Solara
Parental Consent Framework

• Parent or legal guardian: A person with legal authority to make decisions on behalf of the child, including biological parents, adoptive parents, legal custodians, or other caregivers as authorized by applicable law.
• Child/children: Users under the age of 13 (or the applicable local age of digital consent).
• Teen: Users between 13-17 years of age.
• Minor: All users under 18 (children and teens).

This document outlines Solara's comprehensive parental consent mechanism for users under 18 years of age. Solara is an AI-powered social intelligence coaching service that helps users develop communication skills, emotional intelligence, and relationship-building abilities through personalized guidance. Because our service involves AI-driven conversations that may touch on personal experiences and social development, we take extra precautions when serving minors.

1.1 Initial Age Screening

During the sign-up process, all users are required to provide their date of birth. Based on this information, Solara implements the following procedures:

• Users 18 and older: Proceed directly to standard account creation
• Users 13-17: Redirected to teen registration flow requiring parental permission
• Users under 13: Redirected to child registration flow requiring verifiable parental consent

1.2 Age Verification Measures

• Date of birth is required, not just age
• Users cannot create multiple accounts using the same device in a short timeframe
• If a user attempts to change their birth date to bypass age restrictions after being denied, the system flags the account for review
• Account creation is temporarily limited to three attempts per device to prevent experimentation with different birth dates

2.1 Child Registration Flow

1. When a child under 13 attempts to register, they are informed that parental consent is required
2. The child provides their name or username and a parent/guardian's email address
3. No personal information is collected from the child beyond what is necessary for parental consent
4. A temporary account in "pending status" is created (limited functionality until consent is received)

2.2 COPPA-Compliant Verification Methods

Primary Method: Credit Card Verification

1. Parent receives an email with information about Solara and a link to the consent portal
2. Parent reviews the Privacy Policy and Terms of Service
3. Parent provides credit card information for a nominal authorization hold ($0.50)
4. Authorization is immediately reversed/canceled (no actual charge)
5. This verification method is accepted by the FTC as meeting COPPA requirements

Alternative Methods (upon request):

• Signed Consent Form: Parent can print, sign, and upload or mail a physical consent form
• Video Verification: Schedule a brief video verification call with a Solara team member
• Government ID Verification: Upload a photo ID (personal information redacted) with a signed consent statement

Solara uses Level 2 Identity Verification (L2 IDV) practices and encrypts all verification data in accordance with NIST 800-63 and OWASP recommendations. All verification processes are conducted through secure, encrypted channels with regular security audits to ensure the protection of sensitive information.

2.3 Parent Notification and Consent Email

• Clear subject line: "Parental Consent Required for [Child's Name] to Use Solara"
• Explanation of what Solara is and how it works
• Link to Privacy Policy and Terms of Service
• Detailed description of personal information collected from the child
• How the information will be used
• Parent's rights to review and delete the child's information
• The verification options available
• Timeline for consent (14 days before pending account data is deleted)

2.4 Information Collection Limitation

• Collects only the child's age, username, and parent contact information
• Does not activate full account features
• Stores this limited information securely for up to 14 days
• Automatically deletes the information if parental consent is not received within 14 days

For teens 13-17, Solara implements a parental permission process that acknowledges both teens' increasing autonomy and parents' supervisory role.

For users located in the European Economic Area, UK, or Switzerland, parental consent is required for children under the age of 16 in accordance with Article 8 of the GDPR, unless local member state law provides for a lower age (not below 13). For clarity, this means:

• France, Germany, Netherlands, Ireland: consent required for users under 16
• Spain, Denmark, UK: consent required for users under 13
• Other EEA countries: as per their specific implementations of GDPR Article 8

3.1 Teen Registration Flow

1. Teens 13-17 are informed that parental permission is required (or 13-15/16 for applicable EEA countries)
2. Teen provides their information and a parent/guardian's email address
3. A provisional account is created with limited features

3.2 Parental Permission Process

1. Parent receives an email notification about their teen's interest in Solara
2. Email includes information about Solara, Privacy Policy, and Terms of Service
3. Parent is directed to a permission portal where they can:
   • Review what Solara does and what data is collected
   • Understand how Solara protects teens' privacy
   • Grant or deny permission
4. Email verification and secure link ensure the parent receives and responds to the request
5. Teen is notified when permission is granted

3.3 Teen-Specific Safety Measures

• Content filtering adjusted for age appropriateness
• Specific AI guidance parameters for teen users
• Automatic detection and escalation of concerning conversations
• Periodic safety tips and reminders about responsible use

4.1 Detailed Explanation of Service

• What Solara Is: An AI-powered social intelligence coach that helps users improve communication skills, emotional intelligence, and relationship building through text-based conversation.
• What Solara Is Not: Not a licensed therapist, counselor, or healthcare provider. Not a replacement for professional mental health support.
• Content Areas Covered: Social skills, conversation techniques, emotional awareness, conflict resolution, and personal relationship development.

4.2 Data Collection and Usage

• Data Collected: Account information, conversation content with the AI, usage patterns
• Data Usage: To provide the AI coaching service, improve the system (with appropriate anonymization), and ensure platform safety
• Data Security: Encryption, access controls, and other measures to protect sensitive information
• Third-Party Services: Information about Stripe (payments), Firebase (authentication), and OpenAI (AI processing)

Solara acts as the data controller for personal information collected from children and teens. Parents may exercise their data protection rights under GDPR, COPPA, and applicable laws at any time. We clearly identify the legal basis for processing children's data in each jurisdiction where we operate.

4.3 Potential Risks and Benefits

• Benefits: Improved social skills, communication abilities, and emotional intelligence in a private, judgment-free environment
• Potential Risks: AI limitations, inappropriate advice (though filtered), and the possibility of sharing sensitive personal experiences
• Mitigation Measures: Content filters, safety monitoring, child-friendly configuration

4.4 Explicit Acknowledgments

• "I understand Solara uses artificial intelligence to provide social skills coaching"
• "I understand Solara is not a substitute for professional counseling or mental health services"
• "I understand I can review my child's activity and revoke consent at any time"
• "I authorize my child to use Solara according to the Terms of Service and Privacy Policy"

5.1 Parent Dashboard

• Account Management: Review child's profile information and subscription details
• Usage Monitoring: View usage statistics (frequency, duration) without viewing private conversations
• Content Controls: Set time limits and access restrictions
• Notification Settings: Configure alerts for unusual activity or concerning content
• Billing Management: Manage subscription and payment information

5.2 Conversation Privacy Balance

• For Users Under 13: Parents have the option to review conversation history and receive automated alerts about potentially concerning conversations
• For Users 13-17: Parents receive general usage information and alerts about potentially concerning content, but do not have automatic access to conversation content (respecting teens' privacy while maintaining safety)

5.3 Topic Restrictions

• Dating and romantic relationships
• Politics
• Religion
• Other sensitive areas as defined by the parent

5.4 Session Limits

• Daily or weekly time limits
• Scheduled access times (e.g., only between 3pm-8pm)
• Maximum session length

6.1 Accessing Child's Data

1. Log in to the Parent Dashboard using their registered email and password
2. Navigate to the "Account Management" section
3. Select "Review Account Data" to see:
   • Profile information
   • Account settings
   • For under-13 users: access to conversation history
   • For 13-17 users: usage statistics and flagged content alerts

6.2 Consent Revocation Process

1. Parent Dashboard: "Revoke Consent" button in the Account Management section
2. Email: Sending a request to revocation@solara.com from the registered parental email
3. Support Request: Contacting customer support with appropriate verification

Upon revocation:

• The child's account is immediately suspended
• Parents receive a confirmation email with options for data disposition
• Parents can request complete deletion of all account data or receive a data export

6.3 Data Retention After Revocation

• All personal information is marked for deletion
• Account data is deleted within 30 days
• Any backups containing the data are cycled out within 90 days
• Parents receive confirmation when deletion is complete

6.4 Re-granting Consent and Age Transitions

• A new consent process must be completed if a parent wishes to re-grant consent after revocation
• The previous account data is not recoverable
• A new account is created with fresh settings

If the child turns 13 (or the applicable local age of digital consent) while using the Service, we will prompt the child to confirm continued use and present an updated privacy notice in age-appropriate language. The parent will be notified of this transition and informed of the updated privacy settings and controls applicable to the teen account category. The parent will retain oversight capabilities appropriate to the teen's new status.

7.1 Annual Consent Renewal

• Parental consent/permission is valid for one year
• Parents receive a renewal notification 30 days before expiration
• If not renewed, account features are limited until new consent is obtained
• If not renewed within 30 days after expiration, the account is suspended

7.2 Material Change Notifications

• Parents receive notifications requiring new consent when Solara makes significant changes to data collection practices
• New features are added that materially affect privacy or content
• Terms of Service or Privacy Policy undergo substantial revision

7.3 Regular Updates

• Parents receive periodic updates: monthly account activity summaries, notification of any safety concerns, product updates relevant to minor users, and tips for discussing digital citizenship with their child

7.4 Verification of Ongoing Authority

• Solara will verify the parent email is still active
• Confirm the parent still maintains authority to provide consent
• Update contact information as needed

8.1 Consent Records

• Date and time of consent grant
• Verification method used
• Parent identity and contact information
• Specific version of Terms and Privacy Policy agreed to
• Subsequent interactions (revocations, renewals, data access requests)

8.2 Retention of Consent Records

• Maintained for the duration of the child's account plus 3 years
• Stored securely with restricted access
• Available for regulatory compliance if required
• Accessible to parents upon verification

9.1 Support for Parents

• Email address: legal@solara.com

• Children's Online Privacy Protection Act (COPPA)
• General Data Protection Regulation (GDPR) and UK GDPR
• State laws governing minors online
• Industry best practices for child safety

This parental consent framework is reviewed regularly to ensure ongoing compliance with the above regulations and best practices.

Last updated: May 11, 2025