COPPA Policy

Related policies:

Privacy PolicyTerms & Conditions

1. Introduction and Purpose

1845 Solutions, Inc., its affiliates, and subsidiaries (“1845 Solutions,” “Company,” “we,” “our,” or “us”) is committed to protecting the privacy of children who use our Services. This Children's Online Privacy Protection Act (“COPPA”) Policy (“COPPA Policy”) supplements and should be read together with our general Privacy Policy, available at https://www.est1845.com/ (the “Privacy Policy”). In the event of a conflict between this COPPA Policy and the Privacy Policy with respect to the personal information of children under 13, this COPPA Policy shall control.

This COPPA Policy describes how we collect, use, disclose, and otherwise process personal information from children under the age of 13 (“children” or “child”) in compliance with the Children's Online Privacy Protection Act, as amended.

We do not sell children's personal information. We do not use children's personal information for targeted advertising.

2. Scope

This COPPA Policy applies to personal information collected from or about children under the age of 13 who use our Services, including our websites at https://www.est1845.com/ and https://www.stacks.est1845.com (collectively, the “Site”), our mobile application (the “App”), and all related services, features, and content (collectively, the “Services”).

Our Services, including in-person sports performance and athletic training assessments, are offered to young athletes ages 8–17 as well as adult athletes. However, our website and online account portal are designed and intended for users who are 13 years of age or older. The Site is not directed to children under the age of 13. All access and use of the Services by minors is permitted only through a parent or legal guardian.

While COPPA applies to children under 13, 1845 Solutions also requires parental or guardian consent for minor athletes ages 13–17. All access to the Services by minor athletes ages 13–17 is permitted only through a parent or legal guardian account, and we require written parental or guardian consent before collecting or using their personal information. We do not sell the personal information of minor athletes ages 13–17, and we do not use it for targeted advertising.

Where this COPPA Policy cross-references the Privacy Policy, those provisions apply to children's personal information only to the extent consistent with COPPA and this COPPA Policy. In particular, the data license granted to 1845 Solutions under the Terms of Use — including any license to use data for AI training or model improvement — does not apply to children's personal information except to the extent a parent or guardian has provided separate, verifiable consent as described in this COPPA Policy.

3. Personal Information We Collect from Children

We collect personal information from or about children only after obtaining verifiable parental consent (see Section 5 below). The categories of personal information we may collect from or about children include:

  • Name, Email Address, and Phone Number. Collected when a parent creates an account on behalf of a child athlete and provides their contact information in connection with the child's profile.

  • Account and Profile Information. Information associated with the child's athlete account and profile, including username, preferences, and settings configured by the parent or guardian.

  • Sports Performance Data. Data collected from third-party scoring systems and sensor-based equipment used during training sessions and performance assessments as part of the Services, including programs such as BASE and other team programs.

  • Video Clips and Content. Video recordings and other content captured or shared through App features in connection with the child's athletic training and performance.

  • Device and Browsing Information. Information collected automatically when the child accesses the Services, including browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique device identifier, Internet service provider, referring and exiting URLs, and clickstream data.

  • Activity and Usage Data. Information about how the child interacts with the Services, such as features used, content viewed, and time spent within the Services.

  • General Location Information. Approximate location derived from IP address. We do not collect precise geolocation from children.

For additional details on the types of personal information we collect across our Services, please refer to Section 2 (Personal Information Collected) of our Privacy Policy.

4. How We Use Children's Personal Information

We limit our use of children's personal information to what is reasonably necessary to provide the Services. Specifically, we use children's personal information only for the following purposes:

Providing the Features and Functions of the Services

To deliver sports performance assessments, training programs, video analysis, and other features and functionality of the Services that the child's parent has enrolled them in.

Providing a Personalized Experience

To personalize the child's experience within the Services, such as displaying relevant performance data, progress tracking, and training recommendations.

Service-Related Communications

To send push notifications and other communications relating to the Services to athletes through the athlete's or parent's mobile device.

We do not use children's personal information for any other commercial purpose, including marketing, advertising, or creating behavioral profiles unrelated to the provision of the Service.

5. Verifiable Parental Consent

Before collecting, using, or disclosing personal information from a child under 13, we obtain verifiable parental consent through one or more of the following methods:

Individual (Parent) Account Creation and Payment Verification

A parent or legal guardian creates an account using their own name, email address, and contact information, and then completes payment for the Services. The payment verification process serves as confirmation that the person providing consent is the child's parent or legal guardian. Only a parent or legal guardian may open an individual account on behalf of an athlete under 18 years of age.

Signed Consent Forms

Parents and legal guardians may sign a written consent form authorizing the collection and use of their child's personal information. Consent forms may be submitted in person, by email, by mail, or by upload through the Services. The consent form specifies the categories of personal information to be collected from the child; how the personal information will be used; whether and with whom personal information may be shared, including authorized coaches and sport performance data capture providers, as applicable. Parents may provide consent for the collection and use of their child's personal information without consenting to the disclosure of that information to third parties, except where disclosure is necessary to provide the Services or as required by law.

6. Disclosures of Children's Personal Information

We do not sell children's personal information. We may disclose children's personal information only in the following limited circumstances, and only with verifiable parental consent (or as otherwise permitted under COPPA):

Authorized Coaches

In connection with team programs (such as BASE and other programs), a child's personal information and performance data may be shared with authorized coaches who have created their own dedicated coach accounts on the platform. Coaches receive access solely for the purpose of supporting the child's participation in the program. This sharing is subject to parental consent.

Service Providers

We may disclose children's personal information to service providers—companies that process such content on our behalf, such as email delivery services, and customer service support. These service providers are contractually obligated to:

  • Use children's personal information solely to provide services on behalf of 1845 Solutions;

  • Maintain the confidentiality, security, and integrity of the personal information;

  • Not use or disclose the personal information for any other purpose.

Technology Partners

Separate from our service providers, 1845 Solutions engages certain identified technology partners that provide athletic performance tracking and biomechanical analysis services. Unlike service providers, technology partners both may (i) provide athletic tracking services as part of the Services, and (ii) use athlete videos and related data to train, evaluate, and improve their own artificial intelligence and machine-learning systems.

Sharing of a child's personal information (including video recordings) with a technology partner will occur only pursuant to a program-specific written verifiable parental consent form. Parents should be aware that once a child's videos or related data have been used by a technology partner to train an AI system, that data cannot be removed or deleted from the trained model. Revocation of consent will prevent further sharing and further training use but will not affect data already incorporated into previously trained systems.

Special Circumstances

We may also disclose children's personal information when reasonably necessary to:

  • Comply with applicable law or respond to legal process, including subpoenas, court orders, or requests from law enforcement or government agencies;

  • Investigate, prevent, or take action regarding suspected fraud, illegal activity, or other wrongdoing, or to protect and defend the rights, property, or safety of our Company, our users, or others; or

  • Facilitate a business transfer, including in connection with an acquisition, merger, bankruptcy proceeding, or sale of all or a portion of our business assets. In such cases, the acquiring entity will be bound by the terms of this COPPA Policy with respect to previously collected children's personal information.

We may also share aggregated or de-identified information that does not reasonably identify a child. For additional details on how we share personal information generally, please refer to Section 4 (Disclosures of Personal Information) of our Privacy Policy.

7. Parental Rights

Under COPPA, parents have the following rights with respect to their child's personal information:

  • Right to Review. You may request to review the personal information we have collected from your child. We will provide you with a copy of the information within a reasonable time after verifying your identity as the child's parent or legal guardian.

  • Right to Request Deletion. You may request that we delete the personal information we have collected from your child. Upon verification of your identity, we will delete such information, except to the extent retention is permitted or required by applicable law.

  • Right to Refuse Further Collection. You may refuse to permit any further collection or use of your child's personal information. If you exercise this right, your child may no longer be able to access certain features of the Services that require such information.

  • Right to Revoke Extended Retention Consent. You may revoke your consent to extended retention of your child's performance data at any time, as described in Section 8 below.

To exercise any of these rights, please contact us using the information provided in Section 12 (Contact Information) below. We will take reasonable steps to verify your identity before fulfilling your request. We will not require your child to provide more personal information than is reasonably necessary to participate in the Services.

8. Data Retention and Deletion

We retain children's personal information only for as long as is reasonably necessary to fulfill the purposes for which it was collected, provide the Services, and comply with our legal obligations. Children's personal information is not retained indefinitely.

Optional Extended Retention

Athletes and parents may also elect an optional extended retention feature. Under this feature, 1845 Solutions will retain the athlete's performance data and related personal information between service engagements so that the data is available for historical reference, longitudinal progress tracking, and future service sessions. Extended retention is entirely voluntary and is not a condition of receiving the Services.

Consent required for extended retention: For children under the age of 13, extended retention requires verifiable parental consent under COPPA. For minor athletes ages 13–17, extended retention requires written parental or guardian consent in accordance with 1845 Solutions' internal policy.

Revocation. A parent or legal guardian may revoke extended retention consent at any time by contacting us using the information in Section 12. Upon revocation, we will cease extended retention and will delete or de-identify the subject performance data and personal information within a reasonable period, except to the extent retention is required or permitted by applicable law.

AI-trained data. To the extent the athlete's videos or related data have been shared with a technology partner and used to train that partner's AI systems pursuant to separate program-specific consent (see Sections 6 and 10), such data cannot be removed from the trained systems. Revocation of extended retention consent will stop further extended retention and further training use, but will not affect data already incorporated into previously trained AI models.

When a child's account is closed or when a parent requests deletion of their child's personal information, we will delete or de-identify the child's personal information within a reasonable period, except to the extent retention is required or permitted by applicable law.

9. Data Security

We maintain a written information security program that includes administrative, technical, and physical safeguards designed to protect children's personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security program:

  • Identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of children's personal information;

  • Establishes and maintains safeguards that are appropriate to the Company's size, complexity, and the nature and scope of the personal information collected;

  • Is regularly evaluated and updated in response to changes in our business practices, technology, and identified risks.

Despite our efforts, no method of electronic transmission or storage is 100% secure. If you have reason to believe that your child's personal information has been compromised, please contact us immediately using the information in Section 12 below.

10. Third-Party Operators and Services

Certain features of the Services may involve third-party operators, service providers, and technology partners who collect personal information from children through or in connection with our Services. Where a third party collects or receives information from children through our Services, we:

  • Require these third parties to comply with applicable provisions of COPPA;

  • Obtain verifiable parental consent before permitting such collection, or ensure the third party has done so;

  • Contractually require these service providers to use children's personal information only for the purpose of providing services in connection with the 1845 Solutions platform and not for any other commercial purpose.

We are not responsible for the privacy practices of third-party websites, services, or applications that are linked from our Services but are not operated by us or on our behalf. We encourage parents to review the privacy policies of any third-party services before allowing their children to use them.

Certain programs may involve sharing children's personal information (such as video recordings) with technology partners for athletic tracking and technology development purposes, including AI model improvement. Any such sharing will only occur pursuant to a program-specific written consent form identifying the third party, the data to be shared, the purpose, the applicable retention period, and the parent's right to decline without affecting the child's access to the core Services or to revoke consent at any time.

We will not disclose children's personal information for any such purpose unless and until a parent has signed the applicable program-specific consent form. Parents who have provided program-specific consent may revoke it at any time by contacting us using the information in Section 12 below.

11. Changes to This COPPA Policy

We may update this COPPA Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post a date of when this policy changes to alert users that a new policy is in place. If we intend to use or disclose your child's personal information in a manner materially different from that stated at the time of collection, we will notify you via email and obtain your consent to such changes.

We encourage parents to review this COPPA Policy periodically to stay informed about how we are protecting children's personal information.

12. Contact Information

If you have any questions, concerns, or requests regarding this COPPA Policy, your child's personal information, or our privacy practices as they relate to children, please contact us at:

1845 Solutions, Inc.
Email: team@est1845.com
Website: https://www.est1845.com/

We will respond to verified parental requests within a reasonable timeframe and in compliance with applicable law.

This COPPA Policy is a standalone supplement to the 1845 Solutions, Inc. Privacy Policy. For information about our general privacy practices applicable to all users, please review our Privacy Policy at https://www.est1845.com/.