MyChessCoach Privacy and Children's Privacy Policy

1. Who operates MyChessCoach

The operator responsible for information collected through MyChessCoach is:

FiverKids LLC d/b/a MyChessCoach 32400 Seaside Drive, Union City, CA privacy@mychesscoach.com

MyChessCoach provides an online platform through which Families may engage independent chess Coaches.

Some Coaches are located in India or other countries outside the United States.

2. Parent-controlled accounts

MyChessCoach accounts used to purchase or manage services must be created and controlled by an adult.

A child may not independently:

• Create a purchasing account
• Provide payment information
• Accept the Terms
• Provide recording consent
• Enter a private communication relationship with a Coach

Parents or guardians provide information about the Student and control the Student's participation.

For children under 13, MyChessCoach provides required notice and obtains verifiable parental consent before collecting personal information directly from the child, except where a limited legal exception applies.

3. Information we collect from Families

We may collect the following information from a parent, guardian or other authorized adult:

• Contact and account information
• Name
• Email address
• Telephone number
• Mailing address where needed
• Password or account authentication information
• Time zone
• Country or general location
• Communication preferences
• Transaction information
• Plan selected
• Purchase amount
• Billing dates
• Payment status
• Refunds
• Credits
• Chargebacks
• Transaction identifiers
• Complete payment-card information is generally processed by our payment provider and is not ordinarily stored by MyChessCoach.
• Family preferences
• Scheduling availability
• Preferred lesson length
• Language preferences
• Coach preferences
• Customer-support requests
• Feedback
• Reviews

4. Information we collect about Students

Depending on the services used and the information provided by the Family, we may collect:

• First name
• Last initial or last name where necessary
• Age
• Birth month or year where needed to determine age
• Grade level
• Country or time zone
• Chess experience
• Chess rating
• Learning goals
• Tournament experience
• Schedule
• Coach preferences
• Attendance
• Lesson history
• Chess games and game records
• Practice activity
• Assignments
• Coach notes
• Progress information
• Platform messages
• Customer-support information
• Safety reports
• Technical information associated with use of the Platform

We ask Families not to provide unnecessary sensitive information.

If a Family voluntarily provides information about a disability, learning need, health condition or accommodation, we use it only as reasonably necessary to provide requested support, protect the Student or comply with law.

5. Information collected through Platform Messaging

Families and Coaches communicate through Platform Messaging.

We may collect and store:

• Message content
• Attachments
• Message dates and times
• Sender and recipient
• Delivery status
• Safety flags
• Support history

Platform messages may be reviewed by MyChessCoach for:

• Child safety
• Customer support
• Quality review
• Dispute resolution
• Fraud prevention
• Enforcement of Platform rules
• Legal compliance

Families and Students should not use Platform Messaging to share unnecessary personal information.

6. No direct sharing of Coach or Family contact details

MyChessCoach generally does not provide a Coach's personal email address or telephone number to a Family or Student.

MyChessCoach also limits the personal contact information provided to a Coach.

Coaches are contractually required to use Platform Messaging for Platform-introduced Coaching Engagements and may not:

• Contact a Student privately
• Contact a Family through personal email or telephone
• Request a Student's personal contact information
• Move communications to WhatsApp, social media or another private service
• Request direct payment

Platform notifications may be sent to a parent's email address or telephone number, but responses must be made through Platform Messaging unless MyChessCoach expressly authorizes another method.

7. Information collected during lessons

During an online lesson, a Coach may see or hear:

• The Student's name
• The Student's image
• The Student's voice
• The Student's chessboard or screen
• Chess games
• Lesson work
• Information voluntarily discussed during the lesson

Families should position the Student's device to avoid displaying unnecessary personal or household information.

The assigned Coach may access Student information reasonably necessary to deliver the Coaching Services, such as:

• First name
• Age or grade
• Chess level
• Goals
• Schedule
• Relevant lesson history
• Parent-visible messages
• Practice activity

The Coach is contractually required to use that information only to provide the accepted Coaching Services and comply with safety and legal obligations.

8. Session recordings

MyChessCoach does not record Coaching Sessions by default.

If MyChessCoach proposes to record a session, we will provide notice describing:

• That recording will occur
• The purpose of the recording
• What information will be captured
• Who may access it
• How long it will ordinarily be retained
• How the parent may provide or decline consent where applicable

Where legally required, MyChessCoach will obtain verifiable parental consent before collecting a recording containing a child's image or voice.

Unless a longer period is necessary to investigate a reported incident or comply with law, a safety or quality recording will ordinarily be deleted within 90 days.

We will not use a child's lesson recording in advertising or public marketing without separate, optional consent.

Coaches and Families may not independently record lessons without appropriate authorization.

9. Technical and device information

When an adult or Student uses the Platform, we may automatically collect:

• IP address
• Browser type
• Device type
• Operating system
• General location inferred from IP address
• Pages viewed
• Features used
• Date and time of access
• Referring page
• Session identifiers
• Error logs
• Security events
• Cookie and similar technology identifiers

We use this information to:

• Operate the Platform
• Authenticate users
• Remember preferences
• Maintain security
• Diagnose errors
• Understand general Platform usage
• Prevent fraud
• Improve performance

We do not intentionally collect precise geolocation from Students.

10. Cookies and similar technologies

We may use:

• Essential cookies

Required for:

• Login
• Security
• Account functions
• Scheduling
• Purchases
• Platform preferences
• Analytics cookies

Used to understand how adult visitors and Families use the website and improve performance.

Advertising technologies

MyChessCoach does not use personal information collected from children for targeted advertising or cross-context behavioral advertising.

MyChessCoach does not knowingly permit advertising providers to build behavioral profiles of Students.

If MyChessCoach uses advertising technologies on adult-facing marketing pages, those technologies must not be enabled inside Student learning areas or used to target advertising based on children's activity.

Where required, adult visitors will be provided with cookie controls or privacy choices.

11. Information collected from Coaches

For Coach applicants and Coaches, MyChessCoach may collect:

• Name
• Address
• Email
• Telephone number
• Date of birth
• Country
• Identity documentation
• Photograph
• Chess ratings
• Professional history
• Education
• Certifications
• Languages
• References
• Interview information
• Background-screening information
• Availability
• Preferred compensation
• Accepted engagements
• Lesson records
• Parent feedback
• Complaints
• Platform messages
• Payment and bank information
• Tax information
• Device and security information

Coach screening and payment information is used only for legitimate business, safety, contractual and legal purposes.

Public Coach profiles display only information selected or approved for profile use.

12. Sources of information

We may receive information:

• Directly from a Family
• Directly from a Coach
• From a Student with parental authorization
• Through Platform activity
• From payment providers
• From video-conferencing or chess-service providers
• From background-screening providers
• From references
• From publicly available chess rating or tournament sources
• From customer-support providers
• From schools or organizations where authorized
• From fraud, security or analytics providers

13. How we use personal information

We may use personal information to:

• Provide services
• Create and manage accounts
• Match Families with Coaches
• Allow Coaches to accept or reject engagements
• Schedule lessons
• Process payments
• Distribute Coach compensation
• Provide Platform Messaging
• Provide practice tools
• Run tournaments
• Track attendance and credits
• Provide customer support
• Personalize services
• Recommend a suitable Coach
• Understand Student goals
• Suggest learning paths
• Support lesson continuity
• Adapt account settings
• Protect Students and users
• Enforce the Child Safety Code
• Review Platform messages
• Investigate reports
• Prevent private Coach-Student communication
• Detect fraud
• Suspend inappropriate accounts
• Protect Platform security
• Communicate
• Send booking confirmations
• Send Platform-message notifications
• Send lesson reminders
• Provide billing notices
• Respond to support requests
• Provide policy updates
• Send marketing to adults who have not opted out
• Improve the Platform
• Analyze Platform performance
• Diagnose errors
• Improve matching
• Develop features
• Conduct aggregated or de-identified analysis
• Meet legal obligations
• Maintain transaction records
• Respond to lawful requests
• Protect legal rights
• Enforce contracts
• Meet tax and accounting requirements
• Comply with child-safety and privacy obligations

14. How we disclose information

We may disclose personal information as described below.

Assigned Coaches

We disclose limited Student and Family information to the assigned Coach where necessary to:

• Evaluate a proposed match
• Accept or reject the engagement
• Deliver lessons
• Review prior lesson activity
• Communicate through Platform Messaging
• Support the Student

A Coach may be located in India or another country.

Coaches receive only information reasonably required for the Coaching Engagement and are contractually prohibited from using it for unrelated purposes.

Service providers

We may use providers for:

• Website hosting
• Cloud storage
• Payment processing
• Email and notifications
• Video conferencing
• Scheduling
• Customer support
• Background screening
• Fraud prevention
• Security
• Analytics
• Chess technology

Service providers are permitted to use personal information only for specified services or as otherwise allowed by law.

Safety and legal disclosures

We may disclose information where we reasonably believe it is necessary to:

• Protect a child
• Investigate abuse or misconduct
• Prevent fraud
• Respond to an emergency
• Comply with legal process
• Respond to law enforcement
• Report to child-protection authorities
• Enforce our agreements
• Protect our rights or another person's rights

Business transactions

Information may be disclosed in connection with a proposed or completed:

• Merger
• Financing
• Acquisition
• Reorganization
• Asset sale
• Bankruptcy
• Transfer of the business

Any recipient will remain subject to applicable privacy obligations.

With consent

We may disclose information for another purpose where the parent, adult user or Coach has provided appropriate consent.

15. Sale and targeted advertising

MyChessCoach does not sell children's personal information.

MyChessCoach does not disclose children's personal information for targeted advertising or cross-context behavioral advertising.

MyChessCoach does not condition a child's participation on providing personal information beyond what is reasonably necessary for the activity.

MyChessCoach does not knowingly sell personal information in exchange for money.

If our adult-facing advertising practices change in a way that creates a legal right to opt out, we will provide the required notice and opt-out method before implementing that practice.

16. International access and transfers

MyChessCoach is based in the United States.

Coaches and service providers may operate in other countries, including India.

As a result, personal information may be accessed, processed or stored outside the Family's state or country.

Privacy laws in another country may differ from those in the Family's jurisdiction.

We use contractual restrictions, access controls and other safeguards intended to limit use of information to the purposes described in this Policy.

A Coach located outside the United States may access only the information reasonably necessary to evaluate and deliver the accepted Coaching Engagement.

17. Children under 13

MyChessCoach is intended to provide educational services to children, including some children under 13.

For a Student under 13, MyChessCoach will:

• Provide the parent with notice of relevant information practices
• Obtain verifiable parental consent where required
• Collect no more information than reasonably necessary
• Allow the parent to review the child's personal information
• Allow the parent to request deletion
• Allow the parent to withdraw consent
• Protect the confidentiality and security of the information
• Retain the information only as long as reasonably necessary
• Restrict disclosure to Coaches and providers that need the information for the service
• Avoid targeted advertising based on the child's information

The assigned Coach's access to limited Student information is integral to delivering the Coaching Services. This disclosure is explained to the parent before the Coaching Engagement begins.

18. Verifiable parental consent

Where required, MyChessCoach uses a method reasonably designed to confirm that the person providing consent is the child's parent or legal guardian.

The method may depend on:

• The information being collected
• How it will be used
• Whether it will be disclosed
• The applicable legal requirements

Consent may be obtained through an approved electronic process, a payment-related verification, a signed consent, a video interaction or another legally permitted method.

MyChessCoach will retain appropriate records of parental consent.

Consent for service delivery is separate from optional consent for:

• Public testimonials
• Marketing photographs
• Advertising videos
• Public tournament publicity
• Other secondary uses

Declining optional marketing consent will not prevent the Student from receiving Coaching Services.

19. Parent rights concerning a child's information

A verified parent or legal guardian may request to:

• Review personal information collected from the child
• Correct inaccurate information
• Delete the child's personal information
• Withdraw consent to future collection
• Prevent further use of the child's information
• Ask what categories of information are collected
• Ask which parties receive the child's information

Submit a request to:

privacy@mychesscoach.com

We may request information reasonably necessary to verify the requesting person's identity and authority.

Withdrawing consent or requesting deletion may make some or all Coaching Services unavailable.

We may retain limited information where reasonably necessary for:

• Safety investigations
• Fraud prevention
• Transaction records
• Legal claims
• Compliance with law
• Enforcement of agreements

20. Public information

MyChessCoach does not create public Student profiles containing full identifying information.

A Student's name, image, voice, chess activity or work will not be made publicly available through MyChessCoach unless:

• The parent receives appropriate notice
• The parent provides appropriate consent
• The publication is limited to the consent provided

Tournament display names should use a first name, nickname or non-identifying username where reasonably possible.

Parents should not include unnecessary child information in public reviews.

21. Marketing communications

We may send adults information about:

• MyChessCoach programs
• Chess events
• Tournaments
• Offers
• New services

Adults may unsubscribe through the link in the message or by contacting us.

We do not send behavioral advertising directly to children.

Service messages, safety communications, billing notices and account notices are not marketing and may continue while the account remains active.

22. Data retention

We retain personal information only for as long as reasonably necessary for the disclosed purpose, including the following general periods:

Family account information

Retained while the account is active and ordinarily for up to two years after the last Coaching Engagement, unless a longer period is required for legal, fraud or safety purposes.

Student profiles and lesson history

Retained while services are active and ordinarily for up to two years after the last lesson to support continuity, reactivation and parent requests.

A parent may request earlier deletion, subject to lawful retention needs.

Platform messages

Ordinarily retained during the Coaching Engagement and for up to two years afterward for support, safety and dispute resolution.

Messages connected with a safety report may be retained longer.

Session recordings

MyChessCoach does not record sessions by default.

Where a recording is properly created, it is ordinarily retained for no more than 90 days unless it is connected to a complaint, legal hold or safety investigation.

Transaction and tax records

Retained for up to seven years or another period required by tax, accounting, payment or legal obligations.

Safety and misconduct records

Retained for as long as reasonably necessary to protect users, prevent repeat misconduct, address legal claims and meet reporting obligations. Serious safety records may be retained for up to seven years or longer where required by law.

Coach screening and payment records

Ordinarily retained during the Coach relationship and for up to seven years afterward for contractual, tax, safety and legal purposes.

Technical logs

Ordinarily retained for between 30 days and 18 months, depending on security, fraud and operational needs.

When information is no longer needed, we delete it, de-identify it or securely isolate it from ordinary use.

23. De-identified and aggregated information

We may create aggregated or de-identified information that does not reasonably identify a Family, Student or Coach.

We may use that information to:

• Analyze program performance
• Improve matching
• Understand general learning patterns
• Improve Platform features
• Prepare business reports

We will not attempt to re-identify information that we maintain as de-identified except as permitted by law to evaluate the de-identification process.

24. Information security

MyChessCoach uses administrative, technical and organizational safeguards intended to protect personal information.

Measures may include:

• Role-based access
• Account authentication
• Encryption in transit
• Restricted Coach access
• Contractual confidentiality obligations
• Security logging
• Backups
• Vendor review
• Incident-response procedures
• Staff and Coach safety requirements

No system is completely secure. MyChessCoach cannot guarantee that unauthorized access, loss or misuse will never occur.

Families should:

• Use a strong password
• Protect account credentials
• Sign out of shared devices
• Avoid sharing sensitive information in messages
• Notify MyChessCoach of suspected unauthorized access

25. Data incidents

If MyChessCoach learns of a data-security incident, it may:

• Investigate the incident
• Restrict access
• Preserve relevant records
• Notify affected users
• Notify regulators or law enforcement
• Take corrective measures

Notifications will be provided where and when required by applicable law.

26. Third-party websites and platforms

MyChessCoach may link to or integrate with third-party services such as:

• Video-conferencing platforms
• Chess platforms
• Payment services
• Scheduling services

Those providers may have their own privacy policies.

MyChessCoach takes reasonable steps to use providers capable of protecting information, but Families should review relevant third-party practices.

A parent should supervise the Student's use of any third-party account.

27. California privacy notice

This section applies to California residents to the extent the California Consumer Privacy Act or another California privacy law applies to MyChessCoach and the relevant information.

California residents may have the right to request:

• The categories of personal information collected
• The sources of that information
• The purposes for collection and use
• The categories of recipients
• Specific pieces of personal information
• Deletion
• Correction
• Opt-out of sale or sharing
• Limitation of certain sensitive-personal-information uses
• Equal treatment for exercising privacy rights

MyChessCoach does not sell children's personal information and does not share it for cross-context behavioral advertising.

Requests may be submitted to:

privacy@mychesscoach.com

We will verify requests as required by law.

A parent or authorized agent may submit an appropriate request for a child.

28. Privacy rights in other US states

Residents of certain states may have rights to:

• Access personal information
• Correct personal information
• Delete personal information
• Receive a portable copy
• Opt out of certain targeted advertising, sales or profiling
• Appeal a denied request

We will honor applicable rights based on the requester's jurisdiction and our legal obligations.

To submit a request or appeal:

privacy@mychesscoach.com

29. Verification of privacy requests

Before responding to a request, we may ask for information reasonably necessary to verify:

• Identity
• Account ownership
• Parental authority
• The scope of the request

We use verification information only to process and protect the request.

We may deny or limit a request where:

• Identity cannot be verified
• Parental authority cannot be verified
• The request is fraudulent or abusive
• Retention is legally required
• An applicable legal exception applies

We will explain a denial where required.

30. Authorized agents

Where permitted by law, an adult may use an authorized agent to submit a privacy request.

We may require:

• Written authorization
• Verification of the adult's identity
• Direct confirmation of the request

An agent requesting information about a child must also demonstrate the parent's or guardian's authority.

31. Non-discrimination

MyChessCoach will not unlawfully discriminate against a person for exercising a privacy right.

Exercising a right may affect the service where the requested information is necessary to provide it.

For example, deletion of all Student information may prevent continued coach matching or lesson delivery.

32. Changes to this Policy

MyChessCoach may update this Policy to reflect changes in:

• Services
• Technology
• Safety practices
• Data practices
• Law

We will update the effective date.

We will provide additional notice and obtain new consent where required for a material change involving children's information.

33. Contact us

For privacy questions or requests:

FiverKids LLC d/b/a MyChessCoach 32400 Seaside Drive, Union City, CA contact@mychesscoach.com

For child-safety concerns: contact@mychesscoach.com

For general support: contact@mychesscoach.com