Minor-Data & Parental Consent Policy

1. Purpose

This policy describes how JAC Collective Co., LLC ("JAC," "we," "us") handles personal information of minors, with particular focus on the scenario where a parent or legal guardian Member of a JAC-built white-label client app adds a minor child's phone number or other contact information to their account for the purpose of receiving church communications.

2. Scope

This policy applies to:

• The white-label client app operated for any client church
• The SMS notification system tied to the client app
• Any other JAC-operated service where a parent can add a minor's information

It does not apply to information collected directly from minors visiting our website. Our website is not directed to children under thirteen (13).

3. We Do Not Knowingly Collect Information Directly from Children Under 13

JAC Collective does not knowingly create accounts for, market directly to, or collect personal information directly from children under thirteen (13). Our Services are intended for adults (clients, members) and for minors only through their parent or legal guardian.

If we learn we have collected personal information directly from a child under thirteen without verified parental consent, we will delete that information promptly. To report such an incident, contact us at alex@jaccollectiveco.com.

4. Parent-Added Minor Information

A member who is the parent or legal guardian of a minor may, at their discretion, add the minor's first name and phone number to the member's client app account so the minor can receive church notifications.

When a parent does this, they must affirm the following before the number is added:

The affirmation is timestamped and logged in our consent records as described in our SMS Consent Notice.

5. What Information We Collect About a Parent-Added Minor

For a minor added by a parent, we collect and store only:

• First name (optional — parent may leave blank)
• Phone number (E.164 format)
• The fact that the number is parent-added and which parent member added it
• The opt-in/opt-out history for that number
• Delivery and read status of messages sent

We do not collect:

• Email address (unless the parent expressly provides it for ministry communications)
• Photographs or images of the minor
• Geolocation data
• Behavioral profile information for advertising

6. How We Use Minor Information

We use parent-added minor numbers only for:

• Sending church notifications, sermon clips, devotionals, and event updates that the parent enrolled them in
• Delivering opt-out confirmation if the minor (or parent) replies STOP
• Compliance and audit recordkeeping

We do not use minor information for:

• Behavioral or interest-based advertising
• Selling, renting, or sharing with third parties for marketing
• Profile building beyond what is necessary to operate the Service

7. Access Controls

Personal information of parent-added minors is segregated within our data store and subject to stricter access controls than adult member data. Access is limited to:

• The parent or guardian member who added the number (within their own account view)
• The operating client church administrator (for ministry purposes)
• JAC support personnel on a documented need-to-know basis
• Automated systems necessary to deliver the SMS service

8. Parental Rights

A parent or legal guardian who has added a minor's number may at any time:

• View the information stored about that number through their member account
• Edit the information (e.g., update the number or first name)
• Remove the number from their account, which deletes the associated record from the active database within thirty (30) days
• Withdraw consent, which has the same effect as removal
• Request a record of all messages sent to that number by emailing alex@jaccollectiveco.com with subject line "Minor-Data Policy: Message Record Request"

The minor can also opt out directly by replying STOP from the minor's phone. This terminates messaging to that number immediately and is recorded in our consent log.

9. Retention

Once a parent-added minor number is removed or opts out, JAC Collective retains only:

• The opt-out timestamp and source
• A minimum identifier necessary to prevent re-messaging
• Audit records required by TCPA and carrier rules (typically 5 years)

All other data tied to the minor's number is purged from the active operating database.

10. No Cross-Use

We do not link a minor's number to any other JAC service or use it across clients. A minor's number added to Church A's app is used only for Church A's communications. If the parent later joins Church B's app, the number must be added again under Church B's consent flow.

11. Client Church Responsibilities

When a client church uses the client app, the church agrees:

• It will not solicit minor information from minors directly (e.g., no QR-code in-service flow targeting children for direct signup — the QR flow is for adult members who may then add their children)
• It will not use minor information for any purpose beyond ministry communications
• It will direct any subpoena, regulator inquiry, or parental complaint about minor data to JAC Collective promptly

These obligations are included in the Client Service Agreement.

12. International Considerations

If a parent or minor is located outside the United States, additional protections may apply under local law (such as GDPR-K for the European Economic Area or local data protection statutes). JAC Collective will honor local requirements as applicable. Parents outside the U.S. with jurisdiction-specific requests should contact alex@jaccollectiveco.com.

13. Changes to This Policy

We may update this policy. Material changes will be communicated via the client app and the Privacy Policy update process. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the Services after the effective date constitutes acceptance.

14. Contact

Questions, complaints, or rights requests regarding minor data: