keeping personal details private.
4. How we use information
We use personal information only to:
- Create and run accounts, Circls, friendships, chat, games and the CirBux shop.
- Run safety features: the kindness filter, Mindful Breaks, caring support messages, reports, blocks, account pauses and parent alerts.
- Let parents see and control their child's activity.
- Keep KindCircl secure, prevent abuse, and fix problems.
- Meet legal duties, including required reports to the National Center for Missing & Exploited Children (NCMEC) or law enforcement.
We do not use children's information for advertising, profiling or marketing to kids.
5. What other users can see
- Any signed-in KindCircl user can see every kid's username, avatar and Pal Buddy (which Pal it is and its level), the list of Circls (names, descriptions, emoji and member counts), including Circls created by kids.
- Kids who are members of a Circl can see its member list and the messages posted in it. Non-members see only the member count. Parents cannot see member lists.
- Approved friends can see private messages between the two of them. Each kid's parent (with verified consent) can read their own child's private messages.
- Players in a live game (only kids who can already see that Squad, Circl or private chat) see each other's username, look, Buddy, scores and reactions while the game runs.
- Team organizers (a verified parent who sets up a Team Circl for a real-world group such as a sports team, scout troop, class, club or camp) can see the team roster (each kid's username and avatar, plus only the first letter of each parent's email address), the team chat, and their own announcements. They can remove a kid from the team or end it. They cannot see kids' private messages, Squads, Circls, friends, coins or any other data. Only kids whose own parent used the team code or link can join a Team; strangers cannot find or join it. Each member's parent can see the team's name, organizer name and roster, but not the team chat.
- Teammates can see each other's usernames and avatars and the team chat, the same as a Squad.
- Squad members (every member is an approved friend of the kid who started the Squad) can see the Squad's member list and its group chat. Each member's parent can see the Squad's name and who is in it, but not the group chat, the same as Circl chat.
- Anyone a kid shares their invite link with sees that kid's username, avatar, Pal Buddy and Founder badge on the invite page. The link contains the kid's friend code and nothing else. KindCircl never asks kids for a friend's phone number or email address.
- Age groups are never shown to other users.
- If a friend's account is deleted, the private message thread is closed. The deleted kid's messages are removed, and the other kid keeps their own messages until they expire after 90 days.
6. Who we share information with
We do not sell personal information and do not share it for targeted advertising.
We disclose information only:
- To service providers who run KindCircl for us, under terms that limit their use of the data and require them to protect it:
- Google (Firebase and Google Cloud): hosting, database, file storage, login and server functions. The database is in Google's us-west2 region (Los Angeles). Signed consent forms are stored in Google Cloud Storage in the United States (Oregon, us-west1).
- Stripe, Inc.: parent verification by card. Stripe receives your email address, your account's reference number and the card or wallet (Apple Pay, Google Pay) details you type into Stripe's checkout page. It charges 50 cents and we refund it right away. Stripe never receives your child's information.
- Within KindCircl, as described in section 5. This is part of how the service works.
- To NCMEC or law enforcement when the law requires it or to protect a child's safety.
- If KindCircl.com is sold or merged, to the new owner, who must keep following this policy or get new parental consent.
Because we do not disclose children's information to third parties for their own purposes, there is no separate third-party consent to request today. If that ever changes, we will ask for a separate consent first, and saying no will not affect your child's use of KindCircl.
7. Parental consent
Before a kid account can be created, the parent must:
- Read our Notice to Parents.
- Verify they are a parent, using a method permitted under COPPA. Parents can choose either:
- A card check (about 1 minute): we charge 50 cents to a credit card, debit card, Apple Pay or Google Pay through Stripe's secure checkout, and refund it in full right away (16 C.F.R. 312.5(b)(2)(ii): a payment method that notifies the account holder of each transaction, used in connection with a monetary transaction). Your bank or card issuer tells the account holder about the charge. The refund can take a few days to appear.
- A signed form: parents print and sign our parental consent form and upload a photo or scan of it in the app (16 C.F.R. 312.5(b)(2)(i)). A KindCircl admin checks that the form is complete and signed and matches the account, usually within 24 hours. If something is missing, we delete the upload and tell you what to fix.
Until verification succeeds, a parent account cannot add kids or view any kid or shared data. No information is collected from a child before consent.
8. Data retention policy
We keep children's personal information only as long as reasonably necessary for the purpose we collected it, and we do not keep it indefinitely. This is our written retention policy under 16 C.F.R. 312.10. The internal version with technical details is our Data Retention Policy.
| Information | Purpose | Why we keep it | When it is deleted |
|---|---|---|---|
| Chat messages and stickers | Deliver chat; parent review | So kids and parents can see recent conversations | Automatically 90 days after sending |
| Messages stopped by the kindness filter | None | Not needed | Not saved |
| Excerpt in a safety report (up to 300 characters) | Safety review | To judge risk and meet legal reporting duties | With the report (below) |
| Safety reports (by or about a kid) | Investigate safety issues | To spot repeat problems and meet legal duties | Automatically about 1 year after the report is created, unless we must keep it longer by law |
| Reports a kid filed | (as above) | (as above) | Also when that kid's account is deleted |
| Parent activity feed | Show parents alerts and approvals | Recent safety history | Automatically after 1 year |
| Username, age group, avatar look, friend code, friends, memberships, CirBux, shop items, card collection and Pal Buddy, blocks | Run the account | Needed while the account is used | When the parent deletes the kid's account or their own account. We plan to delete accounts unused for 24 months, with advance notice to the parent. |
| Circls a kid created | Run the club | Other members use it | Deleted with the kid's account if the kid is its only member; otherwise kept for the other members with no owner |
| Private message threads with a deleted kid | Let the other kid keep their own messages | The other kid's own content | The deleted kid's messages are removed at once; the rest expire after 90 days |
| One-time pairing codes | Sign a kid's device in | 10 minutes | When used, or within a day after expiring |
| Scrambled IP counters for pairing | Stop code guessing | Short-term abuse prevention | Within 1 to 2 days |
| Admin audit log | Accountability for staff actions | Review of safety decisions | Automatically after 2 years |
| Consent session IDs, with Stripe's payment and refund reference numbers | Match verification results; make sure the refund went through | Short-term | Automatically after 30 days. A short summary (session number, amount, refund status) stays on the parent account as part of the consent record until the account is deleted. |
| Signed consent form (photo or scan) that was approved | Proof that a parent gave consent | COPPA requires us to be able to show consent was obtained | Kept while the parent account exists; deleted when the parent deletes their account. The separate review record (who reviewed it and when) expires 1 year after submission. |
| Signed consent form that we sent back | None | Not needed | Deleted immediately when we send it back |
| Parent account that never finished verification and has no kids | Request consent | Only while consent is pending | After 30 days |
| Parent account, email and consent record | Run the parent account; prove consent | Needed while the parent uses KindCircl | When the parent deletes their account |
| Google Cloud server logs | Security and troubleshooting | Detect abuse | About 30 days (Google's required admin audit logs about 400 days) |
9. Parents' rights
At any time, a parent can:
- Review the information we have about their child. Much of it is in the parent dashboard (profile, friends, private messages, activity). For a full copy, email kindcircl@yahoo.com.
- Delete their child's account and personal information from the dashboard (My kids → Delete account), or delete their own account and all their kids in Settings. Deletion happens promptly; some safety records are kept as described in section 8.
- Limit features: private messages are off by default and can be turned on or off; creating Circls is on by default and can be turned off.
- Withdraw consent in Settings. This pauses all of the parent's kid accounts right away and stops further collection. Verifying again unpauses them. To have the data deleted, delete the accounts.
We confirm that a request comes from the child's parent before acting on it.
10. How we protect information
We maintain a written Information Security Program. Highlights:
- The app cannot write to our database directly. Every action goes through a server check.
- Database rules deny access by default. Kids can see Circl listings and other kids' usernames and avatars, but only the chats and member lists of Circls they belong to and their own private messages. Parents can see only their own kids' data, and only after verified consent.
- Kids sign in with a one-time code from their parent, not a password.
- Rate limits protect sign-in codes and chat. Additional app verification (App Check) will be enabled before public launch.
- Only a small number of named adult staff can access safety tools, and every action they take is logged.
No system is perfectly secure. If a breach affects your child's information, we will notify you as the law requires.
11. California residents
California law gives residents rights to know, delete and correct personal information and to opt out of its sale or sharing. We do not sell or share personal information, including that of anyone under 16. We do not use sensitive personal information to infer characteristics about anyone. To make a request, email kindcircl@yahoo.com. We will not treat you differently for using your rights.
12. Teens
KindCircl accounts are always created by a parent, for kids up to age 15. Kids 13 to 15 get the same protections as younger kids.
13. Changes to this policy
If we make a material change to how we collect, use or share children's information, we will notify parents and get new consent where the law requires before the change applies to their child.
14. Contact us
KindCircl.com, 700 N. Central Ave., Suite 530, Glendale, CA 91203
kindcircl@yahoo.com · kindcircl@yahoo.com · (818) 579-2188 · https://kindcircl.com