COPPA Statement | Rushing Waters Consulting

Section 1 — Our Commitment

Rushing Waters Consulting LLC and the Wise Zebra platform are fully compliant with the Children's Online Privacy Protection Act (COPPA) and the FTC's implementing regulations (16 CFR Part 312). We take the privacy of children under 13 with the utmost seriousness.

Section 2 — Verifiable Parental Consent

We do not collect Personally Identifiable Information (PII) from children under 13 without express Verifiable Parental Consent (VPC). Our platform implements a two-step age verification process: (1) the parent or legal guardian creates the account and enters the student's date of birth; (2) if the student is under 13, the platform requires explicit parental consent before any student data is collected or any tutoring session begins. This consent mechanism complies with the FTC's "email plus" consent method.

Section 3 — School Consent Exception

In the context of formal school and district partnerships, Rushing Waters operates under the COPPA "School Authorization" exception (16 CFR §312.5(b)(1)), where the educational institution provides consent on behalf of parents for educational data collection. Under this exception: the institution must obtain parent notification prior to engaging our platform; data collected is used solely for educational purposes; and parents retain the right to review and request deletion of their child's data directly from Rushing Waters.

Section 4 — What We Collect From Children Under 13

Under parental or school consent, we collect only: student first name, assigned grade level, assignment text entered during tutoring sessions, and AI-synthesized Learning Profile observations. We do not collect photos, videos, voice recordings, precise geolocation, or any information beyond what is necessary for tutoring service delivery.

Section 5 — Parental Rights

Parents and legal guardians retain absolute control over their child's data. At any time, parents may: review all information collected about their child; request correction of inaccurate information; refuse further collection of their child's data; and request permanent, irrecoverable deletion of all student data. These rights are exercised through the Parent Dashboard or by contacting founders@rushingwatersconsulting.com. We will fulfill all parental data requests within 10 business days.

Section 6 — Data Retention for Children Under 13

We retain data for children under 13 only for the duration of the active account. All data is permanently deleted within 30 days of account cancellation or upon parental request.