Draft — pending legal review. This document is not yet effective and may change before launch.
EAI Young Developer · Notice to Parents
Status: Draft v1.0 (initial publication-ready draft) · pending external counsel review Effective Date: [TBD upon launch] Last Updated: 2026-05-29 Version: v1.0 (Initial publication-ready draft, pending external counsel review)
This is the separate direct notice to parents required by 16 CFR §312.4(c). It is delivered to you by email before you are asked to give your verifiable parental consent. It is distinct from — and complementary to — our public Privacy Policy, which provides our full disclosures.
Why You Received This Notice
Your child wants to use EAI Young Developer. Before they can, the U.S. Children's Online Privacy Protection Act (COPPA) requires us to tell you what information we collect from your child, how we use it, and how you can control it. Please read this notice before giving your consent.
This notice is provided under the COPPA Rule (15 U.S.C. §§ 6501–6506; 16 CFR Part 312), and specifically the direct-notice requirement at 16 CFR §312.4(c).
A Note on Age
Federal COPPA applies to children under 13. On EAI Young Developer, we require verifiable parental consent for every user aged 5 through 17. We extend the parental-consent requirement to teens as a deliberate child-protection posture, consistent with the Youth Developer Agreement. If your child is 13–17, this Notice applies to them and to you on the same terms as for a younger child.
What Is EAI Young Developer
EAI Young Developer (eai-kids.com) is an open K-12 robotic-programming community modeled on Scratch. Kids learn to code Skills — small programs that run in our online simulator or, if you have one, on a real FF EAI Brain robot (Futurist, Master, FX Aegis, or FX Navi). They can browse and Remix Skills shared by other kids around the world.
We are a zero-commerce platform. There are no ads, no in-app purchases, and no marketing to your child.
What Information We Collect From Your Child
| Category | What we collect | How | Why |
|---|---|---|---|
| Account info | Username (you or your child create it), hashed password, your child's age band (5–7, 8–12, or 13–17) — not full date of birth |
At registration | To create the account and apply age-appropriate settings |
| Skill content | Code your child writes; an auto-generated thumbnail of the running Skill | When your child creates a Skill | To enable publishing, browsing, and Remixing |
| Activity logs | Logins, publishes, downloads of others' Skills, reports filed | During use | Service operation, safety, and abuse prevention |
| Comments | Limited preset phrases + emoji reactions (no free-text) — only if your child uses commenting | During use | Community interaction |
| Robot operational data | When your child runs a Skill on a physical FF robot: motion logs, simulation telemetry | Only if you have connected a robot and consent | To enable physical execution and diagnose problems |
What We DO NOT Collect From Your Child
- We do not collect your child's full name or date of birth
- We do not collect your child's email address or phone number
- We do not collect your child's home address or school
- We do not collect uploaded photos, videos, or audio from your child
- We do not collect precise geolocation
- We do not collect biometric data (face, voice, fingerprint, etc.)
- We do not track your child for behavioral advertising
What We Collect From YOU (the Parent)
- Your email address (the "Parent Email") — used only for verifiable parental consent (VPC), password recovery, parental-rights requests, and required notices
- Your VPC verification record — depending on the method used, this may include confirmation that email-plus consent was completed, or (when the signed-form fallback is used) a signed consent form reference (per 16 CFR §312.5(b)(2))
Per COPPA, parent contact information is parent PII and is held separately from your child's account. We delete it when your child's account is deleted.
How We Use Your Child's Information
- Provide the Service (account, Skill creation, publishing, simulator, robot deployment)
- Safety and abuse prevention (content moderation, handling reports)
- Service quality improvement (aggregated, de-identified telemetry)
- Communication with you about your child's account and our Service
We do NOT use your child's information for advertising, marketing, profiling, or to train general-purpose AI models.
Who We Share Your Child's Information With
- Our service providers (cloud hosting, content moderation, error monitoring, email delivery) — each bound by a Data Processing Agreement to handle child data with at least the protections in this Notice and our Privacy Policy
- Law enforcement or regulators when legally required
We do NOT sell or rent your child's information. We do NOT share it for third-party marketing.
For the complete list of our service providers and the specific data each handles, see the Privacy Policy §6 (Data Sharing and Third-Party Service Providers).
Your Rights as a Parent
You may at any time:
- Review the personal information we have collected from your child
- Refuse to permit further collection or use of your child's information
- Direct us to delete your child's information and account
- Revoke your consent at any time
How to Exercise Your Rights
- Fastest: Log into the Parent Portal at
eai-kids.com/parent/[token](the link arrives in our email — click "Manage my child's account") - By email: Send a request to
privacy@eai-kids.comfrom the registered Parent Email - By mail: [FF US Subsidiary Legal Entity Name], [Mailing Address]
Once we receive a deletion request:
- We confirm receipt within 24 hours
- We complete deletion in production systems within 5 business days
- Backup-system unwind completes within 30 days
How to Give Your Consent (the VPC Process)
- Click the link in our email to enter the consent flow.
- Confirm your consent — approved under 16 CFR §312.5(b)(2):
- Email-plus (our primary method) — confirm in the email we send you, then complete one additional confirming step (a follow-up confirmation), per §312.5(b)(2)(vi). No credit card or payment is required.
- Signed consent form — download, sign, and upload, per §312.5(b)(2)(i); used as a higher-assurance fallback (for example, v1 robot voice/image features)
- Read and sign the Youth Developer Agreement on your child's behalf.
- Your child's account is activated.
The verifiable parental consent we obtain is recorded in compliance with 16 CFR §312.10 and retained for the period required by law.
How to Revoke Consent
Use the same channels as above ("How to Exercise Your Rights").
Revoking consent will:
- Deactivate your child's account
- Trigger deletion per the timeline above
- Not retract existing copies of your child's published Skills that other users have already downloaded or Remixed — those may continue to exist outside our control, because published Skills are released under the open Creative Commons license CC BY-SA 4.0 (this is a feature of open community publishing)
More Information
- Our full Privacy Policy (longer, detailed)
- Our Terms of Service
- The Youth Developer Agreement you'll be asked to sign
- FTC's COPPA resources for parents: https://www.ftc.gov/coppa
Questions?
- Email:
privacy@eai-kids.com - Mail: [FF US Subsidiary Legal Entity Name], [Mailing Address]
Version and Effective Date
- Effective Date: [TBD upon launch]
- Last Updated: 2026-05-29
- Version: v1.0 (Initial publication-ready draft, pending external counsel review)
This Notice is provided pursuant to 16 CFR §312.4(c) of the Children's Online Privacy Protection Rule. It is a separate document from, and should be read together with, our Privacy Policy.