Privacy Policy

Journey GPS - My Circle of Champions

Effective Date: March 30, 2026

Last Updated: March 30, 2026

1. Introduction

This Privacy Policy ("Policy") describes how [Your Educational Services Company Name] ("Company," "we," "us," or "our"), a California corporation providing educational services, collects, uses, discloses, retains, and protects the personal information of individuals ("users," "you," or "your") who access or use our platform, website, and related services (collectively, the "Services").

We are committed to protecting your privacy and complying with applicable federal and California state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), the California Education Code, and other applicable regulations.

By creating an account or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our Services, we collect the following categories of personal information:

  • Contact Information: Email address and phone number, collected from all users upon account creation.
  • Location Information: Street address, collected from certain users as required for specific services or enrollment purposes.
  • Identifying Information: Date of birth, collected from certain users for age verification, eligibility determination, or regulatory compliance purposes.
  • Account Credentials: Username, password (stored in encrypted form), and security information.
  • Communications: Messages, inquiries, or feedback you send to us.

2.2 Information Collected Automatically

When you use our Services, we may automatically collect:

  • Device and usage data, including IP address, browser type, operating system, and access times.
  • Log data and cookies as described in our Cookie Policy.
  • Educational activity records, progress data, and performance metrics within our platform.

2.3 Information from Third Parties

We may receive information about you from third-party sources, such as educational institutions, payment processors, identity verification services, or publicly available sources, to the extent permitted by law.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

  • Account Management: To create, maintain, and manage your account and authenticate your identity.
  • Service Delivery: To provide, personalize, and improve our educational services, content, and features.
  • Communication: To send transactional messages, service updates, account notifications, and respond to your inquiries via email or phone.
  • Safety & Compliance: To verify age, prevent fraud, maintain security, and comply with legal obligations.
  • Legal Basis (FERPA): To maintain and disclose education records as permitted or required by FERPA and applicable California law.
  • Analytics & Improvement: To analyze usage patterns, conduct research, and improve our Services.
  • Marketing (with consent): To send promotional communications where you have provided explicit opt-in consent. You may opt out at any time.

4. Legal Basis for Processing

We process your personal information under one or more of the following legal grounds:

  • Performance of a contract — to fulfill our obligations to you under our Terms of Service.
  • Compliance with a legal obligation — including FERPA, COPPA, CCPA/CPRA, and applicable California Education Code requirements.
  • Legitimate interests — to improve, secure, and operate our Services, provided such interests are not overridden by your rights.
  • Consent — for certain processing activities, including marketing communications and the collection of sensitive personal information.

5. Data Sharing and Disclosure

5.1 Permitted Disclosures

We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

  • Service Providers: With trusted third-party vendors who assist in operating our Services (e.g., cloud hosting, analytics, payment processing), under contractual data protection obligations.
  • Educational Institutions: With schools, districts, or other educational entities as necessary to provide services and as permitted by FERPA.
  • Legal Requirements: When required by law, court order, subpoena, or governmental authority.
  • Protection of Rights: To protect the safety, rights, or property of our Company, users, or the public.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations and notice to affected users.
  • With Your Consent: For any other purpose with your explicit consent.

5.2 California "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about disclosures of personal information to third parties for direct marketing purposes. To make such a request, contact us as described in Section 11.

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, resolve disputes, and enforce our agreements. Our retention practices are as follows:

  • Account & Contact Information (email, phone number): Retained for the duration of your active account and for a period of up to three (3) years following account closure, unless a longer retention period is required by law.
  • Street Address: Retained only as long as operationally necessary or as required by applicable California or federal recordkeeping requirements, and deleted within twelve (12) months of the address no longer being needed for the stated purpose.
  • Date of Birth: Retained for as long as necessary to verify eligibility or comply with age-related legal requirements, including COPPA obligations. Where collected solely for age verification, deleted once verification is complete unless retention is otherwise required.
  • Education Records (FERPA): Retained and disposed of in accordance with FERPA, applicable California Education Code provisions, and institutional records retention schedules. Generally retained for a minimum of five (5) years or as required by the relevant educational institution.
  • Financial Records: Retained for a minimum of seven (7) years to comply with IRS requirements and California tax law.
  • Security Logs & Usage Data: Retained for up to twenty-four (24) months for fraud prevention and security purposes.

Upon expiration of the applicable retention period, personal information is securely deleted or anonymized in accordance with industry standards and applicable law.

7. Children's Privacy (COPPA Compliance)

Our Services may be used by minors under the age of 13 only with the verifiable consent of a parent or legal guardian, in compliance with the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. § 6501 et seq., and the FTC's COPPA Rule (16 C.F.R. Part 312).

We do not knowingly collect personal information from children under 13 without verifiable parental consent. If we become aware that we have collected personal information from a child under 13 without such consent, we will delete that information promptly. Parents or guardians may contact us to review, correct, or delete their child's information.

For users between the ages of 13 and 17, we take additional precautions to limit data collection and use, and to ensure parental rights are respected as required by applicable law.

8. Family Educational Rights and Privacy Act (FERPA)

To the extent our Services involve the processing of "education records" as defined under FERPA (20 U.S.C. § 1232g), we comply with FERPA requirements and operate as a "school official" with a "legitimate educational interest" where applicable, under written agreement with the relevant educational institution.

Eligible students and parents/guardians retain rights under FERPA, including the right to inspect and review education records, request corrections, and consent to or restrict certain disclosures. Requests should be directed to the relevant educational institution or to us at the contact information in Section 11.

9. California Privacy Rights (CCPA/CPRA)

As a business subject to the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act, California residents have the following rights:

  • Right to Know: The right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes, and third parties with whom it is shared.
  • Right to Delete: The right to request deletion of your personal information, subject to certain exceptions.
  • Right to Correct: The right to request correction of inaccurate personal information.
  • Right to Opt-Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising. If this practice changes, we will provide a "Do Not Sell or Share My Personal Information" mechanism.
  • Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information (including precise geolocation and date of birth) to purposes necessary to provide the Services.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise these rights, submit a verifiable consumer request by contacting us as described in Section 11. We will respond within 45 days of receipt of a verifiable request, with the possibility of a 45-day extension where reasonably necessary.

Authorized agents may submit requests on your behalf with proper written authorization. We may require verification of identity before processing requests.

10. Data Security

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, destruction, or loss, consistent with the requirements of California Civil Code § 1798.81.5. These measures include, but are not limited to:

  • Encryption of personal information in transit (TLS/SSL) and at rest.
  • Access controls and authentication mechanisms.
  • Regular security assessments and vulnerability testing.
  • Employee training on data privacy and security practices.

No method of transmission over the Internet or electronic storage is 100% secure. In the event of a data breach affecting your personal information, we will notify you as required by California's data breach notification law (Cal. Civ. Code § 1798.82) and other applicable law.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Privacy Office:

[Company Name]
Privacy Office / Data Protection Officer
[Street Address], [City, State, ZIP Code]
Email: privacy@[yourdomain].com
Phone: [Phone Number]

For complaints or concerns that we are unable to resolve, California residents may contact the California Privacy Protection Agency (CPPA) at https://cppa.ca.gov or the California Attorney General's office.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email or by posting a prominent notice on our platform prior to the change becoming effective, and update the "Last Updated" date at the top of this Policy.

Your continued use of the Services after any such modification constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

13. Governing Law

This Privacy Policy is governed by the laws of the State of California and applicable federal law. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts located in the State of California.

© 2026 [Your Educational Services Company Name]. All rights reserved. This document was prepared for informational purposes and does not constitute legal advice. Consult qualified legal counsel to ensure compliance with all applicable laws and regulations specific to your operations.